ML20050C163
| ML20050C163 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 03/29/1982 |
| From: | Stiede W COMMONWEALTH EDISON CO. |
| To: | |
| Shared Package | |
| ML20050C161 | List: |
| References | |
| NUDOCS 8204080226 | |
| Download: ML20050C163 (7) | |
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e UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of
)
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Docket No. 50-10 COMMONWEALTH EDISON COMPANY
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(Decontamination)
(Dresden Nuclear Power Station,
)
Unit No. 1)
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AFFIDAVIT OF WAYNE L.
STIEDE STATE OF ILLINOIS
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SS.
COUNTY OF C O O K
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I, Wayne L.
Stiede, being first duly sworn, state as follows:
I have been. employed by Commonwealth Edison Company
(" Commonwealth Edison") since 1968 and I am an Assistant Vice President responsible for all-activities associated with our Station Nuclear Engineering, Nuclear Licensing and Nuclear
-Fuel Services Departments.
I received a Bachelor of Science degree in Electrical Engineering from the University of Wisconsin in 1958 and a Master of Management from Northwestern University in 1975.
The purpose of this Affidavit is-to inform the Licensing Board of developments concerning the scheduling of the decontamination of Dresden Unit 1.
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It has been recently determined that Commonwealth Edison will be unable to decontaminate Unit 1 in 1982.
Commonwealth Edison was prepared to initiate the decon-
. tamination operation in June 1980; however, lack of regulatory approval prohibited commencement of the decontamination
- operation.
'At that time, trained DOW personnel were on sitei chemicals had been procured and all equipment had been preoperationally-tested and qualified in preparation for the actual operation.
Because of the long licensing delays, it became evident that the decontamination of Dresden 1 would not occur in the usurmner of 1980 and that we could no longer retain the services of those DOW operators specifically
- trained for the Dresden 1 effort.
As a result, these DOW personnel were redeployed and are no longer available to the project.
Therefore, there-is a lead time of approximately.
9-12 months during which time it will be necessary to obta in and train new personnel as well as preoperationally retest all the equipment in order to again bring the project to a condition of readiness for solvent' injection.
On September.28, 1981, the Commission issued a Memorandum and Order by which it instructed the Staff.to
~ issue'the' Safety Evaluation Report and directed the Chairman
. of the Atomic Safety and' Licensing. Board Panel to appoint a '
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Licensing Board..The NRC Staff issued the Safety Evaluation
' Report- (in which a "no significant hazards" determination was made) and necessary technical specifications on December 18, 1981.
Commonwealth Edison felt it would not be prudent to reactivate the project.until the appeal period had passed in mid-February.
After a great deal of discussion, it became
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evident that we would be unable to meet the 1982 chemical cleaning schedule.
The decontamination of Dresden 1 is further impacted by the currently scheduled Dresden Unit 2 and 3 outages.
There is a seven-month " window" of time available between the end of the Dresden 3 outage (January 2, 1982 -
4 May 4, 1982) and-the beginning of the Dresden 2 outage (January 15, 1983 - April 1, 1983) during which the decon-tamination could be performed.
However, the lead time required for the remobilization of this project extends beyond the available window.
There is a significant amount of support which must be provided by the Station-
-personnel in the areas of operation, helath-physics and radiation chemistry both prior to and'during the actual decontamination.
The actual decontamination operation
. (which. includes -such milestones as the mock run, solvent-
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injection.and circulation, subsequent draining and-rinses,
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spcnt. solvent processing and solidification as well as
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facility-lay-up) will'take approximately three months of intensive work on the part of the-station.
Any preparatory work which would lead into the decontamination is excluded from this three-month estimate.
Thus, the demands of the current Dresden 3 outage make J.t impractical for the Station to complete preparatory work in order to support a 1982 decontamination schedule in the limited time available.
Therefore, due to the long lead time for training new personnel and retesting equipment, conflicts with other unit outages, the limited time available, and to some extent certain economic considerations discussed below, we will be unable to decontaminate Dresden 1 in 1982.
It is our judgment that the earliest the decon-tamination'could be initiated (given the before-mentioned
' time and outage limitations) is June 1, 1983.
- However, due to economic constraints, it is uncertain whether Commonwealth Edison can commence decontamination of Unit 1 in 1983.
Currently, Commonwealth Edison is involved in a major construction program with plans to complete work on six nuclear units in the next four years.. This program is very capital-intensive and, as a result, we have been-required to:re-evaluateJplans for activities which may be delayed without any serious consequences to cost and reliability of service to customers.
For this reason, we.
are at present uncertain as to whether sufficient funds will be available for a 1983 decontamination but do not expect decontamination to take place before 1984.
Although the exact schedule for the decontamination is unknown, Commonwealth Edison has a strong commitment to the project.
Commonwealth Edison definitely plans to go forward with the decontamination of Dresden Unit 1 as soon as our current cash flow difficulties are resolved.
It is the request of Commonwealth Edison that any hearing which may be required (as determined by the Licensing Board) go forward this year.
In the December 18, 1981 response to the Petitioners' Amended Petition and Initial Contentions, Commonwealth Edison argued that none of the petitioners should be allowed to' participate as parties in this proceeding and that a
- hearing is not required.
Commonwealth Edison still adheres to this position.
However, should the Licensing Board determine.otherwise, it would be advantageous to initiate the. proceeding as soon as possible so that, should any of the issues raised in a heari:rg prove to be valid, we would have adequate time to address them prior to the decontamination operation.
Based upon-the strength of
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- the NRC Staff's "no significant hazards" finding in their Safety Evaluation Report dated December 18, 1981, I do not believe that anything substantial would be identified.~
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This has been further_ supported through the conclusions of
- the NRC's Final' Environmental Statement (NUREG 0686) dated October 1980.
Nevertheless, it would be unfortunate for Commonwealth Edison to remobilize the project and to once again have regulatory approval withheld.
It has recently come to our attention that the Office of-Nuclear Reactor Regulation, in their weekly report to the Commissioners dated February 25, - 1982, dis-closed that Commonwealth Edison does not plan to proceed with the decontamination of Dresden Unit 1 in 1982 as previously scheduled.
The report attributes the delay to financial considerations, difficulty in meeting the June-October window between the Dresden 3 and Dresden 2 refueling outages and uncertainty about the total cost of returning the unit to service.
While the first two reasons'did indeed attribute to our postponing the decon-tamination operation, the third reason had no bearing upon our decision.
Commonwealth Edison intends to carry out the-
- decontamination whether or not Dresden Unit 1 is ever returned.to service.. We wish to reiterate that the decon-tamination should be kept-separate from the restart issue.
In._our response' dated January 16, 1981, to the Commissioners' January 8, 1981 Order for additional information, we' argued that the restart and subsequent operation of Dresden Unit 1 should not be addressed in any hearing related to the e
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proposed decontamination, but should be the subject of a separate hearing.
Commonwealth Edison felt at that time, as well as now, that the issues involved in the decontamination and restart are clearly separable and should be kept so.
The NRC Staff in their response to the Commissioners' Order dated January 28, 1981, agreed that this distinction should be.made.
This was further supported by the NRC Commissioners' Memorandum and Order dated September 28, 1981, in which the Commissioners stated that the scope of any hearing should be limited only to matters related,to the decontamination.
Wa e L.
Stiede Subscribed ancLsworn to before me this gre "' day of March, 1982.
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