ML20051Y796

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Response to ASLB 820406 Memorandum & Order,Assessing Impact of Util 820329 Affidavit on Contentions & Petitions to Intervene.Util Financial Status & Plans for Future Nuclear Plants Must Be Considered.W/Certificate of Svc
ML20051Y796
Person / Time
Site: Dresden Constellation icon.png
Issue date: 05/10/1982
From: Ginsburg R, Mintz D
CITIZENS FOR A BETTER ENVIRONMENT, ILLINOIS SAFE ENERGY ALLIANCE, MINTZ, D., PRAIRIE ALLIANCE
To:
Shared Package
ML20051Y469 List:
References
ISSUANCES-OLA, NUDOCS 8205180167
Download: ML20051Y796 (4)


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UNITED STATES Ok4 AMERICA

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NUCLEAR REGULATORY COMMISSION

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I Docket No. 50-10-OLA Dresden Nuclear Power

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Station Unit I

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PETITIONERS RESPONSE TO MEMORANDUM AND ORDER On March 29, 1982, Commonwealth Edison Company (CECO) submitted an affadavit from Mr. Wayne Stiede concerning the schedule for decontamination of Dresden Nuclear Station Unit I.

In an order dated April 6, 1982, the Atomic Safety and Licensing Board requested petitioners comments on the general impact of the CECO affadavit on their petition and contentions and specifically on those contentions or portions of contentions which address the potential problem of an extended lay-up of the reactor between decontamination and the return to commercial service.

CECO's statement of March 29, 1982 raised several important issues:

1.

The purpose of this proceeding is to determine whether CECO has the ability to carry out the decontamination of Unit I without any adverse environmental consequences.

CECO's March 29, 1982 submittal calls into question their ability to fund and properly staff this operation.

In particular it is unclear whether CECO will be able to employ and train enough qualified personnel, or whether they will be able to handle increased costs due to inflation, rising radioactive waste disposal rates, etc.

As a 8 2 0 518 o i (o'

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consequence both CECO's financial status and its plans or pre-dictions for future nuclear generating capacity must be considered in these proceedings in order to properly establish if CECO will ever be able to or want to properly fund the decontamination and return of Unit I to commercial service.

2.

Additionally, by delaying decontamination CECO will likely push back the date when Unit I will be returned to com-mercial service.

Any such delays after decontamination increase the risk of corrosion which could cause the facility to be unsafe when restarted.

(Petitioner's Amended Petition and Additional Contentions, p.

3, 8 A.l.)

3.

Any delays in the decontamination increase the likeli-hood that additional problems (cracks, etc.) may have developed due to the long period of time between shut-down and decontami-nation.

This reinforces contention A.2 which questions the ability of CECO to adequately detect and correct (if possible) the phenomena referred to in contentions A.1, A.3 and A.4.

Such delays in the decontamination further validate contention 1'. 5.

In particular, will the disposal sites be able to accept the waste and meet the disposal criteria described in the EIS in 1984 or later?

4.

Given the economic uncertainties in CECO's ability to carry out the decontamination, the uncertainty as to when, if ever, Dresden I will be returned to commerical service and the environmental concerns raised by the delay between those two events, Petitioners request the Board to get clarification from i

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the Nuclear Regulatory Commission as to admissibility in these proceedings, of questions related to when and if CECO intends to return Dresden I to commercial operation.

It might be added that if CECO does not intend to return this unit to commercial sercice or if CECO only intends to temporarily return the 4

unit to a functional state then several contentions might be moot, while others, notably contention B.1, B.2 and B.3, will be substantially valid and relevant.

t Respectfully submitted, Citizens for a Better Environment Prairie Alliance Illinois Safe Energy Alliance Kay Drey May 10, 1982 Br' _ t Rorem F

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BY:

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Q _^ - 8p DANIEL MINTZ RdEERT GINSBUBli, PhTD.

Their Attorney esearch Direc tor 59 E.

Van Buren Street Citizens for a'Better Environment Suite 1600 Chicago, Illinois 60605 (312) 939-1530 f

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y UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THEqCOMMISSION COMMONWEALTH EDISON p131 Dresden Nuclear Power Station,T2 )i)d ),.

Docket No. 50-10-OLA Unit No. I

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ed k@M CERTIFIEATEOF^ SERVICE I hereby certify that copies of " Petitioner's Response to Memorandum and Order" in the above-captioned proceeding have been served upon the following by deposit in the United States mail, first class, postage prepaid, this 10th day of May, 1982:

Lawrence Brenner, Esq.

Docketing and Service Office of the Executive Office of the Secretary Legal Director U.S.

Nuclear Regulatory U.S.

Nuclear Regulatory Commission Commission Washington, D.C.

20555 Washington, D.C.

20555 Leonard Bickwit, Esq.

Office of the Attorney General Office of the General Counsel State of Illinois U.S.

Nuclear Regulatory Enviror.nental Control Division Commission 188 West Randolph St.

Washington, D.C.

20555 Chicago, IL 60601 John H.

Frye, III Richard E.

Penske Atomic Safety and Licensing 635 Forest Avenue Board Oak Park, IL 60302 U.S.

Nuclear Regulatory Commission Samuel J.

Chilk, Secretary Washington, D.C.

20555 U.S. Nuclear Regulatory Commission Dr. Martin J. Steindler Washington, D.C.

20555 Argonne National Laboratory 9700 Cass Avenue Atomic Safety and Licensing Argonne, IL '60439 Appeal Board Panel U.S. Nuclear Regulatory Dr. Robert L. Holton Commission School of Oceanography t;a. Thing ton,

D.C.

20555 Oregon State University Corvallis, Oregon 97331 Ms. Martha Gutis Isham, Lincoln & Beale f

One First National Plaza

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Chicago, IL_ 60603

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Ipbert GinsDurfg}, Ph.D.

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