ML20069B909
| ML20069B909 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 03/11/1983 |
| From: | Harrington W BOSTON EDISON CO. |
| To: | Eisenhut D Office of Nuclear Reactor Regulation |
| References | |
| 83-69, NUDOCS 8303170330 | |
| Download: ML20069B909 (2) | |
Text
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BOSTON EDISON COMPANY B00 BOYLSTON STREET BOSTON. MASSACHUSETTS 02199 WILLIAM D. HARRENGTON March 11,1983
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BECo Letter No. 83-69 Mr. Darrell G. Eisenhut, Director Division of Licensing Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D.C.
20555 License No. OPR-35 Docket No. 50-293
References:
a) BECo Ltr. dated June 25, 1982.
b) Telephone call between BECo and NRC dated December 15, 1982.
c) Telephone call between BECo and NRC dated January 7,
1983.
d) NRC Ltr. dated January 31, 1983.
Dear Sir:
In Reference a), Boston Edison Company (BECo) requested ten exemption requests from the requirements of 10CFR50.48 and Section III.G of Appendix R to 10CFR50.
By your letter dated January 31,1983 (Reference d) you denied each of the requests for exemption.
BECo does not contest the denial of 7 of the 10 exemption requests filed with Reference a).
However, we request that yo" reconsider your denial of exemption requests numbers 7, 8 & 10 that were fileu with Reference a).
BECo strongly con-tends that the information which was provided to justify the requests for exemp-tion was neither general in nature nor insufficient for the NRC to render a favor-able determination as required by 10CFR50.48(c)(6) for tolling the schedular requirements of 10CFR50.48(c).
BECo's request for schedular exemption (exemption #10) from the requirements of 50.48(c) and requests for exemption (#'s 7 & 8) from the technical requirements of Section III.G of Appendix R to 10CFR50 were denied without allowing us the opportunity to formally clarify our positions.
During the Reference b) telecon, BECo was advised that additional information would be required for exemption requests numbers 7 and 8, and would be formally requested by the NRC.
The need for additional information concerning exemption request #10 was not discussed.
The Reference c) telecon changed this direction and alerted us to the intended wording of the Reference d) letter, which we believe effectively denies us the opportunity to receive exemptions which are necessary and justifiable.
Therefore BECo does not believe that a resubmittal for exemption under the pro-visions of 10CFR50.12 is warranted, but rather the denial of our initial exemption requests numbers 7, 8 and 10 should be rescinded and the final judgement held in abeyance pending resolution of the additional information issue.
8303170330 830311 PDR ADOCK 05000293 F
CD'JTON EZ I".O N COMPANY Mr. Darrell G. Eisenhut, Director March 11,1983 Page 2 We are prepared to meet and discuss this issue with you at your earliest conven-ience and respectfully request your immediate attention in this regard.
Very truly yours, 6
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