ML20082D814
| ML20082D814 | |
| Person / Time | |
|---|---|
| Site: | LaSalle  |
| Issue date: | 11/21/1983 |
| From: | Schroeder C COMMONWEALTH EDISON CO. |
| To: | Harold Denton Office of Nuclear Reactor Regulation |
| References | |
| 7648N, NUDOCS 8311230063 | |
| Download: ML20082D814 (2) | |
Text
_-
j,d Commonwealth Edison A
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, one First National Ptn, Chicago, Illinois
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O 7 ' Address Reply to: Post Office Box 767
-(j Chicago, Illinois 60690 November 21, 1983 Mr. Harold R. Denton, Director
^
10ffice of Nuclear Reactor Regulation U.S.-Nuclear Regulatory Commission Washington, DC -20555
Subject:
LaSalle County Station Unit 2 Forty Year Operating ~ License NRC Docket No.-50-374
References:
(a)-
L.O. DelGeorge letter to H.
R. Denton dated September 23, 1981 (b)
C.
W. Schroeder letter to A. Schwencer dated April 8,.1982 (c)
W. L.
Stiede' letter to H. R. Denton dated June 10, 1982 (d)
C.
W. Schroeder letter to A. Schwencer dated March 18, 1983
Dear Mr. Denton:
The purpose of this letter is to reaffirm, at the request of Dr. A. Bournia, that Commonwealth Edison Company requests that a forty (40) year license.be issued for LaSalle County Station Unit 2, and-that the previously submitted information also applies to Unit 2.
Reference (a) provided the legal background and stated:
" Commonwealth Edison Company anticipates receiving operating licenses for its LaSalle County Nucl' ear Power Station, Units 1 and 2,
this fall and next year.
The purpose of this letter is to request the Nuclear Regulatory Commission to issue each of these operating licenses for a -full term of 40 years each, running from the date of the issuance of the licenses."
The information provided therein does apply to Unit 2.
Reference (b) provided additional information requested by Mr. R. Purple and stated:
pel 8311230063 831121 I
gDRADOCK 05000374 i
PDR 1
1 "The Purpose of this letter is to provide additional basis for the issuance of a forty-year operating license for LaSalle County Station Units 1 and 2."
-The information therein does apply to Unit 2.
Reference ~(c) was provided,following discussions with the
-NRC staf f _ on June 9 and 10, 1962.
Reference (c) provided additional information regarding forty year license issue and was docketed for LaSalle County Station Units 1 and 2.
The information provided therein does apply to Unit 2.
Reference (d) provided a review of the status of Unit 2 license conditions as potentially applying to Unit 2.
Reference (d) officially requested that a forty year license be issued for Unit 2.
Therefore Commonwealth Edison Company reaffirms and requests that a forty year license should be issued for LaSalle County Station Unit 2, based on our previous transmittals (a), (b),
(c), and (d), portions of which have been attached for your reference.
If there are any further questions in this matter, please contact this office.
Very truly yours, 0]Ad
.,1v M C.
W. Schroeder Nuclear Licensing Administrator cc: NRC Resident
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) one First Nati nal Plaza, Chicago. !!hnois tr Addr;ss Pealy 13: Post Offics Box 767
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-,/ Chicago,1[nois 60690
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September 23, 1981 Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, DC 20555
Dear Mr. Denton:
Commonwealth Edison Company anticipates receiving cperating licenses for its LaSalle County Nuclear Power Station, Units 1 and 2, this fall and next year.
Tha purpose of this let+er is to request the Nuclear Regulatory Commission to issue each of these operating licenses for a full term of 40 years each, running from the date of the issuance of the licenses.
The requested 40-year term would be consistent with the safety reviews conducted by the Energy Act and the NRC regulations.
The NRC's past practice has been to issue an operating license for a term of 40 years, which is backdated to the issuance of the construction permit rather than starting with the issuance of the operating license itself.
Because the time required for the construction of nuclear power plants has steadily increased over the past few years, the Commission's practice-of backdating has resulted in the steady erosion of authorized operating periods for newer plants.
(See Attachment 1).
This practice of reducing the lifetime of operating licenses is apparently unintentional and arbitrary.
It is not' required for the safety of nuclear power plants, nor is it in T
keeping with the intent of the Atomic Energy Act.
/
For LaSalle County Nuclear Station, following the past practice of backdating operating license would result in an effective duration of only 32 years, a 20% reduction in the authorized operating life of the Station.
This result is not compelled by the NRC Staff's thorough safety and environmental
-review of the LaSalle units.
The Staff did not base its reviews on a fixed number of years from the date of the construction permit.
Commonwealth Edison is. unaware of any safety or environmental considerations which require limiting the effective duration of the LaSalle operating licenses to a period of less than 40 years.
Section 103(c) of the Atomic Energy Act of 1954, 42 U.S.C. $ 2133(c) (1976), authorizes the Nuclear Regulatory Commission to issue commercial operating licenses for a "specified period...but er il J s i-i ~
xii f ppve
.' not exceeding 40 years."
The 40 year limitation in the statute, however, was not dictated by a concern for safety or for the environmental effects of continued operation.
In fact, a close study of the legislative history to Section 103(c) reveals that it was economic considerations which were behind the decision to establish a 40 year limit.
Interestingly, the first proposal in April, 1954, to amend the Atomic Energy Act of 1946 provided for a 25 year limitation on operating licenses.
(A Proposed Act tc Amend the Atomic Energy Act of 1946, Joint Committee on Atomic Energy, 83d Cong., 2d Sess. 21 (Comm. Print April 1954 reprinted in Legislative History of the Atomic Energy Act of 1954, at 81 (1955).)
However, in hearings held before the Joint Committee on Atomic Energy in May, 1954, a representative of interested public utilities, E.
H.
- Dixon, testified that the 25 year limitation would discourage nuclear power plant construction projects.
(Hearings Before the Joint Committee on Atomic Energy, 83d Cong., 2d Sess. 203-31 (May ll, 1954)
(statement of E.
H.
Dixon) reprinted in Legislative History of the Atomic Energy Act of 1954, at 1864-1865 (1955).)
Apparently because of tnis testimony, the Joint Committee amended the prnposed bill and expanded the 25 year maximum on operating licenses to 40 years.
(Draft In Bill Form, Joint Committee Print, 83d Cong., 2d Sess. 41 (May 21, 1954) reprinted in Legislative History of the Atomic Energy Act of 1954, at 297 (1955).)
It was this latter proposal which became law on February 17, 1954.
Pub. L. No. 703-1073, 68 Stat. 919 (1954).
Frnm the legislative history of Section 103(c), it seems fairly clear that the intent of Congress was to provide a full 40 year licensing term so that public utilities would not be discouraged from taking on the costly burdens of constructing nuclear power stations only to find the licenses expire when their investments still had economic usefulness.
The fact that modern power plants are more expensive and take longer to build and license than older plants increases the justification for allowing a successful applicant and the public it serves the full economic benefit of the 40 year term originally intended by Congress.
The NRC regulations which implement Section 103(c) carry forth the intent of the statute by prescribing procedures which insure a full term of 40 years to an applicant who meets the
=
necessary safety and environmental requirements of the Commission.
In particular, 10 CFR 50.51 entitled " Duration of License,"
provides:
Each license will be issued for a fixed period of time to be specified in the license but in no case to exceed 40 years from the date of issuance.
Where the operation of a facility is involved the Commission will issue the license for the term requested by the applicant or for the estimated useful life of the facility if the Commission determines that the estimated useful life is less than than term requested....
. This regulation clearly requires the NRC to grant Commonwealth Edison's request for 40 year operating licenses unless the useful life of LaSalle County Station is determined to be something 2ess.
In addition, the language of Section 50.51 states that the license should run "from the date of Assuance, " not from a date prior to the issuance.
10CFRh50.56isnotinconsistentwith10CFR50.51.
Section$50.56referstothe" conversion"ofaconstructionpermit to an opern ing license.
But in NRC practice there has always been a clear distinction between a construction permit and an operating license.
Construction permits and operating licenses have their own distinct terms and conditions, including different environmental monitoring requirements, different safety inspection schedules, and different time limits.
There is no more reason why the term of the construction permit should be reflected in the term of the operating license than there is that a particular monitoring program, appropriately developed for construction activities, should be included in the operating license technical specifications.
Moreover, the rule governing duration of operating licenses is found in 42 U.S.C. $2133, while the need for time limits for construction permits is derived from'a completely different source.
See 42 U.S.C.$2235.
Therefore, there is no logical reason why
" conversion" of a construction permit into an operating license shoeld require subtracting apples (the time for construction) from oranges (the time for operation).
A f air appreciation of the enormous ef fort which has gone into the construction and licensing review of the LaSalle County Nuclear Station, and a careful reading of the Atomic Energy Act of 1954, the legislative history, and the regulations supports the view that, once construction is completed, there is really no reason why anything less than a full 40 year term should be granted.
Arbitrarilv foreshortened license terms do not serve the best intersts o't the NRC, the applicant or the public.d.
Commonwealth Edison asks that the NRC Staff grant its request to have the operating licenses for the LaSalle County Station issued for full 40 year terms beginning with the dates of issuance.
In the event the Staf f cannot support our position, we ask that our request be forwarded to the Commission for its consideration and that we be givEn an opportunity to address the Commission in support of our request.
Commonwealth Edison would like to stress, however, that its principal concern lies in the 1
timely licensing of the LaSalle County Station.
We do not want this
.- request to; result in any delay in this licensing process.
Sincerely, L. O. DelGeorge Director of Nuclear Licensing cc:
Martin Malsch Colleen Woodhead l.
The statute and regulations do provide for renewal of licenses upon expiration.
42 U.S.C 2133; 10 CFR 50.51.
But re-licensing a nuclear power plant would be an enormous, uncertain undertaking which can not be regarded as a satisfactory answer to Commonwealth Edison's present request for the full-term, 40-year operating _ licenses to which it is entitled by law.
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NUCLEAR UNITS ARRAN D CIIRONOLOGICALLY BY DATE OF OPERATING LICENSE
'SEP 23 Mit EFFECTIVE LIFETIME NRC OF A 40-YEAR DOCKET COMPANY NUCLEAR UNIT DATE OF DATE OF OPERATING LICENSE C.P.
O.L.
NUMBER l
50-10 Commonwealth Edison Dresden - 1 5-04-56 9-28-59 36 yrs. 7 mos.
l Co.
50-456 Yankee Atomic Yankee-Rowe 11-04-57 7-09-60 37 yrs. 4 mds.
Electric Company 50-213 Consolidated Edison Indian Pt - 1 5-04-56 3-26-62*
34 yrs. 1 mo.
Co. of N.Y.
50-133 Pacific Gas and Humboldt Bay 11-09-60 8-28-62 38 yrs. 2 mos.
i Electric 50-155 Consumers Power Big Rock Point 5-31-60 8-30-62*
37 yrs. 9 nos.
Co.
50-206 Southern California San Onofre - 1 3-02-64 3-27-67 37 yrs.
Edison Co.
50-213 Connecticut Yankee Conn. Yankee 5-26-64 6-30-67 36 yrs. 9 mos.
Atomic Electric Co.
50-409 Dairyland Power Coop.
La Grosse 3-29-63 7-03-67**
35 yrs. 9 mos.
50-219 Jersey Central Power Oyster Creek 12-15-64 4-09-69 35 yrs. 7 mos.
& Light 50-220 Niagara Mohawk Nine Mile pt - 1 4-12-65 8-22-69 35 yrs. 8 mos.
Power Corp.
- Date for provisional operating license.
- Date for provisional operating authorization.
~
~
~
A NUCLEAR UNITS'ARRA b CHRONOLOGICALLY BY DATE OF OPERATING LICENSE EFFECTIVE LIFETIME NRC DOCKET COMPANY NUCLEAR UNIT DATE OF DATE OF OF A 40-YEAR DPERATING LICENSE NUMBER C.P.
O.L.
- 50-244 Rochester Gas and Ginna 4-25-66 9-19-69*
36 yrs. 1 mo.
Electric Corporation 50-237 Commonwealth Edison Dresden - 2 1-10-66 12-22-69 36 yrs.-1 mo.
Co.
50-261 Carolina Power and Robinson - 2 4-13-67 7-31-70 36 yrs. 7 mos.
Light 50-263 Northern States nticello 6-19-67 9-08-70 36 yrs. 7 mos.
Power Co.
50-266 Wisconsin Electric Point Beach - 1 7-19-67 10-05-70 36 yrs. 9 mos.
Power 1
50-245 Northeast Utilities Millstone - 1 5-19-66 10-07-70 35 yrs. 7 mos.
i 50-249 Commonwealth Edison Dresden - 3 10-14-66 1-12-71 35 yrs.10 mos.
Co.
) 50-254 Commonwealth Edison Quad Cities 1 2-15-67 10-01-71 35 yrs. 4 mos.
,t Co.
50-265 Commonwealth Edison Quad Cities 2 2-15-67 3-31 34 yrs.10 mos.
Co.
50-301 Wisconsin Electric Point Beach 2 7-25-68 5-25-72 36 yrs. 2 mos.
i Power i
i i
- Date for provisional operating license.
i I
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(~5 e-NUCLEAR UNITS ARRANGED CHRONOLOGICALLY DY DATE OF OPERATING LICENSE EFFECTIVE LIFETIME NRC
'OF A 40-YEAR i
DOCKET COMPANY NUCLEAR UNIT DATE OF DATE OF OPERATING LICENSE HUMBER C.P.
O.L.
50-280 Virginia Electric Surrey - 1 6-25-68 5-25-72 36 yrs. 1 mo.
and Power j
50-293 Boston Edison Pilgrim - 1 8-26-68 6-08-72 36 yrs. I mo.
50-250 Florida Power and Turkey Pt. -3 4-27-67 7-19-72 34 yrs. 9 mos.
l Light 4
j 50-309 Maine Yankee Atomic Maine Yankee 10-21-68 9-15-72 36 yrs. 1 mo.
Power Co.
50-255 Consumers Power Palisades 3-14-67 10-00-72*
34 yrs. 5 mos.
i
)
50-281 Virginia Electric Surrey - 2 6-25-68 1-29-73 35 yrs. 5 mos.
l and Power 50-269 Duke Power Co.
Oconee - 1 11-06-67 2-06-73 34 yrs. 9 mos.
i 50-270 Duke Power Co.
Oconee - 2 11-06-67 2-06-73 34 yrs. 9 mos.
50-271 Vermont Yankee Vt. Yankee 12-11-67 2-28-73 34 yrs. 9 mos.
50-295 Commonwealth Edison Zion - 1 12-26-68 4-06-73 35 yrs. 6 mos.
j Co.
l 50-251 Florida Power Turkey Pt. -4 4-27-67 4-10-73 34 yrs.
i and Light l
50-285 Omaha Public Power Ft. Calhoun - 1 6-07-68 5-24-73 35 yrs.
District
- Date for full power authorization, P.O.L. issued 3/24/71.
NUCLEAR UNITS ARRAN b CIIRONOLOGICALLY
~
BY DATE OF OPERATING LICENSE NRC EFFECTIVE LIFETIME DOCKET COMPANY NUCLEAR UNIT DATE OF DATE OF OF A 40-YEAR NUMBER C.P.
O.L.
OPERATING LICENSE 50-259 Tennessee Valley Br' owns Ferry 1 5-10-67 6-26-73 34 yrs. l'mo.
Authority 30-277 Philadelphia Electric Peach Bottom 2 1-31-68 8-08-73 34 yrs. 5 mos.
Co.30-282 Northern States Prairie Island 6-25-68 8-09-73 34 yrs.ll mos.
Power Co.30-247 Consolidated Edison Indian Point 2 10-14-66 9-28-73*
33 yrs. 1 mo.
Co. of N.Y.
50-304 Commonwealth Edison Zion 2 12-26-68 11-14-73 35 yrs. 1 mo.
Co.30-305 Wisconsin Public Kewaunee 8-06-68 12-21-73 34 yrs. 8 mos.
Service Corp.30-267 Public Service Co. of Fort St. Vrain 1 9-01-68 12-21-73 34 yrs. 9 mos.
Oklahoma 50-290 Nebraska Public Cooper 6-05-68 1-18-74 34 yrs. 5 mos.
Power District 30-331 Iowa Electric Light Arnold 6-22-70 2-22-74 36 yrs. 4 mos.
& Power Co.30-289 Metropolitan Edison Three Mile Island - 1 5-18-68 4-19-74 34 yrs. 1 mo.
'Date for full power authorization, O.L. issued 10/19/71.
/*%..W -
n NUCLEAR UNITS ARRANL > CHRONOLOGICALLY BY DATE OF OPERATING LICENSE EFFECTIVE LIFETIME NRC DOCKET COMPANY NUCLEAR UNIT DATE OF DATE OF OF A 40-YEAR OPERATING LICENSE NUMBER C.P.
O.L.
50-313 Arkansas Power Ak. Nuclear 1 12-06-68 5-21-74 34 yrs. 6 mos.
& Light 50-260 Tennessee Valley Browns Ferry 2 5-10-67 6-28-74 32 yrs.ll mos.
s Authority 50-287 Duke Power Co.
Oconee - 3 11-06-67 7-19-74 33 yrs. 4 mos.
50-317 Baltimore Gas and Calvert Cliffs 1 7-C7-69 7-31-74 34 yrs.11 mos.
Electric 50-321 Georgia Power Hatch - 1 9-30-69 8-06-74 35 yrs. 2 mos.30-312 Sacramento Municipal Rancho - Seco 1 10-11-68 8-16-74 34 yrs. 2 mos.
Utility District 50-333 Power Authority of James A.
Fitzpatrick 5-20-70 10-17-74 35 yrs. 7 mos.
State of N.Y.
50-315 Indiana & Michigan Cook - 1 3-25-69 10-25-74 34 yrs. 5 mos.
Electric Co.10-306 Northern States Prairie Island 2
'6-25-68 10-29-74 33 yrs. 8 mos.
Power Co.
50-324 Carolina Power and Brunswick - 2 2-07-70 12-27-74 35 yrs. 3 mos.
Light
' NUCLEAR UNITS ARPAN CIIRONOLOGICALLY BY DATE OF OPERATING LICENSE NRC EFFECTIVE LIFETIME DOCKET COMPANY NUCLEAR UNIT DATE OF DATE OF OF A 40-YEAR NUMBER C.P.
O.L.
OPERATING LICENSE iO-336 Northeast Utilities Millstone - 2 12-11-70 8-01-75 35 yrs. 4 mos.
0-344 Portland General Trojan 2-08-71 11-21-75 35 yrs. 3 mos.
Electric Co.
0-286 Power Authority of Indian Pt. -3 8-13-69 12-12-75 33 yrs. 3 mos.
State of N.Y.
0-334 Duquesue Light Co.
Beaver Valley - 1 6-26-70 1-30-76 34 yrs. 5 mos.
0-335 Florida Power & Light St. Lucie - 1 7-01-70 3-01-76 34 yrs. 6 mos.
0-296 Tennessee Valley Browns Ferry 3 7-31-68 7-02-76 32 yrs. 1 mo.
Authority 0-318 Baltimore Gas &
Calvert Cliffs 2 7-07-69 8-13-76 32 yrs.ll mos.
Electric 0-325 Carolina Power Brunswick - 1 2-07-70 9-08-76 33 yrs. 5 mos.
& Light 0-302 Florida Power Co.
Crystal River 3 9-25-68 12-03-76 31 yrs.10 mos.
0-272 Public Service Salem - 1 9-25-68 4-06-77*
31 yrs. 7 mos.
Electric & Gas Co.
0-346 Toledo Edison Co.
Davis-Besse - 1 3-24-71 4-22-77 33 yrs.ll mos'.
0-348 Alabama Power Farley - 1 8-16-72 6-25-77 35 yrs. 2 mos.
Date for full power authorization, O.L. for 1% power issued 8/13/76.
-; qkA--7 NUCLEAR UNITS ARRANGED CHRONOLOGICALLY BY DATE OF OPERATING LICENSE EFFECTIVE LIFETIME NRC OF A 40-YEAR I
DOCKET COMPANY NUCLEAR UNIT DATE OF DATE OP OPERATING LICENSE C.P.
O.L.
NUMBER 50-338 Virginia Electric North Anna - 1 2-19-71 11-26-77 33 yrs. 3 mos,
& Power Co.
4 i
50-316 Indiana and Michigan Cook - 2 3-25-69 12-23-77 31 yrs. 3 mos.
Electric Co.
]
50-320 Metropolitan Edison Three, Mile Island - 2 11-04-69 2-08-78 32 yrs. 4 mos.
Co.
i 50-366 Georgia Power Co.
Hatch - 2 12-27-72 6-13-78 34 yrs. 6 mos.
i 1
50-368 Arkansas Power &
Arkansas Nuclear 12-06-72 7-18-78 34 yrs. 7 mos.
Light Co.
One-2
~
i 50-339 Virginia Electric &
North Anna - 2 2-19-71
.10-11-80 30 yrs. 4 mos.
Power Co.
50-364 Alabama Power Co.
Farley - 2 2-16-72 10-23-80 31 yrs. 4 mos.
I 50-327 Tennessee Valley Sequoyah - 1 5-27-70 10-23-80 29 yrs. 7 mos.
i Authority l
50-369 Duke Power Co.
McGuire - 1 2-28-73 6-29-81*
31 yrs.10 mos.
50-311 Public Service Salem - 2 9-25-68 Expected I
81**
l Electric & Gas
- Date for full power authorization, O.L. issued on 4/18/80 for low power testing.
l
- Zero power O.L. issued 1/23/81.
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I NUCLEAR UNITS ARRANd" CHRONOLOGICALLY
\\'
N BY DATE OF OPERATING LICENSE 1
EFFECTIVE LIFETIME NRC DOCKET COMPANY NUCLEAR. UNIT DATE OF DATE OP.
OF A 40-YEAR HUNDER C.P.
O.L.
OPERATING LICENSE 50-361 Southern California San onofre - 2 10-18-73 Expected 81*
50-328 Tennessee valley Sequoyah - 2 5-27-70 Expected Authority 81*
A,
- O.L.'s have been Commission Agenda items in 1981.
Source:
Compiled from NUREG-0652, Vol. 1, No. 1, Facilities License Application Record, Data as of 4/1/81, NRC (1981);. Commercial Nuclear Power Plants, Ed. No. 13, NUS Corp. (1981); Actual Dockets of NRC; and, The Energy Daily (June 30, 1981).
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/O Commonwealth Edison h one Fiat Nati;nal Pt*2a. Chicago, litinois jr :
7 Address R; ply 0: Post Offica Box 767
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v (j Chicago. I!!inois 60690 April 8, 1982 Mr. A. Schwencer, Chief Licensing Branch #2 Division of Licensing U. S. Nuclear Regulatory Commission Washington, DC 20555
Subject:
LaSalle County Station Units 1 & 2 Additional Basis for Forty-Year Operating License NRC Docket Nos. 50-373 and 50-374 Reference (a):
L. DelGeorge letter to H. R. Denton dated September 23, 1981.
D:ar Mr. Schwencer:
The purpose of this letter is to provide additional basis for issuance of a forty-year operating license for LaSalle County Station Units 1 and 2.
Commonwealth Edison Company initially made this request in Reference (a).
Recently (April 2, 1982), Mr. Purple requested that cdditional information be provided.
The following material is provided as justification for a 40-year operating license measured from the issuance of the operating license-date rather than from the date of the construction permit.
These ideas were garnered from the LaSalle design experience, Edison's nuclear g:neration experience, and a cursory appraisal of the major facets of potential LaSalle operational effects on public health and safety.
The planned life for LSCS Units 1 & 2 is forty years of commercial service on the Commonwealth Edison network.
The siting, design and operations for LaSalle were all planned for that lifetime with conservative margin added to assure its accomplishment.
In anticipation of long service life from nuclear generating stations Edison purchased and operates a uranium mine and milling subsidiary to retain the long-term economic advantage nuclear generation has over alternate power generation methods.
For our new nuclear units, and our operating nuclear units, that economic advantage is expected to remain favorable and to endure ovar a period exceeding the forty-year life of LaSalle or the planned life of other new generating stations currently under construction.
- l.,.
, t, I e-e, v-reo arit v.
q A'. Schwencer Aprl'1 8, 1982
.For LaSalle-in particular, t' he siting and plant interf ace with the. environment and the surrounding. demography has significantly less
. dependence.than earlier nuclear generating stations in~ the following espects:
independent cooling lake, single -elevated. ef fluent stack, integrated air handling for entire plant, benign seismicity, excellent hydrology with no; flooding potential, favorable meteorology with few
- radiological-threat pathways, isolation from industrial and transpor-totion hazards, sparce and' essentially-non-changing demography.
These l siting factors were thoroughly evaluated and none was determined to be constraining for. the 40-year operational life of the plant.
The facilities and plant structures along with their essential t
utility. and transportation services were designed with margin for an
~
' objective 40-year lifetime 'o f. service.
For example, the concrete primary c
containment structure was initially = prestressed with a conservative
. margin for 40-years of service (although this is adjustable enroute); the corrosion allowance on piping,. tanks,-valve and pump bodies, etc. was conservatively established for 40 years service and measured in the
(-
preservice-inspection to verify that minimum thicknesses met ASME code requirements; the power generation equipment and the safety equipment "were analyzed for stress margins on the basis of service pressures and temperatures corresponding to operational profiles while in service. ~The
. plants internal shielding and the equipment accessibility routes were j
designed for a full 40-year service life on the basis-of prior experience L
with.similar BWR power plants; the radwaste facility was designed to 2
" accommodate end-of-cycle conditions over a plant operating life 'of 40
-years..
The structural design basis includes thermal,. hydrodynamic, saismic, and other combined loads on plant equipment, including icssociated Lanchors and mountings, etc.. including 40 years of cyclic
_offects plus-margin.
Both the BOP equipment and the NSSS equipment acknowledged the thermohydraulic and radiological inputs for a 40 year service life. ~ The reactor pressure vessels for these BWR's are not lifetime constrained by neutron fluence.
Fatigue appraisals o f key
-in-reactor structures:
grid plates, jet pump beams, fuel channels, for
- instance, were evaluated against the postulated worst load conditions representative of 40 year's service life and were found to have adequate margins.
Both the seismic (SQRT) and environmental qualification programs for safety related equipment have utilized the 40-year service c
life as the desired goalT' Test conditions and qualification profiles represent this same basis.
Appraisals of life limited equipment have
- resulted in. surveillance and maintenance requirements to maintain the
. qualification objectives throughout the plant lifetime.
Operability
. tests to certify the availability of safety equipment for operations (LCO's) are 'a part of the' plant Tech Specs.
Safety margins established by-the-Tech Spec setpoints acknowledge 1the original 40-year design 4
capability Lof pressure boundary equipment with respect to performance profiles while in service.
Again, the context.of operational safety
$J lE includes the entire 40-year design life of the plant.
Even though operational procedures may change enroute, their basis is the Tech Spec
.and the engineering. design of the plant as analyzed in the FSAR.
The operational term of that basis is 40-years from initial heatup.
i
r:
w A~. Schwencer 3,--
April 8, 1982 The combination of conservative design, extensive performance evaluations during preoperational and startup tests to validate the design, plus surveillance and maintenance practices enable Edison to s i' - confidently expect 40-years of operational service from LaSalle.
Of all domestic BWR's, the Quad Cities Unit 2 had the highest availability during calendar year 1981.
A Dresden unit had essentially the same availability.
-These facts attest the credibility of Edison's expectation for :LaSalle which incorporates '-improved: design features and m'akes use of ocrlier Edison experience.
With conti'nuing modification programs, the
-older ' units are expected to be upgraded _for years.
With LaSalle as a compartmentalized plant.-=(physicall~y and electrically separated redundant
-safetyedivisions) future modifications for upgrading are expected to be somewtat easier to incorporate into the plant; however, because it has current state-of-art equipment,, its operation is not expected to challenge any safety limits nor compromise any 40-year life design parameters.
If there are<Nhy further questions in this matter, please contact this office.
Very truly yours, c
+
CMic h */s/st C. W. Schroeder
- Nuclear Licensing Administrator 1m A
cc:.NRC Resident Inspector - LSCS
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One First Nabonal Ptn Chicago. Ilknois Addr:ss R: ply to: Post Offic? Box 767 Chicago. Illinois 60690 Jun e 10, 1982 Mr. Harold R.
Denton, Director Of fice o f Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, DC 20555
Subject:
LaSalle County Station Units 1 and 2 Forty-Year Operating License NRC Docket Nos. 50-373 and 50-374 References (a):
L. DelGeorge letter to H. R. Denton dated September 23, 1981.
(b):
C. Schroeder letter to A. Schwencer dated April 8, 1982.
(c):
NRC License NPF-11 dated April 17, 1982.
Dear Mr. Centon:
In Reference (a), Commonwealth Edison Company requested that the licenses for LaSalle County Station Units 1 and 2 be issued for 40 years, effective at date of issue.
In Re ference (b),
~
additional information was provided to record the basis for the 40 year operating license.
During conversations with NRC personnel on June 9 and 10, 1982, it was requested that Commonwealth Edison provide additional information on this topic.
The purpose of this letter is to provide the requested information.
Commonwealth Edison Company has performed an environmental assessment of the effects of 40 years of operation from date of license issuance versus date of construction permit issuance.
This was accomplished by reviewing the impacts identified in the Operating License-Final Environmental Statement.
It was determined that there will be no significant adverse impacts attributable to extending the operating license to allow 40 years of unit operation.
During this. review, it was determined that the population estimates utilized were to the year 2020.
'A review o f population estimates made by the Illinois Bureau of the Budget provided the following data:
Estimate from 1981 Year Mid-1970's Estimate LaSalle County 2020 136,293 122,804 2025 148,104 127,263 LaSalle County 2020 580,946 528,266 and 9 contiguous 2025 636,095 548,354 counties
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H. R. Denton June 10, 1982 l-sg
_A Thus, the current (1981) population projections for the end j!
of life reactor operation are lower than those estimates made during 25 the mid-1970's, during which time the LSCS-OL-ER population projections were prepared.
The review of environmental impacts' also 1:
revealed positive impacts which could be reaped from a full 40 years a
of unit operation and which are summarized in subsequent paragraphs.
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Upon our request, General Electric Company has confirmed Eg that 40 year operation is not a limiting consideration for:
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1.
Safety analysis (transients or accidents)
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2.
Design of NSSS equipment, vessel, core, or reactivity 22 control equipment, and in vessel equipment.
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Design of ECCS (ie specifications for accessible equipment).
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5 Based upon the information provided in Reference (a),
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Reference (b), our review of environmental impacts and input from Sargent & Lundy and General Electric Company, Commonwealth Edison
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Company concludes that there are no unreviewed safety or environmental issues in providing a 40 year cperating license for
$l LaSalle County Station.
In addition, our environmetal review has revealed positive impacts, which include:
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Additional years of property tax benefits.
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E 2.
Additional years of secondarf benefits to the local ji economy from employee payroll and expenditures for 4
goods and services to operate plant.
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3.
Lower cost of electricity to customers served by CECO 3
by spreading capitol costs over the additional units E
of energy produced in the extendeo operating life.
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5 4.
De ferred capital costs and environmental impacts associated with constructing 2156 MWe of additional g
k generating capacity to replace the power that would g
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have been lost if units 1 and 2 are prematurely retired.
7 Therefore, we reaffirm our request that the Unit 1 license
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be issued for a 40 year term expiring at midnight on April 17, 2022.
7 Based on various discussions between NRR and CECO personnel, d
it is our understanding that, if the NRC does not issue a license d
L for 40 year operating license, the license will contain a statement j
g to the effect that the issuance of a license expiring September 10, d
2013 is without prejudice to ongoing consideration by the 9
Commission, pending satisfactory NRC Staf f review, o f the licensee's 2
L request for a license expiring at midnight, April 17, 2022.
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H. R. Denton 3--
Jun e 10,.198 2 If-there are any further questions on this matter, please contact this_ office...
One (1)' copy of this letter is being transmitted by telecopy for your immediate consideration.
In addition, one (1) signed origi-nal and thirty-nine (39) copies of this letter are being provided for your use.
Very truly yours, Q
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W ne L. Stiede Assistan t Vice-Presider.
4 CWS/1m cc:
NRC Resident Inspector - LSCS P. Steptoe; IL&B
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one First Nationat Pt za. Chicago, litmois
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7 jf Addr;ss Reply 13: P;st Offica Box 767 (j
Chicago, Illinois 60690 9
March 18, 1983 Director of Nuclear Reactor Regulation Attention:
Mr. A. Schwencer, Chief Licensing B, ranch No. 2 Division of Licensing
'U. S. Nuclear Regulatory Commission Washington,_DC 20555
Subject:
LaSalle County Station Unit 2 Potential License Conditions NRC Docket No. 50-374
Reference:
LaSalle County Station Unit 1, License NPF-ll, as amended through Amendment 12.
Daar Sir:
The purpose of this letter is to review the stat'us of Unit I licence conditions, as por1ntially applied to Unit 2 at LaSalle County Station.
The attachment quotes each Unit 1 license condition and then provides the status of ir.plementation or Commonwealth Edison Company's position on each condition as potentially applied to Unit 2.
In cases where an implementation date is stated this is the current best estimate of completion date.
For those items that are classified as installed, documentation, corrections of deficiencies (if any) and completion of testing is expected to be completed prior to Unit 2 license issue.
This letter will be updated as the fuel load date approaches.
Please note that the attachment contains the following official roquests by Commonwealth Edison Company regarding the Unit 2 license:
2.C.(1)
- Maximum Power Level - Request for full power license issue 2.C.(25) - Fire Protection - Request for exemptions 2.C.(27)
-Industrial Security - Request for exemptions 2.C.(34) - Single Loop Recirculation - Request for permission 2.D.
- Cricicality Monitor - Request for exemption
- Startup Testing Inerting - Request for exemption 2.H.
- License Expiration - Request for 40-year license.
To the best of my knowledge and belief the statements contained harein and in the attachment are true and correct.
In some respects these statements are not based on my personal knowledge but upon informa-tion furnished by other Commonwealth Edison and contractor employees.
Such information has been reviewed in accordance with Company practice and I oelieve it to be reliable.
f
t Director of NRR March 18, 1983 If there are any questions in this matter, please contact this copies of this letter and the attachment. Enclosed for your use are one (1) signed origina Very truly yours, 3 JislB3 C. W. Schroeder Nuclear Licensing Administrator J
1m Attachment cc:
J. G. Keppler - RIII NRC Resident Inspector - LSCS 6085N l
4 UNIT LICENSE CONDITION This license is e,2022.ffective as of the date of issuance and shall 2.H.
expire April 17, UNIT'2 - STATUS / CECO POSITION Commonwealth Edison Company officially requests that the Unit 2 license also be effective for 40 years from the date of issuance.
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