ML20148D112
| ML20148D112 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 12/26/1973 |
| From: | Staszesky F BOSTON EDISON CO. |
| To: | Ray D US ATOMIC ENERGY COMMISSION (AEC) |
| Shared Package | |
| ML20148D021 | List: |
| References | |
| NUDOCS 8009150081 | |
| Download: ML20148D112 (4) | |
Text
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De.cemb er 26, 1973
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Honorable Dixy Lee Ray, Chairman United States Atomic Energy Commission 1.'ashington, D..C, 20545 l
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Dear Chairman Ray:
On behalf of Boston Edison Company, I wish to express our deep concern with the Determination and Order date Dec;mber 17, 1973 tion on the week of December 23; and further, to urge prompt ac doun.
4Te the-licensing requirements associated with this shut
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hat-are convinced, based on the evidence in this proceeding, t
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by the selection of the shutdown data constituted a judgement l
i and which,.in requiring a premature shutdoun, unnec f:
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penalizes the consumers of.the New England Region.
We are mindful of the Commission's f tnetion and par'a-the public mc..nt duty under the Atomic Etiergy Act to protect'Ihese same objec p2 health and safety.
i continue to be the Company's foremost concern in the operat on pui. i.ic utilit*f, and while strictly observing public_ health and of the Pilgrim Station.
safety considerations Boston Edison is obligated g
l mert in light of the New England Region's very substantia l
dependence on imported oil.
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Based on the technical evidence disclosed to date an including Pilgrim's conservative mode of operation and the urgeae i
the time need to conserve valuable oil resources, we believe ifficult l
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period chosen for shutdown in the Determinat-ion is most dis ro justify, and in fact, tion of the public health and safety.
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9 k'hile the Commission is, of course, aware of the facts P
d of' this proceeJing, we believe it,tg be in the public interest' to.
forth certain aspects -leading to the Director's Decenter 17 set
. De termination.
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On October 5,1973 following observation of fuel channel
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box assembly wear at the Swiss KKM and Vermont Yankee Reactors, a
and af ter analysis and discussion with its nuclear steam system supplier, Boston Edison reduced core power and flow at Pilgrim These limitations were subsequently Station to 50 percent confirmed in an October 16 letter to Boston Edison.from the Regulatory Staff which also concluded that such levels,,of s'i.xty days.
operatios would be acceptable for a period of about.The Oc
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i Staff would be performing additional analyses based on further f.3 information to' be supplied by the Company.
On October 15, the Union of Concerned 3cientists and
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Friends of the Earth filed a joint petition for an immediate and.
Treating the petition as a indefinite shutdown of Pilgrim.
for issuance of a show cause order under its Rules of in an October 23 Memorandum and Order the Commission reouest Prz.c tic e,
instructed the Director of Regulation to determine whether further On action including an immediate shutdown was appropriate.
October 26, the Director issued a Determination accofapanied by a Staff Safety Evaluation, which concluded that there was no need there was for any shutdown or other emergency action and that reasonable assurance that the public health and safety would be protected while the sub.iece of the petition uas under con ence of KKM and Vermont Yankee and certain tests interim operation tion.
fuel failure under the restricted conditions would result'in no and little or no increase in the limited channel box damage assumed Moreover the Determination s::ated that to have occurred already.
under steady state or anticipated transient conditions any loss of hydraulic thermal margins due to channel box damage would be greatly offset due to the restricted mode of operation. '
5 In a November 14 submittal and personal presentation on the Regulatory Staf f, Boston Edison extensively
- Owomber 15 to for its position that, consistent with public documented support h :alth and safety, Pilgrim Station could be operated until m*ud-of design power and flow levals W thin April of 1974 at 50 percerit
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Enclosure II-11
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the b'ounds of data develo. :ed from the e::perica.ce of th.a Kg'.!
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j teactor.
Following ' the m ietinh; uith the Staff on.Ncvc=ber 15, Boston Edison on. November 30 proposed continuation of c,peration until' January 11, 1974.
This date was chosen on the basis of au optimized outage for refueling thus reducing downtime and the h
unnecessary use of valuable oil supplies.
It was al,so pointed E=
out. that extension of operation in Januar'/ would benefit New England by reducing ; fossil fuel consumption over the winter peak-electric' use period and by lessening the imbalance between fuel
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oil deliveries and rate of usage by utilities. - Bos ton Edison again reemphasized in its November 30 submittal that the opera-tion could be extended into January,1974 uhile remaining well uithin the parameters of experience at the RKM reactor.
Thus there was posed no undue risk to public health and safety, g...
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It is extremely disturbing that in light of the gravity -
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of the situation, the December 17 Determina' tion fails to address j;..
other than in the briefest and most conclusory manner the sub-6 stantive data uhich was presented to support operation unt-il' j
January 11, 1974.
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[E.: c The most alarmi ig consequence of the decision is that E?
from the energy. conservation viewpoint in New England, Pilgrim at 50 percent load results in generation equivalent to 364,000 barrels i..;
of oil per month if generated on a fossil unit.
The New England 5
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oil situation is deteriorating with anticipated deliveries less chan energy demand and thus oil supplies in New England may be precariously low by January 31, 1974.
I would also call your g at tention to the fact that from the New England peak load point g of view it is very likely that the peak will occur during the
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\\ fir >.r half of January at a time when it is extremely important 5
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- to have'Eli"g?e"nsrata.ng equa.pment available for service, t
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s3 Fur th er, the world-wide shortage of fuel oil has resulted -
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in staggering increases in the price of oil.. To the extent that c
.e can meet our customers' requirements with generation by nuclem-E cleans we are able to mitigate the effects of these increases to our -
.a The early shutdown of Pilgrim will result in substantiali j
customers.
increases in consumer electric bills because of the entr ordinary
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rise in the price of oil.
In the case of Boston Edison, the-
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increased reliance on fossil fuel will increase our generated
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per kilowatthour by sccewhat more than 20 percent.
i cost Nevertheless, car intention is to commence shutdown on Friday, December 28, 1973 in compliance with the Determination and Order of. the Director.
Our planning studies to date indicate that additional outage tima will result by commencing the shutdo'.:n
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in December 1973 rather than in mid-January 1974 because of the lead time required for preparation for the refueling license. We 4
have been working closely with the General Electric Company to expedite ' work on this license submittal and we n'ow understand that the license submittal any be completed by February 15, 1974.
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It is, therefore, crucial that the review and approval of the.
license submittal be expedited so that unproductive outage ex--
tensions will not result.
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=5 Ver..tru.Ly yours, t.,..
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N"i< Y 8' f id
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/ Francis 41. St Executive Vic,a zesky President y=
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