ML20244D506
| ML20244D506 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 06/07/1989 |
| From: | Conner T CONNER & WETTERHAHN, PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | Chilk S NRC OFFICE OF THE SECRETARY (SECY) |
| References | |
| CON-#289-8736 OL-2, NUDOCS 8906190099 | |
| Download: ML20244D506 (4) | |
Text
? 8'$ ?
l c
+4 ALT nu mst mu urn.rm.n f.3 Si2 563~
LAW OFFICES
~
CONNER 8e WETTERH AHN P.C.*
y.],.
17 4 7 P E N N SY LVANI A AV E N U E..N. W.
WASHINGTON. D. C. 20000 I;
Trov m.coNNEn,Ja.
89 JW -8 L P5 :00 MARK d. wErTEkHANN aa= Ear.= oEn wit. w. nicuota
,,,T, imo o.macunorrem June 7, 1999 iF ',.
<*oai cas =*o or couwssL OGCK! M i..
'r BR QV gApLg ADDRESB: ATOMLAW Samuel J. Chilk, Secretary.
United States Nuclear-Regulatory Commission Washington, D.C.
.20555 In the Matter of.
' Philadelphia Electric Company.
(Limerick Generating ~ Station, Unit 2)
Docket No. 50-353 l
(
Dear Mr. Chilk:
Pursuant to our letter to ' you of June 5, 1989-in the above-captioned matter, we are enclosing'the signed original of Corbin A.
- McNeill, Jr., to be ' substituted for Affidavit the telefax copy.we attached to the " Applicant's Motion For Clarification Of The. Commission's Delegation Of Authority-And For Issuance Of An Operating License Or,- Alternatively,.
For An Exemption From Any Procedural' Requirement That A License For Limerick Unit 2'Cannot Issue Until The Conten-tion Remanded By The Third Circuit IsfResolved."
Sincerely, 27 O*1W\\,J1 TBC:sch Trcy B.' Conner, Jr.
Enclosure 9906190099 890607 PDR ADOCK 05000352 PDR C
I i
1
+
,,r
' " ' ' p' UNITED STATES 0F AMERICA 1
NUCLEAR' REGULATORY COMMISSION-Before the Nuclear Regulatory CommissiffiB J'J.;' -8. P5 :00 I
J In the Matter.of
)
..g -
)
h, 9
Philadelphia. Electric' Company
)
Docket No. 50-3534-l
)'
(Limerick Generating Station,.
-)
Unit 2)
')
Affidavit-of Corbin A. McNeill, Jr.
' Executive Vice President-Nuclear Philadelphia Electric Company Corbin A. McNeill, Jr., being first duly sworn, states' as follows:
1.
My name is Corbin A. McNeill.
I am Executive Vice President-Nuclear of Philadelphia Electric Company, owner and operator of Limerich Generating Station, Units 1 and 2 (Limerick).
I am responsible for the construction, licensing, and_ operation of Limerick and-oversee the efforts of the Company in obtaining a -
license for Unit 2.
2.
On February 28, 1989, the United States Court of Appeals for the Third Circuit issued it: decision-in
~
Limerist Ecology Action. Inc. v. NRC, 869 F.2d 719 (3d Cir. 1989), affirming for the most part NRC action.
authorizing the licensing of Limerich. -The Court remanded to the Nuclear Regulatory Commission the issue of whether severe accident mitigation. design alternatives should be considered for Limerick' pursuant to the National Environmental Policy Act (NEPA), 42 U.S.C.
94321 et aq.
m ;
-m f II N
. 3.
Despite the Third Circuit's explicit explanation that its decision should not impede the licensing of Limerick, the NRC Staff has nonetheless indicated that it will not issue a license for Unit 2 until completion of the proceeding on the remanded issue.
Past experience suggests resolution of.the remanded proceeding will-take many months, if not years, to complete.
4.
The schedule for completion of Unit 2 is such that'the plant will be ready to proceed to. load fuel in the period of June 16-30, 1989.
It is anticipated that Unit 2 will be ready to exceed five percent. power by about August 1, 1989 and enter commercial operation by the end of the year, j
5.
Delays in the issuance of approval for proceeding to i
full power will result in a delay in the commercial operation of Unit 2.
Such delays will increase the i
costs of Unit 2 by $35.7 million per month.
This cost figure ic made up of $30.4 million per month'AFUDC and
$5.3 million per month operational, security and maintenance costs.
In addition, the fuel costs of the Company's customers will be increased by $11.9 million a month for each month of delay.
l l
6.
Delays in the issuance of approval for proceeding to full power operation could impact the capacity available to the PJM Interconnection of which the Company is part during a crucial period of this
^ -*
- summer, i.e., August through late: September.
Any..
power generation from Limerick Unit"2 during this-
~
period'is highly desirable andlwould help alleviate
-power shortages.if they'wereltoloccur.
The.PJM Interconnection-is cur:ently experiencing power:
shortages.due to weather and unavailability of many' generating units.
7.
Delays in the issuance of approval for proceeding.to-load fuel and.to full power' operation will-impact the Company's ability to-retain-the. highly qualified and.
experienced contractors who have been assembled to-support start-up and power ascension testing activities.
8.
PECo would agree that, for purposes'of evaluation of SAMDA's, the cost / benefit analysis of alternatives for' i
Unit 2 could be viewed as of the time of initial lic'ensing.
Hence, the evaluation would not'be. skewed by any-incremental costs c.ssociated with, adding a design alternative-after~'o'peration has' commenced.
Based upon this evaluation, the fac't.that Unit 2-would be operated during the pendency of a hearingiwould not prejudice the addition of design alternatives.
Executive Vice President-Nuclear I
Philadelphia Electric Company I
Subscribed and sworn to before me
'1%
This.)
day of June. 1989.
)
M Y
- NoTAREL SEA 4.
/
l
" D o" M _E M No g C g g l
'