ML20245F751

Reply by Licensee Philadelphia Electric Co to NRC Staff Response to Commission Questions.* Commission Should Rely on Licensee Cost Analysis in Response to Question 5 & Rc Williams Affidavit.W/Certificate of Svc

ML20245F751
Person / Time
Site:	Limerick
Issue date:	08/09/1989
From:	Conner T CONNER & WETTERHAHN, PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:	NRC COMMISSION (OCM)
Shared Package
ML20245F692	List: ML20245F687 ML20245F716 ML20245F729 ML20245F751
References
OL-2, NUDOCS 8908150056
Download: ML20245F751 (4)

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'89 Aug -9 P 3 :43 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Commission Sh;yj,(

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l l In the Matter of ) Docket No. 50-353-OL-2 l )

l: Philadelphia Electric Company )

) (Severe Accident (Limerick Generating Station', ) Mitigation Design Unit 2) ) Alternatives)

REPLY BY LICENSEE PHILADELPHIA ELECTRIC COMPANY TO NRC STAFF RESPONSE TO COMMISSION QUESTIONS Licensee Philadelphia Electric Company (" Licensee")

offers two comments in reply to the response of the Nuclear Regulatory Commission (" Commission" or "NRC") Staff on the Commission's five questions.

First, with regard to Question 5, Licensee does not agree that carrying charges in the form of Allowance for Funds Used During Construction ("AFUDC") and security, maintenance and operational costs are not incremental costs attributable to delay in commercial operation of Limerick Generating Station (" Limerick"), Unit 2. As set forth in the attached Affidavit of Raymond C. Williams, Vice President -

Rates, Philadelphia Electric Company, these costs, which well exceed $500 million, were incorrectly disregarded by the NRC Staff in its analysis. The Commission should therefore rely upon the Licensee's cost analysis in its response to Question 5 and the Affidavit of Raymond C. Williams.

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k Second, with regard to Question 2, Licensee does not agree that the incremental environmental impacts of operating Limerick Unit 2 without SAMDAs should be' deemed,.

as the Staff suggests, the total risk of a severe accident for the assumed period of delay. Rather, the truly incremental risk for the assumed period of delay equals the risk of operating Unit 2 without SAMDAs minus the risk of operation with SAMDAs. Accordingly, the Commission should rely upon the Licensee's analysis of incremental environmental costs, which considered the use of the most nearly cost beneficial SAMDA for the assumed period of delay.

Respectfully submitted, CONNER & WETTERHAHN, P.C.

M M Troy B. Conner, Jr.

Mark J. Wetterhahn Counsel for Licensee August 9, 1989 i

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UNITED STATES OF AMERICA  %@C NUCLEAR REGULATORY COMMISSION

'89 AUG -9 P3 :43 In the Matter of ) Docket No. 50-353-OL-2

) Of f iti .. -e Philadelphia Electric Company ) 00CM Yn . 'C

) (Severe Accident #

(Limerick Generating Station, ) Mitigation Design Unit'2) ) Alternatives)

CERTIFICATE OF SERVICE I hereby certify that copies of " Reply by Licensee Philadelphia-Electric-Company to Response of Intervenor Limerick Ecology Action, Inc. to Memorandum and Order of Commission dated July 26, 1989," " Affidavit of Raymond C.

Williams" and " Reply by Licensee Philadelphia Electric Company to NRC Staff Response.to Commission Questions" all dated August 9, 1989 in the captioned matter have been served upon the following by deposit in the United States mail as noted this 9th day of August, 1989:

• Thomas M. Roberts, Samuel J. Chilk, Secretary Commissioner Office of the Secretary U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D.C. 20555 Washington, D.C. 20555

• James:R. Curtiss, Morton B. Margulies, Esq.

Commissioner Chairman, Atomic Safety U.S. Nuclear Regulatory and Licensing Board Panel Commission U.S. Nuclear Regulatory Washington, D.C. '20555 Commission Washington, D.C. 20555

• Kenneth C. Rogers, Commissioner Frederick J. Shon U.S. Nuclear Regulatory Atomic Safety and Licensing Commission Board Panel Washington, D.C. 20555 U.S. Nuclear Regulatory Commission

• Kenneth M. Carr, Washington, D.C. 20555 Commissioner l U.S. Nuclear Regulatory 4 Commission Washington, D.C. 20555

• Hand Delivery

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2-4 Dr. Jerry Harbour Mr. Ralph Hippert Atomic Safety and Pennsylvania Emergency Licensing Board Panel Management Agency U.S. Nuclear Regulatory B151 - Transportation Commission Safety Building Washington, D.C. 20555 Harrisburg, PA 17120 Atomic Safety and Michael B. Hirsch, Esq.

Licensing Appeal Panel Federal Emergency U.S. Nuclear Regulatory Management Agency Commission 500 C Street, S.W.

Washington, D.C. 20555 Room 840 Washington, D.C. 20472

• Joseph Rutherg, Esq.

Ann Hodgdon, Esc. Theodore G. Otto, Er '.

Counsel for NRC Staff Department of Corrections Office of the General Office of Chief Counsel Counsel P. O. Box 598 U.S. Nuclear Regulatory Camp Hill, PA 17011 Commission Washington, D.C. 20555

• Docketing and Service Section Atomic Safety and U.S. Nuclear Regulatory Liceniing Board Panel Commission U.S. Nuclear Regulatory Washington, D.C. 20555 Commission Washington, D.C. 20555 Gregory E. Dunlap, Esq.

Deputy General Counsel Edward J. Cullen, Esq. Office of General Counsel Philadelphia Elec.ric 333 Market Street, 17th Fl.

Company Harrisburg, PA 17120 2301 Market Street Philadelphia, PA 19101

• • Charles W. Elliott, Esq.

Poswistilo, Elliott &

Elliott Suite 201 1101 Northampton Street Easton, PA 18042 Angus Love, Esq.

107 East Main Street Norristown, PA 19401

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Robert M. Rader Hand Delivery l

• • Federal Express a - ___