ULNRC-04622, Request for Extension of Time to Submit an Answer or Request a Hearing

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Request for Extension of Time to Submit an Answer or Request a Hearing
ML020810016
Person / Time
Site: Callaway Ameren icon.png
Issue date: 03/18/2002
From: Affolter R
AmerenUE
To: Collins S
Document Control Desk, Office of Nuclear Reactor Regulation
References
ULNRC-04622
Download: ML020810016 (5)


Text

PO Box 620 Fulton, MO 65251 573.676.8240 573.676.4056 fax ArnerenUE Callaway Plant Ronald D. Affolter Vice President - Nuclear March 18, 2002 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Mail Station P 1-137 1 White Flint North 11555 Rockville Pike Rockville, MD 20852 U.S. Nuclear Regulatory Commission ATTN: Mr. Samuel J. Collins, Director Room 5 D2, Mail Stop 0-5 E7 1 White Flint North 11555 Rockville Pike Rockville, MD 20852 WAmemn UE Gentlemen:

ULNRC-04622 DOCKET NUMBER 50-486 UNION ELECTRIC COMPANY CALLAWAY PLANT REQUEST FOR EXTENSION OF TIME TO SUBMIT AN ANSWER OR REQUEST A HEARING

Reference:

1) NRC Letter from Samuel J. Collins, Director Office of Nuclear Reactor Regulation to Garry L. Randolph, Senior Vice President Generation and Chief Nuclear Officer, Callaway Plant dated February 25, 2002, enclosing Order Modifying Licenses (Effective Immediately)
2) 20-Day Response to NRC Order for Interim Safeguards and Security Compensatory Measures, ULNRC-04621 dated March 18, 2002 Via Reference 1, the U. S. Nuclear Regulatory Commission (NRC or Commission) issued an Order to Union Electric Company (AmerenUE or UE) that modifies the current operating licenses for Callaway Plant. The Order was immediately effective and requires compliance with specific interim safeguards and security compensatory measures as stated in an attachment to the Order.

Section IV of the NRC's February 25, 2002, Order Modifying Licensee

("Order") states that, in accordance with 10 CFR 2.202, a Licensee must submit an answer to the Order and may request an extension of time in which to submit an answer or to request a hearing on the Order within 20 days of the date of the Order.

In addition, the Order states "where good cause is shown, consideration will be given to extending the time to request a hearing."

a subsidiary ofAmeren Corporation

U.S. Nuclear Regulatory Commission March 18, 2002 Page 2 of 3 Union Electric Company's response to the Order is provided in Reference 2.

For the following reasons, UE hereby requests an extension of time to supplement the answer to the Order submitted March 18, 2002 and to request a hearing.

In one instance, because of the extensive analyses required as detailed in the attachment to this letter, we are unable to complete the necessary evaluations within 20 days to determine what actions are appropriate and what an appropriate schedule for implementation would be. Because we will be unable to ascertain within 20 days what actions would be appropriate to comply with Interim Compensatory Measure B.2.a(2), we are also unable at this time to determine whether it is necessary to request a hearing with respect to that measure.

Accordingly, UE respectfully requests that the time within which to respond to Interim Compensatory Measure B.2.a.(2), be extended for supplementing UE's response to the item to 20 days after completing the necessary evaluations to determine what actions are appropriate and what an appropriate schedule for implementation would be. We estimate that that evaluation will be completed on or before May 31, 2002. UE also requests that the time to request a hearing on the Order with respect to Interim Compensatory Measure B.2.a(2) be extended to 20 days after UE completes the necessary evaluations and responds to the Commission pursuant to the Order with respect to these measures.

We appreciate your written concurrence to this request for extension as soon as practical.

If you have any questions concerning this matter, please contact John Blosser at (573) 676-8190 or Dave Shafer at (314) 554-3104.

Sincerely, fofD. Affolter Vice President, Nuclear DS/mlo : Extension Request for Interim Compensatory Measures Requiring Significant Analysis

U.S. Nuclear Regulatory Commission March 18, 2002 Page 3 of 3 cc:

Ellis Merchoff, Regional Administrator U.S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive Suite 400 Arlington, TX 76011-8064 Senior Resident Inspector Callaway Resident Office U.S. Nuclear Regulatory Commission 8201 NRC Road Steedman, MO 65077

STATE OF MISSOURI

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SS CALLAWAY COUNTY

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Ronald D. Affolter, of lawful age, being first duly sworn upon oath says that he is Vice President-Nuclear, for Union Electric Company; that he has read the foregoing document and knows the content thereof, that he has executed the same for and on behalf of said company with full power and authority to do so; and that the facts therein stated are true and correct to the best of his knowledge, information and belief.

By Z~Ii RonalNt1I Affolter Vice President-Nuclear SUBSCRIBED and sworn to before me this

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to ULNRC-04622 Page 1 of 1 EXTENSION REQUEST FOR INTERIM COMPENSATORY MEASURE REQUIRING SIGNIFICANT ANALYSES: ITEM B.2.A(2)

The analyses required to meet Order Conditions B. 1, B.2, and C. 1 could not be completed within the required order response period for Interim Compensatory Measure B.2.a(2). The following steps and schedule for responding to this section are:

1.

UE is obtaining TM5-1300, "Tri-Services Manual, Structures to Resist the Effects of Accidental Explosions" and the BLAST/FX program.

2.

UE will analyze the required vehicle bomb impacts using TM5-1300, "Tri Services Manual, Structures to Resist the Effects of Accidental Explosions",

BLAST/FX computer program, Air Force publication AFR 88-22, Structures to Resist the Effects of Accidental Explosions, FACEDAP computer program, or acceptable substitute analysis methodologies for structures and personnel. UE expects to complete this analysis by May 31, 2002.

3.

UE will determine the necessary mitigating steps if the analysis identifies vulnerabilities. This determination is expected to be completed by May 31, 2002.

4.

Within 20 days after completion of the determination of mitigating measures, UE will provide the responses directed by Order Conditions B. 1, B.2, and C.1.