ML19274D297

in Response to 781215 Ltr,Potential Const Delays Are Due,In Part,To Cash Flow Restrictions & Design Changes to Conform to Current Regulatory Criteria.Requests Extension to 861101 & 871201 for Const Permits CPPR-114 & CPPR-15,respectively

ML19274D297
Person / Time
Site:	North Anna
Issue date:	01/17/1979
From:	Brown S VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.)
To:	Harold Denton, Parr O Office of Nuclear Reactor Regulation
References
NUDOCS 7901230107
Download: ML19274D297 (2)

Text

9 VIllGINIA Er.ncrrenc Ann Pownnr CObti'ANY Ricaix onn.Vi noin A 20201 January 17, 1979 Mr. Ha rold R. Denton, Di rector Serial No. 739/121578 Office of Nuclear Reactor Regulation LQA/RMN:esh Attn: Mr. O. D. Parr, Chief Light Water Reactors Branch No. 3 Docket Nos. 50-404 Division of Project Management 50-405 U. S. Nuc1 car Regulatory Commission Washington, DC 20555

Dear Mr. Denton:

We have received a request for additional information from Mr. O. D.

Parr dated December 15, 1978, concerning our applicatioa to extend the Construc-tion Permits for North Anna Units 3 and 4. Specifically requested were details about the unquantifiab!e potential delays and design changes being made to con-form with current regulatory requirements. According to the letter, the informa-tion is needed to Justify any extension beyond 1983 and 1984, the currently scheduled fuel load dates. Construction is currently 7.0% and 3.7% complete.

It should be noted that although those fuel load dates were considered realistic when the schedule was last updated several years ago, they are not in-tended to be the " latest completion dates" referred to in 10 CFR 50.55(b). To arrive at the latest possible completion date, one must adjust the schedule to 1979 and allow for potential future delays which are by nature unquantifiable.

We cannot update the schedule to 1979 without a decision on our application for a rate increase. The potential delays include, but are not necessarily limited to, cash flow restrictions and design changes to conform to current regulatory criteria.

Our annual construct!on budget is dependent on the availability of funds af ter operating expenses are met. Increasing operating and construction expenses have forced us to apply for rate relief. On February 15, 1978, we applied with the Virginia State Corporation Conynission (SCC) for a $117 million surcharge, $82 million representing an annual revenue requirement for North Anna Unit I and $35 million to cover a shortfall in 1977 earnings. The $82 million surcharge was approved subject to possible refund af ter a hearing. The $35 million surcharge was determined not to be urgent and therefore was delayed until a hearing could be held on a permanent rate increase.

On April 24, 1978, we supplemented the application for a total permancnt rate increase of $246 million. The hearing did not commence until September 5,1978 and was not complete until September 26, 1978 We are still waiting for a decision.

When rate relief is delayed or denied, we cannot build as fast as was originally planned. We have not yet determined the full effect of the delay to date on the schedule, nor do we have any indication when a decision will be made or what it will be. This problem could be repeated if operating costs continue to rise.

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VWOINIA ELECTHIC AND rOWEN COMPANY TOMr. Ha rold R. Denton 2 Design changes to conform with current regulatory requirements can also cause delays. Because the design is not final, it is unclear what the potential delays are. On November 21, 1978, Mr. R. S. Boyd sent us a letter on implementation of Staff review requirements for North Anna Units 3 and 4.

Attached was a list of 17 " Category 2" guides that the Staff will consider for this project and 10 " Category 3 - clearly backfit" guides. Each guide is dated af ter the Construction Permit issuance. We have not yet determined how much delay compliance with the current Regulatory Guides and Branch Technical Posi-tions will cause. We are still reviewing the November 21, 1978, letter from Mr. Boyd and plan to respond to that letter separately. We do think that cur-rent and future regulatory requirements are a potential cause of delay.

Based on the above reasons, we believe that an extension to November 1, 1986 and December 1,1987 for Construction Permits CPPR-114 and CPPR-115, respec-tively, is reasonable. If, however, you do not think that an extension of that length has been justified, then please extend the permits to December 31, 1983 and December 31, 1984, which is indicated to be possibly a reasonable extension in Mr. Parr's December 15, 1978 letter. This would necessitate another request for an extension in 1983, however, we would have more specific and detailed information at that time.

I Very ruly your , l

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j Senior Vice resident-Power Statio EngineerngandConstructionf

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