ML13311B023

Answer to NRC 800102 Order to Show Cause Why Licensee Should Not Implement Category a TMI Lessons Learned Task Force short-term Requirements by 800131.Requests Relief Due to Difficulty in Obtaining Equipment.W/Certificate of Svc

ML13311B023
Person / Time
Site:	San Onofre
Issue date:	01/18/1980
From:	Pigott D Chickering & Gregory, San Diego Gas & Electric Co, Southern California Edison Co
To:	Office of Nuclear Reactor Regulation
Shared Package
ML13311B021	List: ML13311B020 ML13311B023 ML13311B024 ML13311B025 ML13311B028
References
RTR-NUREG-0578, RTR-NUREG-578, TAC-44652 NUDOCS 8001230219
Download: ML13311B023 (8)

Text

BEFORE THE UNITED STATES NUCLEAR REGULATORY COMMISSION In the Matter of SOUTHERN

)

CALIFORNIA EDISON COMPANY and

)

DOCKET NO. 50-206 SAN DIEGO GAS & ELECTRIC COMPANY )

(San Onofre Nuclear Generating

)

ANSWER TO ORDER TO Station, Unit No. 1)

)

SHOW CAUSE ORIGINAL SOUTHERN CALIFORNIA EDISON COMPANY on behalf of SAN DIEGO GAS AND ELECTRIC COMPANY and itself, licensees for San Onofre Nuclear Generating Station, Unit No. 1 hereby responds pursuant to 10 CFR S2.202 to the Order to Show Cause (-"OSC") issued in the above docket on January 2, 1980:

I Answering Paragraph I of the Order to Show Cause Licensees allege that Provisional Operating License No. DPR-13 was issued to Licensees Southern California Edison Company and San Diego Gas & Electric Company to operate San Onofre Nuclear Generating Station, Unit No. 1 ("SONGS Unit 1") and that Southern California Edison Company is the operator of that facility and submits this Answer in such capacity.

Save and except the above allegation, Licensees admit the contents of Paragraph I.

II Answering Paragraph II of the OSC,,Southern California Edison Company ("Licensee") admits the allegations of Paragraph II.

III In response to Paragraph III, of the OSC Licensee admits it has committed to implement each "Category A" requirement S001 230

albeit not completely by January 31, 1980.

Licensee'has no infor mation or belief concerning the commitments of other licensees nor the delivery dates for equipment ordered by other licensees and on that basis denies said allegations. Licensee admits that in some instances thirty days after delivery of equipment is a practical time period during which equipment necessary for "Category A" actions can be installed but denies that all such necessary equip ment can be received by licensee prior to June 1, 1980.

As set forth in the "Declaration of D. K. Nelson," which is attached hereto as Exhibit A and by this reference incorporated herein as though set forth in full, all necessary equipment for "Category A" actions will not be available to licensee by June 1, 1980.

1/

IV Further answering Paragraph III of the OSC, licensee has been informed and is aware that the Pacific Northwest region of the Western System Coordinating Council ("WSCC") is experiencing 1/ In responding to the Order to Show Cause licensees have assumed that, as indicated in Paragraph IV of the OSC, the requirement of 2.1.7.a of NUREG-0578 is not within the scope of this OSC. Licensees further assume and respond assuming that operability of individual valves following containment isolation reset is considered to be Category A requirement.

Licensees, in fact, believe it a matter related to Lessons Learned §2.1.4 but was not specifically identified as a requirement in NUREG-0578, as supplemented by letters dated September 13, 1979 and October 30, 1979.

If NRC agrees that operability of individual valves following containment iso lation reset is not a specified requirement of Lessons Learned

§2.1.4, licensees have no equipment availability problems with respect to the January 31, 1980 date.

-3 reliability problems.

The "Affidavit of M. D. Whyte" attached hereto as Exhi bit B, and by this reference incorporated herein as though set forth in full concludes that a February 1980 shutdown of San Onofre Nuclear Generating Station, Unit No. 1 would adversely impact the reliability of the combined electric power systems of the State of California and reduce California's ability to aid the Pacific Northwest with respect to its reliability problems. As previously stated, WSCC concludes that based on reliability con siderations, the shutdown of SONGS Unit 1 for implementing of Category A action items and the shutdown for refueling now scheduled for April 1, 1980 should be combined and scheduled for March 15,' 1980.

Attached hereto as Exhibit C, and by this reference incorporated herein as though set forth in full is a letter from Mr. James L. Mulloy, Chairman, Western System Coordinating Council to Mr. M. D. Whyte, Manager of Electric System Planning for Southern California Edison Company. Exhibit C reflects WSCC's conclusion "that an accelerated commencement of the scheduled refueling outage from early April to mid-March to accommodate both refueling and the retrofit simultaneously would enhance the reliability of the California and Northwest systems during a period of tight margins."

V Licensee denies that continued operation of Unit 1 beyond June 1, 1980, in the absence of complete satisfaction of the "Category A" actions would pose a threat to the'public health

-4 and safety. For the reasons set forth in the "Declaration of J. G. Haynes," which is attached hereto as Exhibit D and by this reference-incorporated herein as though set forth in full, the inability to implement modifications before June 1, 1980, because of unavailability of equipment does not pose a threat to the public health and safety and certainly does not warrant a shutdown of the facility.

VI In the event this response and proposed relief is not found acceptable, licensee hereby reserves the right.to demand a hearing on all issues raised by the Order to Show Cause.

WHEREFORE: Licensees Southern California Edison Company and San Diego Gas & Electric Company request relief from the Order to Show Cause as follows:

(1) That.due to reliability considerations, the earliest date for shutdown of San Onofre Unit No. 1 to effectu ate the "Category A" action items be March 15, 1980; (2) That implementation of all "Category A" actions to San Onofre Unit No. 1 shall be completed during the shut down commencing March 15, 1980, except those actions described in Exhibit A for which equipment is unavail able during said shutdown period; (3) That "Category A" actions which cannot be implemented because of equipment unavailability during the March 15, 1980 shutdown be implemented within thirty (30) days of delivery of said equipment to licensee; (4) That in the event the above-requested relief is not

-5 acceptable, licensee reserves the right to demand a hearing on all contested issues arising out of the Order to Show Cause.

DATED:

F()

DAVID R. PIGOTT SAMUEL B. CASEY Chickering & Gregory Three Embarcadero Center San Francisco, CA 94111 Attorneys for Applicants CHARLES R. KOCHER JAMES A. BEOLETTO 2244 Walnut Grove Avenue Rosemead, CA 91770 Attorneys for Southern California Edison Company By David R. Pigott One of Counsel for Southern California Edison Company and San Diego Gas &

Electric Company

VERIFICATION ROBERT DIETCH, says:

(1) That I am an officer, Vice President, Nuclear Engineering and Operations of Southern California Edison Company.

(2) That I am authorized to execute a verification of the foregoing ANSWER TO ORDER TO SHOW CAUSE.

(3) That I affirm under penalty of perjury that to the best of my knowledge, information, and belief the contents of the foregoing ANSWER TO ORDER TO SHOW CAUSE are true and correct.

Executed this _

day of January, 1980, at Vi,4 /44

, California.

ROBERT DIETCH

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of SOUTHERN CALIFORNIA EDISON CMPANY and SAN DIEGO GAS & ELECTRIC COMPANY

)

Docket No. 50-206 (San Onofre Nuclear Generating Station Unit No. 1)

CERIIFICATE OF SERVICE I hereby certify that a copy of Answer to Order to Show Cause was served on the following by deposit in the United States mail, postage prepaid, on the;2 Oiday of January, 1980.

Harold R. Denton, Director Michael L. Mellor, Esq.

Office of Nuclear Reactor Regulation Thelen, Marrin, Johnson & Bridges United States Nuclear Regulatory Two Embarcadero Center Commission San Francisco, California 94111 Washington, D.C. 20545 Huey Johnson Henry J. McGurren, Esq.

Secretary for Resources Staff Counsel State of California United States Nuclear Regulatory 1416 Ninth Street Commission Sacramento, California 95814 Washington, D.C.

20545 Janice E. Kerr, General Counsel Charles R. Kocher, Esq.

California Public Utilities James A. Beoletto, Esq.

Comission Southern California Edison Company 5066 State Building P. 0. Box 800 San Francisco, California 94102 Rosemead, California 91770 J. Rengel Jack E. Thomas Atomic Power Division Harry B. Stoehr Westinghouse Electric Corporation San Diego Gas & Electric Company Box 355 P. 0. Box 1831 Pittsburgh, Pennsylvania 15230 San Diego, California 92112 A. E. Gaede I. R. Caraco P. O. Box 373 Bechtel Corporation San Clemente, California 92672 P. 0. Box 60860, Terminal Annex Los Angeles, California 90060 Frederick E. John, Executive Director California Public Utilities Commission 5050 State Building

//

San Francisco, California 94102

Docketing and Service Section Jim Liberman Office of the Secretary Office of the Executive Legal United States Nuclear Regulatory Director Commission United States Nuclear Regulatory Washington, D.C. 20555 Comission Washington, D.C.

20555 United States Nuclear Regulatory Comtission Director Attention: Robert J. Pate Technical Assessment Division P. 0. Box 4167 Office of Radiation Programs San Clemente, California 92672 (AW-459)

U. S. Environmental Protection Agency Mission Viejo Branch Library Crystal Mall #2 24851 Chrisanta Drive Arlington, Virginia 20460 Mission Viejo, California 92676 U.S. Environmental Protection Agency Mayor Region TX Office City of San Clemente Attention:

EIS Coordinator San Clemente, California 92672 215 Frent Street San Francisco, California 94111 Chairman Board of Supervisors County of San Diego San Diego, California 92101 California Department of Health Attention:

Chief, Environmental Radiation Control Unit Radiological Health Section 714 "P" Street, Room 498 Sacramento, California 95814SanF