ML13317A249
| ML13317A249 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 08/02/1982 |
| From: | Baskin K Southern California Edison Co |
| To: | |
| Shared Package | |
| ML13317A247 | List: |
| References | |
| TAC-48143 NUDOCS 8208050487 | |
| Download: ML13317A249 (10) | |
Text
1 DAVID R. PIGOTT ALAN C. WALTNER 2
Of ORRICK, HERRINGTON & SUTCLIFFE A Professional Corporation 3
600 Montgomery Street San Francisco, California.94111 4
Telephone:
(415) 392-1122 5
CHARLES R. KOCHER JAMES A. BEOLETTO 6
SOUTHERN CALIFORNIA EDISON COMPANY P. 0. Box 800 7
2244 Walnut Grove Avenue Rosemead, California 91770 8
Telephone:
(213) 573-1900 9
Attorneys for Applicant, 10 Southern California Edison Company 11 UNITED STATES OF AMERICA 12 NUCLEAR REGULATORY COMMISSION 13 14 In the Matter of
)
Docket No. 50-206 15 SOUTHERN CALIFORNIA EDISON
)
AFFIDAVIT OF KENNETH P.
COMPANY
)
BASKIN IN SUPPORT OF 16
)
SUPPLEMENTAL REQUESTS (San Onofre Nuclear
)
FOR EXEMPTION AND 17 Generating Station Unit 1)
)
RECONSIDERATION 18 19 STATE OF CALIFORNIA
)
)
ss 20 COUNTY OF LOS ANGELES
)
21 KENNETH P. BASKIN, being first duly sworn, hereby 22 attests and deposes as follows:
23
- 1.
At all pertinent times referred to herein, I 24 have been employed by Southern California Edison Company 25
("SCE") as Manager, Generation Engineering Services (prior to 26 January 1, 1980), Manager, Nuclear Engineering and Licensing 32 -08050467 920203 PDR ADC " 05000206 DR p DR
1 (from January 1, 1980 to September 1, 1980), and Manager of 2
Nuclear Engineering, Safety and Licensing (since September 1, 3
1980).
In this capacity I have direct management 4
responsibility for Nuclear Regulatory Commission ("NRC")
5 licensing proceedings for the San Onofre Nuclear Generating 6
Station, Units 1, 2 and 3 ("SONGS 1, 2 and 3").
7
- 2.
My educational background and professional 8
affiliations are as follows:
I received by Bachelor of 9
Science in Mechanical Engineering from the University of 10 Southern California in 1960, and a Master of Science Degree 11 in Nuclear Engineering from Purdue University in 1968. At 12 all pertinent times referred to herein, I have been 13 registered in California as a Professional Engineer in 14 Mechanical Engineering and Nuclear Engineering. I am a 15 member of the American Society of Mechanical Engineers, the 16 American Nuclear Society, and the Pacific Coast Electric 17 Association.
18
- 3.
I have been employed as an engineer or manager 19 by SCE for the last twenty years and the positions I have 20 held include those of Project Engineer for SONGS 1, 21 Supervising Engineer and Project Manager for SONGS 2 and 3 22 and Chief of Nuclear Engineering.
23
- 4.
SCE is currently in the midst of a 24 comprehensive safety review of SONGS 1 under the Systematic 25 Evaluation Program ("SEP").
26 2
1
- 5.
SCE has also undertaken extensive fire safety 2
modifications at SONGS 1. These modifications have included 3
installation of fire detection equipment, water supply, 4
water, foam and gas suppression equipment, fire doors, 5
barriers and dampers and emergency lighting, isolation 6
devices and combustibles control measures.
7
- 6.
The fire protection measures described above 8
have substantially enhanced the fire safety of SONGS 1, and 9
have led to improved protection of the public health and 10 safety.
11
- 7.
SCE will be required to make additional 12 extensive modifications to SONGS 1 in response to the Fire 13 Protection Rule.
It is estimated, based on conceptual 14 engineering performed to date, that the total cost to 15 Applicant of these measures will be approximately $50 16 million. Because extensive facility modifications would have 17 been required under an alternative or dedicated shutdown 18 approach in any event, SCE elected to adopt a separation and 19 fire suppression approach involving many of the same measures 20 by providing two fully safety-qualified shutdown trains 21 meeting the separation requirements, together with any 22 necessary fire suppression measures. Applicant considers the 23 additional costs resulting from this safety-related approach 24 to be justified by the broad safety benefits that will be 25 provided.
26 3
1
- 8.
Separation and suppression modifications that 2
require plant shutdown are to be implemented under 10 C.F.R.
3
§ 50.48(c)(3) before start up after the earliest of the 4
following events commencing 180 days or more after the 5
effective date of the Fire Protection Rule (February 17, 6
1981):
(1) the first refueling outage, (2) another planned 7
outage that lasts for at least 60 days, or (3) an unplanned 8
outage that lasts for at least 120 days. This schedule would 9
require implementation of all of the measures identified by 10 SCE during the current outage, with the exception of the 11 modifications associated with the Remote Shutdown Panel, 12 which is the only alternative shutdown system identified by 13 NRC. Application of this schedule could cause a prolonged 14 outage of SONGS 1 lasting two or three years.
15
- 9.
Supply of backup power during such an extended 16 outage will result in substantial costs to SCE's ratepayers 17 without corresponding safety benefits.
18
- 10.
Because SCE elected to implement a safety 19 related system offering additional safety benefits, the scope 20 of the improvements proposed for SONGS 1 will be of a 21 magnitude similar to, and in some cases more extensive than, 22 that of alternative or dedicated shutdown systems proposed by 23 other utilities.
24
- 11.
Many of the modifications identified by SCE 25 will require coordination with SEP. Under the current 26 timetable, if SCE is held to its July 1 submission, 4
1 duplicative, wasteful and inefficient modifications may 2
result.
3
- 12.
Ongoing analysis may produce alternative fire 4
safety approaches that will better serve health and safety 5
concerns.
6
- 13.
Among the more significant Additions 7
identified in SCE's July 1, 1982 submission are a second 4KV 8
Switchgear Room, approximately 1000 power and control 9
circuits to meet separation requirements and for new 10 equipment, a new Auxiliary Feedwater Train, a Remote Shutdown 11 Panel, and new redundant valves for the CVCS and RHR Systems.
12
- 14.
The Modifications and Additions described in 13 to the July 1 submissions may be impacted by the 14 results of SEP Integrated Assessment. The SEP Topics which 15 may impact the Modifications and Additions for Fire 16 Protection Safe Shutdown are:
17 111-2 Wind and Tornado Loadings.
18 111-4 Tornado Missiles.
19 III-5.A Effects of Pipe Break on Structures Systems and 20 Components Inside Containment.
21 III-5.B Pipe Break Outside Containment.
22 V-10.B RHR Reliability.
23 V-11.A Requirements for Isolation of High and Low Pressure 24 Systems.
25 V-11.B RHR Interlock Requirements.
26 VII-3 Systems Required for Safe Shutdown.
5
1
- 15.
The resolution of open items in the area of 2
applied criteria and backfit requirements resulting from SEP 3
Integrated Assessment may lead to design changes to the 4
Modifications and Additions of Fire Protection Safe Shutdown.
5
- 16.
The new circuits that will be installed must 6
satisfy the separation requirements of Appendix R. These 7
requirements will be used as design criteria for the location 8
of these circuits.
SEP Topics III-5.A and III-5.B involve 9
the review of pipe breaks inside and outside containment and 10 their effect on neighboring safe shutdown equipment. An 11 integrated design approach would include the requirements 12 resulting from these topic reviews as part of the design 13 criteria for locating the new circuits. This would eliminate 14 the risk of routing the new circuits associated with 15 redundant trains of safe shutdown equipment in an area where 16 they would be impacted by a high energy pipe break. Similar 17 design criteria should be applied to the design of the new 18 Auxiliary Feedwater Train and in addition, the possible 19 effects of tornadoes should be included as defined in SEP 20 Topics 111-2 and 111-4.
21
- 17.
The Modifications and Additions of Fire 22 Protection Safe Shutdown provide improved redundancy through 23 separation of the systems and equipment required for safe 24 shutdown. As such, these modifications will both impact and 25 be impacted by the SEP review of Topic VII-3.
In some cases, 26 new equipment is required to be added such as the redundant 6
I.
1 MOV's for the RHR system. These were added to the Fire 2
Protection Safe Shutdown system since they resolve possible 3
single failure concerns which might arise from SEP Integrated 4
Assessment of the Safe Shutdown Topic and Topic V-10.B.
5 Topics V-11.A and V-11.B have resulted in NRC concerns with 6
respect to the RHR system which are to be resolved as part of 7
SEP Integrated Assessment. The resolution of these concerns 8
may create new requirements on the RHR system which should be 9
included as design criteria in conjunction with the criteria 10 for these systems resulting from Fire Protection.
11
- 18. Due to the extensive nature of the 12 Modifications and Additions proposed by SCE to provide a safe 13 shutdown capability in compliance with Appendix R to 10 14 C.F.R. § 50.48, exemptions are necessary from the current 15 implementation schedule to allow coordination with SEP.
16
- 19.
Because fire safety measures have already been 17 installed at SONGS 1 and these measures provide the 18 capability to ensure a safe shutdown of the station, the 19 requested exemptions and reconsideration will not endanger 20 life or property or the common defense and security and is 21 otherwise in the public interest.
22 23 24 25 26 7
1
- 20. Reconsideration of the July 1 deadline for 2
submission of fire safety plans and schedules is necessary to 3
allow modification of SCE's July 1 submission as SEP'develops.
4 KENNETH P. BASKIN 6
Subscribed and sworn to before me 7
this day of August, 1982.
8 9/
Notary Public for the State of California 10 County of Los Angeles 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 8
PROOF OF SERVICE BY MAIL 2
3 I declare that:
4 I am employed in the City and County of San 5
Francisco, California.
6 I am over the age of eighteen years and not a party 7
to the within entitled action; my business address is 8
600 Montgomery Street, 11th Floor, San Francisco, California 9
94111.
10 On August 3, 1982, I served the attached 11 SUPPLEMENTAL REQUESTS FOR EXEMPTION AND PETITION FOR 12 RECONSIDERATION AND AFFIDAVIT OF KENNETH P. BASKIN IN SUPPORT 13 THEREOF by placing a true copy thereof in the United States 14 mail in San Francisco, California, enclosed in a sealed 15 envelope with postage thereon fully prepaid, addressed as 16 follows (except where indicated by *):
17
- Harold R. Denton Director of Nuclear Reactor Regulation 18 U.S. Nuclear Regulatory Commission Washington, D.C. 20545 19
- Henry J. McGuerren, Esq.
20 Staff Counsel U.S. Nuclear Regulatory Commission 21 Washington, D.C. 20545 22
- James A. Beoletto, Esq.
Assistant Counsel 23-Southern California Edison Company P.O. Box 800 24 2244 Walnut Grove Avenue Rosemead, California 91770 25 26
1
- John V. Morowski Bechtel Power Corporation 2
P.O. Box 60860 Terminal Annex 3
Los Angeles, California 90060 4
Michael L. Mellor, Esq.
Thelen, Marrin, Johnson & Bridges 5
Two Embarcadero Center San Francisco, California 94111 6
- Huey Johnson 7
Secretary for Resources State of California 8
1416 Ninth Street Sacramento, california 95814 9
Janice E. Kerr 10 General Counsel California Public Utilities Commission 11 5066 State Building San Francisco, California 94012 12
- J. Rengel 13 Atomic Power Division Westinghouse Electric Corporation 14 Box 355 Pittsburgh, Pennsylvania 15230 15
- A.E. Gaede 16 P.O. Box 373 San Clemente, California 92672 17 Joseph E. Bodovitz 18 Executive Director California Public Utilities Commission 19 5050 State Building San Francisco, California 94102 20
- Docketing and Service Section 21 Office of the Secretary U.S. Nuclear Regulatory Commission 22 Washington, D.C. 20555 23 24
~f~><~"/2
Rebecca Howard 25 26
- Served by Express Mail 2