ML13330A912

Affidavit Re Support of Application for Exemption from Deadline to Submit Fire Safety Plans & Schedules.Proof of Svc by Mail Encl

ML13330A912
Person / Time
Site:	San Onofre
Issue date:	11/04/1981
From:	Baskin K Southern California Edison Co
To:
Shared Package
ML13330A909	List: ML13330A908 ML13330A910 ML13330A911 ML13330A912 ML20038A727
References
TAC-48143 NUDOCS 8111160237
Download: ML13330A912 (5)

Text

ORU GIU DAVID R. PIGOTT ALAN C. WALTNER Of ORRICK, HERRINGTON & SUTCLIFFE A Professional Corporation 600 Montgomery Street San Francisco, CA 94111 Telephone:

(415) 392-1122 CHARLES R. KOCHER JAMES A. BEOLETTO SOUTHERN CALIFORNIA EDISON COMPANY P. 0. Box 800 2244 Walnut Grove Avenue Rosemead, CA 91770 Telephone:

(213) 572-1900 Attorneys for Applicant, Southern California Edison Company UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of

) Docket No. 50-206 SOUTHERN CALIFORNIA

) AFFIDAVIT OF KENNETH P.

EDISON CO.

) BASKIN IN SUPPORT OF APPLICATION FOR EXEMPTION (San Onofre Nuclear

) FROM DEADLINE TO SUBMIT Generating Station Unit 1)

) FIRE SAFETY PLANS AND

)

SCHEDULES STATE OF CALIFORNIA ss.

COUNTY OF LOS ANGELES KENNETH P. BASKIN, being first duly sworn, hereby attests and deposes as follows:

1.

At all pertinent times referred to herein, I have been employed by Southern California Edison Company

("SCE") as Manager, Generation Engineering Services (prior to January 1, 1980), Manager, Nuclear Engineering and Licensing 8111160237 811109 PDR ADOCK 05000206 F

PDR

(from January 1, 1980 to September 1, 1980), and Manager of Nuclear Engineering, Safety and Licensing (since September 1, 1980).

In this capacity I have direct management responsibility for Nuclear Regulatory Commission ("NRC")

licensing proceedings for the San Onofre Nuclear Generating Station, Units 1, 2 and 3 ("SONGS 1, 2 and 3").

2. My educational background and professional affiliations are as follows:

I received my Bachelor of Science in Mechanical Engineering from the University of Southern California in 1960, and a Master of Science Degree in Nuclear Engineering from Purdue University in 1968. At all pertinent times referred to herein, I have been registered in California as a Professional Engineer in Mechanical Engineering and Nuclear Engineering.

I am a member of the American Society of Mechnical Engineers, the.

American Nuclear Society, and the Pacific Coast Electric Association.

3. I have been employed as an engineer or manager by SCE for the last twenty years and the positions I have held include those of Project Engineer for SONGS 1, Supervising Engineer and Project Manager for SONGS 2 and 3 and Chief of Nuclear Engineering.

4. SCE is currently in the midst of a comprehensive safety review of SONGS 1 under the Systematic Evaluation Program ("SEP").

5.

SCE has also undertaken extensive fire safety 2

modifications at SONGS 1. These modifications have included installation of fire detection equipment, water supply, water, foam and gas suppression equipment, fire doors, barriers and dampers and emergency lighting, isolation devices and combustibles control measures. Those measures required to have been implemented by Core 8 refueling under Amendment No. 44 to the operating license for SONGS 1 cost approximately $9 million and other fire protection measures have cost a significant amount.

6. The fire protection measures described above have substantially enhanced the fire safety of SONGS 1, and have led to improved protection of the public health and safety.

7. In response to regulations issued by the NRC on November 19, 1980, and received on December 1, SCE began evaluation of methods to achieve compliance with those regulations.

However, due to the extensive nature of the modifications required by those regulations, only preliminary data on such modifications could be developed by and were available on March 19, 1981.

These data were forwarded to NRC on that date.

SCE has continued its review of the measures necessary to comply with the regulations.

8. SCE's initial approach to compliance with Appendix R at SONGS 1 involves a combination of separation of existing equipment and/or utilization of alternative or dedicated shutdown equipment, which will encompass extensive 3

modifications to SONGS 1 costing close to an estimated

$40 million. These measures were outlined in a letter from me to the Director, Office of Nuclear Reactor Regulation, dated March 19, 1981.

9. Due to the extensive nature of modifications required to provide a safe shutdown capability in compliance with Appendix R, and the need to coordinate this work with SEP, an exemption is necessary from the schedular requirement to submit plans and schedules by March 19, 1981 for installation of a safe shutdown capability. Without such an exemption, unnecessary, duplicative and conflicting requirements will likely be faced with a corresponding waste of engineering and economic resources.

10.

Because fire safety measures have already been installed at SONGS 1 and these fire saftey measures provide the capability to ensure a safe shutdown of the station, an exemption from the schedular requirements of the November 19, 1980 regulations will not endanger life or property or the common defense and security and is otherwise in the public interest.

11.

Additional time, until approximately six months after completion of SEP, is necessary to develop the necessary plans and schedules for installation of a safe shutdown capability which properly considers other plant 4

modifications which may be contemplated in connection with completion of the SEP.

KENNETH P. BASKIN Subscribed and sworn to before me this day of 1981.

OFFICIAL SEAL SHEILA N. GAUTHIER NOTARY PUBLIC-CALIFORNIA PRINCIPAL OFFICE IN LOS ANGELES COUNTY My Commission Expires Nov. 4, 1983 Notary Public for tine State of California, County of Los Angeles 5