ML20010C912
| ML20010C912 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 08/17/1981 |
| From: | Rogin E ORRICK, HERRINGTON & SUTCLIFFE, SAN DIEGO GAS & ELECTRIC CO., SOUTHERN CALIFORNIA EDISON CO. |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML20010C913 | List: |
| References | |
| ISSUANCES-OL, NUDOCS 8108210210 | |
| Download: ML20010C912 (3) | |
Text
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DAVID R. PIGOTT j)'>h s g f
EDWARD B. ROGIN c
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SAMUEL B. CASEY ALAN C.
WALTNER syx 4
of ORRICK, HERRINGTON & SUTCLIFFE f' % a [J
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c;,7f jg y {Q ' 86 A Professional Corporation kOV I
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600 Montgomery Street San Francisco, CA 94111
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5 Telephone:
(415) 392-1122 N N-6 CHARLES R. KOCHER N
JAMES A.
BEOLETTO D
7 SOUTHERN CALIFORNIA EDISON COMPANY P. O. Box 800 gj A
8 2244 Walnut Grove Avenue Rosemead, CA 91770 9
Telephone:
(213) 572-1900 (l-
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10 Attorneys for Applicants, D'
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Southern California Edison Company 11 and San Diego Gas & Electric Company j
CD 12 13 UNITED STATES OF AMERICA 14 NUCLEAR REGULATORY COMMISSION 15 BEFORE THE ATOMIC SAFETY aND LICENSING BOARD l
16 17 18 In the Matter of
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19
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SOUTHERN CALIFORNIA
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Docket Nos. 50-361 OL 50-362 OL 20 EDISON COMPANY, ET AL.,
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21 (San Onofre Nuclear
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Generating Station,
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22 Units 2 and 3)
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23 REQUEST FOR CE7.;IFICATION
{$o3 24 TO THE NUCLEAR REGULATORY g
i 25 COMMISSION 1
1 26 81C'3210210 010817 DR ADOCK 05000
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Mpplicants Southern California Edison Company and 2
San Diego Gas & Electric Company (" Applicants") hereby 3
request, pursuant to 10 C.F.R. 52.718(1), that this Atomic 4
Safety and Licensing Board (" Board") certify the following questions to the Nuclear Regulatory Commission (" Commission"):
5 6
Whether the Board has improperly abused its 7
discretion and its sua spante oowers (10 C.F.R. 52.760a) by 8
requiring, without factual basis, and in excess of the 9
Commission's regulatory requiremento consideration of 10 emergency planning features following:
11 (1)
An earthquake in excess of the Safe Shutdown 12 Earthquake ("SSE") which is assumed, without 13 factual basis, to cause a major radiologica]
14 release and evacuation in the plume exposure 15 pathway of the Emergency Planning Zone 16
("EPZ"), and/or 17 (2)
An earthquake in excess of the SSE which is 18 assumed co occur coincident with a 19 non-earthquake related radiological release 20 requiring evacuation in the plume exposure 21 pathway of the EPZ.
22 This request for certification is made necessary by 23 the Board's " Order, (Modifying an Issue Concerning 1981.
24 Earthquakes and Emergency Planning)," dated August 7, the 25 The request for certification is based on thin accument, 26 above described Order dated August 7, 1981, Applicants' 2
e 1
" Memorandum of Points and Authorities in Support of Request 2
for Certification to the Nuclear Regulatory Commission" and 3
" Memorandum in Opposition to Issue Raised Sua Sponte by order 4
of August 7, 1981" and the (Proposed) Order Certifying 5
Emergency Planning Contention to the Nuclear Regulatory 6
Commission filed herewith, the record in the above-captioned proceeding and any and all oral or documentary evidence and 7
8 argument at may be presented.
9 Due to the importance of this issue and the approaching date for the commencement of the hearing, 10 Applicants urge that the Licensing Board consider this 11 Request on an expedited basis and that other parties' replies 12 13 be required three (3) days after receipt hereof with service 14 by Express Mail or other expedited delivery.
15 Dated. August 17, 1981 Respectfully submitted, 16 DAVID R. PIGOTT 17 EDWARD B. ROGIN SAMUEL B. CASEY 18 ALAN C. WALTNER Of ORRI.CK, HERRINGTON & SOTCLIFFE 19 A Professional Corporation 20 CHARLES R. KOCHER JAMES A.
BEOLETTO 21 SOUTHERN CALIFORNIA EDISON COMPANY 22 23 EDWARD B. ROGIN N
By Edward B. Rogin 25 Attorneys for Applicants One of Counsel ~for Applicants 26 Southern California Edison Company and San Diego Gas &
Electric Company 3