ML20010F883
| ML20010F883 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 08/31/1981 |
| From: | Pigott D ORRICK, HERRINGTON & SUTCLIFFE, SAN DIEGO GAS & ELECTRIC CO., SOUTHERN CALIFORNIA EDISON CO. |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML20010F885 | List: |
| References | |
| ISSUANCES-OL, NUDOCS 8109150075 | |
| Download: ML20010F883 (4) | |
Text
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1 DAVID R. PIGOTT EDWARD B.
ROGIN 2
ALAN C. WALTNER Of ORRICK, HERRINGTON & SUTCLIFFE 3
A Professional Corporation 600 Montgomery Street 4
San Francisco, CA 94111 Telephone:
(415) 392-1122 CHARLES R. KOCHER p
A 6
JAMES A.
BEOLETTO SOUTHERN CALIFORNIA EDISON COMPANY 7
P.
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Box 800 Do De 7g 2244 Walnut Grove Avenue 2
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Rosemead, CA 91770 E-9 198(' 3 L
f C[g.an;r3f%y Telephone:
(213) 572-1900 ef 9
Attorneys for Applicants, 1
Agn:4 #4 10 Southern California Edison Company
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and San Diego Gas & Electric Company
' / MI 11 12 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION l
13 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 14 l
15 In the Matter of
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l 16' SOUTHERN CALIFORNIA EDISON
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Docket No. 50-361 OL COMPANY, et al.
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(San Onofre Nuclear
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l 18 Generating Station Unit 2)
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19 20 ALTERNATIVE MOTION OF APPLICANTS 21 SOUTHERN CALIFORNIA EDISON COMPANY, ET AL.
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~FOR AN OPERATING LICENSE FOR FUEL LOADING AND LOW-POWER TESTING 23 O50
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1 Applicants Southern California Edison Company, San 2
Diego Gas and Electric Company, and the cities of Riverside 3
and Anaheim (" Applicants") will be ready to commence fuel 4
loading and low-power testing of the San Onofre Nuclear 5
Generating Station Unit 2 (" SONGS l') on or about October 15, 6
1981.
Unde.r the original hearing schedule, potential delays 7
in the operation cf SONGS 2 appeared to be only moderate.
8 However, on August 7, 1981 the Board issued an order 9
dramatically expanding the potential scope of these 10 proceedings, leading to the likelihood of substantially 11 increased delays in operation of SONGS 2.
12 Applicants would prefer that the original schedule 13 be restored and that a full-power operating license be issued 14 expeditiously.
To that end, Applicants have requested the 15 Board to certify to the Commission the appropriateness of the 1
16 Board's issue.
However, if at the end of the originally 17 scheduled emergency planning hearings (currently underway),
18 the Board considers the record inadequate to support issuance 19 of a full-power operating license, Applicants hereby move, 20 pursuant to 10 C.F.R.
550.57(c), for an operating license for 21 SONGS 2 authorizing Applicants to (1) load fuel, (2) proceed 22 to initial criticality, (3) perform startup testing at zero 23 power, and (4) after prior written approval of the Director, 24 Office of Nuclear Reactor Regulation, operate SONGS 2 for 25 testing at reactor core power levels not in excess of 5% of 26 its rated power (169.5 megawatts thermal)
(" low-power l
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testing").
The fuel loading and testing program requested to 2
be performed by Applicants is outlined in the testing program 3
summary attached hereto as Appendix 1 and incorporated herein 4
by reference as if set forth fully herein.
5 Due to the substantial costs of delay in full-power 6
operation of SONGS 2, Applicants make this motion for 7
low-power testing only as an alternative to its pending 8
application for a full-power operating license.
Because of 9
the costs of any delay, this motion should not slow the 10 current full-power licensing proceedings.
However, due to 11 the added delay resulting from the 3oard's issue, a 12 full-power operating license will not issue until ws_1 after 13 Applicants are prepared to commence low-power testing.
Such 14 delay on low-power testing vill result in a corresponding 15 delay in full-power operations, with attendant costs.
16 This motion is made on the ground that all 1,
17 requirements for issuance of the requested operating license 18 have been met as described more fully in the attached 19 memorandum of points and authorities.
Issuance of the 20 requested operating license for fuel leading and low-power l
21 testing will not prejudice intervenors with respect to 22 contentions that have been admitted into this proceeding.
23 Favorable findings on the matters specified in 10 C.F.R.
24 550.57(a) can be made oy this Licensing Board and the 25 Director of Nuclear Reactor Regulation.
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1 This motion is based on the motion; the attached 2
memorandum of points and authorities in support of the 3
motion; the attached proposed order; the record of this 4
proceeding; and such further documentary evidence as may be 5
filed herein or such oral argument of counsel as may be 6
presented at a hearing on this motion.
7 Dated:
August 31, 1981 8
Respectfully submitted, 9
DAVID R. PIGOTT EDWARD B.
ROGIN 10 ALAN C. WALTNER Of ORRICK, HERRINGTON & SUTCLIFFE 11 A Professional Corporation 12 CHARLES R.
KOCHER JAMES A.
BEOLETTO 13 SOUTHERN CALIFORNIA EDISON COMPANY 14 15 by David R. Pigott
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16 Attorneys for Applicants 17 18
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