ML20040H088

Affidavit of R Dietch Opposing Carstens 820127 Application for Stay of Low Power License.Facility Const Complete,Util Prepared to Commence Fuel Loading & Low Power Testing & Delay Would Cause Irreparable Injury.Proof of Svc Encl

ML20040H088
Person / Time
Site:	San Onofre
Issue date:	02/08/1982
From:	Dietch R SOUTHERN CALIFORNIA EDISON CO.
To:
Shared Package
ML20040H083	List: ML20040H082 ML20040H088
References
ISSUANCES-OL, NUDOCS 8202170143
Download: ML20040H088 (9)

Text

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NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL BOARD In the Matter of SOUTHERN

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Docket Nos. 50-360 OL CALIFORNIA EDISON COMPANY,

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50-361 OL et al. (San Onofre Nuclear

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AFFIDIVIT OF ROBERT DIETCH Generating Station,

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IN OPPOSITION TO INTERVENORS' Units 2 and 3).

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APPLICATION FOR STAY OF LOW

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POWER LICENSE State of California,

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ss.

County of Los Angeles. )

I, Robert Dietch, being first duly sworn, declare that if called to testify in this proceeding, I could competently do so, as follows:

1.

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

("SCE") as Vice President, Nuclear Engineering and Operation.

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

licensing proceedings and for the operation of the San Onofre Nuclear Generating Station (" SONGS").

2.

The purposes of this affidavit are to demonstrate that construction of SONGS Unit 2 is complete; that Applicants are prepared to commence the fuel-loading and low-power testing program for SONGS Unit 2 in February, 1982; that to Applicants' knowledge there are no unresolved issues barring the issuance of the fuel-loading and low-power testing license for SONGS Unit 2; that it appears to P202170143 B'20200 PDR ADOCK 05000361 Q

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Applicants at this time that such issuance is imminent; that any delay in the Project Schedule for any reason, including the grant of the stay requested by the Intervenors, will result in substantial and irreparable injury to Applicants, Applicants ralepayers, and the environment; and that the radioactivity created by the low power testing program will not preclude the Applicants' capability to implement any plant modifications that may be required by the NRC.

3.

On January 11, 1982, the Atomic Safety and Licensing Board (the " Board") of the United States Nuclear Regulatory Commission ("NRC") issued its Partial Initial Decision and Order authorizing issuance of a fuel-loading and low-power testing license for SONGS Unit 2.

Under the NRC's Rules of Practice, the Board's Order is immediately effective and requires issuance of the license authorized by the initi al Decision and Order within ten (10) days from the date of ti.e decision or as soon thereafter as the NRC's Director of Nuclear Reactor Regulation (the " Director") can make the findings required by 10 C.F.R. 5 50.57(a).

The Partial Initial Decision and Order also required that the onsite Emergency Plan for SONGS Units 2 and 3 be in effect.

4.

Since issuance of the Partial Initial Decision and Order the following items noted by Intervenors in their Application for a Stay have been completed:

4.1 The NRC Staff has announced that the required number of Senior Reactor Operators are now qualified to operate SONGS Unit 2.

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4.2 An independent consultant has submitted to the Director a report on the Seismic Design Verification Program for SONGS Unit 2.

Applicants have no reason to believe that this report is insufficient to justify issuance of a fuel-loading, low-power testing license for SONGS Unit 2.

5. : The onsite Emergency Plan for SONGS Units 2 and 3 has been fully implemented, including complete implementing procedures and accomplishment of all required training.

The NRC Staff has completed its inspection and is currently preparing its report to the Board regarding the onsite Emergency Plan.

Based upon exit interviews with the NRC Staff, Applicants have no reason to believe that this report will not be favorable.

6.

As of this date, I am informed and believe that all items remaining to permit the Director to make the necessary findings under 10 C.F.R. S 50.57(a) and issue the license for SONGS Unit 2 have been resolved and issuance of said license is imminent.

7.

Construction of SONGS Unit 2 is substantially complete and the Project Schedule currently calls for fuel loading in February, 1982.

All required equipment and personnel are onsite awaiting the issuance of the fuel loading, low-power testing license for SONGS Unit 2.

Upon issuance of this license, a detailed low-power testing program will be accomplished.

Completion of this program 3

takes approximately 108 days of continuous activities and involves licensed operators supported by a group of about

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3

I twenty SCE start-up personnel, approximately ten start-up personnel from the Combustion Engineering Company, and various other technical experts from SCE and other vendors of major components, as required.

8.

2 The record on the Applicants' application for full-power authorization for SONGS Units 2 and 3, is closed and no reason appears why issuance of an Initial Decision on this application cannot be issued by the Board well in advance of the completion of the low power testing program for SONGS, Unit 2.

Based upon industry experience, it is unlikely that SONGS Unit 2 low-power testing program can be accomplished in much less time, and it may take more time.

For example, Sequoyah Unit 1 took 147 days; Maquire Unit 1 took about 132 days; North Anna Unit 2 took 103 days, and Salem Unit 2 took 98 days.

Accordingly, it reasonably appears to Applicants that any delay in commencing the low power testing program will result in a day-for-day delay in full-power operation of SONGS Unit 2.

9.

Any delay in the Project Schedule for SONGS Unit 2 will result in substantial increases in the cost of the project.

These costs will ultimately be borne either by the Applicants or the Applicant's ratepayers in the form of increased utility rates.

A delay in the Unit 2 Project Schedule would result in additional costs of approximately

$52.5 million per month, or $1.73 million per day, of delay.

This cost increase is attributable to the following factors:

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l 9.1 Cost of Alternative Fuel:

In the event SCE is unable to operate SONGS 2, it must turn to fuel oil to generate the electricity which would otherwise have been generated by Unit 2.

Approximately O.9 million barrels of fuel oil per month would be needed to generate this power.

This will result in additional fuel costs of $36 million per month.

9.2 Financing Costs:

Applicants are precluded by law from recovering the costs of construction of the SONGS Unit 2 from the utility ratepayer until SONGS Unit 2 is placed in full-power operation.

As a result, Applicants must finance all construction costs until SONGS Unit 2 is placed in full-power operation.

These financing costs are approximately $12.5 million per month.

Accordingly, each month of delay in placing SONGS Unit 2 in operation results in increased financing costs of $12.5 million.

9.3 Additional Costs:

Additional operating costs would be incurred by the Applicants in the amount of approximately $4 million for each month in which Applicants are forced to maintain SONGS Unit 2 in a standby, nonoperational mode.

I, 9.4 Environmental Costs:

Because it will be necessary to burn an additional 0.9 million barrels of fuel oil in place of the nuclear fuel in the event operation of the SONGS Unit 2 is delayed, an additional 1350 tons per month of pollutants (based upon system simulation due 5

m primarily to additional Nitrogen Oxides and Sulfur Dioxides) will be emitted relative to the amount of polluntants which will be emitted if the SONGS Unit 2 could be placed in operation.

10."

It has been the industry experience that performance of repairs, maintenance and modificaticas after completion of low-power tests are not made significantly more difficult or costly by reason of fission products in the core or contamination of the primary coolant system resulting from low-power test.

In fact, both Salem Unit 2 and North Anna Unit 2 have reported that after completion of low-power tests there was no increase in background radiation in the containment.

Indeed, workers at Salem 2 performed a number of TMI-related improvements, including modifications requiring contact with the primary coolant, without protective clothing.

11.

SCE has had substantial experience involving structural and mechanical modifications to SONGS Unit 1 after that reactor had been operating for a number of years at full power creating a much larger inventory of fission products in the core and in the primary coolant system than would be present at the completion of a low-power testing program.

Based on SCE's experience, I would conclude that there is no work which cannot be accomplished at SONGS Unit 2 simply because low-power tests have been conducted and fission products are in the reactor core.

Any work that might be 6

required would only result in minor cost increases due to special provisions to minimize worker radiation.

12.

Based upon the considerations described above, I would conclude that while a decision to stay the low-power licenseisnokrequiredtopreserveApplicants' ability to make whatever modifications the NRC should decide in the future are necessary, such a decision would immediately cause unnecessary and irreparable environmental damage and financial loss to Applicants, Applicants ratepayers and the public at large.

Robert Dietch Subscribed and Swog to before me this

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day

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of February, 1982.

AGNES CRABTREE NOTARY PUBlic - cat *0ANtA PRINCIPAL OFFICE IN g

LOS ANGELES COUNTY My Commimon Esp Aug 27.1982 qw Notyliry Public, State of California, County of Los Angeles 7

,. lE i

PROOF OF SERVICE BY MAIL I declare that:

I am employed in the City of Rosemead, California, County of Los Angeles.

I am over the age of eighteen years and not a party to the within entitled action; my business address is 2244 Walnut Grove Avenue, Rosemead, California 91770 On February 8, 1982, I served the attached APPLICANTS' RESPONSE IN OPPOSITION TO INTERVENORS' CARSTENS, ET. AL.'S APPLICATION FOR A STAY in said cause, by placing a true copy thereof enclosed in the United States mail at Rosemead, California addressed as follows:

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• Stephen F. Eilperin, Esq.

• James L. Kelly, Chairman Chairman, Atomic Safety And Administrative Judge Licensing Appeal Board Atomic Safety and U.S. Nuclear Regulatory Commission Licensing Board Washington, D. C.

20555 U.

S. Nuclear Regulatory Commission

• Dr. Reginald L. Gotchy Washington, D.

C.

20555 l

Atomic Safety and Licensing Appeal Board Dr. Cadet H. Hand, Jr.

U. S. Nuclear Regulatory Commission Administrative Judge Washington, D. C.

20555 c/o Bodega Marine Laboratory

• Dr. W. Reed Johnson University of California Atomic Safety and Licensing P. O. Box 247 Appeal Board Bodega Bay, CA 94923 U. S. Nuclear Regulatory Commission Washington, D.

C.

20555 Mrs. Elizabeth B. Johnson Administrative Judge Oak Ridge National Laboratory Oak Ridge, TN 37830

• Copy Served by overnight Courier

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Robert Dietch, Vice President Alan R,.

Watts, Esq.

Southern California Edison Rourke & Woodruff Company California First Bank P. O. Box 800 Building 2244 Walnut Grove Avenue 10555 North Main Street Rosemead, CA 91770 Santa Ana, CA 92701

• Lawrence J. Chandler, Esq.

David W. Gilman Donald F. Hassell, Esq.

Robert G. Lacy Nuclear Regulatory Commission San Diego Gas & Electric Office of the Executive Legal P. O. Box 1831 Director San Diego, CA 92112 Washington, D. C.

20555 Mr. Lloyd von Haden Mrs. Lynn Harris Hicks 2089 Foothill Drive GUARD Vista, CA 92083 3908 Calle Ariana San Clemente, CA 92801 James F. Davis State Geologist Richard J. Wharton, Esq.

Division of Mines and University of San Diego Geology School of Law 1416 Ninth Street, Alcala Park Room 1341 San Diego, CA 92110 Sacramento, CA 95814 Janice E. Keer, Esq.

Atomic Safety and Licensing J. Calvin Simpson, Esq.

Appeal Board Lawrence Q. Garcia, Esq.

U. S.

Nuclear Regulatory California Public Utilities Commission Commission Washington, D,C.

20555 5066 State Building San Francisco, CA 94102 Atomic Safety and Licensing Board Docketing and Service Section U.S. Nuclear Regulatory l

Office of the Secretary Commission l

U.S. Nuclear Regulatory Washington, D.C.

20555 Commission Washington, D.C.

20555 Phyllis M. Gallagher, Esq.

Charles E. McClung, Jr., Esq.

1695 W. Crescent Avenue 23521 Paseo de Valencia Suite 222 Suite 308 Anaheim, CA 92801 Laguna Hills, CA 92653

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Jam A. Beoletto

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One Counsel for Applicants

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