ML20198A150
| ML20198A150 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 09/09/1985 |
| From: | Allen H SOUTHERN CALIFORNIA EDISON CO. |
| To: | Dircks W NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| Shared Package | |
| ML20198A146 | List: |
| References | |
| NUDOCS 8509230304 | |
| Download: ML20198A150 (2) | |
Text
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EtlCLOSURE 3 Southem Califomia Edison Company l
RO.Som800 3844 WALNUT OROVE AVENUE MOwARD P. ALLEN OSEMEAD.CALiromN8A Sf770 towemam.F Tag sosas ano tit o.g en.o useuws n.ca.
September 9, 1985
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Mr. William J. Dircks Executive Director for Operations U.S. Nuclear Regulatory Commission Washington, D.C.
20555 i
Dear Mr. Dircks:
As you probably know, the Southern California Edison Company is involved in a proceeding before the California Public Utilities Commission (CPUC) on the reasonableness of the construction expenditures for Sar onofre Units 2 and 3.
In the course of this proceeding, the line between economic regulation by the CPUC and safety regulation by the NRC has become blurred in a way that is deeply troubling to me i
not only because of the possible impact for our own plants but i
also because of the broader implications for the safety of all commercial nuclear plants.
While implementing safety require-t ments in design, construction, and operation during the course of building nuclear plants is the utility's primary responsi-l bility, the adequate discharge of that responsibility is chal-lenged, examined, and verified at every stage of the licensing review process by the Nuclear Regulatory Commission Staff.
Ironically, we find ourselves defending against charges that we have been too forthcoming in our relations with the NRC.
For example, the CPUC Staff has recommended a capital disallowance because we delayed startup for several days to perform an NRC-mandated inspection when we thought it was necessary rather than at the next refueling which would have been allowed by the NRC Bulletin.
The amount of money involved in this instance is not overly large, but the implications are enormous.
In another instance, our initiative to perform an indepen-dent seismic design review in the wake of the discovery of the mirror-image error at Diablo Canyon has been questioned by the l
CPUC Staff on the grounds that we went beyond NRC require-ments.
Finally, the time to license Units 2 and 3 has been 0723030 u. -
f Mr. William J. Dircks Page 2 September 9, 1985 t
deemed excessive because it is supposed to be obvious that the NRC supplies an operating license whenever a plant is com-pleted, no matter what.
These notions are as repugnant to us as they must be to you, and we hope they will be rejected by the California Commission.
However, at this point we cannot be sure.
No matter how well intended, the effect of this line of argument by the CPUC Staff, if upheld by the California com-mission, will be to establish economic disincentives for full and wholehearted compliance with the requirements of safety regulation.
This will not alter our commitment to safety.
I am, however, concerned that this will make it more difficult for us to discharge our health and safety responsibilities.
This issue is not limited to California in view of the importance of the California commission among the public utility commissions around the country.
The implications for the relationship between the NRC and the utilities around the country are obvicus.
We have no intention of drawing the NRC into our rate proceeding.
We feel we have an excellent record both in terms of cost and schedule for the construction of San Onofre Units 2 and 3.
We are very proud of our achievement and we expect to put on a very powerful case.
We hope for a favorable ruling from the california commission, and we also hope it will reject the Staff arguments I have described.
At the same time, the implications of an extension of economic regulation into the safety arena are significant for the reasons noted.
I would appreciate any comments you may i
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wish to provide.
Sincerely,
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