November 12, 1998
Andrew Barnsdale, Project Manager
c/o Environmental Science Associates
225 Bush Street, Suite 1700
San Francisco, CA 94104

Re: Mitigated Negative Declaration And Initial Study Of The California Public Utilities Commission On San Diego Gas & Electric Company’s Application No. 97-12-030 – Proposal For Divestiture

Dear Mr. Barnsdale:

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Southern California Edison Company (SCE) is operating agent of San Onofre Nuclear Generating Station Unit Nos. 1, 2, and 3 (SONGS). SCE is 80% owner of SONG 1 and 75.05% owner of SONGS 2&3. As such, SCE has an interest in assuring that the description of San Diego Gas & Electric Company’s (SDG&E) 20% share of SONGS in the Mitigated Negative Declaration is accurate.

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At page 2-39 of the Mitigated Negative Declaration, it states that SCE "is solely responsible for operating and maintaining the SONGS facility, for conducting required capital improvements, arranging for nuclear fuel, and refueling of the units" At p. 2-43 of the Mitigated Negative Declaration, it states that "SDG&E does not now manage or control the operations of SONGS . . ." These descriptions are not entirely accurate. the duties and responsibilities of SCE, as operating agent, and the other co-owners, including SDG&E, are set forth in the SONGS Ownership Agreement, dated October 5, 1967, San Onofre Units 2&3 Participation Agreement, dated November 1, 1997, and the Second Amended San Onofre Operating Agreement, dated February 26, 1987 (SONGS Agreements). SDG&E, as a co-owner, has certain responsibilities related to operating and maintaining the SONGS facility as described in the SONGS Agreements.

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SCE also notes that on pages 2-36 and 2-39 the Mitigated Negative Declaration refers to the net generating capacity of SONGS 2&3, combined, by unit, and by SDG&E’s share. In each place, the Mitigated Negative Declaration does not state that the amount of capacity noted is the rated capacity. Specifically, on page 2-39, the Mitigated Negative Declaration states: "SDG&E’s share of SONGS’ maximum output is a total of 214 MW from Unit 2 and 216 MW from Unit 3, or a combined output of 430 MW." In fact, these amounts are SDG&E’s share of SONG’S rated output. The maximum output of SONGS on any given day varies due to ambient temperature and other operating conditions and can exceed or be lower than the rated output.

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The Mitigated Negative Declaration at page 2-36 states: "Unit 1 had a net generating capacity of 436 MW and has since been decommissioned." In fact, Unit 1 has not yet been decommissioned, but has been permanently shutdown. SCE and SDG&E are currently planning to submit a request in December of this year to commence decommissioning of SONGS 1.

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Finally, the Mitigated Negative Declaration states, on page 2-36: "Units 2&3 were constructed in 1983 and 1984, respectively." In fact, Units 2&3 were constructed over a much longer period than just the years 1983 and 1984. However, Units 2&3 were placed in commercial operation in 1983 and 1984, respectively.

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SCE respectfully submits these comments on the Mitigated Negative Declaration. Any questions with regard to these comments may be directed to me at (626) 302-1337.

Very truly yours,
Carol A. Schmid-Frazee

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