ML062900332

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Issuance of License Amendment Nos. 207 and 199 Regarding Revision of Administrative Controls
ML062900332
Person / Time
Site: San Onofre  Southern California Edison icon.png
Issue date: 11/15/2006
From: Kalyanam N
NRC/NRR/ADRO/DORL/LPLIV
To: Rosenblum R
Southern California Edison Co
Kalynanam N, NRR/DORL/LP4, 415-1480
Shared Package
ML062900329 List:
References
TAC MD2581, TAC MD2582
Download: ML062900332 (17)


Text

November 15, 2006 Mr. Richard M. Rosenblum Senior Vice President and Chief Nuclear Officer Southern California Edison Company San Onofre Nuclear Generating Station P.O. Box 128 San Clemente, CA 92674-0128

SUBJECT:

SAN ONOFRE NUCLEAR GENERATING STATION, UNITS 2 AND 3 -

ISSUANCE OF AMENDMENTS RE: REVISION OF ADMINISTRATIVE CONTROLS (TAC NOS. MD2581 AND MD2582)

Dear Mr. Rosenblum:

The Commission has issued the enclosed Amendment No. 207 to Facility Operating License No. NPF-10 and Amendment No. 199 to Facility Operating License No. NPF-15 for San Onofre Nuclear Generating Station, Units 2 and 3, respectively. The amendments consist of changes to the Technical Specifications (TSs) in response to your application dated July 14, 2006.

The amendments propose to delete duplicative notification, reporting, and restart requirements if a safety limit is violated; replace plant-specific position titles with generic position titles; and additional administrative changes.

A copy of our related Safety Evaluation is also enclosed. The Notice of Issuance will be included in the Commissions next biweekly Federal Register notice.

Sincerely,

/RA/

N. Kalyanam, Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-361 and 50-362

Enclosures:

1. Amendment No. 207 to NPF-10
2. Amendment No. 199 to NPF-15
3. Safety Evaluation cc w/encls: See next page

Pkg ML062900329 (ML062900332, TS ML063190553)

OFFICE NRR/LPL4/PM NRR/LPL4/LA NRR/DIRS/ITSB OGC-NLO NRR/LPL4/BC w/comments NAME NKalyanam LFeizollahi TKobetz JRund DTerao DATE 9/20/06 9/20/06 9/25/06 10/12/06 10/18/06 SOUTHERN CALIFORNIA EDISON COMPANY SAN DIEGO GAS AND ELECTRIC COMPANY THE CITY OF RIVERSIDE, CALIFORNIA THE CITY OF ANAHEIM, CALIFORNIA DOCKET NO. 50-361 SAN ONOFRE NUCLEAR GENERATING STATION, UNIT 2 AMENDMENT TO FACILITY OPERATING LICENSE Amendment No. 207 License No. NPF-10

1. The Nuclear Regulatory Commission (the Commission) has found that:

A. The application for amendment by Southern California Edison Company, et al.

(SCE or the licensee), dated July 14, 2006, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commissions regulations set forth in 10 CFR Chapter I; B. The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commissions regulations; D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commissions regulations and all applicable requirements have been satisfied.

2. Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment, and paragraph 2.C(2) of Facility Operating License No. NPF-10.
3. This license amendment is effective as of the date of its issuance and shall be implemented within 60 days of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION

/RA/

David Terao, Chief Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the Facility Operating License and Technical Specifications Date of Issuance: November 15, 2006

ATTACHMENT TO LICENSE AMENDMENT NO. 207 FACILITY OPERATING LICENSE NO. NPF-10 DOCKET NO. 50-361 Replace the following page of the Facility Operating License with the attached revised page.

The revised page is identified by an amendment number and contains a marginal line indicating the area of change.

REMOVE INSERT Replace the following pages of the Appendix A Technical Specifications with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.

REMOVE INSERT 2.0-1 2.0-1 2.0-2 --------

5.0-1 5.0-1 5.0-2 5.0-2 5.0-3 5.0-3 5.0-4 5.0-4 5.0-5 5.0-5 5.0-8 5.0-8 5.0-31 5.0-31

SOUTHERN CALIFORNIA EDISON COMPANY SAN DIEGO GAS AND ELECTRIC COMPANY THE CITY OF RIVERSIDE, CALIFORNIA THE CITY OF ANAHEIM, CALIFORNIA DOCKET NO. 50-362 SAN ONOFRE NUCLEAR GENERATING STATION, UNIT 3 AMENDMENT TO FACILITY OPERATING LICENSE Amendment No. 199 License No. NPF-15

1. The Nuclear Regulatory Commission (the Commission) has found that:

A. The application for amendment by Southern California Edison Company, et al.

(SCE or the licensee), dated July 14, 2006, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commissions regulations set forth in 10 CFR Chapter I; B. The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commissions regulations; D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commissions regulations and all applicable requirements have been satisfied.

2. Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment, and paragraph 2.C(2) of Facility Operating License No. NPF-15.
3. This license amendment is effective as of the date of its issuance and shall be implemented within 60 days of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION

/RA/

David Terao, Chief Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the Facility Operating License and Technical Specifications Date of Issuance: November 15, 2006

ATTACHMENT TO LICENSE AMENDMENT NO. 199 FACILITY OPERATING LICENSE NO. NPF-15 DOCKET NO. 50-362 Replace the following page of the Facility Operating License with the attached revised page.

The revised page is identified by an amendment number and contains a marginal line indicating the area of change.

REMOVE INSERT Replace the following pages of the Appendix A Technical Specifications with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.

REMOVE INSERT 2.0-1 2.0-1 2.0-2 --------

5.0-1 5.0-1 5.0-2 5.0-2 5.0-3 5.0-3 5.0-4 5.0-4 5.0-5 5.0-5 5.0-8 5.0-8 5.0-31 5.0-31

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 207 TO FACILITY OPERATING LICENSE NO. NPF-10 AND AMENDMENT NO. 199 TO FACILITY OPERATING LICENSE NO. NPF-15 SOUTHERN CALIFORNIA EDISON COMPANY SAN ONOFRE NUCLEAR GENERATING STATION, UNITS 2 AND 3 DOCKET NOS. 50-361 AND 50-362

1.0 INTRODUCTION

By application dated July 14, 2006 (Agencywide Documents Access and Management System Accession No. ML061990014), Southern California Edison Company (the licensee) requested changes to the Technical Specifications (TSs) for San Onofre Nuclear Generating Station (SONGS), Units 2 and 3.

The proposed changes would delete duplicative notification, reporting, and restart requirements if a safety limit is violated; replace plant-specific position titles with generic position titles; and make several additional administrative changes. The proposed deletion of notification, reporting, and restart requirements, if a safety limit is violated, deletes requirements from the TSs that are duplicative or contained in other regulations or required to comply with regulations (Section 50.36 of Title 10 of the Code of Federal Regulations (10 CFR)). The proposed changes to replace plant-specific position titles with generic position titles do not eliminate any of the qualifications, responsibilities, or requirements for these positions.

Specifically, the proposed changes would revise:

TS 2.0 SAFETY LIMITS (SLs), Section 2.2, SL Violations Delete the following Parts 2.2.3, 2.2.4, 2.2.5, and 2.2.6:

A. 2.2.3 Within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />, notify the NRC [Nuclear Regulatory Commission]

Operations Center, in accordance with 10 CFR 50.72.

B. 2.2.4 Within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, notify the Vice President - Nuclear Generation and the Nuclear Safety Group (NSG) Supervisor.

C. 2.2.5 Within 60 days of the violation, a Licensee Event Report (LER) shall be prepared pursuant to 10 CFR 50.73. The LER shall be submitted to the NRC, the NSG Supervisor, and the Vice President - Nuclear Generation.

D. 2.2.6 Operation (Modes 1 and 2) of the unit shall not be resumed until authorized by the NRC.

TS 5.0 ADMINISTRATIVE CONTROLS, Section 5.1, Responsibility Section 5.1, Responsibility, Parts 5.1.1, 5.1.2, and 5.1.3:

Replace Vice President - Nuclear Generation with corporate officer with direct responsibility for the plant.

TS 5.0 ADMINISTRATIVE CONTROLS, Section 5.2, Organization A. Part 5.2.1 Onsite and Offsite Organizations, Subpart 5.2.1.a: Add , including the plant-specific titles of those personnel fulfilling the responsibilities of the positions delineated in these Technical Specifications, to the last sentence. This sentence will then read as follows: These relationships, including the plant-specific titles of those personnel fulfilling the responsibilities of the positions delineated in these Technical Specifications, are documented in the UFSAR

[Updated Final Safety Analysis Report].

B. Part 5.2.1 Onsite and Offsite Organizations, Subpart 5.2.1.b: Replace Vice President - Nuclear Generation with corporate officer with direct responsibility for the plant.

C. Part 5.2.1 Onsite and Offsite Organizations, Subpart 5.2.1.c: Replace the plant-specific titles the Vice President - Engineering & Technical Services and the Vice President - Nuclear Generation with A specified corporate officer (or officers) and revise this part as follows: A specified corporate officer (or officers) shall have corporate responsibility for overall plant nuclear safety and shall take any measures needed to ensure acceptable performance of the staff in operating, maintaining, and providing technical support to the plant to ensure nuclear safety.

D. Part 5.2.2 UNIT STAFF, Subpart 5.2.2.d: Replace health physics technician with radiation protection technician.

E. Part 5.2.2 UNIT STAFF, Subpart 5.2.2.e: Replace cognizant Vice President within the Nuclear Organization with cognizant corporate officer.

F. Part 5.2.2 UNIT STAFF, Subpart 5.2.2.f: Replace Manager, Unit 2/3 Plant Operations with Manager, Plant Operations, and delete the second sentence:

The Control Operators and Assistant Control Operators shall hold a Reactor Operators license or Senior Reactor Operators license.

TS 5.0 ADMINISTRATIVE CONTROLS, Section 5.3, Unit Staff Qualifications

Part 5.3.1: Replace Health Physics Manager with radiation protection manager.

TS 5.0 ADMINISTRATIVE CONTROLS, Section 5.5, Procedures, Programs, and Manuals Part 5.5.2, Programs and Manuals, Subpart 5.5.2.1.1.b: Replace Vice President -

Nuclear Generation with corporate officer with direct responsibility for the plant, and delete his before designee.

TS 5.0 ADMINISTRATIVE CONTROLS, Section 5.8, High Radiation Area Part 5.8.2: Replace shift supervisor with shift manager and replace health physics supervisor with radiation protection supervisor.

2.0 REGULATORY EVALUATION

The staff finds that the licensee in Section 5.2 of its submittal identified the applicable regulatory requirements.

Section 50.36 of 10 CFR requires TSs for nuclear reactors to include items in the following categories: (1) SLs and limiting safety system settings (LSSSs); (2) limiting conditions for operation; (3) surveillance requirements; (4) design features; and (5) administrative controls.

The regulation does not specify the particular requirements to be included in a plants TSs.

The regulations in 10 CFR 50.4 provide direction regarding written communications, and include general requirements, distribution requirements, form of communications, and the regulation governing submission.

Pursuant to 10 CFR 50.36(c)(1) on SLs, LSSSs, and limiting control settings, If any safety limit is exceeded, the reactor must be shut down. The licensee shall notify the Commission, review the matter, and record the results of the review ... and for these reactors, the licensee shall notify the Commission as required by § 50.72 and submit a Licensee Event Report to the Commission as required by § 50.73... The regulations in 10 CFR 50.36(c)(5) on administrative controls states, [a]dministrative controls are the provisions relating to organization and management, procedures, recordkeeping, review and audit, and reporting necessary to assure operation of the facility in a safe manner. Each licensee shall submit any reports to the Commission pursuant to approved technical specifications as specified in § 50.4.

The regulations in 10 CFR 50.72 address the immediate notification requirements for operating nuclear power reactors for general events and non-emergency events under 1-hour, 4-hour, and 8-hour classifications. The licensee event report system is discussed in 10 CFR 50.73.

Adequate administrative controls exist in administrative programs at SONGS, Units 2 and 3 for the identification and necessary reporting of SL violations in accordance with 10 CFR 50.36, 10 CFR 50.72, and 10 CFR 50.73. This change is consistent with NRC approved Industry/Technical Specification Task Force (TSTF) Standard Technical Specification Change Traveler TSTF-5-A, Revision 1, Delete notification, reporting, and restart requirements if a safety limit is violated. The proposed change is also consistent with NUREG-1432, Standard Technical Specifications - Combustion Engineering Plants, Revision 3.

The function of the Administrative Controls section of the Technical Specifications, as stated in 10 CFR 50.36(c)(5), is to provide provisions relating to organization and management, procedures, recordkeeping, review and audit, and reporting necessary to assure operation of the facility in a safe manner. Under the proposed changes, Technical Specifications 2.0 and 5.0 will continue to meet these objectives.

The proposed changes from plant-specific to generic position titles are consistent with TSTF-65-A, Revision 1, Use of generic titles for utility positions. The proposed changes from plant-specific to generic position titles are also consistent with NUREG-1432, Revision 3.

Additional administrative changes are proposed which do not modify the qualifications, responsibilities, or requirements for the positions.

3.0 TECHNICAL EVALUATION

TS 2.0 SAFETY LIMITS (SLs), Section 2.2, SL Violations Delete the following Parts 2.2.3, 2.2.4, 2.2.5, and 2.2.6:

A. 2.2.3 Within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />, notify the NRC Operations Center, in accordance with 10 CFR 50.72.

B. 2.2.4 Within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, notify the Vice President - Nuclear Generation and the Nuclear Safety Group (NSG) Supervisor.

C. 2.2.5 Within 60 days of the violation, a Licensee Event Report (LER) shall be prepared pursuant to 10 CFR 50.73. The LER shall be submitted to the NRC, the NSG Supervisor, and the Vice President - Nuclear Generation.

D. 2.2.6 Operation (Modes 1 and 2) of the unit shall not be resumed until authorized by the NRC.

TS 2.0 contains actions to be taken in the event of a SL violation. These actions require that the NRC Operations Center be notified by telephone within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />, and the Vice President -

Nuclear Generation and the NSG Supervisor within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> following any such violation.

Further, a report describing applicable circumstances preceding the violation; effects of the violation on the facility components, systems, or structure; and corrective action taken to prevent recurrence of the violation must be submitted to the Commission, Vice President -

Nuclear Generation within 60 days of the violation. TS 2.0 also requires that critical operation of the unit not be resumed until authorized by the Commission.

These requirements are after-the-fact notifications and reviews, and are not required to assure the safe operation of the facility. These requirements are duplicated in 10 CFR 50.36, 10 CFR 50.72, and 10 CFR 50.73, except the telephone notification to the NRC Operations Center may be made within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />, as set forth in 10 CFR 50.72(b)(2). Because SONGS 2 and 3 are still required to meet these regulations, repetition of the requirements in the TSs is not needed. Additionally, these changes are consistent with NUREG-1432, Revision 2, as modified by TSTF-5, Revision 1. The removal of the statements from TS Safety Limit Action 2.2.3, Safety Limit Action 2.2.4, Safety Limit Action 2.2.5, and Safety Limit Action 2.2.6, and conforming change made to pages 2.0-1 and 2.0-2 are administrative changes, do not change the technical content, intent, or interpretation of these of the TS and do not relieve the licensee

of any obligations except to extend reporting time to that which is specified in the regulations.

Therefore, the staff finds these changes to be acceptable.

TS 5.0 ADMINISTRATIVE CONTROLS, Section 5.1, Responsibility Section 5.1, Responsibility, Parts 5.1.1, 5.1.2, and 5.1.3:

Replace Vice President - Nuclear Generation with corporate officer with direct responsibility for the plant.

TS 5.0 ADMINISTRATIVE CONTROLS, Section 5.2, Organization A. Part 5.2.1 Onsite and Offsite Organizations, Subpart 5.2.1.a: Add, including the plant-specific titles of those personnel fulfilling the responsibilities for the positions delineated in these Technical Specifications, to the last sentence. This sentence will then read as follows: These relationships, including the plant-specific titles of those personnel fulfilling the responsibilities for the positions delineated in these Technical Specifications, are documented in the UFSAR.

B. Part 5.2.1 Onsite and Offsite Organizations, Subpart 5.2.1.b: Replace Vice President - Nuclear Generation with corporate officer with direct responsibility for the plant.

C. Part 5.2.1 Onsite and Offsite Organizations, Subpart 5.2.1.c: Replace the plant-specific titles the Vice President - Engineering & Technical Services and the Vice President - Nuclear Generation with A specified corporate officer (or officers) and revise this part as follows: A specified corporate officer (or officers) shall have corporate responsibility for overall plant nuclear safety and shall take any measures needed to ensure acceptable performance of the staff in operating, maintaining, and providing technical support to the plant to ensure nuclear safety.

D. Part 5.2.2 UNIT STAFF, Subpart 5.2.2.d: Replace health physics technician with radiation protection technician.

E. Part 5.2.2 UNIT STAFF, Subpart 5.2.2.e: Replace cognizant Vice President within the Nuclear Organization with cognizant corporate officer.

F. Part 5.2.2 UNIT STAFF, Subpart 5.2.2.f: Replace Manager, Unit 2/3 Plant Operations with Manager, Plant Operations, and delete the second sentence, The Control Operators and Assistant Control Operators shall hold a Reactor Operators license or Senior Reactor Operators license.

TS 5.0 ADMINISTRATIVE CONTROLS, Section 5.3, Unit Staff Qualifications Part 5.3.1: Replace Health Physics Manager with radiation protection manager.

TS 5.0 ADMINISTRATIVE CONTROLS, Section 5.5, Procedures, Programs, and Manuals Part 5.5.2, Programs and Manuals, Subpart 5.5.2.1.1.b: Replace Vice President -

Nuclear Generation with corporate officer with direct responsibility for the plant, and delete his before designee.

TS 5.0 ADMINISTRATIVE CONTROLS, Section 5.8, High Radiation Area Part 5.8.2: Replace shift supervisor with shift manager and replace health physics supervisor with radiation protection supervisor.

The NRC staff has identified the licensees proposed TS changes, identified above, as being administrative in nature; i.e., changes that neither reduce nor increase the existing operational limitations and administrative controls for the facility. Administrative changes, which are incidental to adopting Standard Technical Specification (STS) format or phrasing, are intended to incorporate human factors principles into the form and structure of the TSs making them easier to understand and use by plant operations personnel. These changes involve reorganizing, reformatting, and clarifying current TS requirements without affecting technical content or operational restrictions.

The NRC approved this change to STS Revision 1 on December 2, 1997. This traveler modified the STS to allow the use of generic organizational titles in lieu of plant-specific titles.

The licensee proposed to adopt this traveler where applicable, thus meeting the intent of the changes in the traveler while continuing to reflect site-specific commitments. Therefore, the revised TSs contain no significant deviations from the corresponding changes in TSTF-65-A, Revision 1.

These changes would allow SONGS 2 and 3 to revise organizational titles without incurring the resource burden of obtaining a change to the TSs, while ensuring that organizational changes will receive appropriate review under 10 CFR 50.59. Use of generic organizational position titles in the TSs does not eliminate any qualifications, responsibilities, or requirements for the positions currently denoted by site-specific titles. The adoption of the applicable parts of TSTF-65-A, Revision 1, as described above, has no safety impact. Therefore, the administrative changes proposed by the licensee in the present application are found acceptable by the NRC staff.

4.0 STATE CONSULTATION

In accordance with the Commissions regulations, the California State official was notified of the proposed issuance of the amendment. The State official had no comments.

5.0 ENVIRONMENTAL CONSIDERATION

The amendments change recordkeeping, reporting, or administrative procedures or requirements. The Commission has previously issued a proposed finding that the amendments involve no significant hazards consideration and there has been no public comment on such finding (71 FR 53720, dated September 12, 2006). Accordingly, the amendments meet the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(10). Pursuant to

10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments.

6.0 CONCLUSION

The Commission has concluded, based on the considerations discussed above, that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commissions regulations, and (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public.

Principal Contributor: N. Kalyanam Date: November 15, 2006

San Onofre Nuclear Generating Station Units 2 and 3 cc:

Mr. Daniel P. Breig State Department of Health Services Southern California Edison Company P.O. Box 997414, MS 7610 San Onofre Nuclear Generating Station Sacramento, CA 95899-7414 P. O. Box 128 San Clemente, CA 92674-0128 Resident Inspector/San Onofre NPS c/o U.S. Nuclear Regulatory Commission Mr. Douglas K. Porter, Esquire Post Office Box 4329 Southern California Edison Company San Clemente, CA 92674 2244 Walnut Grove Avenue Rosemead, CA 91770 Mayor City of San Clemente Mr. David Spath, Chief 100 Avenida Presidio Division of Drinking Water and San Clemente, CA 92672 Environmental Management P. O. Box 942732 Mr. James T. Reilly Sacramento, CA 94234-7320 Southern California Edison Company San Onofre Nuclear Generating Station Chairman, Board of Supervisors P.O. Box 128 County of San Diego San Clemente, CA 92674-0128 1600 Pacific Highway, Room 335 San Diego, CA 92101 Mr. James D. Boyd, Commissioner California Energy Commission Mark L. Parsons 1516 Ninth Street (MS 31)

Deputy City Attorney Sacramento, CA 95814 City of Riverside 3900 Main Street Mr. Ray Waldo, Vice President Riverside, CA 92522 Southern California Edison Company San Onofre Nuclear Generating Station Mr. Gary L. Nolff P.O. Box 128 Assistant Director - Resources San Clemente, CA 92764-0128 City of Riverside 3900 Main Street Mr. Brian Katz Riverside, CA 92522 Southern California Edison Company San Onofre Nuclear Generating Station Regional Administrator, Region IV P.O. Box 128 U.S. Nuclear Regulatory Commission San Clemente, CA 92764-0128 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011-8064 Mr. Michael R. Olson San Diego Gas & Electric Company 8315 Century Park Ct. CP21G San Diego, CA 92123-1548 Director, Radiologic Health Branch March 2006

San Onofre Nuclear Generating Station Units 2 and 3 cc:

Mr. Steve Hsu Department of Health Services Radiologic Health Branch MS 7610, P.O. Box 997414 Sacramento, CA 95899 Mr. A. Edward Scherer Southern California Edison Company San Onofre Nuclear Generating Station P.O. Box 128 San Clemente, CA 92674-0128 March 2006