ML11168A078

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30-Day Response to NRC Bulletin 2011-01 Mitigating Strategies
ML11168A078
Person / Time
Site: San Onofre  Southern California Edison icon.png
Issue date: 06/10/2011
From: Bauder D R
Southern California Edison Co
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
BL-11-001
Download: ML11168A078 (4)


Text

  • SOUTHERN CALIFORNIA Douglas R. Bauder FDIS N Site Vice President

& Station Manager San Onofre Nuclear Generating Station An EDISON INTERNATIONAL Company 10 CFR 50.54(f June 10, 2011 10 CFR 50.54(hh)U. S. Nuclear Regulatory Commission Attention:

Document Control Desk One White Flint North 11555 Rockville Pike Rockville, MD 20852-2738

Subject:

San Onofre Nuclear Generating Station, Units 2 and 3 Docket Nos. 50-361 and 50-362 30-Day Response to NRC Bulletin 2011-01

Reference:

NRC Bulletin 2011-01, "Mitigating Strategies", dated May 11, 2011 On May 11, 2011, the U.S. Nuclear Regulatory Commission (NRC) issued Bulletin 2011-01, "Mitigating Strategies" (Reference).

The NRC issued this Bulletin to achieve the following objectives:

1. To require that addressees provide a comprehensive verification of their compliance with the regulatory requirements of Title 10 of the Code of Federal Regulations (10 CFR) Section 50.54(hh)(2), 2. To notify addressees about the NRC staffs need for information associated with licensee mitigating strategies under 10 CFR 50.54(hh)(2) in light of the recent events at Japan's Fukushima Daiichi facility in order to determine if 1) additional assessment of program implementation is needed, 2) the current inspection program should be enhanced, or 3) further regulatory action is warranted, and 3. To require that addressees provide a written response to the NRC in accordance with 10 CFR 50.54(f.The Enclosure to this letter contains Southern California Edison's 30-day response to the requested information pursuant to the provisions of 10 CFR 50.54(f) for San Onofre Nuclear Generating Station.There are no regulatory commitments contained in this letter or the Enclosure.

P.O. Box 128 San Clemente, CA 92672 (949) 368-9275 PAX 89275 Fax: (949) 368-9881 Doug.Bauder@sce.com Document Control Desk-2-June 10, 2011 In accordance with 10 CFR 50.54(f), the following affirmation is provided: I declare under penalty of perjury that the foregoing is true and correct.Executed on ( oa1 0 0/

Enclosure:

30-Day Response to NRC Bulletin 2011-01 for SONGS Units 2 and 3 cc: E. E. Collins, Regional Administrator, NRC Region IV R. Hall, NRC Project Manager, San Onofre Units 2 and 3 G. G. Warnick, NRC Senior Resident Inspector, San Onofre Units 2 and 3 ENCLOSURE 30-day Response to NRC Bulletin 2011-01 San Onofre Nuclear Generating Station, Units 2 and 3 The Bulletin requested that within 30 days of the date of this Bulletin, licensees provide information on their NRC mitigating strategies programs.

The NRC questions related to the 30-day response are restated below followed by the Southern California Edison (SCE) response for San Onofre Nuclear Generating Station (SONGS).1. Is the equipment necessary to execute the mitigating strategies, as described in your submittals to the NRC, available and capable of performing its intended function?Response SCE has confirmed that the equipment necessary to execute the mitigating strategies, as described in our submittals to the NRC (References 1, 2, 3, 5 and 6) and as reviewed and approved by the NRC (References 4, 7 and 8), is available and capable of performing its intended function at SONGS, with the exception of plant-specific strategy 3 in Table A.2-4 of Reference

5. The equipment for this plant-specific strategy was confirmed to be available and capable of performing its intended function, but the locations differ from those described in Reference 5.The equipment was recently inventoried, inspected or tested. Letters of Agreement and Memoranda of Understanding with offsite organizations were also recently re-validated or re-issued as needed.2. Are the guidance and strategies implemented capable of being executed considering the current configuration of your facility and current staffing and skill levels of the staff?Response SCE has confirmed that the guidance and strategies implemented at SONGS Units 2 and 3 are capable of being executed considering the current configuration of the facility and current staffing and skill levels of SONGS personnel.

Each procedure implementing the required mitigation strategies was walked down to ensure that the procedures were in place and capable of being executed with the current configuration of the facility.

SCE determined that the guidance and strategies could be executed with the current staffing levels. Skill levels of the SONGS personnel that would execute the guidance and strategies were verified from training records, and additional training and walk-throughs performed as necessary.

Page 1 of 2 ENCLOSURE 30-day Response to NRC Bulletin 2011-01 San Onofre Nuclear Generating Station, Units 2 and 3 References

1. Letter from B. Katz (SCE) to Document Control Desk (NRC), Response to NRC Staff Guidance for Use in Achieving Satisfactory Compliance with February 25, 2002, Order Section B.5.b,

Subject:

"Docket Nos. 50-361 and 50-362, San Onofre Nuclear Generating Station, Units 2 and 3", dated May 27, 2005.2. Letter from B. Katz (SCE) to Document Control Desk (NRC), Response to Request for Additional Information regarding implementation of NRC Staff Guidance for Use in Achieving Satisfactory Compliance with February 25, 2002, Order Section B. 5. b,

Subject:

"Docket Nos. 50-361 and 50-362, San Onofre Nuclear Generating Station, Units 2 and 3", dated December 14, 2005 3. Letter from B. Katz (SCE) to Document Control Desk (NRC), Response to Report of Inspection of Nuclear Reactor Safeguards Interim Compensatory Measure -Section B. 5. b, Temporary Instruction 2515/164 NRC Inspection Report 05000361/2005011 and 05000362/2005011,

Subject:

"Docket Nos. 50-361 and 50-362, NRC Phase 1 Assessment of B.5.b Implementation, San Onofre Nuclear Generating Station, Units 2 and 3", dated March 1, 2005 4. Letter from T. Pruett (NRC) to R. M. Rosenblum (SCE), subject: "San Onofre Nuclear Generating Station -NRC Inspection Report (05000361/2006401, 05000362/2006401), dated September 20, 2006.5. Letter from A. E. Scherer (SCE) to Document Control Desk (NRC), subject: "Response Providing Information Regarding Implementation Details for the B.5.b Phases 2 and 3 Mitigation Strategies, including Responses to Requests for Additional Information," dated January 10, 2007.6. Letter from A. E. Scherer (SCE) to Document Control Desk (NRC), subject: "Supplemental Information, Phase 2 and 3 Mitigation Strategies, San Onofre Nuclear Generating Station", dated May 29, 2007 7. Letter from N. Kalyanam (NRC) to R. M. Rosenblum (SCE), subject: "San Onofre Nuclear Generating Station, Units 2 and 3 -Conforming License Amendments to Incorporate the Mitigation Strategies Required by Section B.5.b of Commission Order EA-02-026 (TAC Nos.MD4564 and MD4565)," dated July 26, 2007.8. Letter from R. E. Lantz (NRC) to R. T. Ridenoure (SCE), subject: "San Onofre Nuclear Generating Station, Units 2 and 3 -Site Specific Implementation of B.5.b Phase 2 and 3 Mitigating Strategies Temporary Instruction Inspection (NRC Inspection Report 05000361/2008007 and 05000362/2008007)", dated October 3, 2008 Page 2 of 2