ML12093A248

Answer to March 12, 2012 Commission Order Modifying License with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051)

ML12093A248
Person / Time
Site:	San Onofre
Issue date:	03/28/2012
From:	Bauder D Southern California Edison Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-12-051
Download: ML12093A248 (2)

Text

SOUTHERN CALIFORNIA Douglas R. Bauder EDISON° U ~ Site Vice President & Station Manager San Onofre Nuclear Generating Station An EDISON INTERNATIONALI SCompany 10 CFR 2.202 March 28, 2012 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555

Subject:

Docket Nos. 50-361 and 50-362 License Nos. NPF-10 and NPF-15 ANSWER TO MARCH 12, 2012 COMMISSION ORDER MODIFYING LICENSE WITH REGARD TO RELIABLE SPENT FUEL POOL INSTRUMENTATION (ORDER NUMBER EA-12-051)

San Onofre Nuclear Generating Station, Units 2 and 3

Dear Sir or Madam:

On March 12, 2012, the Nuclear Regulatory Commission ("NRC" or "Commission")

issued an immediately effective order in the captioned matter entitled Order Modifying License with Regard to Reliable Spent Fuel Pool Instrumentation (Effective Immediately)

("Order") to, inter a/ia, Southern California Edison (SCE). The Orders state that, as a result of the NRC's evaluation of the lessons learned from the accident at Fukushima Dai-ichi in March 2011, the NRC had decided to direct nuclear power plant licensees and construction permit holders to take certain actions. Specifically, the NRC is requiring additional defense-in-depth measures to address uncertainties associated with protection from beyond-design-basis external events. With respect to this Order, licensees are specifically directed to provide a reliable means of remotely monitoring "wide-range spent fuel pool levels" to support effective prioritization of event mitigation and recovery actions in the event of a beyond-design-basis external event. Specific requirements are outlined in Attachment 2 to the Order.

The Order requires submission of an overall integrated plan including a description of how compliance with the requirements described in Attachment 2 will be achieved to the NRC for review by February 28, 2013. In addition, the Order requires submission of an initial status report 60 days following issuance of the final interim staff guidance and at six month intervals following submittal of an overall integrated plan on February 28, 2013. The Order states that the NRC intends to issue the interim staff guidance containing specific details on implementation of the requirements of this order in August 2012. Finally, the order requires full implementation of its requirements no later than two refueling cycles after submittal of the overall integrated plan, or December 31, 2016, whichever comes first.

P.O. Box 128 1 San Clemente, CA 92672 (949) 368-9275 PAX 89275 Fax: (949) 368-9881 Doug,.Bauder@sce.com YI

Document Control Desk March 28, 2012 Pursuant to 10 C.F.R. § 2.202 and the terms specified in the Order, SCE hereby submits its answer to the Order. SCE consents to the Order and does not request a hearing.

Based on information currently available, SCE has not identified any circumstances of the type described in Sections IV.B.1 and IV.B.2 of the Order requiring relief at this time.

In addition, SCE has not identified any impediments to compliance with the Order within two refueling cycles after submittal of the integrated plan, or December 31, 2016, whichever is earlier. SCE will provide further responses as required by Section IV.C. in accordance with the specified deadlines. However, given the uncertainties associated with the ultimate scope of required work caused by the unavailability of implementing guidance until August 2012, and the impact on the ability of SCE to comply with the specific compliance deadline dates based on the probable availability of that guidance, SCE's future responses may include requests for schedule relief as warranted by subsequent NRC requirements or implementing guidance or the results of engineering analyses not yet performed. Any such request would be submitted in accordance with the relaxation provision in Section IV of the Order.

If you have any questions regarding this confirmation of receipt, please contact Mr. Steven D. Root at 949-368-6480.

I declare under penalty of perjury that the foregoing is true and correct.

By: _ _ _ _ _ _ _ _ _ _

Dou glas Bauder Site Vice President and Station Manager 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