ML121030472

Audit of the Licensee'S Management of Regulatory Commitments, Audit Performed 12/14/2011

ML121030472
Person / Time
Site:	San Onofre
Issue date:	05/31/2012
From:	Thadani M Plant Licensing Branch IV
To:	Peter Dietrich Southern California Edison Co
Thadani, M C, NRR/DORL/LP4, 415-1476
References
TAC ME7572, TAC ME7573
Download: ML121030472 (28)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555*0001 May 31, 2012 Mr. Peter T. Dietrich 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 - AUDIT OF THE LICENSEE'S MANAGEMENT OF REGULATORY COMMITMENTS (TAC NOS. ME7572 AND ME7573)

Dear Mr. Dietrich:

In U.S. Nuclear Regulatory Commission (NRC) Regulatory Issue Summary 2000-17, "Managing Regulatory Commitments Made by Power Reactor Licensees to the NRC Staff," dated September 21, 2000, the NRC informed licensees that the Nuclear Energy Institute (NEI) document NEI 99-04, "Guidelines for Managing NRC Commitment Changes," contains acceptable guidance for controlling regulatory commitments and encouraged licensees to use the NEI guidance or similar administrative controls to ensure that regulatory commitments are implemented and that changes to the regulatory commitments are evaluated and, when appropriate, reported to the NRC.

The NRC Office of Nuclear Reactor Regulation has instructed its staff to perform an audit of licensees' commitment management programs once every 3 years to determine whether the licensees' programs are consistent with the industry guidance in NEI 99-04, and that the regulatory commitments are being implemented effectively.

An audit of the San Onofre Nuclear Generating Station (SONGS), Units 2 and 3 commitment management program was performed at the plant site on December 14, 2011. Based on the results of the on-site audit of SONGS, Units 2 and 3 procedures, processes, and records for managing regulatory commitments, and review of the identified sample of regulatory commitments and regulatory commitments change report, the NRC staff concludes that the licensee has implemented the regulatory commitments management program effectively, and implemented regulatory commitment changes appropriately in accordance with NRC accepted industry guidance in NEI 99-04. No programmatic inconsistencies and deficiencies were noted.

Details of the audit and the NRC staffs conclusions are set forth in the enclosed audit report.

P. Dietrich -2 The NRC staff appreciates the assistance of your staff, both before and during the audit. If there are any questions, I can be contacted at (301) 415-1476 or by electronic mail at mohan. thadani@nrc.gov.

Sincerely, Z~~~anager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-361 and 50-362

Enclosure:

As stated cc w/encl: Distribution via Listserv

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 AUDIT REPORT BYTHE OFFICE OF NUCLEAR REACTOR REGULATION LICENSEE'S MANAGEMENT OF REGULATORY COMMITMENTS SOUTHERN CALIFORNIA EDISON COMPANY SAN ONOFRE NUCLEAR GENERATING STATION, UNITS 2 AND 3 DOCKET NOS 50-361 AND 50-362

1.0 INTRODUCTION AND BACKGROUND

In U.S. Nuclear Regulatory Commission (NRC) Regulatory Issue Summary 2000-17, "Managing Regulatory Commitments Made by Power Reactor Licensees to the NRC Staff," dated September 21, 2000 (Agencywide Documents Access and Management System (ADAMS)

Accession No. ML003741774), the NRC informed licensees that the Nuclear Energy Institute (NEI) document NEI 99-04, "Guidelines for Managing NRC Commitment Changes," contains acceptable guidance for controlling regulatory commitments and encouraged licensees to use the NEI guidance or similar administrative controls to ensure that regulatory commitments are implemented and that changes to the regulatory commitments are evaluated and, when appropriate, reported to the NRC.

The NRC Office of Nuclear Reactor Regulation (NRR) has instructed its staff to perform an audit of licensees' commitment management programs once every 3 years to determine whether the licensees' programs are consistent with the industry guidance in NEI 99-04, and that the regulatory commitments are being implemented effectively.

NEI 99-04 defines a "regulatory commitment" as an explicit statement to take a specific action agreed to, or volunteered by, a licensee and submitted in writing on the docket to the NRC.

NRR guidelines direct the NRR Project Manager to audit the licensee's commitment management program by assessing the adequacy of the licensee's implementation of a sample of commitments made to the NRC and changes made to the NRC commitments in past licensing actions (amendments. relief requests, exemptions, etc.) and activities (bulletins, generic letters, etc.). The audit is to be performed every 3 years.

2.0 AUDIT PROCEDURE AND RESULTS On December 14, 2011, the NRC staff performed an audit of the San Onofre Nuclear Generating Station (SONGS), Units 2 and 3, regulatory commitments program and regulatory commitments change process. The audit reviewed commitments made by the Southern California Edison Company (the licensee) since the previous audit on July 28,2008, which was Enclosure

-2 documented in an audit report dated August 12, 2008 (ADAMS Accession No. ML082200447).

The audit consisted of two major parts: (1) verification of the licensee's program for implementation of NRC commitments, and (2) verification of the licensee's program for managing changes to NRC commitments.

2.1 Verification of Licensee's Implementation of NRC Commitments The primary focus of this part of the audit is to confirm that the licensee has implemented commitments made to the NRC as part of past licensing actions/activities. For commitments not yet implemented, the NRC staff determines whether they have been captured in an effective program for future implementation.

2.1.1 Audit Scope The audit addressed a sample of commitments made during the review period. The audit focused on regulatory commitments (as defined above) made in writing to the NRC as a result of past licensing actions (amendments, relief requests, exemptions, etc.) or licensing activities (bulletins, generic letters, etc.). Before the audit, the NRC staff performed a search in ADAMS for the licensee's submittals since the last audit, obtained records of the commitments from the licensee, and selected a representative sample for verification licensee's records of commitments tracking, and commitments change report submitted to the NRC staff.

The audit excluded the following types of commitments that are internal to licensee processes:

(1) Commitments made on the licensee's own initiative among internal organizational components.

(2) Commitments that pertain to milestones of licensing actions/activities (e.g.,

respond to an NRC request for additional information by a certain date).

Fulfillment of these commitments was indicated by the fact that the subject licensing action/activity was completed.

(3) Commitments made as an internal reminder to take actions to comply with existing regulatory requirements such as regulations, Technical Specifications, and Updated Final Safety Analysis Reports. Fulfillment of these commitments was indicated by the licensee having taken timely action in accordance with the commitments requirements.

2.1.2 Audit Results The licensee has implemented Procedure S0123-X39, "Regulatory Commitments Tracking (RCT) Program," which establishes its methods for identifying, documenting, tracking, and dispositioning regulatory commitments and for justifying changes to regulatory commitments.

The procedure specifies the objectives, procedures, definition of terms, responsibilities and tracking procedure, authorities and responsibilities, requirements for effective management of regulatory commitments, tracking of commitments, and procedures for implementing changes to regulatory commitments. From the collected information, the NRC staff developed a

- 3 representative sample of regulatory commitments that met the selection criteria identified in NRR's guidance.

The documents furnished by the licensee included summary sheets providing the status of the regulatory commitments, source documents, and appropriate backup documentation as needed (Le., plant procedures, regulatory commitment tracking forms, actions, regulatory commitment change forms, biennial commitments changes reported to the NRC staff, and other plant documentation). The NRC staff reviewed the database and documents and summarized the selected commitments information in Attachment 12 to this audit report.

The NRC staff audit was intended to confirm that the licensee has documented its implementation of its regulatory commitments made to the NRC staff as part of past licensing communications, and the commitments that had not yet been implemented or incorporated in design bases documents are captured in an effective manner for future implementation.

The process described in Procedure S0123-XV-39 provides acceptable tools for the licensee to capture the NRC regulatory guidance on commitment management programs. The licensee enters the regulatory commitments made to the NRC into regulatory commitments identification, tracking, and change forms. Each commitment is numbered and described by a commitment title and brief description. These commitment forms are reviewed and approved by dedicated staff. The licensee's staff was knowledgeable of procedures for entering and updating the regulatory commitments status. The regulatory commitments program procedure S0123-XV-39 followed in documenting, tracking, implementing, and changing the regulatory commitments.

The sources of the commitments are clearly documented and retained. The status of the commitments was found to be well documented. No deficiencies were noted.

In general, documents or procedures that are used to fulfill a commitment are changed to reference the commitment. This provides a means to ensure that commitments are neither removed nor changed without management approval in accordance with the plant procedures.

No deficiencies were noted.

Based on the results of the on-site audit, the NRC staff concludes that the licensee has implemented the regulatory commitments management program adequately and consistent with NEI99-04. The attachment to this audit report contains references to the licensee's commitments selected for review and a summary of the audit results.

2.2 Verification of Licensee's Program for Managing Changes to Licensee's Commitments to NRC The primary focus of this part of the audit is to verify that the licensee has established administrative controls for modifying or deleting commitments made to the NRC. For the period covered by the audit, the NRC staff reviewed both a sample of commitment changes determined to be reportable to the NRC, and a sample of changes determined to be not reportable. The NRC staff also reviewed the licensee's report of commitment changes reported to the NRC for the period December 19,2008, to March 17, 2011 (ADAMS Accession No. ML110871482). Commitment changes were appropriately justified and reported to the NRC in accordance with the licensee's process. No deficiencies were noted.

- 4 Based on the results of the on-site audit, the NRC staff concludes that the licensee has implemented regulatory commitment changes appropriately, consistent with NEI 99-04.

3.0 CONCLUSION

Based on the results of the audit, the NRC staff concludes that the licensee has implemented the regulatory commitments management program satisfactorily, and implemented regulatory commitment changes appropriately, consistent with NEI 99-04.

4.0 LICENSEE PERSONNEL CONTACTED FOR THIS AUDIT Ryan Treadwell Allison James Lee Kelly Principal Contributor: Mohan Thadani Date: May 31,2012 Attachments

1. Summary of Audit Results - Regulatory Commitments

2. Summary of Audit Results - Reference to Regulatory Commitments Changes Report.

SUMMARY

OF AUDIT RESULTS FOR REGULATORY COMMITMENTS Audit Performed December 14,2011 San Onofre Nuclear Generating Station, Units 2 and 3 Commitment No.1 Implementation Letter Subject Tracking No. Description of Commitment Status (7/28/2008) Implementation Status (1212011)

Open.8pmmitments from Al.!gU~t;2008 Audit Report

? ..: .

Letter from Request for NRCT 2006-08-001 Following NRC approval of the The referenced letter Cancelled, AR 060701155-02 was Southern Emergency Plan Action Request (AR) proposed EP Change, enhance operator has three cancelled 6/13/2007, No changes were California (EP) Change 060701155-02] training to demonstrate and evaluate commitments within necessary to demonstrate and evaluate Edison (SCE) to increase in crew's ability to perform key emergency the document. The crew's ability to perform emergency Nuclear Emergency response functions, licensee has response functions for an additional Regulatory Response expanded the three 30 minutes, Commitment was Commission Organization (ERO) commitments to eight "withdrawn" via 6/18/2007 submittal.

(NRC) dated Augmentation Time NRCT 2006-08-002 Following approval of this proposed specific commitments Transferred to SAP Order 800072367 6/18/2007 from 60 to 90 [Previously AR change, the Shift ManagerlEmergency for tracking the 0010, which was closed 8/29/2009, No (ADAMS minutes, 060701155-03; Coordinator will be responsible for individual items, The procedure change was necessary to Accession No, transferred to SAP assigning an on-shift Units 2/3 licensed application is under ensure the ENS Communicator function ML071700672 800072367-0010] operator to notify the NRC following review by the NRC is implemented per the Safety Evaluation not publicly notification of offsite agencies and within staff, The ARs are Report for changing to 90 minutes and no available), 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> of the event declaration. This accorded the "OPEN" additional training is needed, individual will serve as the Control status.

[Note: The Room Emergency Notification System 6118/2007 letter (ENS) Communicator to provide superseded a additional information as necessary or letter dated maintain communication with the NRC if 8/28/2006 requested until the Technical Support (ADAMS Center (TSC) Red Phone Accession No. Communicator arrives in the TSC and ML062420187 assumes that responsibility. The notpublicly Control Room ENS Communicator will available) fulfill the responsibility of the 30-minute responder as designated in NUREG 0654, Table 8-1 for communications and shown in Attachment 2, Attachment 1

-2 Commitment No.1 Implementation Letter Subject Tracking No. Description of Commitment Status (7/2812008) Implementation Status (1212011)

NRCT 2006-08-003 Primary equipment operators (PEOs) Cancelled. Transferred to SAP Order

[Previously AR will be trained on the use of handheld 800072370, which cancelled the 0607001155-07; survey instruments providing the commitment based on commitment transferred to SAP capability of self-monitoring during change evaluation performed under NN 800072370] accident conditions. The self-monitoring 200434603. Regulatory Burden capability, along with the use of the Reduction (RBR) log indicated no report computerized radiological emergency to NRC required. NRCT 2008-09-002 preparedness (REP) process and from 9/24/2008 letter (ADAMS Accession personal electronic dosimeters (PEDs), No. ML082740060) rendered this will provide these responders adequate commitment unnecessary.

radiological protection to support emergency response activities.

NRCT 2007-06-001 Implement a new calibration protocol for The intent of this commitment included

[Previously AR the Pressurized Ion Chamber (PIC) prior development of a schedule for calibrating 060701155-11 ; to implementation of the approved EP each PIC, but not necessarily completing transferred to Order change. all the calibrations prior to implementation 800072366] of the EP change. Calibrations were completed 9/23/2009.

License The LAR revises the NRCT 2004-12-004 Following approval of LAR PCN 555, The referenced letter 041201316-06 closed on 6/25/2007 with amendment SONGS 2 and 3 [AR 041201316-06] future revisions to Updated Final Safety has five commitments issuance of DBD-S023-TR-AA, Rev. 9.

request (LAR), accident source Analysis Report (UFSAR) Chapter 15 within the document.

Proposed term (AST) used in design basis accident control room and The licensee has Change Notice the design basis offsite radiological consequence expanded the three to (PCN) 555, radiological analyses will be performed using AST twelve specific dated consequences methodology. commitments for 12/27/2004 analyses. tracking individual (ADAMS items.

Accession No. Closed.

ML043650403) NRCT 2004-12-008 Following approval of this LAR, SCE will Open UFSAR change submitted 6/10/2009.

from SCE to [AR 041201316-03; provide the revised UFSAR sections to NRC moved to NN the NRC as part of its normal UFSAR 200000532] update required by 10 CFR 50.71 (e).

- 3 Commitment No.1 Implementation Letter Subject Tracking No.

New

. , .Commitments Description of Commitment

. ... ,,'. SInce

\ ...,

7/2112008 Audit Status (7/28/2008) Implementation Status (1212011)

.* *;**i;~,~;*;};!:~.*. .'

Letter from SCE Response to 2008-09-002 1 Prior to implementation of SONGS' NIA Commitments closed as of 5/22/2009.

to NRC dated request for SAP Operation proposed EP change. SCE will: 1} add Requirements were incorporated into the 9/24/2008 additional 800173618-0020 nine qualified Health Physics (HP) EP; therefore, these actions do not need (ADAMS information (RAI) Technicians to the automatic recall to be tracked further in the commitment Accession No. Regarding Request system. data base.

ML082740060) for EP Change 2008-09-003 1 Prior to implementation of SONGS' NIA Increase in ERO SAP Operation proposed EP change, SCE will: 2} add Augmentation Time 800173618-0030 one Electrical Maintenance Technician, from 60 to 90 to the automatic recall system.

minutes 2008-09-004 1 Prior to implementation of SONGS' NIA SAP Operation proposed EP change, SCE will: 3} add 800173618-0040 one Instrument and Control (I&C)

Technician to the automatic recall system.

2008-09-005 I Prior to implementation of SONGS' N/A SAP Operation proposed EP change. SCE will: 4) 800173618-0050 ensure that either an I&C Technician or a Shift Rotating General Foreman (SRGF) is on-shift at all times.

2008-09-006 Prior to implementation of SONGS' N/A SAP Operation proposed EP change, SCE will: 5}

800173618-0060 change the facility activation requirements for the Operations Support Center to include the additional 90 minute responders described in the above items 1, 2, and 3.

- 4 Commitment No.1 Implementation Letter Subject Tracking No. Description of Commitment Status (7/28/2008) Implementation Status (12/2011)

Letter from SCE 3-Month Response 2008-05-001 An assessment of the system piping to NIA Closed. Provided in 9-month response to NRC dated to Generic Letter [080101157 -10, confirm adequate vent capability will be dated 10/14/2008 (ADAMS Accession 5/15/2008 (GL) 2008-01, 200004023-0001] performed in order to assure successful No. ML082950468).

(ADAMS "Managing Gas management of gas accumulation Accession No. Accumulation in volumes. Potential gas accumulation ML081430019) Emergency Core volumes will be determined by Cooling, Decay Heat conservatively applying construction Removal, and tolerances to the plant isometric Containment Spray drawings.

Systems" 2008-05-002 Where additional vent valves are NIA Closed. Provided in 9-month response

[200004023-0001] deemed to be required, confirmatory dated 10/14/2008 (ADAMS Accession walkdowns will be conducted to verify No. ML082950468) the need for additional vents.

2008-05-003 SCE will submit a response within nine NIA Closed. 9-month response submitted in

[Previously months of the date of the generic letter letter dated 10/14/2008 (ADAMS 080101157-10; providing the results of the evaluation, Accession No. ML082950468).

moved to Task identifying required confirmatory 200004023-0001] walkdowns that have not been completed, and providing the schedule for their completion.

Letter from SCE 9-Month Response 2008-10-001 1) Technical Specification (TS) Bases NIA Closed.

to NRC dated to GL 2008-01 [800179610-0020] for Surveillance Requirement (SR) Changed pages B 3.5-19 and B 3.5-20a 10/14/2008 3.5.2.4 will be revised to read as noted by revision bars.

(ADAMS "Maintaining the piping from the RWST TS Bases for SR 3.5.2.4 changed.

Accession No. [refueling water storage tank) to the ML082950468) RCS [reactor coolant system] full of water" 90 days after completion of the Unit 3 (U3) Cycle 15 refueling outage (RFO) (scheduled for October 2008).

2008-10-002 2) Procedure S023-3-2. 7.2, "Safety NIA Closed.

[800179610-0030] Injection System Removal/Retum to Procedure revision 17 issued 11/21/2008.

Service Operation" (Reference 15), will be revised to include sweeping of the inverted "U" sections in the high pressure safety injection (HPSI) Train "A" discharge piping during plant restart until new vents are installed. Prior to restart of the unit for the U3 Cycle 15 RFO (scheduled for October 2008).

-5 Commitment No.1 Implementation Letter Subject Tracking No. Description of Commitment Status (7/28/2008) Implementation Status (1212011) 2008-10-003 3) Procedure S023-3-3.8, "Safety N/A Closed.

[800179610 -0040] Injection Monthly Tests" (Reference 17) Procedure S023-3-3.8, Rev. 21, was specifies that one of the objectives is to issued 11/21/2008.

vent accessible valves on the discharge side. The procedure vents valves on both the suction and discharge sides and vents valves deemed necessary to ensure that the system is sufficiently full without limitations imposed by accessibility. The procedure objective will be revised for clarification only. Due prior to restart of the unit for the U3 Cycle 15 RFO (scheduled for October 2008).

2008-10-004 4) A vent valve will be added to the N/A Closed.

[800194395-0010 Train "A" discharge piping of the high Unit 2 completed 4/2712009.

(Unit 2); 800229823 pressure safety injection pumps in each Unit 3 completed 3/6/2011.

(Unit 3)] unit.

Due: Unit 2 (U2) Cycle 16 and U3 Cycle 16 RFOs scheduled for the fall of 2009 and 2010, respectively.

2008-10-005 5) An Engineering procedure will be N/A Closed.

[800179610 -0060] developed to formalize safety injection S023-V-16, Emergency Core Cooling tank (Sin monitoring to provide a formal System Piping Gas Void Calculation was process of quantifying leakage into the issued on 2/23/2009.

low pressure side of the Safety Injection system. Due: 90 days after completion of the U3 Cycle 15 RFO (scheduled for October 2008).

-6 Commitment No.1 Implementation Letter Subject Tracking No. Description of Commitment Status (7/28/2008) Implementation Status (12/2011) 2008-10-006 6) SCE is continuing to support the NIA Open.

[800179610-0070] industry and Nuclear Energy Institute The TSTF is meeting with the NRC on (NEI) Gas Accumulation Management January 12, [2011], to discuss the Team activities regarding the resolution appropriate regulatory method to capture of generic TS changes via the Technical the on-going requirements from Generic Specification Task Force (TSTF) Letter 2008-01, "Managing Gas traveler process. Following NRC Accumulation in Emergency Core approval of this TSTF, SCE will evaluate Cooling, Decay Heat Removal, and adopting the TSTF to either supplement Containment Spray Systems."

or replace current TS and leakage control system (LCS) requirements. The NRC has not yet accepted the Due 1 year after NRC approval of TSTF. approach proposed by the TSTF in TSTF-523, Rev. 0, "Generic Letter 2008-01, Managing Gas Accumulation."

TSTF-523 is applicable to all plant types.

Due date for operation moved to 1/13/2012.

2008-10-007 7) SCE will conduct confirmatory NIA Closed.

[800179610-0080] walkdowns as identified in Item 6 of the Letter to NRC dated 6/17/2009 (ADAMS Design Evaluation for U2 accessible and Accession No. ML091690343), 9-month inaccessible piping and submit a Supplemental (Post-Outage) Response 9-month supplemental response with to GL 2008-01, Unit 2.

the results of these walkdowns and any (Due date for final analysis was changed resulting corrective actions. Due: to 120 days after outage (6/18/2009) per 60 days after completion of the U2 NN 200385859 and as documented in outage (scheduled for January 2009). letter to NRC dated 4/17/2009 (ADAMS Accession No. ML091070587).)

2008-10-008 8) SCE will conduct confirmatory NIA Closed.

walkdowns as identified in Item 6 of the Letter to NRC dated 6/17/2009 (ADAMS Design Evaluation for U3 accessible and Accession No. ML091690343), 9-month inaccessible piping and submit a Supplemental (Post-Outage) Response 9-month supplemental response with to GL 2008-01.

the results of these walkdowns and any resulting corrective actions.

Due date: 60 days after completion of the U3 Cycle 15 RFO. U3 breakers closed 12/18/2008; therefore, due date is 211612009.

-7 Commitment No.1 Implementation Letter Subject Tracking No. Description of Commitment Status (7/28/2008) Implementation Status (1212011)

Letter from SCE Amendment 2008-06-001 The proposed steam generator plugging NIA Closed.

to NRC dated Application Nos. 252 [200092517-0001] criterion is a preliminary value and SCE Letter to NRC dated 8/13/2008 (ADAMS 6/27/2008 and 238, will provide a confirmation or a corrected Accession No. ML082280080) notified (ADAMS Replacement Steam value when the calculation is approved. the NRC that the original proposed SG Accession No. Generators tube plugging criterion is unchanged.

ML081830421) -------

Letter from SCE Extension Request 2008-10-009 SCE is committing in this submittal to NIA Closed.

to NRC dated Related to GL [Order 800168679] completing a chemical effects retest This commitment closed with submittal of 10/30/2008 2004-02, "Potential program, and identifying any additional letter to NRC dated 11/12/2009 (ADAMS (ADAMS Impact of Debris required plant modifications, by Accession No. ML093210174). Two new Accession No. Blockage on 11/20/2009. commitments were made in this letter.

ML083080295) Emergency See NRCTS 2009-11-001 through -003.

Recirculation During Design Basis Accidents At Pressurized Water Reactors," Test Protocol used in Testing at VUEZ Letter from SCE NRC GL 2004-02 2009-11-001 As discussed in the SCE to NRC NIA Open.

to NRC dated Supplemental [800168679-70] supplemental response dated NRC SE not yet issued.

11/12/2009 Response 11/12/2009 submittal letter Attachment (ADAMS 1, Section 3.n.i; Attachment 2, Open Accession No. Item 20; and Attachment 3, Item B.1 ,

ML093210174) SCE plans to perform the necessary evaluations prescribed by Westinghouse topical report WCAP-16793-NP relative to potential fuel debris blockage, once the associated NRC safety evaluation (SE) is issued.

2009-11-002 Reference 3 and this supplemental NIA Closed. U2 steam generators replaced

[200230225-0004] response credit the U2 and U3 and action closed 4/16/2010.

replacement steam generators (RSGs).

The U2 RSGs were installed during the cycle 16 refueling outage I

2009-11-003 Reference 3 and this supplemental N/A Closed. U3 steam generators replaced

[200230225-0005] response credit the U2 and U3 RSGs. and action closed.

The U3 RSGs were installed during the fall 2010 refueling outage. -------

-8 Commitment No.1 Implementation Letter Subject Tracking No. Description of Commitment Status (7/28/2008) Implementation Status (1212011) I Letter from SCE Request to Revise 2009-01-011 1) Prior to use of AREVA Lead Fuel N/A Closed. This commitment has been to NRC dated TS 5.7.1.5 Core [200297246 -0004] Assemblies (LFAs) for a second fuel captured into Revision 11 of S023 1/30/2009 Operating Limits cycle of irradiation, poolside LFA XXXVI-2.6, Section 6.4.1, issued (ADAMS Report (COLR) and examinations will be performed to 2/8/2010.

Accession No. Request for evaluate assembly and cladding ML090360738) Temporary performance, and acceptability for I

Exemption from continued use.

10 CFR 50.46 and 2009-01-012 2) Prior to use of AREVA LFAs for a N/A Closed. This commitment has been 10 CFR 50 [200297246 -0005] third fuel cycle of irradiation, poolside captured into Revision 11 of S023 Appendix K LFA examinations will be performed to XXXVI-2.6, Section 6.4.1, issued evaluate assembly and cladding 2/8/2010.

performance, and acceptability for continued use.

2009-01-013 3) If the AREVA LFAs are inserted for a N/A Closed. For U2 Cycle 16, this regulatory

[200297246 -0006] third fuel cycle of irradiation, then commitment is implemented in U2 Cycle poolside LFA examinations will be 16 reload process as documented in performed after completion of the third U2C16 Reload ECP (Order 800247870).

fuel cycle of irradiation to evaluate assembly and cladding performance. For future cycles, this regulatory .

commitment is implemented in the NFM reload checklist procedure S023-XXXVI 2.10 section 6.1.14.1.

2009-01-014 4) The AREVA LFAs will be placed in N/A For U2 Cycle 16, this regulatory

[200297246 -0007] core locations where the peak commitment is implemented in U2 Cycle integrated radial power peaking factor in 16 reload process as documented in the LFAs will be 0.95 or less of the core U2C16 Reload ECP (Order 800247870).

maximum integrated radial power peaking factor at all times in life. For future cycles, this regulatory commitment is implemented in the NFM reload checklist procedure S023-XXXVI 2.10 section 6.1.14.2.

2009-01-015 5) The AREVA LFAs will be modeled in N/A Closed. For U2 Cycle 16, this regulatory

[200297246 -0008] the SONGS core physics models and commitment is implemented in U2 Cycle their impact will be analyzed in the 16 reload process as documented in cycle-specific core physics calculations U2C16 Reload ECP (Order 800247870).

that support the reload analyses.

For future cycles, this regulatory commitment is implemented in the NFM reload checklist procedure S023-XXXVI 2.10 section 6.1.14.2.

- 9 tion Subject Description of Commitment 008) Implemen

6) Analyses will be performed to verify I N/A Closed. AREVA has performed the the performance of the AREVA LFAs. analyses mentioned above. Results and These analyses include thermal- conclusions were summarized in the hydraulic compatibility, loss-of-coolant following reports:

accident (LOCA) and non-LOCA criteria, mechanical design, thermal hydraulic, ANP-2839(P), Revision 1, "San Onofre seismic, core physics, and neutronics Nuclear Generating Station Lead Fuel compatibility of the AREVA LFAs in the Assembly Fuel Design Criteria Review,"

SONGS reactor core. The analyses will September 2009.

make use of the fact that the LFAs will be operated in non-limiting core regions ANP-2840(P), Revision 1, "San Onofre and will verify the reload analyses are Nuclear Generating Station Lead Fuel not adversely impacted. Assembly Thermal-Hydraulic Compatibility Report," September 2009.

These reports were issued and transmitted to Corporate Documentation Management (COM) on 10/14/2009.

2009-01-017 7) A compatibility analysis will be I N/A Closed. Westinghouse has performed

[200297246 -010] performed to ensure that insertion of the the compatibility analyses mentioned AREVA LFAs will not cause the above. Results and conclusions are remaining Westinghouse fuel to exceed summarized in the compatibility study its operating limits and ensure there is report. This report has been issued and no adverse impact on the fuel transmitted to Corporate Documentation performance or mechanical integrity. Management (COM) on 12/24/2009.

Therefore, regulatory commitment #7 has been fulfilled.

- 10 Commitment No.1 Implementation Letter Subject Tracking No. Description of Commitment Status (7/28/2008) Implementation Status (12/2011) I Letter from SCE Notification of Intent 2009-04-066 In letter dated 7/19/1999 (ADAMS NIA Closed.

to NRC dated to Extend Removal [Order 8002800741 Legacy Accession No. 9907210221),

4/24/2009 of the Containment NN 200380809] SCE clarified our intentions regarding Letter dated 12/31/2009 (ADAMS (ADAMS Hydrogen the hydrogen recombiners and other Accession No. ML100060791) stated Accession No. Recombiners hydrogen control systems, upon NRC SCE will permanently leave the U2 and ML091180592) approval of our exemption request, as U3 Train B hydrogen recombiners follows: "... it is currently Southern removed from containment. The California Edison's intention to continue opposite train hydrogen recombiner to maintain these systems to the extent (Train A) for each unit remains functional that it remains prudent and practical." "If at this time and is being maintained on a at some future time equipment becomes frequency determined by SCE to be inoperable and Southern California appropriate. SCE is maintaining the Edison decides to permanently cease Train A hydrogen recombiner in each unit repair efforts, Southern California consistent with its original commitment.

Edison will then inform the NRC of that decision."

In letter dated 2/5/2007 (ADAMS Accession No. ML070380096), SCE provided notification of its intention to remove one of the two hydrogen recombiners (E146) per containment for the duration of the Cycle 15 operating cycle of each unit. SCE has completed planning for the U2 Cycle 16 outage and it is now SCE's intention to leave the U2 and U3 E146 hydrogen recombiners removed from containment through the end of operating cycle 16. The opposite train hydrogen recombiner (E145) for each unit remains functional at this time and SONGS intends to continue to maintain the second hydrogen recombiner in each unit consistent with its original commitment.

- 11 Commitment No.1 Implementation Letter Subject Tracking No. Description of Commitment Status (7/28/2008) Implementation Status (1212011)

Letter from SCE Notification of Intent 2009-12-008 SCE is installing a Class 1E 480 V Load NIA Open.

to NRC dated to Permanently [800434133 and Center on U2 and intends to make 12/31/2009 Remove 800127366] similar changes to U3. This Class 1E Installation of 480 V Load Center in U3 is (ADAMS Containment 480 V Load Center provides a safety planned for U3 C17 outage at end of Accession No. Hydrogen benefit of increased margin for the 2012.

ML100060791) Recombiners affected system. As a result. SCE will Train B permanently leave the U2 and U3 Train B hydrogen recombiners removed from containment. The opposite train hydrogen recombiner (Train A) for each unit remains functional at this time and is being maintained on a frequency determined by SCE to be appropriate.

Letter from SCE LAR for TSTF-511, 2009-06-001 Removal of the plant-specific TS NIA Closed. NRC Letter of 10/20/2009 to NRC dated Eliminate Working [NN 200005253-35] requirements will be performed (ADAMS Accession No. ML092880169) 6/10/2009 Hour Restrictions concurrently or subsequent to has been received and assessed. The (ADAMS from TS 5.2.2 to implementation of 10 CFR Part 26, necessary changes to implement Unit 2/3 Accession No. Support Compliance Subpart I requirements. This amendments 221/214 (PCN-591)for ML091630061 ) with 10 CFR 26 commitment will be completed no later TSTF-511, Revision 0, "Eliminate than 10/1/2009 or within 60 days of TS Working Hour Restrictions from TS 5.2.2 approval, whichever is later. to Support Compliance with 10 CFR Part 26" were incorporated by CDM into the SONGS 2/3 TSs today (11119/2009).

Letter from SCE License Amendment 2009-11-004 Implement Cyber Security Plan in NIA Working. Milestones due 12/31/2012 and I to NRC dated Application Nos. 257 [Order 800412767] accordance with the implementation 12/31/2015.

11/23/2009 and 243, Cyber schedule submitted to the NRC as part (ADAMS Security Plan ofPCN 595.

Accession No. ML093410251) Due: SCE requests an implementation period of 90 days following NRC approval of this license amendment.

- 12 Commitment No.1 Implementation Letter Subject Tracking No. Description of Commitment Status (7/28/2008) Implementation Status (12/2011)

Letter from SCE Inspection of Divider 2009-12-007 As discussed in the public meeting, SCE NIA Working. Incorporated inspection to NRC dated Plate Weld Joint in [800414457-0020, commits to perform additional requirements in site order S023SG-1, 121712009 the RSGs 200599777 -0004 confirmatory examinations of the divider Revision 17.

(ADAMS through -0007] plate welds following the installation of Accession No. the RSGs for both U2 and U3. The U2C17 will be first inspection - estimate ML093430116) examinations will consist of remote 1/1/2013 until outage date is known.

visual examinations of the accessible areas of the divider plate to channel head and tubesheet welds and repeat baseline straight beam ultrasonic examinations from the accessible locations outside the channel head.

Examinations will be performed during the first steam generator inspection outage and in a steam generator inspection outage near the end of the first 10-year inspection interval for the RSGs for each unit."

Letters from Amendment 2010-01-001 SONGS will continue to implement NIA Working.

SCEto NRC Applications 258 [800440164, revised applicability of TSs that are

References:

dated 1/14/2010 and 244, TSs 200741690] pertinent to the movement of fuel 2-EDMR-2008-0004 (ADAMS Applicable to assemblies using administrative controls 3-EDMR-2008-0044 Accession No. Movement of Fuel in accordance with NRC Administrative ACE 800168808 ML100210200) Assemblies Letter 98-10.

and 9/2/2011 [Resubmitted on (ADAMS 9/2/2011 with same Due: Until NRC completes its review Accession No. commitment] and issues revised TS pages.

~2528110)

- 13 II Commitment No.1 Implementation I Letter Subject Tracking No. Description of Commitment Status (7/28/2008) Implementation Status (1212011) I Letters from Change to 201 0-06-002 From July 1. 2010 forward, individuals NIA Closed.

SCEto NRC Commitments for [Order 800498507] filling the STA position at SONGS will Sustainability for this action is carried in dated 6/14/2010 Shift Technical comply with Option 2 of the Commission Procedure S023-XXI-1.11.12 Rev 17 (ADAMS Advisor Program Policy Statement on Engineering "Shift Technical Advisor Training Accession No. Expertise on Shift. 50 FR 43621, Program Description" and is anchored by ML101670162). published on October 28. 1985. the commitment 2.1.5 (Attachment 3, 4/26/2010 Option 2 states: pages 2 and 3).

(ADAMS "This option is satisfied by placing on Accession No. each shift a dedicated Shift Technical UFSAR Section 13.1 Revision 31 issued ML101170163), Advisor (STA) who meets the STA 6/10/2011 (ADAMS Accession No.

2/3/2006, and criteria of NUREG-0737, Item 1.A.1.1. ML11173A141) incorporated the STA 4/14/1988. The STA should assume an active role commitment.

in shift activities. For example, the STA should review plant logs, participate in shift turnover activities, and maintain an awareness of plant configuration and status:

Letters from One-TimeTS 2010-08-010 thru 029 Online Unit Compensatory Measures NIA Closed.

SCE to NRC Changes Applicable [200839078-0013 thru SCEwill:

dated 6/17/2010 to TS 3.8.1, "AC 0032;

• Protect the available offsite source: via Amendment with commitments was (ADAMS Sources NN 201191021] switchyard barriers and 4.16 kiloVolt withdrawn in 7/22/2010 letter, Accession No. Operating" (kV) cross-tie breaker barriers. resubmitted in 8/16/2010 letter.

ML101690069),

• Protect both onsite sources - Perform 7/22/2010 Surveillances on the operating unit Commitment prohibiting switchyard work (ADAMS emergency diesel generators (EDGs) was revised in commitment change letter Accession No. prior to entering Action Statement, and dated 3/2512011 (ADAMS Accession No. ML102080039), protect the available switchgear room. ML110871482) from "Do not allow any and 8/16/2010

• Ensure the protected train is the train switchyard work during ...

• to: "Establish (ADAMS with the Operable 4.16 kV cross-tie. Switchyard Restricted Access during ....

• Accession No.

• Ensure affected train common NN 201191021 documented the change ML102290073) equipment (1E 480 VAC buses, evaluation. Bases change is being emergency chillers, control room tracked under NN 201236592.

emergency cooling units) are aligned to the on-line unit. These commitments were incorporated

• Protect all 3 auxiliary feedwater (AFW) into Tech Spec and Basis 3.8.1 ;

pumps therefore, the commitments were closed,

• Protect switchgear room normal since they are controlled by a licensing heating, ventilation and air conditioning basis document.

(HVAC) cooling unit and exhaust fan.

• Do not allow any switch yard work, or train work on the protected train.

- 14 Commitment No.1 Implementation Letter Subject Tracking No. Description of Commitment Status (7/28/2008) Implementation Status (12/2011)

Letters from One-TimeTS 2010-08-010 thru 029 Outage Unit Compensatory Measures NIA Closed.

SCE to NRC Changes Applicable [200839078*0013 thru SCEwill .... Amendment with commitments was dated 6/17/2010 to TS 3.8.1, "AC 0032]

• Protect the available train offsite withdrawn in 7/22/2010 letter, (ADAMS Sources- source: via switchyard barriers and 4.16 resubmitted in 8/16/2010 letter.

Accession No. Operating" kV cross-tie breaker barriers.

ML101690069),

• Protect the available train onsite These commitments were incorporated 7/22/2010 source, EDG and 4.16 kV bus. into Tech Spec and Basis 3.8.1; (ADAMS

• Protect all available train safety therefore, the commitments were closed, Accession No. function equipment CCW (component since they are controlled by a licensing ML102080039), cooling water), SWC (saltwater cooling), basis document.

and 8/16/2010 SOC (shutdown cooling), and SFP (ADAMS (Spent Fuel Pool) cooling.

Accession No.

• Do not allow any work in the ML102290073) switchyard or on the protected electric power buses that are providing safety function fulfillment.

• Scheduling: Work the supply cubicles and cross-tie cubicle bottle replacements first, allowing for a quicker "emergency" return to service.

• Develop a plan to effect an emergency return to service, if required to support the operating unit.

• Bus outages are to be performed during the core offload window, when all fuel is removed from the reactor vessel.

-15 Commitment No.1 Implementation Letter Subject Tracking No. Description of Commitment Status (7/28/2008) Implementation Status (12/2011)

Letters from One-Time TS 2010-08-010 thru 029 The following compensatory measures NIA Closed.

SCE to NRC Changes Applicable [200839078-0013 thru apply to the U3 Cycle 16 refueling only dated 6/17/2010 to TS 3.8.1, uAC 0032] since U3 steam generator replacement Amendment with commitments was (ADAMS Sources- is planned for this outage: withdrawn in 7/2212010 letter, Accession No. Operating"

• Rigging activities to be limited to one resubmitted in 8/16/2010 letter.

ML101690069), end of the steam generator replacement 7/22/2010 outside lift system (OLS) to limit These commitments were incorporated (ADAMS potential impact to U3 Train A diesel into Tech Spec and Basis 3.8.1; Accession No. generator cables located underground therefore, the commitments were closed, ML102080039), near the containment equipment hatch. since they are controlled by a licensing and 8/16/2010

• OLS construction, use, and removal to basis document.

(ADAMS be limited to specific outage windows to Accession No. reduce risk to the U3 Train A diesel ML102290073) generator cables.

• SONGS NUREG-0612 heavy loads procedural requirements are to be implemented for both the OLS and the service crane to ensure safe load paths are followed, or safe shutdown equipment is taken out of service, during the rigging activity.

• A U3 Cycle 16 shutdown qualitative risk assessment to be performed to provide qualitative risk management actions to demonstrate acceptable outage risk during construction, use, and deconstruction or the OLS.

o Work controls to be in place to lay the service crane boom down prior to severe weather o No load movements by the service crane over the switchyard

-16 Commitment No.1 Implementation Letter Subject Tracking No. Description of Commitment Status (7/28/2008) Implementation Status (1212011)

Letters from Notification Letter 2010-09-001 In the Reference (2) letter, NRC is also NIA Closed.

SCE to NRC designating SONGS [NN 201129568, requiring that each nuclear power plant Because of changing regulatory direction, dated 9/29/2010 Station Balance of Order 800585909, NN submit a revised cyber security plan to SCE submitted a letter on 11/30/2010 (ADAMS Plant Systems 201386754] the NRC for its review and approval. On indicating that SCE would provide a Accession No. within the Cyber or before 11/30/2010, SCE will supplement to the SONGS Cyber ML102730183), Security Rule Scope supplement its Cyber Security Plan to Security Plan in accordance with a 11/30/2010 clarify the scope of systems described in schedule to be provided by the NRC.

(ADAMS Section 2.1, Scope and Purpose. The NRC sent an RAI on 3/1/2011 Accession No. Section 2.1 will be amended to clarify (ADAMS Accession No. ML110600635).

ML103350155), the balance of plant systems, structures, SCE sent letter to NRC dated 3/31/2011 and 3/3112011 and components (SSCs) that will be that fulfilled this commitment.

(ADAMS included in the scope of the Cyber Accession No. Security Program.

ML11112A028)

Letter from SCE Response to Notice 2010-10-175 SCE commits to transition to and NIA Working.

to NRC dated of Violation in NRC [800601127-0020] implement National Fire Protection 10/2912010 Triennial Fire Agency Standards NFPA 805 for its Letter to NRC dated 6/24/2011 (ADAMS (ADAMS Protection SONGS fire protection program. Accession No. ML111780512) committed Accession No. Inspection Report to an LAR submittal date of 3/31/2013, ML103020527) 05000361/2010007 and requested enforcement discretion through that date.

Letter dated 7/28/2011 (ADAMS Accession No. ML112020559), to P. T.

Dietrich (SCE) from J. G. Giitter (NRC) granted the extension of enforcement discretion to 3/31/2013.

Therefore, SCE must now submit the NFPA 805 LAR no later than 3/31/2013.

-17 Commitment No.1 Implementation Letter Subject Tracking No. Description of Commitment Status (7/28/2008) Implementation Status (12/2011)

Letter from SCE LAR 260 and 246 2011-07-001 1. SCE will establish the TS for Limiting NIA Pending NRC approval of LAR.

to NRC dated for TS Conversion to [800745502-0020] Condition for Operation (LCO) 3.0.4, as 7/29/2011 NUREG-1432 modified with the applicable license (ADAMS amendment.

Accession No. Due upon implementation.

ML112510214) 2011-07-002 2. SCE will ensure that if LCO 3.0.4.b is N/A Pending NRC approval of LAR.

[800745502-0030] used, the risk assessments will be conducted using the procedures and guidance endorsed by Regulatory Guide 1.182, "Assessing and Managing Risk Before Maintenance Activities at Nuclear Power Plants." Regulatory Guide 1.182 endorses the guidance in Section 11 of NUMARC 93-01, "Industry Guideline for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants."

2011-07 -003 3. SCE will establish the TS Bases for NIA Pending NRC approval of LAR.

[800745502-0040] LCO 3.0.8, as adopted, with the applicable license amendment.

2011-07-004 4. SCE will ensure that when LCO NIA Pending NRC approval of LAR.

[800745502-0050] 3.0.8a is used, appropriate plant procedures and administrative controls are revised to implement the following Tier 2 Restriction:

• At least one AFW train (including a minimum set of supporting equipment required for its successful operation) not associated with the inoperable snubber(s), must be available.

- 18 Commitment No.1 Implementation Letter Subject Tracking No. Description of Commitment Status (7/28/2008) Implementation Status (12/2011)

[2011-07-005 5. SCE will ensure that when lCO N/A Pending NRC approval of LAR.

[S00745502 -0060] 3.0.Sb is used, appropriate plant procedures and administrative controls are revised to implement the following Tier 2 Restriction:

• At least one AFW train (induding a minimum set of supporting equipment required for its successful operation) not associated with the inoperable snubber(s). or some alternative means of core cooling (e.g .* feed and bleed (F&B). firewater system or "aggressive secondary cooldown" using the steam generators) must be available.

2011-07-006 6. SCE will ensure that when lCO 3.0.S N/A Pending NRC approval of LAR.

[800745502-0070] is used appropriate plant procedures and administrative controls are revised to implement the following Tier 2 Restriction:

• Every time the provisions of lCO 3.0.S are used SCE will confirm that at least one train (or subsystem) of systems supported by the inoperable snubbers would remain capable of performing their required safety or support functions for postulated design loads other than seismic loads. lCO 3.0.S does not apply to non-seismic snubbers. In addition, a record of the design function of the inoperable snubber (i.e .* seismic vs. non-seismic), implementation of any applicable Tier 2 restrictions, and the associated plant configuration shall be available on a recoverable basis.

2011-07-007 7. SCE will revise the UFSAR or TS N/A Pending NRC approval of LAR.

[S00745502-0080] Bases to describe the restrictions in commitments 4 and 5.

- 19 Commitment No.1 Implementation Letter Subject Tracking No. Description of Commitment Status (7/28/2008) Implementation Status (12/2011) 2011-07 -008 SCE will ensure that when using end NIA Pending NRC approval of LAR.

[800745502-0090] state changes being adopted as part of TSTF-422 incorporation, appropriate plant procedures and administrative controls are revised to perform a risk assessment in accordance with 10 CFR 50.65(a)(4), regardless of whether maintenan~ is being performed. The risk assessment will follow Regulatory Guide 1.182, "Assessing and Managing Risk Before Maintenance Activities at Nuclear Power Plants," which endorses NUMARC 93-01, "Industry Guideline for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants,"

Section 11 guidance for implementation of 10 CFR 50.65(a)(4). SCE will also follow the industry-developed implementation guidance, WCAP 16364-NP, Rev. 0, "Implementation Guidance for Risk Informed Modification to Selected Required Action End States at Combustion Engineering NSSS Plants (TSTF-422)," November 2004.

2011-07-009 For all Frequencies being moved to the NIA Pending NRC approval of LAR.

[800745502-0100] Surveillance Frequency Control Program, SCE will ensure both the current Frequencies and the basis for the Frequencies are included in the Program. SCE will also ensure that any changes to the Frequencies will be in accordance with NEI 04-01, "Risk-Informed Method for Control of Surveillance Frequencies," Rev. 1.

- 20 Commitment No.1 Implementation letter Subject Tracking No. Description of Commitment Status (7/28/2008) Implementation Status (12/2011) 2011-07-0010 SCE will ensure that appropriate NIA Pending NRC approval of LAR.

[800745502-0110] administrative procedures are in place when using the lCO 3.9.3 Note that allows penetration flow path(s) providing direct access from the containment atmosphere to the -outside atmosphere to be unisolated under administrative controls. The administrative procedures will ensure that in the event of a refueling accident, the open penetration(s) can and will be promptly closed.

2011-07-0011 SCE will ensure procedures are in place NIA Pending NRC approval of LAR.

[800745502-0120] to require the continuing performance of the Hazardous Cargo Traffic Report in accordance with Regulatory Guide 1.78, "Evaluating the Habitability of Nuclear Power Plant Control Room During a Postulated Hazardous Chemical Release." The report will include hazardous cargo traffic on Interstate 5 and the Atchison, Topeka, and Santa Fe Railway and be submitted to the NRC regional administrator every 3 years.

SUMMARY

OF AUDIT RESULTS FOR REGULATORY COMMITMENTS CHANGE Audit Performed December 14.2011 San Onofre Nuclear Generating Station, Units 2 and 3 Report is available in ADAMS at Accession No. ML110871482 Attachment 2

P. Dietrich - 2 The NRC staff appreciates the assistance of your staff, both before and during the audit. If there are any questions, I can be contacted at (301) 415-1476 or by electronic mail at mohan.thadani@nrc.gov.

Sincerely, IRA!

Mohan C. Thadani, Senior Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-361 and 50-362

Enclosure:

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