ML13056A604

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Southern California Edison Company'S Third Notification of Responses to RAIs in the Matter of San Onofre, Units 2 and 3
ML13056A604
Person / Time
Site: San Onofre  Southern California Edison icon.png
Issue date: 02/25/2013
From: Burdick S
Morgan, Morgan, Lewis & Bockius, LLP, Southern California Edison Co
To: Gary Arnold, Anthony Baratta, Hawkens E
Atomic Safety and Licensing Board Panel
SECY RAS
References
RAS 24149, 50-361-CAL, 50-362-CAL, ASLBP 13-924-01-CAL-BD01
Download: ML13056A604 (13)


Text

Morgan, Lewis & Bockius LLP 1111 Pennsylvania Avenue, NW Washington, DC 20004 Tel. 202.739.3000 Fax: 202.739.3001 www.morganlewis.com Stephen J. Burdick 202.739.5059 sburdick@morganlewis.com February 25, 2013 E. Roy Hawkens, Chair Dr. Anthony J. Baratta Dr. Gary S. Arnold Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Docket: Southern California Edison Company, San Onofre Nuclear Generating Station, Units 2 and 3, Docket Nos. 50-361-CAL & 50-362-CAL Re: Third Notification of Responses to RAIs

Dear Licensing Board Members:

On December 26, 2012, the Nuclear Regulatory Commission (NRC) issued Requests for Additional Information (RAIs) to Southern California Edison Company (SCE) regarding SCEs October 3, 2012 response to the March 27, 2012 Confirmatory Action Letter for San Onofre Nuclear Generating Station Units 2 and 3.

The purpose of this letter is to provide notification to the Licensing Board of additional SCE responses to these RAIs. Specifically, the enclosure provides SCEs response to RAI 32. The Reply Brief of Petitioner Friends of the Earth (Feb. 13, 2013) and Natural Resources Defense Councils Amicus Response in Support of Friends of the Earth (Jan. 18, 2013) both heavily rely upon RAI 32 as a basis for their arguments that SCE needs a license amendment in order to comply with Technical Specification 5.5.2.11.

As discussed in more detail in SCEs response to RAI 32:

  • As a result of SCEs formal commitment established in the CAL response and Unit 2 Return to Service Report, the normal steady state full power in the Current Licensing Basis for Unit 2 is 70% power for the proposed operating period. Since all of the Operational Assessments (OAs) were performed for operation at or above 70% power, TS 5.5.2.11 compliance is demonstrated.

DB1/ 73193408.1

Atomic Safety and Licensing Board February 25, 2013 Page 2

  • Nevertheless, [a]s requested in the RAI, SCE will provide an OA that includes an evaluation of steam generator TTW [tube-to-tube wear] for operation up to the RTP

[rated thermal power of 100%]. This OA will be provided to the NRC for review by March 15, 2013. In this OA, SCE will supplement the Intertek OA (Enclosure 2, Attachment 6, Appendix C of the CAL Response Letter) which is based on traditional industry guidelines. The OA supplement will demonstrate that the Structural Integrity Performance Criteria (SIPC) and the Accident Induced Leakage Performance Criteria (AILPC) are satisfied for 100% Rated Thermal Power (RTP).

Respectfully submitted, Signed (electronically) by Stephen J. Burdick Stephen J. Burdick Counsel for Southern California Edison Company Enclosure

1. SCE Response to RAI 32 (Feb. 25, 2013)

DB1/ 73193408.1

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD

)

In the Matter of )

) Docket Nos. 50-361-CAL & 50-362-CAL SOUTHERN CALIFORNIA EDISON COMPANY )

)

(San Onofre Nuclear Generating Station, ) February 25, 2013 Units 2 and 3) )

)

CERTIFICATE OF SERVICE I hereby certify that, on this date, a copy of the Third Notification of Responses to RAIs was filed through the E-Filing system.

Signed (electronically) by Stephen J. Burdick Stephen J. Burdick Morgan, Lewis & Bockius LLP 1111 Pennsylvania Avenue, N.W.

Washington, D.C. 20004 Phone: 202-739-5059 Fax: 202-739-3001 E-mail: sburdick@morganlewis.com Counsel for Southern California Edison Company DB1/ 73193408.1

BOARD NOTIFICATION ENCLOSURE 1 DB1/ 73193408.1