ML13276A019

Request for Rescission of Fukushima Orders (EA-12-051)

ML13276A019
Person / Time
Site:	San Onofre
Issue date:	09/30/2013
From:	Peter Dietrich Edison International Co, Southern California Edison Co
To:	Document Control Desk, NRC Region 4
References
EA-12-049, EA-12-051
Download: ML13276A019 (2)

Text

SOUTHERN CALIFORNIA Peter T. Dietrich SEDISON enior Vice President & Chief Nuclear Officer An EDISON INTERNATIONAL Company September 30, 2013 10 CFR 2.202 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-001

SUBJECT:

Docket Nos. 50-361 and 50-362 License Nos. NPF-10 and NPF-15 Request for Rescission of Fukushima Orders (EA-12-049 and EA-12-051)

San Onofre Nuclear Generating Station, Units 2 and 3

References:

1. NRC Order Number EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events dated March 12, 2012. [ADAMS Accession Number ML12054A735]

2.

NRC Order Number EA-12-051, Order Modifying Licenses with Regard to Requirements for Reliable Spent Fuel Pool Instrumentation dated March 12, 2012 [ADAMS Accession Number ML12054A679]

3.

NRC letter to Duke Energy dated August 27, 2013, Crystal River Unit 3 Nuclear Generating Plan

- Rescission of Order EA-1 2-049 [ADAMS Accession Number ML13212A366]

4.

NRC letter to Duke Energy dated August 27, 2013, Crystal River Unit 3 Nuclear Generating Plan

- Rescission of Order EA-12-051 [ADAMS Accession Number ML132203A161]

5. SCE letter to NRC, Permanent Cessation of Operations dated June 12, 2013 [ADAMS Accession Number ML131640201]

6.

SCE letter to NRC, Permanent Removal of Fuel from the Reactor Vessel, SONGS Unit 3, dated June 28, 2013 [ADAMS Accession Number ML13183A391]

7. SCE letter to NRC, Permanent Removal of Fuel from the Reactor Vessel, SONGS Unit 2, dated July 22, 2013 [ADAMS Accession Number ML13204A304]

8.

NEI 12-02, Revision 1, Industry Guidance for Compliance with NRC Order EA-12-051, "To Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation"

9. JLD-ISG-2012-03, Revision 0, NRC Interim Staff Guidance for Compliance with Order EA-12-051 Reliable Spent Fuel Pool Instrumentation

Dear Sir or Madam:

On March 12, 2012, the Nuclear Regulatory Commission (NRC) issued Reference 1 and Reference 2 to Southern California Edison (SCE). Reference 1 was immediately effective and directed SCE to develop, implement, and maintain guidance and strategies to maintain or restore core cooling, containment, and spent fuel pool (SFP) cooling capabilities in the event of a beyond-design-basis external event.

Reference 2 was immediately effective and directed SCE to provide reliable SFP level indications.

Implementation of both orders was required to be completed no later than two (2) refueling cycles after submittal of the respective overall integrated plan, or December 31, 2016, whichever comes first.

P.O. Box 128 San Clemente, CA 92672 (949) 368-6255 PAX 86255 Fax: (949) 368-6183 Pete.Dietrich@sce.com

Document Control Desk September 30, 2013 SCE hereby requests rescission of Orders EA-1 2-049 and EA-1 2-049 for SONGS Units 2 and 3. Based on the rescission of Orders EA-1 2-049 and EA-1 2-051 for Crystal River Unit 3 in References 3 and 4, SCE considers that it has good cause for rescission of the Orders as described below:

With respect to the requirements of Order EA-1 2-049:

All nuclear fuel at SONGS Units 2 and 3 has been permanently removed from the reactor vessels and containments (References 5, 6 and 7). The reactor coolant system and secondary coolant systems (steam and feedwater) systems have also been removed from service. The lack of fuel in the reactor vessels and the absence of challenges to the containments render the development of guidance and strategies to maintain or restore core cooling and containment capabilities unnecessary.

At the current decay heat levels, the time to boil in each SFP is approximately 90 hours0.00104 days <br />0.025 hours <br />1.488095e-4 weeks <br />3.4245e-5 months <br /> (3.75 days) and the time to reduce SFP water inventory to a point 10 feet above the top of the spent fuel racks is an additional approximately 11 days. As such, reliance on SFP inventory for passive cooling provides an equivalent level of protection as that which would be provided by the initial phase of the guidance and strategies for maintaining or restoring SFP cooling per Order EA-1 2-049. Further, the low decay heat and long time to boil off the inventory to a point at which makeup would be necessary for radiation shielding purposes obviate the need for transition phase guidance and strategies using on site portable equipment per Order EA-1 2-049. Lastly, the low decay heat and long time to boil off the inventory also provides sufficient time for SCE to obtain off site resources on an ad hoc basis to sustain the SFP cooling function indefinitely, obviating the need for the final phase of guidance and strategies per EA-12-049.

With respect to the requirements of Order EA-1 2-051:

Since SCE has certified the permanent removal of fuel from the reactor vessels and containments, the safety of the fuel in the SFP becomes the primary safety function for site personnel. In the event of a challenge to the safety of the fuel stored in the SFP, decision-makers would not have to prioritize actions and the focus of the staff would be on the SFP condition. Further, because the irradiated fuel in the SONGS Units 2 and 3 SFPs was last used for power generation in January 2012 and full compliance is not required until December 31, 2016, the fuel will have decayed nearly 5 years by the time reliable SFP instrumentation would be required. Section 2.3 of the applicable industry guidance for SFP level instrumentation (Reference 8, which was endorsed by Reference 9), states that for implementation of the order, a SFP "is a water filled structure housing storage racks that contain irradiated fuel discharged from the reactor vessel that has been used for power generation within the last five years". The nuclear fuel most recently discharged from the SONGS Units 2 and 3 reactor vessels will have reached five years of decay time shortly after December 31, 2016 (in early and late January 2017, respectively).

This letter contains no new regulatory commitments. If there are any questions regarding this plan, please contact Mr. Mark Morgan at (949) 368-6745.

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

Execute d on 3 / 3 cc:

S. A. Reynol s, Acti rRegional Administrator, NRC Region IV G. G. Warnick, NRC Senior Resident Inspector, San Onofre Units 2 and 3 R. Hall, NRC Project Manager, San Onofre Units 2 and 3 B. Benney, NRC Project Manager, San Onofre Units 2 and 3