Text

Amendment Application Numbers 265 and 250 Responsibility, Organization, and Qualifications
	ML13296A013
Person / Time
Site:	San Onofre
Issue date:	10/21/2013
From:	Peter Dietrich; Southern California Edison Co
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	Download: ML13296A013 (52)
	v • d • e

SOUTHERN CALIFORNIA Peter T. Dietrich

.J EDISON Senior Vice President & Chief Nuclear Officer An EDISON INTERNATIONAL Company 10 CFR 50.90 October 21, 2013 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555

Subject:

Docket No. 50-361 and 50-362 Amendment Application Numbers 265 and 250 Responsibility, Organization, and Qualifications San Onofre Nuclear Generating Station, Units 2 and 3

References:

(1) Letter from P. T. Dietrich (SCE) to the U.S. Nuclear Regulatory Commission (NRC) dated June 28, 2013;

Subject:

Permanent Removal of Fuel from the Reactor Vessel, San Onofre Nuclear Generating Station Unit 3 (2) Letter from P. T. Dietrich (SCE) to the U.S. Nuclear Regulatory Commission (NRC) dated July 22, 2013;

Subject:

Permanent Removal of Fuel from the Reactor Vessel, San Onofre Nuclear Generating Station Unit 2 (3) Letter from R. St. Onge (SCE) to the U.S. Nuclear Regulatory Commission (NRC) dated August 20, 2013;

Subject:

Request for Approval of the Safe Storage Shift Manager/Certified Fuel Handler Training Program, San Onofre Nuclear Generating Station Units 2 and 3 (4) Letter from R. St. Onge (SCE) to the U.S. Nuclear Regulatory Commission (NRC) dated September 11,2013;

Subject:

Request for exemption from the Requirements of 10CFR50.54(m) and 10CFR55, San Onofre Nuclear Generating Station, Units 2 and 3

Dear Sir or Madam:

Pursuant to 10 CFR 50.90, Southern California Edison (SCE) hereby submits license amendment applications 265 and 250 to operating licenses NPF-10 and NPF-15 for San Onofre Nuclear Generating Station (SONGS) Units 2 and 3, respectively.

Amendment Applications 265 and 250 consist of the enclosed Proposed Change Number (PCN-604).

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

Document Control Desk October 21, 2013 By letters dated June 28, 2013 and July 22, 2013, SCE submitted certifications of permanent removal of fuel from the reactor vessels for SONGS Units 3 and 2 (References 1 and 2). Consequently, the 10 CFR Part 50 licenses for SCE no longer authorizes operation of the reactor or emplacement or retention of fuel into the reactor vessel, as specified in 10 CFR 50.82(a)(2).

The proposed amendment revises Sections 5.1, 5.2, and 5.3 of the Technical Specifications to reflect the permanently shutdown status of SONGS Units 2 and 3.

Specifically, the proposed changes reflect new staffing and training requirements for operating staff.

On August 20, 2013, SCE submitted a request for Commission approval of a certified fuel handler training program (Reference 3). On August 28, SCE submitted a request for exemption from the requirements of 10CFR50.54(m) and 10CFR55 (Reference 4).

This License Amendment Request provides revised Technical Specifications that are consistent with and will allow implementation of the staffing and training requirements described in References 3 and 4.

There are no new regulatory commitments in this letter or the Enclosure.

Should you have any questions, or require additional information, please contact Mr. Mark Morgan at (949) 368-6745.

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

Executed on )01-'/'3 (Date)

Enclosures:

PCN-604 with Attachments cc:

S. A. Reynolds, Acting Regional Administrator, NRC Region IV R. Hall, NRC Project Manager, SONGS Units 2 and 3 B. Benney, NRC Project Manager, SONGS Units 2 and 3 G. G. Warnick, NRC Senior Resident Inspector, SONGS Units 2 and 3 S. Y. Hsu, California Department of Public Health, Radiologic Health Branch

ENCLOSURE EVALUATION OF THE PROPOSED AMENDMENT PCN-604 Responsibilities, Organization, and Qualifications

1.

SUMMARY

DESCRIPTION

2. DETAILED DESCRIPTION

3. TECHNICAL EVALUATION

3.1 Background

3.2 Discussion

4. REGULATORY EVALUATION 4.1 Applicable Regulatory Requirements/Criteria 4.2 No Significant Hazards Consideration 4.3 Conclusions

5. ENVIRONMENTAL CONSIDERATION

6. REFERENCES ATTACHMENTS:

A.

B.

C.

D.

E.

F.

Existing Technical Specifications - Unit 2 Existing Technical Specifications - Unit 3 Proposed Technical Specifications - Markup - Unit 2 Proposed Technical Specifications - Markup - Unit 3 Proposed Technical Specifications - Clean - Unit 2 Proposed Technical Specifications - Clean - Unit 2 1 of 14

1.0

SUMMARY

DESCRIPTION Southern California Edison Company (SCE) is proposing to revise Technical Specifications Section 5.1, "Responsibility," Section 5.2, "Organization," and Section 5.3, "Unit Staff Qualifications" to reflect reduced facility staffing and training requirements in the permanently shutdown and defueled condition.

2.0 DETAILED DESCRIPTION The proposed changes replace reliance on senior reactor operators and reactor operators licensed pursuant to 10 CFR 55 at San Onofre Nuclear Generating Station (SONGS), with Certified Fuel Handlers and Certified Operators, trained in accordance with an NRC-approved training plan. These proposed changes reflect the permanently defueled condition of the plant.

In addition, various other changes are made to sections 5.1, 5.2, and 5.3 to reflect the permanently defueled condition of the plant.

Proposed changes described in detail in Section 3.2.2 with accompanying justifications.

3.0 TECHNICAL EVALUATION

3.1 Background

By letter dated June 12, 2013, SCE submitted a certification of permanent cessation of operations (Reference 6.1). By letters dated June 28, 2013 and July 22, 2013, SCE submitted certifications of permanent removal of fuel from the reactor vessels for SONGS Units 3 and 2 (References 6.2 and 6.3). Upon docketing of the References 6.2 and 6.3 certifications, the 10 CFR Part 50 licenses for SONGS Units 2 and 3 no longer authorize operation of the reactor or emplacement or retention of fuel into the reactor vessel, as specified in 10 CFR 50.82(a)(2).

The scope and radiological consequences of accidents possible at SONGS are substantially lower than those at an operating plant. Because of the significantly reduced scope and consequences of radiological events still possible at the site, the scope of operator actions and corresponding requirements for operator staffing levels may be accordingly reduced. All necessary activities can be appropriately fulfilled by certified fuel handlers and non-licensed operators.

On August 20, 2013, SCE submitted a request for Commission approval of a certified fuel handler training program (Reference 6.4). On September 11, 2013, SCE submitted a request for exemption from the requirements of 10CFR50.54(m) and 10CFR55 (Reference 6.5). Reference 6.5 stated that minimum shift staffing levels would be administratively controlled. Based on discussions with NRC staff and other utilities in 2 of 14

the decommissioning process, SCE has determined that the minimum shift staffing levels should be controlled in the Technical Specifications. This License Amendment Request provides revised Technical Specifications that are consistent with and will allow implementation of the staffing and training requirements described in References 6.4 and 6.5.

3.2 Discussion 3.2.1 Reduced Scope of Radiological Accidents at Permanently Defueled Facilities The irradiated fuel will be stored in the spent fuel pool (SFP) and in the Independent Spent Fuel Installation (ISFSI) until it is shipped off site sometime in the future.

Because the reactor is permanently defueled, the SFP and its supporting systems are dedicated only to spent fuel storage. With the reactor defueled, the reactor, Reactor Coolant System (RCS), and secondary system are no longer in operation and have no function related to the safe storage and management of irradiated fuel.

10CFR50.82(a)(2) specifies that the 10 CFR 50 license no longer authorizes operation of the reactor or emplacement or retention of fuel in the reactor vessel after docketing the certifications for permanent cessation of operations and permanent removal of fuel from the reactor vessel. After the termination of reactor operations at SONGS and the permanent removal of the fuel from the reactor vessel the postulated accidents involving failure or malfunction of the reactor, RCS or secondary system are no longer applicable.

Revised dose calculations were completed to support the changes to the Updated Final Safety Analysis Report (UFSAR) Chapter 15 Accident Analysis. These calculations validate that the dose consequences would be within 10 CFR 50.67 and Regulatory Guide 1.183 dose limits and would be below the Environmental Protection Agency's Protective Action Guidelines. The UFSAR was revised to reflect the new analysis.

3.2.1.1 Fuel Handling Accident with a Personnel Injury Other utilities in the decommissioning process have made similar requests to the NRC to revise their administrative Technical Specifications. As part of the review process, the NRC has issued Requests for Additional Information. One of the questions the NRC has consistently asked regards the expected response to a Fuel Handling Accident with serious, open-wound, personnel injuries (responses to other relevant NRC RAIs are provided throughout this LAR).

No change to the station's response to fuel handling accident is being proposed in this submittal. Because more than 90 days has elapsed since the reactor was permanently shut down, reactor fuel has sufficiently decayed such that the radiological consequences of a fuel handling accident remain within limits without relying on structures, systems and components (SSCs) remaining functional for accident mitigation during or following the event (provided the spent fuel pool water level 3 of 14

requirement of TS 3.7.16 is met). As such, the occurrence of an injury during a fuel handling accident would not adversely impact the resultant radiological consequences of that event.

Station procedures require additional staffing during fuel handling evolutions, beyond the minimal shift staffing requirements specified in Technical Specifications. Since a fuel handling accident can only occur during fuel handling, this additional staff would be available to respond to both a fuel handling event as well as a concurrent injury.

Occurrence of a fuel handling accident would be observed by the individuals involved in moving fuel assemblies (the same as would have occurred when the plant was operating). Radiation monitors would also provide indication of such an event. The response to such an event would be in accordance with plant response procedures for such an event.

Although occurrence of a serious, open-wound, personnel injury during a fuel handling accident is not a postulated event, the additional staffing that is required to be present during fuel handling activities is expected to be sufficient to address such a situation.

SCE has processes in place to address injuries (regardless of when they occur).

Alarms and displays do not factor into the discovery of an injury. Rather an injury would be identified by personal observation and communicated to the shift manager.

Uninjured staff involved in the activity would summon additional assistance from both onsite and offsite resources, as needed, using the plant-wide announcing system and personal communication devices. Since there are no pertinent time constraints associated with the fuel handling accident; addressing the injury would be performed as quickly as feasible commensurate with the severity of the injury. The existing administrative chain of command would be used during the response for both reporting and for command and control, which is under the direction of the shift manager.

The fuel handling accident analysis assumes that all fuel rods in an impacted fuel assembly are breached and the resultant radioactive cloud is released from the pool and is released via the Plant Vent Stack. With the age of the fuel, there is no consequential radioactive iodine released and the majority of the dose would be from Krypton-85. The offsite dose is a small fraction of the Environmental Protection Agency's Protective Action Guide limit and as such, there are no time constraints in staffing the Emergency Response Organization or mitigating the event.

Preliminary evaluation results demonstrate the dose rate on the refueling floor after a fuel handling accident to be a small fraction of the 10 CFR Part 20 allowable limits due to the age of the fuel and the nature of the accident. Should there be an injured individual near the pool during this accident, it would not result in a dose significant event for the injured individual or the responders.

3.2.2 SONGS Defueled Organization Description 4 of 14

The proposed Technical Specifications reflect changes to the SONGS organization, staffing, and training to reflect a transition to the permanently defueled status. These proposed changes reflect a change in focus from potential operating design basis events (Loss of Coolant Accident, Main Steam Line Break, etc.) to safe storage and handling of spent nuclear fuel.

The most significant proposed change is to the minimum staffing and qualification requirements for on-shift staffing. Licensed Operators will be replaced with Certified Fuel Handlers and Certified Operators. Certified Fuel Handlers will be qualified in accordance with a Certified Fuel Handler Training Program, which was submitted on August 20, 2013 (Reference 6.4) and is currently under NRC review. The Shift Manager, who will have command decision authority, will be qualified as a Certified Fuel Handler. Certified Operators will be qualified as plant operators in accordance with plant qualification requirements and consistent with the applicable requirements established in ANSI N18.1-1971.

The proposed Technical Specifications will require a minimum on-shift crew of one Shift Manager/Certified Fuel Handler, who may be shared between units, and one Certified Operator per Unit. The facility is staffed for coverage 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months a day, 7 days a week.

The SONGS management structure will not require any positions above the Shift Manager to be a Certified Fuel Handler or attend equivalent training. Management training requirements are specified in Technical Specification 5.3.1. TS 5.3.1 requires facility staff to meet the requirements of ANSI N 18.1-1971 with the exception of 1) the Radiation Protection Manager, who must meet the qualifications of Regulatory Guide 1.8, September 1975, and 2) multi-discipline supervisors, who have education and experience requirements and must complete a multi-discipline supervisor training program.

At this time, the Units 2 and 3 Control Room remains the center of command for SONGS. There are no activities that are performed in the control room, other than various electrical distribution system manipulations, that could directly affect the safe handling of nuclear fuel. There are, however, activities performed from the Control Room that have the potential to affect the safe cooling and storage of nuclear fuel.

These activities include manipulations and alignments of the spent fuel pool (SFP) cooling, and SFP make up systems. All of these activities will be procedurally controlled and performed by trained and qualified operators with oversight by a CFH on shift.

Detailed descriptions and associated justifications of the individual changes to the Technical Specifications are provided in Section 3.2.3, below.

5 of 14

3.2.3 Individual Proposed Changes and Justifications SONGS Proposed Change Justification Existing Specification General References to "Unit" operation are These changes in terminology more replaced with references to "Facility" appropriately reflect the current shutdown operation. Likewise, references to condition of SONGS. The term "Unit" is "safe operation" or "unit operation" are generally associated with the reactor.

replaced with references to Likewise, "operation" is usually associated "management of the plant" or "storage with operation of the reactor.

and maintenance of nuclear fuel" Section 5.1 Responsibility 5.1.1 Reference to "unit operation" of "Units These changes in terminology more 2 and 3" is replaced with reference to appropriately reflect the current shutdown "management of the plant" condition of SONGS. The term "Unit" is generally associated with the reactor.

Likewise, "operation" is usually associated with operation of the reactor.

5.1.2 This TS is revised by deleting the Because the corporate officer will be requirement for issuance of a responsible for overall plant operation, as management directive to define directed by TS 5.1.1, there is no need for command decision authority for the these requirements in the Technical plant.

Specifications.

5.1.3 This TS is revised by deleting the The change to delete the Control Room position of the Control Room Supervisor reflects the permanently Supervisor. In addition, the shutdown condition of SONGS Units 2 and 3.

requirement for issuance of a Shift Staffing will be controlled by a new set management directive to define of requirements in proposed Table 5.2.2-1 command decision authority for the (see below).

plant and a reference to the (Licensee Controlled Specifications (LCS) for a Because the corporate officer will be definition of the Control Room responsible for overall plant operation, as Boundary are also deleted.

directed by TS 5.1.1, there is no need for a management directive describing command decision authority in the Technical Specifications.

Furthermore, the location that describes what the control room area encompasses (i.e., the LCS) is also not required in the Technical Specifications because this description is more properly located in plant requirements (like the LCS).

6 of 14

Section 5.2 Unit Staff 5.2.1 Reference to "unit" operation is These changes in terminology more changed to "Plant" operation and appropriately reflect the current shutdown reference to safety of the "power condition of SONGS. The term "unit" is plant" is changed to safety of the generally-associated with the reactor.

"fuel."

Likewise, "power plant" is usually associated with power operation of the reactor.

5.2.1.a No changes N/A.

5.2.1.b Reference to the "Unit" is deleted.

These changes in terminology more References to "safe operation" of the appropriately reflect the current shutdown "plant" are replaced with references to condition of SONGS. The term "unit" is

'safe handling and storage" of generally associated with the reactor.

"nuclear fuel.."

Likewise, "operation" is usually associated with power operation of the reactor.

5.2.1.c Reference to "nuclear safety" is These changes in terminology more replaced with "safe management of appropriately reflect the current shutdown nuclear fuel" condition of SONGS. The term "nuclear safety" is generally associated operation of the reactor.

5.2.1.d The phrase "the operating staff' is In the defueled condition, the primary being replaced with "Certified Fuel responsibility of managing safe storage of the Handlers." The phrase irradiated fuel will be performed by Certified "independence from operating Fuel Handlers. Additionally, because the pressures" is being replaced with the plant will no longer be permitted to operate, phrase "ability to perform their the term "operating pressures" is obsolete assigned functions."

and the phrase "ability to perform their assigned functions" provides an analogous In addition, the term "health physics" requirement.

is replaced by the term "radiation protection."

The change from "health physics" to "radiation protection" is an administrative change to reflect updated organization titles.

5.2.2 The title of TS 5.2.2 and the These changes in terminology more requirement of TS 5.2.2 are revised to appropriately reflect the current shutdown replace reference to "Unit" Staff with condition of SONGS. The term "unit" is "Facility" staff.

generally associated with the reactor.

5.2.2.a The requirement for licensed The TS requirement for licensed operators is operators in MODES 1-4 is being applicable in MODES 1 through 4. Therefore deleted. In addition, the requirement it is not applicable in the permanently for non-licensed operators in the defueled condition.

shutdown or defueled condition is also being deleted. These The TS requirement for non-licensed requirements are being replaced by a operators in the defueled condition is being new requirement for each on-duty replaced by the Certified Fuel Handler and shift to be composed of at least the Certified Operator requirements of proposed minimum shift crew composition Table 5.2.2-1. This minimum shift crew shown in proposed TS Table 5.2.2-1.

composition is appropriate for the safe This new Table specifies a minimum management of irradiated fuel at a shift crew composition staffing permanently defueled facility.

requirement of one Certified Fuel Handler and one Certified Operator.

In addition to the existing Technical A footnote is added that a second Specification requirements for licensed Certified Fuel Handler may be used in operators, SONGS is also currently required 7 of 14

lieu of a Certified Operator. A second footnote is added that specifies that the Certified Fuel Handler may be shared between Units 2 and 3.

to comply with the staffing requirements of 10CFR50.54(m). On September 11, 2013, SCE submitted an exemption request to eliminate the licensed operator requirements of 10CFR50.54(m) for SONGS Units 2 and 3.

The proposed TS staffing requirements of one Certified Fuel Handler shared between Units and one Certified Operator per Unit are analogous to the 10CFR50.54(m) requirements for a two-unit, single control-room facility with neither unit operating (one Senior Reactor Operator and two Reactor ODerators).

5.2.2.b The requirements that licensed These requirements are applicable in operators be in the Control Room MODES 1 through 4 and when fuel is in the when fuel is in the reactor or when in reactor. These conditions are not applicable MODES 1, 2, 3, or 4 are deleted in in the permanently defueled condition. Shift their entirety. Additional staffing requirements for the defueled subparagraphs of TS 5.2.2 are re-condition are described above for proposed numbered accordingly.

TS 5.2.2.a.

5.2.2.c TS 5.2.2.c is being revised to replace On September 11, 2013, SCE submitted an references to 10CFR50.54(m)(2)(i) exemption request to eliminate the licensed and TS 5.2.2.a with reference to the operator requirements of 10CFR50.54(m) for new Table 5.2.2-1.

SONGS Units 2 and 3. Requirements for shift staffing will be controlled by proposed TS Table 5.2.2-1.

The 2-hour exception to the minimum staffing requirements is unchanged. This exception is consistent with current Technical Specification requirements and the Standard Technical Specifications for Combustion Engineering Plants (NUREG-1432).

5.2.2.d Existing TS 5.2.2.d requires a The requirement for a radiation protection radiation protection technician on site technician to be on site is being deleted when fuel is in the reactor. A new because this requirement only applies when requirement is added that oversight of fuel is in the reactor. Therefore it is not fuel handling operations will be applicable with the reactor in the permanently provided by a Certified Fuel Handler.

defueled condition.

Neither a radiation protection technician nor a radiation protection manager will be required to be on-shift in accordance with the proposed Technical Specifications. The Radiation Protection and Chemistry Manager is part of normal facility staff. Radiation protection technical oversight during fuel handling operations is provided by facility or supplemental RP personnel as specified in applicable RP and fuel handling procedures.

Tlte new requirement ensures that movement of irradiated fuel is only performed under the oversight of an individual who has 8 of 14

been trained and qualified on the procedures, processes, requirements and standards for safe movement of irradiated fuel.

There are no existing Technical Specifications requirements for oversight of fuel handling operations. SONGS current practice is that fuel handling operations are planned by a qualified Reactor Engineer, authorized by licensed operators, and locally supervised by a qualified Fuel Handling Supervisor. The Reactor Engineer is responsible for managing spent fuel pool configuration, planning and approving fuel movement, and directing "from" and "to" fuel locations. The Fuel Handling Supervisor is responsible for physically handling the fuel including obtaining authorization from the Control Room.

SCE intends to implement the proposed Technical Specification requirement in an analogous fashion. "Oversight" of fuel handling operations will refer to authorization to move fuel from the Shift Manager/Certified Fuel Handler. Direct, local supervision of fuel handling operations will be provided by a qualified Fuel Handling Supervisor.

The qualifications for a Fuel Handling Supervisor include completing a Job Familiarization Guide.

Licensee Controlled Specification 3.9.104 prohibits movement of heavy loads (>2000 Ibs) over spent fuel with the exception of movement of the spent fuel pool gates and test equipment skid. Movement of the spent fuel pool gates and the test equipment skid are administratively controlled as described in the UFSAR. Movement of non-fuel-related loads greater than 1500 lbs would require authorization from the control room and supervision by a qualified rigging supervisor.

5.2.2.e TS 5.2.2.e is currently listed as This is an administrative change only.

"deleted." This proposed change will eliminate TS 5.2.2.e entirely, and re-number subsequent subparagraphs accordingly.

5.2.2.f TS 5.2.2.f is being revised to replace Due to the permanent shutdown of SONGS the requirement that the Manager of Units 2 and 3, and consistent with SCE's Plant Operations, Shift Managers, September 11, 2013 exemption request from and Control Room Supervisors shall the requirements of 10CFR50.54(m), there hold a Senior Reactor Operator's will no longer be a need for operations 9 of 14

license with a requirement that the management staff to hold a Senior Reactor shift manager shall be a Certified Fuel Operator license. Replacing this with a Handler.

requirement that the shift manager shall be Certified Fuel Handler ensures that the senior individual on shift is appropriately trained and qualified, in accordance with the NRC-approved Certified Fuel Handler training program, to supervise shift activities.

5.2.2.g The requirement for a Shift Technical The existing requirement requires STA Advisor (STA) and the associated support in the areas of "thermal hydraulics, qualification requirements are deleted reactor engineering, and plant analysis with in their entirety.

regards to safe operation of the unit." Due to the permanent shutdown of SONGS Units 2 and 3, operation of the plant is no longer allowed and support in these areas is no longer needed.

Table 5.2.2-1 Proposed Table 5.2.2-1 is added to See the discussion of TS 5.2.2.a above for provide new minimum shift staffing more detail.

requirements for Certified Fuel Handlers and Certified Operators.

Section 5.3 Unit Staff Qualifications 5.3 Title The title of Section 5.3 is revised from These changes in terminology more "Unit Staff Qualifications" to "Facility appropriately reflect the current shutdown Staff Qualifications" condition of SONGS. The term "unit" is generally associated with the reactor.

5.3.1 The requirement for qualifications of This proposed change reflects the elimination the Shift Technical Advisor is deleted.

of the Shift Technical Advisor position described in TS 5.2.2.g, above.

Text related to "multi-discipline As a result of deletion of the text regarding supervisors" is deleted.

the Shift Technical Advisor, additional text related to "multi-discipline supervisors" becomes duplicative and is also being deleted.

5.3.2 (new A new requirement is added that The SONGS Certified Fuel Handler Training requirement) states: "An NRC-approved training Program was submitted for NRC review and and retraining program for the approval on August 20, 2013.

Certified Fuel Handlers shall be maintained."

The overall responsibility for the Certified Fuel Handler Training Program resides with the Operations Manager. The Operations Manager may be, but is not required to be, a Certified Fuel Handler. Training will be provided by a previously licensed or certified individual, or by a Certified Fuel Handler.

10 of 14

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements/Criteria 1 0CFR50.82(a)(1) requires that when a licensee has determined to permanently cease operations the licensee shall, within 30 days, submit a written certification to the NRC, consistent with the requirements of §50.4(b)(8), and once fuel has been permanently removed from the reactor vessel, the licensee shall submit a written certification to the NRC that meets the requirements of §50.4(b)(9). SCE submitted the required certifications by letters dated June 12, 2013 (Certification of permanent cessation of operations - Reference 6.1), June 28, 2013 (Certification of permanent removal of fuel from Unit 3 - Reference 6.2), and July 22, 2013 (Certification of permanent removal of fuel from Unit 2 - Reference 6.3).

10CFR50.36 establishes the requirements for Technical Specifications. 50.36(c)(5),

"Administrative Controls," identifies that an Administrative Controls section shall be included in the Technical Specifications and shall include provisions relating to organization and management, procedures, recordkeeping, review and audit, and reporting necessary to assure operation of the facility in a safe manner. This LAR is proposing changes to the organization and management portions of the Administrative Controls section consistent with the decommissioning status of the plant. This LAR applies the principles identified in 50.36(c)(6), "Decommissioning," for a facility which has submitted certification required by 50.82(a)(1) and proposes changes to the Administrative Controls appropriate for the SONGS Units 2 and 3 permanently defueled condition. As 50.36(c)(6) states, this type of change should be considered on a case-by-case basis.

10CFR50.54(m) establishes the requirements for having Reactor Operators and Senior Reactor Operators licensed in accordance with Part 55 based on plant conditions. By letter dated September 11, 2013, SCE requested exemption from the requirements of 10CFR50.54(m) and 10CFR55 (Reference 6.5). The proposed Technical Specifications in this LAR are consistent with and implement SCE's exemption request.

4.2 No Significant Hazards Consideration The proposed changes would replace staffing and training requirements associated with power operation with reduced requirements associated with the permanently defueled condition of San Onofre Nuclear Generating Station (SONGS) Units 2 and 3.

Specifically, licensed operators (Reactor Operators and Senior Reactor Operators) are replaced with Certified Fuel Handlers and Certified Operators. The requirement for a training program for Certified Fuel Handlers is added to the Technical Specifications. In addition, other administrative changes are made to the Organization, Staffing, and Qualifications sections of the Technical Specifications to reflect the permanently defueled condition.

11 of 14

Southern California Edison (SCE) has evaluated whether or not a significant hazards consideration is involved with the proposed amendment by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of Amendment", as discussed below:

1. Do the proposed changes involve a significant increase in the probability or consequences of an accident previously evaluated?

The proposed changes would allow SCE to replace reliance on operators licensed pursuant to 10 CFR 55 at SONGS, with certified fuel handlers and non-licensed operators, to comport to the permanently defueled condition of the station. The proposed changes have no effect on plant systems structures and components (SSCs) and no effect on the capability of any plant SSC to perform its design function. The proposed changes would not increase the likelihood of the malfunction of any plant SSC. Revised dose calculations were completed to support the changes to the Updated Final Safety Analysis Report (UFSAR)

Chapter 15 Accident Analysis, and the UFSAR was revised to reflect the new analysis. The proposed changes would have no adverse effect on any of the previously evaluated accidents in the SONGS UFSAR. Reliance on certified fuel handlers and non-licensed operators allowed under the exemption will not affect the probability of occurrence of any previously analyzed accident.

Therefore, the proposed changes do not involve a significant increase in the probability or consequences of an accident previously evaluated.

2. Do the proposed changes create the possibility of a new or different kind of accident from any accident previously evaluated?

The proposed changes do not involve a physical alteration of the plant. No new or different type of equipment will be installed and there are no physical modifications to existing equipment associated with the proposed changes.

Similarly, the proposed changes would not physically change any structures, systems or components involved in the mitigation of any accidents. Thus, no new initiators or precursors of a new or different kind of accident are created.

Furthermore, the proposed changes do not create the possibility of a new accident as a result of new failure modes associated with any equipment or personnel failures. No changes are being made to parameters within which the plant is normally operated, or in the setpoints which initiate protective or mitigative actions, and no new failure modes are being introduced.

Therefore, the proposed changes do not create the possibility of a new or different kind of accident from any previously evaluated.

12 of 14

3. Do the proposed changes involve a significant reduction in a margin of safety?

The proposed changes do not alter the design basis or any safety limits for the plant. The proposed changes do not impact station operation or any plant SSC that is relied upon for accident mitigation.

Therefore, the proposed changes do not involve a significant reduction in a margin of safety.

Based on the above, SCE concludes that the proposed changes present no significant hazards consideration, and, accordingly, a finding of "no significant hazards consideration" is justified.

4.3 Conclusions In conclusion, based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

5.0 ENVIRONMENTAL CONSIDERATION

The proposed changes meet the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(25), because the proposed exemption involves: (i) no significant hazards consideration; (ii) no significant change in the types or significant increase in the amounts of any effluent that may be released offsite; (iii) no significant increase in individual or cumulative occupational radiation exposure; (iv) no significant construction impact; (v) no significant increase in the potential for consequences from radiological accidents; and (vi) the requirements from which the exemption is sought involve surety, insurance or indemnity requirements or other requirements of an administrative nature.

Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed changes.

6.0 REFERENCES

6.1 Letter from M. Peter T. Dietrich (SCE) to Document Control Desk (USNRC),

dated June 12, 2013, Certification of Permanent Cessation of Power Operations, San Onofre Nuclear Generating Station, Units 2 and 3 (ML131640201) 13 of 14

6.2 Letter from Mr. Peter T. Dietrich (SCE) to Document Control Desk (USNRC),

dated June 28, 2013, Permanent Removal of Fuel from the Reactor Vessel, San Onofre Nuclear Generating Station, Unit 3 (ML13183A391) 6.3 Letter from Mr. Peter T. Dietrich (SCE to Document Control Desk (USNRC),

dated July 22, 2013, Permanent Removal of Fuel from the Reactor Vessel, San Onofre Nuclear Generating Station, Unit 2 (ML13204A304) 6.4 Letter from Mr. Richard J. St. Onge (SCE) to Document Control Desk (USNRC),

dated August 20, 2013), Request for Approval of the Safe Storage Shift Manager/Certified Fuel Handler Training Program, San Onofre Nuclear Generating Station, Units 2 and 3 (ML13234A024).

6.5 Letter from Mr. Richard J. St. Onge (SCE) Document Control Desk (NRC), dated September 11, 2013, Request for Exemption from Requirements of 10CFR50.54(m) and 10CFR55, San Onofre Nuclear Generating Station, Units 2 and 3 (ML13268A143) 14 of 14

Attachment A Existing Technical Specifications San Onofre Unit 2

Responsibility 5.1 5.0 ADMINISTRATIVE CONTROLS 5.1 Responsibility 5.1.1 The corporate officer with direct responsibility for the plant shall be responsible for overall unit operation and maintenance of Units 2 and 3 at San Onofre Nuclear Generating Station, and all site support functions.

He shall delegate in writing the succession to this responsibility during his absence.

5.1.2 The Shift Manager shall be responsible for the ultimate command decision authority for all unit activities and operations which affect the safety of the plant, site personnel, and/or the general public.

A management directive to this effect, signed by the corporate officer with direct responsibility for the plant shall be reissued to all site/station personnel on an annual basis.

5.1.3 The Control Room Supervisor (CRS) shall be responsible for the Control Room command function.

A management directive to this effect, signed by the corporate officer with direct responsibility for the plant, shall be issued annually to all site/station personnel.

The confines of the Control Room Area shall be defined as depicted in the Licensee Controlled Specification (LCS).

During any absence of the CRS from the Control Room Area while the Unit is in MODE 1, 2, 3, or 4, an individual with an active Senior Reactor Operator's (SRO) license shall be designated to assume the Control Room command function.

During any absence of the CRS from the Control Room Area while the Unit is in MODE 5 or 6, an individual with an active SRO license or Reactor Operator's license shall be designated to assume the Control Room command function.

SAN ONOFRE--UNIT 2 5.0-1 Amendment No.

207 1

Organization 5.2 5.0 ADMINISTRATIVE CONTROLS 5.2 Organization 5.2.1 Onsite and Offsite Organizations Onsite and offsite organizations shall be established for unit operation and corporate management, respectively.

The onsite and offsite organizations shall include the positions for activities affecting the safety of the nuclear power plant.

a.

Lines of authority, responsibility, and communication shall be established and defined for the highest management levels through intermediate levels to and including all operating organization positions.

These relationships shall be documented and updated, as appropriate, in the form of organization charts, functional descriptions of departmental responsibilities and relationships, and job descriptions for key personnel positions, or in equivalent forms of documentation.

These relationships, including the plant-specific titles of those personnel fulfilling the responsibilities for the positions delineated in these Technical Specifications, are documented in the UFSAR.

b.

The corporate officer with direct responsibility for the plant shall be responsible for overall unit safe operation and shall have control over those onsite activities necessary for safe operation and maintenance of the plant.

c.

A specified corporate officer (or officers) shall have corporate responsibility for overall plant nuclear safety and shall take any measures needed to ensure acceptable performance of the staff in operating, maintaining, and providing technical support to the plant to ensure nuclear safety.

d.

The individuals who train the operating staff and those who carry out health physics and quality assurance functions may report to the appropriate onsite manager; however, they shall have sufficient organizational freedom to ensure their independence from operating pressures.

(continued)

SAN ONOFRE--UNIT 2 5.0-2 Amendment No. 207

Organization 5.2 5.2 Organization (continued) 5.2.2 UNIT STAFF The unit staff organization shall include the following:

a.

A non-Licensed Operator shall be assigned to each reactor containing fuel and an additional non-Licensed Operator shall be assigned for each unit when a reactor is operating in MODES 1, 2, 3, or 4.

With both units shutdown or defueled, a total of three non-Licensed operators are required for the two units.

b.

At least one licensed Reactor Operator (RO) shall be in the Control Room when fuel is in the reactor.

In addition, while the unit is in MODE 1, 2, 3 or 4, at least one licensed Senior Reactor Operator (SRO) shall be in the Control Room Area.

c.

Shift crew composition may be less than the minimum requirement of 10 CFR 50.54(m)(2)(i) and 5.2.2.a for a period of time not to exceed 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months in order to accommodate unexpected absence of on-duty shift crew members provided immediate action is taken to restore the shift crew composition to within the minimum requirements.

d.

A radiation protection technician shall be on site when fuel is in the reactor.

The position may be vacant for not more than 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , in order to provide for unexpected absence, provided immediate action is taken to fill the required position.

e.

Deleted

f.

The Manager, Plant Operations (at time of appointment), Shift

Managers, and Control Room Supervisors shall hold a Senior Reactor Operator's license.

g.

The Shift Technical Advisor (STA) shall provide advisory technical support to the Shift Manager in the areas of thermal hydraulics, reactor engineering, and plant analysis with regard to the safe operation of the unit.

The STA shall have a Bachelor's Degree or equivalent in a scientific or engineering discipline with specific training in plant design and in the response and analysis of the plant for transients and accidents.

(continued)

SAN ONOFRE--UNIT 2 5.0-3 Amendment No. 221

Organization 5.2 5.2 Organization (continued)

This Page Intentionally Left Blank (continued)

SAN ONOFRE--UNIT 2 5.0-4 Amendment No. 221

Unit Staff Qualifications 5.3 5.0 ADMINISTRATIVE CONTROLS 5.3 Unit Staff Qualifications 5.3.1 Each member of the unit staff shall meet or exceed the minimum qualifications of ANSI N18.1-1971 for comparable positions, except a) the radiation protection manager who shall meet or exceed the qualifications of Regulatory Guide 1.8, September 1975, and b) multi-discipline supervisors who shall meet or exceed the qualifications listed below.

In addition, the Shift Technical Advisor shall meet the qualifications specified by the Commission Policy Statement on Engineering Expertise on Shift.

Multi-discipline supervisors shall meet or exceed the following qualifications:

a.

Education:

Minimum of a high school diploma or equivalent.

b.

Experience:

Minimum of four years of related technical experience which shall include three years power plant experience of which one year is at a nuclear plant.

c.

Training:

Complete the multi-discipline supervisor training program.

SAN ONOFRE--UNIT 2 5.0-5 Amendment No.207 I

Attachment B Existing Technical Specifications San Onofre Unit 3