ML14161A464

Response to Request for Additional Information and Supplement 1 to Amendment Application Numbers 265 and 250 Responsibility, Organization, and Qualifications

ML14161A464
Person / Time
Site:	San Onofre
Issue date:	06/05/2014
From:	Thomas J. Palmisano Southern California Edison Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
TAC MF2954, TAC MF2955
Download: ML14161A464 (17)

Text

SOUTHERN CALIFORNIA Thomas I. Palmisano EDISON Vice President & Chief Nuclear Officer An EDISON INTERNATIONAL Company June 5, 2014 10 CFR 50-90 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555

Subject:

Docket No. 50-361 and 50-362 Response to Request for Additional Information and Supplement I to Amendment Application Numbers 265 and 250 Responsibility, Organization, and Qualifications San Onofre Nuclear Generating Station, Units 2 and 3

Reference:

(1) Letter from P. T. Dietrich (SCE) to the U.S. Nuclear Regulatory Commission (NRC) dated October 21, 2013;

Subject:

Amendment Application Numbers 265 and 250, Responsibility, Organization, and Qualifications, San Onofre Nuclear Generating Station, Units 2 and 3 (2) Letter from M. H. Chernoff (NRC) to T. J. Palmisano (SCE) dated June 5, 2014;

Subject:

San Onofre Nuclear Generating Station, Units 2 and 3, Request for Additional Information re: License Amendment Request to Revise Technical Specifications to Reflect Reduced Staffing/Training in Permanently Shutdown and Defueled Condition (TAC Nos. MF2954 and MF2955)

Dear Sir or Madam:

By letter dated October 21, 2013 (Reference 1), Southern California Edison (SCE) submitted 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 consisted of proposed changes to Administrative Technical Specifications related to Responsibility, Organization, and Qualifications. The purpose of the proposed changes was to reflect the appropriate staffing and training requirements for the permanently defueled condition of SONGS By letter dated June 5, 2014 (Reference 2), the NRC requested additional information related to Amendment Applications 265 and 250. The response to the NRC request for additional information is contained in the Enclosure to this letter. The response results in changes to the proposed Technical Specifications of Reference 1. The revised P.O. Box 128 A San Clemente, CA 92672 (949) 36-655-b/ IPAX 86575:

Fax: (949) 368-6183 Tom. Palmisano@sce.com uLrc

Document Control Desk June 5, 2014 Technical Specification pages are provided as a Supplement to Reference 1 and are included as attachments to the Enclosure to this letter.

The changes to the proposed Technical Specifications do not affect the conclusions of the No Significant Hazards Consideration or the Environmental Consideration provided in Reference 1.

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 -, 4 Sincerely,

Enclosure:

Response to NRC Request for Additional Information cc: M. L. Dapas, Regional Administrator, NRC Region IV M. H. Chernoff, NRC Project Manager, SONGS Units 2 and 3 R. E. Lantz, NRC Region IV, San Onofre 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 Response to NRC Request for Additional Information Regarding Amendment Applications 265 and 250 Responsibility, Organization, and Qualifications San Onofre Units 2 and 3

NRC Request for Additional Information By letter dated June 5, 2014, the NRC requested additional information regarding Amendment Applications 265 and 250 for the San Onofre Nuclear Generating Station (SONGS) Units 2 and 3, respectively. Provided below are the NRC questions and the Southern California Edison (SCE) responses.

NRC Question 1:

The proposed defueled TS section 5.1.2 for SONGS Units 2 and 3 state:

"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."

The proposed defueled TS 5.1.2 states that the Shift Manager shall be responsible for the ultimate command decision authority for all unit activities and operations. However, pursuant to Title 10 of the Code of Federal Regulations (10 CFR) Section 50.82(a)(2),

the operating licenses for SONGS Units 2 and 3 no longer authorize operation of these reactors. Since the Units are not in an operating status, please provide a basis for retention of word 'operations,' in the description of Shift Manager's responsibilities.

SCE Response:

SCE agrees that the term "operations" no longer applies to San Onofre Nuclear Generating Station Units 2 and 3. The term has been deleted from proposed Technical Specification 5.1.2. See attachments for revised markup and clean page of proposed Technical Specification 5.1.2.

NRC Question 2:

SCE proposes to delete paragraph d of TS 5.2.2, which states:

"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 <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, in order to provide for unexpected absence, provided immediate action is taken to fill the required position."

SCE stated that this paragraph is being deleted because this requirement only applies when fuel is in the reactor.

The regulations in Title 10 of the Code of FederalRegulations (10 CFR) paragraph 50.36(c)(5) state that TS Administrative Controls "are the provisions relating to organization and management... necessary to assure operation of the facility in a safe Page 1

manner." The U.S. Nuclear Regulatory Commission (NRC) staff believes it is prudent to have an individual qualified in radiation protection procedures on site during fuel handling operations or during movements of loads over storage racks containing fuel.

This staff position is consistent with the proposed TSs for permanently defueled Westinghouse plants contained in draft NUREG-1625, "Proposed Standard Technical Specifications for Permanently Defueled Westinghouse Plants." This draft requires in TS 5.2.2.c that:

"c. An individual qualified in radiation protection procedures shall be on site during fuel handling operations or movement of loads over storage racks containing fuel; Please provide the Administrative Controls necessary to ensure an individual qualified in radiation protection techniques is onsite during fuel movement or movement of loads over the spent fuel storage racks.

SCE Response:

SCE will include a requirement for an individual qualified in radiation protection procedures to be on site during fuel handling operations or during movements of loads over storage racks containing fuel. The requirement has been added as proposed Technical Specification 5.2.2.e. See the attachments to this Enclosure for revised markup and clean page of proposed Technical Specification 5.2.2.

NRC Question 3:

In the proposed Table 5.2.2-1, minimum Shift Crew Composition, there is a position described as a "Certified Operator". Please describe the minimum qualifications and duties of this position.

SCE Response:

Certified operators are trained in accordance with SONGS procedure S023-XXI-TPD-CO, Certified Operator Training Program Description. This procedure states that the training program shall be in accordance with ANSI N18.1-1971 and that the systems approach to training (SAT) process will be used for initial and continuing training of certified operators. The Certified Operator Training Program Description procedure identifies entry level requirements, initial training requirements, and continuing training requirements. The certified operator is an "operator" as described in ANSI N18.1-1971 Section 3.2.4, "Operators - Technicians - Repairmen," which says that "operators" are "persons principally involved in the.. .operation of plant equipment."

Page 2

Attachment A Replacement Pages Proposed Technical Specifications, Redline and Strikeout 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 maintenamie of management of the 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 15.P. 1 affect the safety of the plant, site personnel, and/or the general public. A m..nagement dire"tive to this effect, signed by the-corporate officcr with direet responsibility for the plant shall be to Ieissued all site/station personnel an an annual basis..

The Control Room Supervisor (CRS) shall be responsible for the 5..

Control Room command function. A mnanagement directive to this effect, signed by the corporate;.. offlicer with direet responsibility for the plant, shall be. iu aniu*ally to all siteII station personn...el. The connes of t Contrl Room Area shall be defined as depicted in the Licensee Controlled Specification (LCS). During any absence of the CRS froeIthe Contr!l Room Area while the Unit isI in MODE 1, 2, 3, or 4, an individual with an active Senior Reactor Operator's (SRO) license shall be designated to assumne the Control Raoom cofmamad function. During any absencc 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. H-7_ XXX I

Organization 5.2 5.2 Organization (continued) 5.2.2 U*FT FACILITY STAFF The tft4 facility staff organization shall include the following:

a. A anoLiensed Operator shall be assigned to ea-h reactor c.ntainifgt fuel and an additional mom-Licensed Operator shall be assigned for each unit when a reactor is operating in MODES 1, 2, 3, or 4. Each on duty shift shall be composed of at least the minimum shift crew composition shown in Table 5.2.2-1.

With both units shutdown or defueled, a total of three men 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 liccnsed Senior Reactor Operator (SRO) shall be in the Control.,Room Area.

e--.b. Shift crew cormposition may be less than the minimum requirement of 10 CFR 0.54,)(),)and 5.2.2.a Table 5.2.2-1 for a period of time not to exceed 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />.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-.c. A radiation protection technician shall be on site when fuel is in the reactor. The position fmay be vacant for not more thanM "2hovur-s, in order to provide for unexpected absence, provided im....ediate action is taken to fill the required position. Oversight of fuel handling operations shall be provided by a Certified Fuel Handler.

t-7 Deleted

-f-.d. The Shift Manager, ,lant Operations (at time of appoi-,ntent), Shift Managers, and Control Room Supervisors. shall held be a Senior Reaet* r Operator's license. Certified Fuel Handler.

g--e. The Shift Technical Advisor (STA) shall provide advisory technical support to the Shift Manager in the areas of thermal hydraulics, reacto. 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 woith specific training in plant design and in the response and analysis of the plant for transients and accidents.An individual qualified in radiation protection procedures shall be on site during fuel handling operations or movement of loads over storage racks containing fuel.

(conti nued)

SAN ONOFRE--UNIT 2 5.0-3 Amendment No. 1 XXX

Attachment B Replacement Pages Proposed Technical Specifications, Redline and Strikeout San Onofre Unit 3

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 maintenane* . of management of the 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 an ... per.t.i- which affect the safety of the plant, site personnel, and/or the general public. A management directive to this effect, signed by the c.rp.rate with direct responsibility for the plant shall be "ffic.r reissued to all site/station personnel an an annual basis.

The Contral Room Supervisor (CRS) shall be responsible for the Contral Room command function. A managem nt ..

dire-tiv- to this effect, signed by the corporatc officer with direct responsibility for the plant, shall be issued annually to all site,'statio personnel. The confines of the Contral Room Area shall be defined as depicted in the Licensee Controlled Specification (LCS). During any absence of the CRS fromf the Control Room Area while the Unit is7 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 d*signated to assume the Control Room command function.

SAN ONOFRE--UNIT 3 5.0-1 Amendment No. 99 XXX I

Organization 5.2 5.2 Organization (continued) 5.2.2 U1N+/-+/- FACILITY STAFF The utt+ facility staff organization shall include the following:

a. A men Licensed Operator shall be assigned to ea.h reactor c.ntainin.g fuel and an additional non Licensed Operator shall be assigned for each unit when a reaater is operating in MODES 1, 2, 3, or 4. Each on duty shift shall be composed of at least the minimum shift crew composition shown in Table 5.2.2-1.

With both units shutdown or defueled, a total of three man Liensed operators are required for the two units.

b-. At least one licensed Reactor Operator (RO) shall be in the Control (SRO when Room shal fuel be*4in^the is Contra in the Roar *_*A reactor. in. addition.,'Ibwhile the unitotois int Area^

MODE 1, 2, 3 or 4, at least one licensu r Reactr Operator e-*,b. Shift crew composition may be less than the minimum requirement of 10 CFR 50.54(m)(2)(i) and 5.2.2.a Table 5.2.2-1 for a period of time not to exceed 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> 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.

4--c. A radiation protection technician shall be on site when fuel is in the reactor. The position mnay be vacant for not more than 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />,--

in order to provide for unexpected absence, provided iffmnediate action is taken to fill the required position. Oversight of fuel handling operations shall be provided by a Certified Fuel Handler.

e-- Deleted

-f-.d. The Shift Manager, Plant Operations (at time of appointm.ent), Shift Managers, and Control Room Supervisors. shall ho-l-d be a Senior Reac*tr Operator's license. Certified Fuel Handler.

g--e. The Shift Technical Advisor (STA) shall provide advisory technical support to the Shift Manager in the areas of thermal hydraulics, reactor -."d.- 4.img, and plant analysis with regard to the safe operation of thc unit. The STA shall have a Bachloelr's Degree or equialen in scintifc orengieering discipline with specific training in plant design and in the response and analysis ofth plant for transients and accidents.An individual qualified in radiation protection procedures shall be on site during fuel handling operations or movement of loads over storage racks containing fuel.

(conti nued)

SAN ONOFRE--UNIT 3 5.0-3 Amendment No. 2-14 XXX

Attachment C Replacement Pages Proposed Technical Specifications, Clean 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 management of the 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 which affect the safety of the plant, site personnel, and/or the general public.

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

Organization 5.2 5.2 Organization (continued) 5.2.2 FACILITY STAFF The facility staff organization shall include the following:

a. Each on duty shift shall be composed of at least the minimum shift crew composition shown in Table 5.2.2-1.

b. Shift crew composition may be less than the minimum requirement of Table 5.2.2-1 for a period of time not to exceed 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> 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.

c. Oversight of fuel handling operations shall be provided by a Certified Fuel Handler.

d. The Shift Manager shall be a Certified Fuel Handler.

e. An individual qualified in radiation protection procedures shall be on site during fuel handling operations or movement of loads over storage racks containing fuel. :1.

(continued)

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

Attachment D Replacement Pages Proposed Technical Specifications, Clean San Onofre Unit 3

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 management of the 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 which affect the safety of the plant, site personnel, and/or the general public.

SAN ONOFRE--UNIT 3 5.0-1 Amendment No.

Organization 5.2 5.2 Organization (continued) 5.2.2 FACILITY STAFF The facility staff organization shall include the following:

a. Each on duty shift shall be composed of at least the minimum shift crew composition shown in Table 5.2.2-1.

b. Shift crew composition may be less than the minimum requirement of Table 5.2.2-1 for a period of time not to exceed 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> 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.

c. Oversight of fuel handling operations shall be provided by a Certified Fuel Handler.

d. The Shift Manager shall be a Certified Fuel Handler.

e. An individual qualified in radiation protection procedures Sup.

shall be on site during fuel handling operations or movement of loads over storage racks containing fuel.

(continued)

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