ML14351A078
| ML14351A078 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 12/15/2014 |
| From: | Thomas J. Palmisano Southern California Edison Co |
| To: | Document Control Desk, Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation |
| References | |
| Download: ML14351A078 (18) | |
Text
SOUIHERN CALIFORNIA Thomas 1. Palmisano EDISON' Vice President & Chief Nuclear Officer An EDISON INTERNATIONALT, Company 10 CFR 50.12 10 CFR 50.47 December 15, 2014 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555
Subject:
Docket No. 50-206, 50-361 and 50-362; and 72-041 Redacted Version of Response to Request for Additional Information Proposed Exemptions from Certain Portions of 10 CFR 50.47 and Appendix E
References:
(1) Letter from Tom Palmisano (SCE), to the U. S. Nuclear Regulatory Commission (NRC), dated October 6, 2014,
Subject:
Response to Request for Additional Information, Proposed Exemptions from Certain Portions of 10 CFR 50.47 and Appendix E, San Onofre Nuclear Generating Station, Units 1, 2, and 3 and Independent Spent Fuel Storage Installation
Dear Sir or Madam:
By letter dated October 6, 2014 (Reference 1), Southern California Edison (SCE) provided responses to an NRC request for additional information (RAI) concerning requested exemptions from certain requirements of 10 CFR 50.47, "Emergency plans," and 10 CFR Part 50, Appendix E, "Emergency Planning and Preparedness for Production and Utilization Facilities," for San Onofre Nuclear Generating Station (SONGS) Units 1, 2 and 3, and the Independent Spent Fuel Storage Installation. The SCE responses to the RAIs were provided in Enclosures 1 and 2 to the Reference 1 letter. This submittal provides a redacted version of the RAI responses which do not contain security-related information and is suitable for public disclosure.
The attachment to Enclosure 1 contains the redacted version of the Unit 2 Spent Fuel Pool Figure. The redacted version does not contain security-related information. Enclosures 1 and 2, with the exception of the redacted version of the attachment, are the same as the versions provided in the Reference 1 letter.
There are no new regulatory commitments in this letter or the Enclosure.
P.O. Box 128 San Clemente, CA 92672 4'v1L45 (949) 368-6575 PAX 86575 Fax: (949) 368-6183 Tom.Palmisano@sce.com
Document Control Desk Should you have any questions, or require additional information, please contact Ms. Andrea Sterdis at (949) 368-9985.
I declare under penalty of perjury that the foregoing is true and correct.
Executed on ,/ 2/7,.*1 4 (Dater Sincerely,
Enclosures:
- 1. Response to NRC Request for Additional Information Regarding Emergency Planning Exemption Requests Attachment, Unit 2 Spent Fuel Pool Figure (Redacted)
- 2. Correspondence Documenting SCE Commitment to Fund Local, County and State Agencies in Accordance with California Government Code Section 8610.5 cc: M. L. Dapas, Regional Administrator, NRC Region IV T. J. Wengert, 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 1 Response to NRC Request for Additional Information (RAI) Regarding Emergency Planning Exemptions Requests San Onofre Units 1, 2 and 3 and Independent Spent Fuel Storage Installation Page 1 of 16
Note, the NRC Requests for Additional Information are provided below in italic text. The SCE responses are provided in plain text.
RAI-010 (Revision 1)
Exemption from emergency planning requirements, as requested, is dependent on the ability of the licensee to promptly mitigate the consequences of applicabledesign basis and beyond design basis accidents resulting in a loss of spent fuel pool (SFP)water inventory.
Please describe the actions SONGS would take to mitigate the consequences of an event involving a catastrophicloss of water inventory from the SFP.
In the event of a catastrophic loss of SFP water inventory, SFP normal make-up as described in UFSAR Section 9.1 would be utilized. If normal makeup is unavailable, the SONGS mitigating strategies include an internal strategy which relies on installed Fire Water Pumps and Service and Firewater Storage Tanks. In addition, there are external mitigating strategies that use portable pumps to initiate make-up flow into the pools through a seismic standpipe located near the stairway outside the Spent Fuel Building and standard fire hoses routed either over the pool's edge or to a spray monitor (spray nozzle) that directs flow from its location immediately outside the door to the SFP operating deck into the adjacent pool. The variables in this process include the water source and its motive force described in more detail in this RAI response. The SFP Normal Makeup, Internal Makeup Mitigation Strategy, External Makeup Mitigation Strategy, and External Spray Mitigation Strategy are depicted on the Unit 2 Spent Fuel Pool Figure in the Attachment to this Enclosure.
Include in the description (SCE responses follow each item identified):
0 Permanentlyinstalled equipment available to fill or spray the SFP; In addition to the SFP cooling and fill systems (UFSAR Section 9.1) there are two motor-driven Fire Water Pumps capable of delivering 1500 gpm (P221 and P222) and one diesel-driven Fire Water Pump capable of delivering 2500 gpm (P222). The Fire Water Pumps take suction from two Service and Firewater Storage Tanks. Each tank has a design capacity of 375,000 gallons.
Fire water can be used to refill the SFP by routing fire hoses from two permanently installed fire hose stations on the spent fuel pool operating deck or though the spray monitor (spray nozzle) into the SFP.
- On-site portable equipment available to fill or spray the SFP; Two engine-driven pumps are maintained as part of SONGS mitigation strategies. One skid-mounted pump (P1058) capable of delivering 500 gpm, is pre-positioned in the Protected Area (PA) near where it would be connected and placed in-service. The additional trailer-mounted pump (P1065) capable of delivering 2500 gpm, is located inside the Owner Controlled Area (OCA) but outside the PA. It can be connected from its normal location or brought into the PA and connected to available water sources and to the SFPs if warranted. Either pump can be used to feed the seismic standpipe located near the stairway outside the Spent Fuel Building.
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In addition to the permanently installed seismic standpipe, sufficient hoses, fittings, spray monitors (spray nozzles), and other equipment are available to support strategy implementation for one or both pools. The equipment is pre-deployed or stored and controlled at a location near the connection points for refill of the SFP.
- Available water sources; SONGS make-up water sources include two Service and Firewater Storage Tanks. Each tank has a design capacity of 375,000 gallons. There are three Demineralized Water Storage Tanks.
Each tank has a design capacity of 535,000 gallons.
- Written procedures to perform the mitigation strategies and how they are maintained; See the attached list of current mitigating strategy references which includes applicable procedures. Mitigating strategy procedures are maintained as quality affecting procedures under QA program requirements.
- The on-shift personnel who would perform these mitigation strategies and how they are trained; SONGS has performed an ERO On-Shift Staffing Analysis to validate the time required to implement the SFP Mitigation Strategies. The staff credited in this ERO On-Shift Staffing Analysis is limited to those required by the proposed SONGS Post Defueled Emergency Plan (PDEP) currently undergoing NRC review. Specifically, the PDEP minimum on-shift staff (Shift Manager, Certified Operator and Shift Radiation Protection Technician) is tasked with implementation of the mitigating strategy. The Shift Manager remains in the Command Center.
The Certified Operator and the Shift Radiation Protection Technician complete all in-plant mitigating actions. In addition to these credited on-shift staff positions, a second on-shift Certified Operator (not credited in the staffing analysis) is required by the proposed SONGS Permanently Defueled Technical Specifications currently undergoing NRC review and is available to assist in the implementation of the mitigating strategy tasks. The staffing analysis validates acceptable implementation without crediting the second on-shift Certified Operator.
Successful implementation of the mitigating strategy does not require mobilization of off-site resources.
Current SONGS staff that will implement mitigating strategies have been trained to perform the tasks. Newly assigned staff will be trained prior to being assigned these new tasks. Training includes initial and periodic requalification training. Training is conducted in accordance with the following procedures:
!, S023-XXI-TPD-CO, "Certified Operator Training Program Description"
) S023-XXI-TPD-SMCFH, "Shift Manager/Certified Fuel Handler Training Program Description" Page 3 of 16
- How the equipment used in the mitigatingstrategiesare stored, maintainedand tested; Excluding pump P1065, mitigating strategy equipment is stored in controlled locations (cargo containers for each unit) in the PA. The equipment is tested in accordance with plant procedures including:
S023-XV-4.67, "Surveillance Requirement Seismic Trailer and Pump Inspection" requires monthly pump test and annual comprehensive flow test for P1065.
S023-XIII-73, "Skid Mounted Pump Test" requires monthly pump test and annual comprehensive flow test for P1058.
S0123-XIII-44, "Surveillance Requirement- Hydrostatic Fire Hose Test" requires annual hydrostatic hose testing.
S0123-XIII-54 "Surveillance Requirement Fire Equipment Inspection" requires monthly inspection of equipment and appliances associated with Mitigating Strategies.
Any required maintenance would be controlled under standard plant processes.
Approximate times it would take to deliver, setup, and startdelivering makeup/spray to the SFP using portable equipment; and An ERO On-Shift Staffing Analysis focused solely on SFP Mitigation Strategies was performed.
The analyses included a detailed table-top task review and analysis, a time-motion study and a field walk-down. The on-site portable equipment described in the preceding responses was used in these analyses. The analyses conservatively estimate the time required to deliver flow to one pool at approximately 55 minutes with an additional 35 minutes to provide water to the second pool. Water is supplied to both pools within a total of 90 minutes.
- How makeup/spray could be delivered to the SFP in the event that radiationlevels at the SFP prohibitedentry to the area.
The SONGS SFP external make-up strategy requires limited access to hose stations on the spent fuel operating deck to drop the hose end into the pool and initiate flow locally. Actual dose rates on the spent fuel pool operating decks are not expected to increase above 20 mrem/hr until the SFP water reaches a level of less than10 feet above the stored fuel.
The external spray/refill strategy requires opening a door to the spent fuel operating deck area to initiate flow from the spray monitors (spray nozzles) or to verify coverage but does not require access to the operating deck if dose rates are prohibitively high.
PDEP RAI-013 Please describe the actions SONGS could take to mitigate the consequences of an event involving a catastrophicloss of water inventory concurrently from both Units 2 and 3 SFPs.
Include in the description:
Page 4 of 16
The information provided in the responses to RAI-010 above is applicable for a catastrophic loss of water inventory from a single pool or a catastrophic loss of water inventory concurrently from both pools. Clarifications applicable to a concurrent loss of inventory from both pools are provided below.
- On-site portable equipment available to fill or spray both of the SFPs; There are two portable pumps available (P1058 and P1065). As described above, Pump P1058 is pre-staged in the PA while Pump P1065 is trailer-mounted and located outside the PA. Pump P1058 can supply significant flow (-500 gpm total; split as warranted) to both pools simultaneously. Pump P1065 can supply 2500 gpm which can also be split as warranted.
0 Availability of on-shift personnel who would perform these mitigation strategies; SONGS has performed an ERO On-Shift Staffing Analysis to validate the time required to implement the SFP Mitigation Strategies. The staff credited in this ERO On-Shift Staffing Analysis is limited to those required by the proposed SONGS Post Defueled Emergency Plan (PDEP) currently undergoing NRC review. Specifically, the PDEP minimum on-shift staff (Shift Manager, Certified Operator and Shift Radiation Protection Technician) is tasked with implementation of the mitigating strategy. The Shift Manager remains in the Command Center.
The Certified Operator and the Shift Radiation Protection Technician complete all in-plant mitigating actions. In addition to these credited on-shift staff positions, a second on-shift Certified Operator (not credited in the staffing analysis) is required by the proposed SONGS Permanently Defueled Technical Specifications currently undergoing NRC review and is available to assist in the implementation of the mitigating strategy tasks. The staffing analysis validates acceptable implementation without crediting the second on-shift Certified Operator.
The successful implementation of mitigating strategies does not require utilization of other potential SONGS on-shift personnel resources or the mobilization of off-site personnel or equipment.
How the equipment would be deployed during this type of event; and In the two-pool case, pump P1 058 would be initially aligned to both SFPs through available cross-tie lines. Otherwise deployment is the same as for a single pool. If the flow from a single pump is insufficient to refill both pools (SFP leakage exceeds pump flow) the pump P1065 could be relocated into the PA and put in-service, or could be put in-service from its normal location via additional hose lengths depending on site circumstances.
- Approximate times it would take to deliver, set-up and start delivering makeup/spray to both of the SFPs using portable equipment.
As described above it would take approximately 90 minutes to initiate flow to both SFPs without relocating pump P1065. Relocation of the pump P1065, if required, takes approximately 30 additional minutes.
Page 5 of 16
- In addition, if using a series style of deployment of makeup! to the SFPs, what would be the impact of changing radiationlevels at the SFP due to a delay in deployment on entry to the areas and how would those impacts be managed.
As noted in the response to RAI-010, SFP operating deck dose levels do not reach prohibitively high radiation levels until the pools are substantially drained. Even when the SFP water level is reduced to 10 feet above the spent fuel, the calculated dose rate is 20 mrem/hr or less.
Therefore, makeup strategies that require access to the SFP operating deck are expected to be utilized for most events.
If high radiation levels do prevent operating deck access, there is an existing spray/refill strategy that does not require SFP operating deck access to provide water to one or both SFPs. The difference in strategies simply involves different methods of discharging the water into the SFP once the fire system is pressurized by the portable engine-driven pump(s) (P1058 and P1065).
When operating deck access is not available, a spray monitor (spray nozzle) connected to the fire system outside the SFP operating deck, is placed in the open doorway to the SFP. Water is then sprayed over the operating deck and into the SFP.
If makeup to both SFPs is necessary, the preliminary steps of hooking up the portable engine-driven fire pump(s) (P1058 and P1065) to the existing Fire Protection System to pressurize the Main Fire Loop need not be re-performed to provide makeup to the second pool. Initiating makeup to the second SFP consists of hooking up a second spray monitor (spray nozzle) in the second SFP doorway and initiating flow to that SFP. The time to initiate makeup to the second SFP following initiation of flow to the first SFP is approximately 35 minutes (i.e., a total of approximately 90 minutes for both SFPs); therefore there is no appreciable delay between initiation of makeup to the first SFP relative to the second SFP. Therefore, there is a minimal impact on achieving successful implementation for both pools.
RAI-014 The response to the RAI provided in Enclosure I to the letterdated September 9, 2014, provided a summary of a calculation to evaluate air cooling of spent fuel in SONGS Unit 2 and Unit 3 spent fuel pools in lieu of the results to a seismic checklist. The NRC staff found that the summary information was not sufficiently clearfor the staff to complete its technical review.
Please provide clarifying information for the following:
Use of guidance from NUREG-0800 ASB 9-2 to determine spent fuel pool heat generation rate: The guidance from NUREG-0800 ASB 9-2 was intended to evaluate accidentdecay heat rates close to the time of reactorshutdown and contains few representativedecay heat groups for the fission and activation products present 31 months following shutdown. Justify the use of this guidance in the air cooling calculation or reference alternatedecay heat models.
The use of ASB 9-2 is part of the SONGS current design and licensing basis for equivalent applications (bulk pool heat-up) and has been validated against a SONGS Unit 2 Spent Fuel Pool (SFP) heat load measurement performed in 2011. For that measurement, the most recent Page 6 of 16
refueling load (109 fuel assemblies) was cooled for about 24 months. The measured SFP heat load was 2.4 MBTU/hr. The calculated heat load based on ASB 9-2 was 2.27 MBTU/hr (about 5.5% lower than measured). Based on the comparison, a conservative multiplier of 1.10 was developed for applying to SFP decay heat calculation using ASB 9-2. For the SFP air cooling calculation, the calculated SFP heat load based on ASB 9-2, after applying a 10% multiplier is 2.77 MBTU/hr. This SFP heat load value was used in a GOTHIC computer code simulation to obtain boundary condition input (air temperature) for COBRA-SFS calculation only. Fuel assembly decay heat rates for the COBRA-SFS model were obtained from ORIGEN-ARP/ORIGEN-S calculations.
- Considerationof fuel handling building ventilation subsystem: Clarify the operatingstate of the ventilation system used in the GOTHIC analysis. Providejustification for the selected operatingstate considering the seismic hazardpresent at the SONGS site.
The calculation assumes the Fuel Handling Building Ventilation System is in its normal operating state (in operation). The design basis of the system is Seismic Category Il/I so it is unlikely to fail due to the most likely event to cause of loss of inventory. The purpose of the SONGS air cooling calculation is to provide SONGS specific results for the air cooling scenario discussed in NUREG-1738, "Technical Study of Spent Fuel Pool Accident Risk at Decommissioning Nuclear Power Plants". The air-cooled analysis, along with SONGS adiabatic heat-up results support a favorable conclusion that there is sufficient time to initiate mitigating actions consistent with plant conditions. The analytical results show that there is sufficient time for offsite authorities to take protective actions in the highly unlikely event such actions are necessary.
The COBRA model considered one assembly from the Cycle 16 discharge and two assemblies from earlierdischarges on two faces, with no heat transferfrom these three assemblies to adjacent assembliesor structures: Clarify the power history for the fuel assemblies and the heat generationmodel used to determine the representativedecay heat rates cited in the list of inputs. Providejustification for the configuration as a realisticor conservative representationof the most limiting actual fuel storage pattern.
The spent fuel storage configuration model utilized is more conservative that the most limiting actual fuel storage pattern in the SONGS SFPs.
Assembly heat rates for the COBRA model were generated using the ORIGEN-ARP/ORIGEN-S modules within the SCALE 6 computer code package. Input parameters to ORIGEN-ARP/ORIGEN-S include: fuel type, initial uranium mass, initial U-235 enrichment, fuel assembly burn-up, specific power, light element weights, and cooling time. A flat power history consistent with core average power density was used in the ORIGEN-S input. This approach is conservative since the assembly power density for high decay heat assemblies is lower than core average. Additional details and sample input are provided in SCE response to (MF3835)
RAI-012 (Reference 2, Enclosure 1, Attachment B).
This analysis uses a three assembly model to simulate heat transfer from one assembly to adjacent assemblies. Per the spent fuel pool maps, the most recently offloaded assemblies Page 7 of 16
(Cycle 16) are typically arranged so there are only a few Cycle 16 assemblies that are not adjacent to two assemblies that are Cycle 13 or older (also referred to as "cooler") assemblies.
The Cycle 16 assemblies not adjacent to two cooler assemblies were identified based on the SFP maps. These assemblies (e.g. S2S555 and S3S553) have a heat rate of at least 17%
lower than the maximum heat rate assembly (S2RO13). Since the results of this analysis show that the heat transferred from the maximum heat rate assembly to adjacent assemblies is roughly 17%, the three assembly model with the limiting assembly adjacent to two assemblies from earlier discharges remain bounding. For this analysis three assemblies are modeled: the worst case Cycle 16 assembly is between two limiting Cycle 13 assemblies (i.e., those with the highest heat rate). This bounding condition is illustrated in Figure RAI-14-1.
This method is conservative for two key reasons. First, it assumes that there is no heat transfer to the other two adjacent assemblies. This is equivalent to modeling the other two adjacent assemblies as also being bounding Cycle 16 assemblies. Second, it assumes that the third and fourth highest heat generation assemblies touching the bounding Cycle 16 assembly are both the worst case Cycle 13 heat assemblies. In reality the fourth adjacent assembly would have an even lower heat rate resulting in more heat transfer from the central Cycle 16 assembly.
Page 8 of 16
Figure RAI-014-1 Configuration modeled in COBRA Note: Only the middle Cycle 16 assembly and the two Cycle 13 assemblies are modeled. The diagonal lines represent the boundary of the COBRA model and are assumed to be adiabatic.
Page 9 of 16
RAI-01 5 Forcomparison purposes, please provide the numeric result of the adiabaticheatup time analysis based on the same decay heat information used in the air cooling analysis (i.e., specific time to reach 900 degrees Celsius based on decay heat on August 31, 2014).
The adiabatic heat-up calculation models the bounding (highest heat rate) assembly in the Spent Fuel Pool. Heat rate for the bounding assembly was calculated using ORIGEN-ARP/ORIGEN-S modules within the SCALE 6 computer code package. Details of the case input have been provided in SCE response to (MF3835) RAI-012 (Reference 2, Attachment B).
Heat-up time for July 25, 2013 was 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br />. Based on the heat rate on August 31, 2014, the heat-up time to reach 900 degrees Celsius is greater than 17 hours1.967593e-4 days <br />0.00472 hours <br />2.810847e-5 weeks <br />6.4685e-6 months <br />.
The Table below provides heat-up times for a number of adiabatic cases at two temperatures of interest taken from various NRC sources.
TABLE RAI-015-1 DATE Decay Time Heat-up Time to Heat-up Time to (months) 5650C (hours)1 9000 C (hours)2 June 12, 2013 17 5.6 9.4 October 12, 2013 21 6.8 11.3 February 12, 2014 25 8.0 13.4 June 12, 2014 29 9.3 15.5 October 12, 2014 33 10.7 17.8 February 12, 2015 37 12.0 20.0 June 12, 2015 41 13.4 22.3 December 12, 2015 47 15.4 25.6 June 12, 2016 53 17.3 28.7 December 12, 2016 59 19.0 31.6 Note 1 565 0C was selected to reflect time to incipient fuel damage (clad swelling and/or creep rupture) and possible release (NUREG/CR6451 and SECY 99-168)
Note 2 9000C was selected based on NRC guidance to determine time to self-sustaining zirconium oxidation (NUREG-1738)
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MITGATION STRATEGY REFERENCES Procedures
) S023-V-5.100, SONGS B.5.b Mitigation Strategies
> SO123-XIII-54, Surveillance Requirement Fire Equipment Inspection
> S023-3-2.11, Spent Fuel Pool Operations
> S023-3-2.11.1, SFP Level Change and Purification Crosstie Operations
> S023-13-20, Fuel Handling Accidents or Loss of SFP Level Control
> S023-13-21, Fire
- S023-13-23, Loss Of Spent Fuel Pool Cooling S023-13-25, Operator Actions During Security Events Guidelines
- SOG-TR-0029, Blitzfire Monitor
> SOG-TR-0032, Seismic Trailer Pump (SA2301MP1 065) Operations
)ý SOG-AD-0023, Fire Department SOG Revisions -EP B.5.b Mitigating Strategies Books
> SOG-EO-0001, Firewater to Plant Systems -Spent Fuel Pool (SFP) Makeup (Internal /
External) and Spent Fuel Pool (SFP) Spray -External Strategies
> SOG-EO-0003, Water Spray Scrubbing -Fog Stream Applications
> SOG-EO-0004, Casualty Collection Centers
> SOG-EO-0009, SOFD Response to Large-Scale Accelerant Fed Fire Event in Protected Area System Descriptions o- SD- S023-430, Fuel Handling and Refueling System
> SD- S023-590, Fire Protection System Page 11 of 16
SECURITY RELATED INFORMATION WITHHOLD UNDER 10 CFR 2.390 ENCLOSURE 1 ATTACHMENT Figure UNIT 2 SPENT FUEL POOL Page 12 of 16
CECtI IDITV DCI ATCrfl IRICnORfA ATIfnl iAIITUUnCU- flAIRWCD In1 fC:0 ) :)nn UNIT 2 SPENT FUEL POOL Page 13 of 16
ENCLOSURE2 Correspondence Documenting SCE Commitment to Fund Local, County and State Agencies in Accordance with California Government Code Section 8610.5
- 1. May 7, 2014 Letter from the Jeremy Kirchner, Chairman, Interjurisdictional Planning Committee (IPC) to SCE
- 2. June 3, 2014 Letter from J. Chris Thompson, Vice President, Decommissioning, SCE to the IPC Page 14 of 16
[Interjurisdictional Planning Committee County of Orange-County of San Diego-City of San Clernente.City of San Juan Capistrano City of Dana Point.California State Parks.U. S. Marine Corps-Southern California Edison May 7, 2014 Tom Palmisano Vice President/Chief Nuclear Officer San Onofre Nuclear Generating Station Southern California Edison P.O. Box 128 San Clemente CA 92674-0128
Dear Mr. PaLmisano:
I am writing on behalf of the Lnterju.risdictional Planning Committee and the emergency managers who plan and prepare for the offsite response to an emergency at the San Onofre Nuclear Generating Station.
As you know, Southern California Edison provides reimbursement for SONGS-related preparedness activities to several local, county, and state agencies. With the plant now starting the decommissioning process, there have been questions regarding future offsite nuclear preparedness activities, and the reimbursement available to support them.
Earlier this year, we were informed of SCE's plans to conthiue reimbursing SONGS-related offsite activities according to current arrangements, based on the nuclear power plant funding provisions of California Government Code section 8610.5 until that section expires in July, 2019. The IPC appreciates your support of the activities we perform to protect the health and safety of the public.
Because the budgeting process for the plannting, response, and support activities these agencies undertake related to SONGS is started well in advance of each fiscal year, the IPC agencies are looking for documented assurance of that funding arrangement, which can be used to support our budget requests.
Therefore, on behalf of the [PC, I am requesting verification of your funding commitment in writing. This will provide the IPC agencies with the confirmation we need to support our nuclear preparedness programs, and will help to prevent any misunderstanding as decommissioning activities continue over the next few years.
I look forward to continuing our work together to ensure the safety of the local population. If you have any questions, or if I can clarify anything for you, please feel free to contact me.
Sincerely, jbnreyK~ircner Comite jhair, Interjurisdictional Planning Committee Page 15 of 16
Aj SOUTHERN CALIFORNIA 1.Christopher Thompson EDISON Vice President Deconmissioning An EDISON INTERNATIONALO Company June 3, 2014 Mr. Jeremy Kirchner Chair, Interjurlsdlctional Planning Committee City of Dana Point, Emergency Services Division 33282 Golden Lantern Dana Point, CA 92629-1805
Dear Mr. Kirchner:
Thank you for your letter dated May 7, 2014 regarding funding under California Government Code Section 8610.5 for local, county, and state agencies for emergency preparedness activities. We appreciate the long-standing collaborative relationship that Southern California Edison (SCE) has enjoyed with the lnterjurisdictional Planning Committee (IPC) and look forward to a continued cooperative relationship to protect the health and safety of the public. We want to assure you and the IPC that we Intend to fully comply with the requirements set forth in Section 8610.5 and provide continued funding for emergency preparedness. We will not seek changes to funding levels without prior consultation with the IPC.
Again, I want to emphasize how much we appreciate the long-standing collaborative relationship SCE has had with the IPC. We look forward to continuing to work together to protect the health and safety of our local communities.
Kind regards, 9.4ý P.O. Box 800 2244 WMInut Grove Ave Ro..enmead, CA 91770 626-302- 1363 Fax 626-302-9213 Page 16 of 16