ML15058A030

Response to a Request for Additional Information and Supplement 2 to Amendment Applications 266 and 251 Permanently Defueled Technical Specifications

ML15058A030
Person / Time
Site:	San Onofre
Issue date:	02/23/2015
From:	Thomas J. Palmisano Southern California Edison Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
TAC MF3774, TAC MF3775
Download: ML15058A030 (20)

Text

- .I SOUTHERN CALIFORNIA Thomas I. Palmisano EDISON Vice President & Chief Nuclear Officer An EDISON INTERN4TIONAL0 Compan; 10 CFR 50.90 February 23, 2015 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555-0001

Subject:

Docket Nos. 50-361 and 50-362 Response to a Request for Additional Information and Supplement 2 to Amendment Applications 266 and 251 Permanently Defueled Technical Specifications San Onofre Nuclear Generating Station, Units 2 and 3

References:

1) Letter from T. J. Palmisano (SCE) to the U. S. Nuclear Regulatory Commission (NRC) dated March 21, 2014;

Subject:

Docket Nos. 50-361 and 50-362, Amendment Applications 266 and 251, Permanently Defueled Technical Specifications, San Onofre Nuclear Generating Station, Units 2 and 3 (ADAMS Accession No. ML14085A141)

2) Letter from T. J. Palmisano (SCE) to the NRC dated October 1, 2014;

Subject:

Docket Nos. 50-361 and 50-362, Supplement 1 to Amendment Applications 266 and 251, Permanently Defueled Technical Specifications, San Onofre Nuclear Generating Station, Units 2 and 3 (ADAMS Accession No. ML14280A264)

3) E-mail from T. Wengert (NRC) to A. Sterdis (SCE) dated December 11, 2014;

Subject:

SONGS - RAI RE: Permanently Defueled Technical Specifications License Amendment Request (TAC Nos. MF3774 and MF3775) (ADAMS Accession No. ML15033A052)

4) E-mail from T. Wengert (NRC) to A. Sterdis (SCE) dated January 23, 2015;

Subject:

SONGS - RAI RE: Permanently Defueled Technical Specifications License Amendment Request (TAC Nos.

MF3774 and MF3775) (ADAMS Accession No. ML15042A394)

Dear Sir or Madam:

By letter dated March 21, 2014 (Reference 1), as supplemented by letter dated October 1, 2014 (Reference 2), Southern California Edison (SCE) submitted a License Amendment Request (LAR), consisting of Amendment Application Nos. 266 and 251, to Facility Operating License Numbers NPF-10 and NPF-15 for San Onofre Nuclear Generating Station (SONGS) Units 2 and 3, respectively. The LAR proposed to revise the Operating License and the associated Technical Specifications (TS) to reflect the permanent cessation of reactor operation for SONGS Units 2 and 3.

P.O. Box 128

'go San Clemente, CA 92672 (949) 368-6575 PAX 86575 Fax: (949) 368-6183 Torn.Palrnisano@sce.comn

Document Control Desk By e-mails dated December 11, 2014 (Reference 3) and January 23, 2015 (Reference 4),

the NRC provided Requests for Additional Information (RAIs) regarding Reference 1.

Enclosures 1 and 2 to this letter provide responses to the RAIs. As part of the RAI response provided in Enclosure 1, SCE has agreed to relocate the requirement of Technical Specification 5.7.1.7, "Hazardous Cargo Monitoring Report," to a licensee-controlled document, rather than deleting the same requirement. This change does not result in any changes to the proposed Technical Specifications pages of Reference 1. The responses in Enclosure 2 result in changes to the proposed Technical Specifications of Reference 1. The revised proposed Technical Specification pages are provided as a Supplement to Reference 1 and are included as attachments to Enclosure 2 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 is one new regulatory commitment in the Enclosures to this letter. See Enclosure 3 for a description of the commitment.

If you have any questions or require any 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 A/,,2., 0 0,*

Sincerely, : Response to NRC Request for Additional Information SBPB-01 : Response to NRC Request for Additional Information STSB-01, -02, and -03 : List of Regulatory Commitments cc: M. L. Dapas, Regional Administrator, NRC Region IV T. J. Wengert, NRC Licensing Project Manager, SONGS Units 2 & 3 R. L. Kellar, NRC Region IV, Branch Chief, Repository Spent Fuel Safety S. Y. Hsu, California Department of Public Health, Radiologic Health Branch 2

ENCLOSURE 1 RESPONSE TO RAI SBPB-01 PROPOSED PERMANENTLY DEFUELED TECHNICAL SPECIFICATIONS SAN ONOFRE UNITS 2 AND 3

RAI-SBPB-01:

Technical Specification 5.7.1.7 requires that the shipment of hazardous materials on nearby Interstate 5 and a railroad track be monitored and the results submitted to the NRC every three years. The regulatory basis for this requirement is from Title 10 of the Code of Federal Regulations (10 CFR) 100.10, "Factors to Be Considered when Evaluating Sites."

This regulation required, in part, that the Commission consider factors such as the nature and inventory of radioactive materials contained in the facility, the safety features engineered into the facility, and the use characteristics of the site environs in determining the acceptability of the site.

Section 2.2.2.2 of the SONGS Updated Final Safety Analysis Report (UFSAR) described that the closest SONGS Units 2 and 3 safety-related structures to these transportation routes are the fuel handling buildings. This UFSAR Section also describes that the hazards considered on these transportation routes included toxic gases, asphixiants, explosives, and flammable materials.

The Section 3.2.14.2 of the Enclosure to the license amendment request states that the Hazardous Cargo Traffic Report required by TS 5.7.1.7 pertains only to an event postulated to occur in MODES 1 through 6. The NRC staff understands this statement is applicable to toxic gas and asphixiant effects on control room operators. However, the basis for the consideration of operating mode with respect to other cargo is not clear because the hazards considered include explosives, the fuel buildings are the nearest safety related structures to the transportation routes, and these structures contain a substantial inventory of spent fuel. Please clarify the basis for deletion of TS 5.7.1.7 by addressing the considerations described above that are required by 10 CFR 100.10.

SCE Response:

Upon further review, SCE agrees with the NRC that the scope of the hazards to be monitored by the Hazardous Cargo Monitoring Report is greater than toxic gas and asphyxiant gases and their effects on control room operators. As a result, there is a continuing need to monitor hazardous chemicals that are shipped in proximity to the San Onofre Nuclear Generating Station (i.e., on Interstate 5 and the railroad track).

SCE notes, however, that reporting requirements similar to the Hazardous Cargo Monitoring Report have largely been deleted from Standard Technical Specifications. For example, the reports listed in Section 5.6 of NUREG-1432, Revision 4, "Standard Technical Specifications, Combustion Engineering Plants," consist of reports that are either 1) specifically called out in Chapter 3.0 (Limiting Conditions for Operation) of the Standard Technical Specifications, such as the Post-Accident Monitoring Report or the Steam Generator Tube Inspection Report, or 2) are specifically required by regulation, such as the Annual Radiological Environmental Operating Report.

The philosophy behind removal of other reports from Chapter 5.0 of the Standard Technical Specifications is that the reports did not meet the threshold of 10 CFR 50.36(c) and would be re-located, as necessary, to licensee-controlled documents, such as a Technical Requirements Manual (TRM). SCE had previously proposed deletion of TS 5.7.1.7 as part of an Improved Technical Specifications Conversion (see ADAMS Accession No. ML11251A108) and additionally proposed a commitment (see ADAMS Page E1-1

Accession No. ML11251A112) to re-locate the requirement to licensee-controlled documents. This specific request had undergone NRC review through the RAI phase with no questions concerning the re-location when the permanent cessation of operations at San Onofre Units 2 and 3 was announced, and the request was subsequently withdrawn.

In similar fashion, SCE hereby revises its request to delete TS 5.7.1.7, "Hazardous Cargo Monitoring Report." Rather than deletion of the requirement, SCE proposes to delete the requirement from Technical Specifications and re-locate the requirement to licensee-controlled documents, and provides the following commitment:

Prior to implementation of Permanently Defueled Technical Specifications, SCE will ensure licensee-controlled documents are in place to require the continuing performance of the Hazardous Cargo Traffic Report. The report will include hazardous cargo traffic on Interstate 5 and the adjacent railway line and be submitted to the NRC regional administrator every three years.

Because the revised request still results in removal of the requirement from the Technical Specifications, there is no change to the proposed pages provided as part of SCE's original submittal. No revision to the proposed pages is necessary or provided as part of this submittal.

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ENCLOSURE 2 RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION STSB-01, -02, AND -03 PROPOSED PERMANENTLY DEFUELED TECHNICAL SPECIFICATIONS SAN ONOFRE UNITS 2 AND 3

RAI-STSB-01:

The proposed change in the BACKGROUND section of TS 1.3, "Completion Times,"

replaces the wording "operation of the unit," with "storage of irradiatedfuel" (emphasis added). The APPLICABILITY for the renumbered Limiting Condition for Operation (LCO) 3.1.3, "Spent Fuel Assembly Storage," states, "Whenever any fuel assembly is stored in the fuel storage pool" (emphasis added).

Please resolve this apparent discrepancy in wording and ensure that the Permanently Defueled Technical Specifications (PDTS) are consistent with your proposed resolution to the RAI.

SCE Response:

SCE reviewed all three LCOs being maintained (LCOs 3.1.1, 3.1.2, and 3.1.3) in the Permanently Defueled Technical Specifications (PDTS) and confirmed the Applicability for each of the three LCOs is not limited to irradiated fuel assemblies, but is for any fuel assembly. Therefore, the proposed TS 1.3 Background Section will be modified to state "storage of fuel assemblies" in lieu of the current wording of "storage of irradiated fuel."

The revised markups and clean typed pages are provided in Attachments A, B, and C to this Enclosure.

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RAI-STSB-02:

In renumbered TS 3.1.3, "Spent Fuel Assembly Storage," proposed renumbered Surveillance Requirement (SR) 3.1.3.1 states the following:

Verify by administrative means the initial enrichment, burnup, and cooling time of the fuel assembly in accordance with LCO 3.1.3 or Design Features 4.3.1.1, or LCS 4.0.100. Rev 2, dated 09/27/07.

For clarity, the NRC staff requests the licensee to define the abbreviation for Licensee Controlled Specification (LCS) in this section, since it is used for the first time in this LCO of the PDTS.

SCE Response:

SCE will define the term LCS in proposed SR 3.1.3.1. In addition, SCE noted that Unit 3 SR 3.7.18.1 (proposed SR 3.1.3.1) inadvertently referenced LCS 4.3.100, not LCS 4.0.100. This typographical error will also be corrected. The revised markups and clean typed pages are provided in Attachments A, B, and C to this Enclosure.

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RAI-STSB-03:

In renumbered TS 3.1.3, "Spent Fuel Assembly Storage," the Frequency for the renumbered SR 3.1.3.1 states the following:

Prior to moving a fuel assembly to any spent fuel pool storage location.

With the docketing of the certification for permanent removal of fuel from the reactor vessel to the spent fuel storage location, there should not be any movement of a fuel assembly into the spent fuel pool. Please explain how the specified Frequency applies to SR 3.1.3.1.

SCE Response:

Proposed LCO 3.1.3 ensures that any fuel assemblies stored in the spent fuel storage pool are within the criticality safety analysis assumptions. That is, as stated in the LCO section of the Bases, the LCO requirements ensure that keff of the spent fuel storage pool will remain < 1.00 under normal, non-accident conditions assuming the pool is flooded with unborated water and < 0.95 under normal, non-accident conditions assuming the pool is flooded with borated water with a maximum soluble boron concentration of 970 parts per million (ppm). The keff of the spent fuel pool will always remain < 0.95 under accident conditions assuming the pool to be flooded with borated water with a minimum soluble boron concentration of 1700 ppm. The purpose of TS SR 3.7.18.1 (proposed TS SR 3.1.3.1) is to ensure this requirement will be met at all times. Therefore, before moving any fuel assembly to a new location within the pool, the SR requires verification that the LCO will be met with the fuel assembly at the new location.

There is no expectation of movement of irradiated fuel into the spent fuel storage pool.

The Surveillance Frequency applies to any movement of any fuel assembly within the pool.

The Surveillance would be applicable to the initial placement of spent fuel assemblies into the pool or movement of a fuel assembly from one location to another. If fuel assemblies are never moved within the pool in the future, then there is no need to re-confirm the LCO is being met. The LCO requirements were verified before each fuel assembly was moved to its current location. Furthermore, the current Frequency for the SR is not being changed by the proposed amendment. The proposed Surveillance Frequency was previously approved by the NRC as being acceptable.

Therefore, it is SCE's position that the current and proposed Frequency for this SR is appropriate and ensures the LCO requirements are being met.

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ATTACHMENT A Replacement Pages Proposed Permanently Defueled Technical Specifications, Markup San Onofre Nuclear Generating Station (SONGS), Unit 2

Completion Times 1.3 1.0 USE AND APPLICATION 1.3 Completion Times PURPOSE The purpose of this section is to establish the Completion Time convention and to provide guidance for its use.

Istorage of fuel assembliesI BACKGROUND Limiting Condition for Operation (LCOs) specify minim m requirements for ensuring safe operation of the unit. The ACTIONS associated with an LCO state Conditions that typically describe the ways in which the requirements of the LCO can fail to be met. Specified with each stated Condition are Required Action(s) and Completion Time(s).

DESCRIPTION The Completion Time is the amount of time allowed for completing a Required Action. It is referenced to the time of discovery of a situation (e.g., inoperable equipment or variable not within limits) that requires entering an ACTIONS Condition unless otherwise specified, providing the

Piyt is in a MODE or specified condition stated in the Applicability of the LCO. Required Actions must be completed prior to the expiration of the specified Completion Time. An ACTIONS Condition remains in effect and the Required Actions apply until the Condition no longer EIt exists or th2-ie is not within the LCO Applicability.

If situations arc discovcrod that require entry into more t-han oncP Cond~ition at.# atim wi-thin a singjlc LCOG (multi4plc Cqonditi#ons, th Requirod Actions r; gash Cnd.i tio must#bo 1.

paerfor-mcd wihi#ho4 associtedCopletio Time.ý Wken-4in u.ltip.lco separate CmltoT.imes arc troc.ke.d for cach Condition starting frcm the time of discovery of ituaionthat r-equir-ed ent-ry intoG the Cniin the nb~systems, oomRpoentAs, o~r vairiables oxprocssod -inth Condition, disoo.orod to h inoperable o.r no-t w !ithFin mts, Snti esultt ip separeate entry intoditiona th unless spcoifioally st-ated., Th4e Reqjui-red- AotJins of; theCodtn ontinJ;uo to apply to each. additional failu4r-e, with; ComRplotion Tims a-sed oN initi--al entryý into theP Condition (continued)

SAN ONOFRE-UNIT 2 1.3-1 Amendment No. 127

Spent Fuel Assembly Storage

-PLAa SYSTEMS 3 Spent Fuel Assembly Storage LCO 2 The combination of initial enrichment and burnup of each SONGS 2 and 3 spent fuel assembly stored in Region I shall be within the acceptable burnup domain of Figure or

_Figure -. 7 . !-2 , or the fuel assembly shall be stored in i accorJdance with Technical Specification 4.3.1.1.

The combination of initial enrichment and burnup of each SONGS 2 and 3 spent fuel assembly stored in Region II shall be within the acceptable burnup domain of Figure 9 or

.. Figure 7.1L-4, or the fuel assembly shall be stored in --H31.3-accordance with Technical Specification 4.3.1.1.

Each SONGS 1 uranium dioxide spent fuel assembly stored in Region II shall be stored in accordance with Technical Specification 4.3.1.1.

APPLICABILITY: Whenever any fuel assembly is stored in the fuel storage pool.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Requirements of the A.I NOTE----------

LCO not met. LCO 3.0.3 is n(t applicable.

Initiate action to bring Immediately the noncomplying fuel assembly into compliance.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 9.-10.1 Verify by administrative means the initial Prior to moving a enrichment, burnup, and cooling time of the fuel assembly to fuel assembly are in accordance with LCO any spent fuel S 7 , or Design Features 4.3.1.1, or 19G pool storage 4.0100. Rev 2, dated 09/27/07. location.

Licensee Controlled Specification (LCS)

SAN ONOFRE--UNIT 2 Amendment No. 213 1

ATTACHMENT B Replacement Pages Proposed Permanently Defueled Technical Specifications, Markup San Onofre Nuclear Generating Station (SONGS), Unit 3

Completion Times 1.3 1.0 USE AND APPLICATION 1.3 Completion Times PURPOSE The purpose of this section is to establish the Completion Time convention and to provide guidance for its use.

Istorage of fuel assemblies BACKGROUND Limiting Condition for Operation (LCOs) specify minirMuMj requirements for ensuring safe operatien of the unit.z The ACTIONS associated with an LCO state Conditions that typically describe the ways in which the requirements of the LCO can fail to be met. Specified with each stated Condition are Required Action(s) and Completion Time(s).

DESCRIPTION The Completion Time is the amount of time allowed for completing a Required Action. It is referenced to the time of discovery of a situation (e.g., inoperable equipment or variable not within limits) that requires entering an ACTIONS Condition unless otherwise specified, providing the

[f> i# is in a MQE Pr- specified condition stated in the Applicability of the LCO. Required Actions must be completed prior to the expiration of the specified Completion Time. An ACTIONS Condition remains in effect and the Required Actions apply until the Condition no longer 4 4 E t exists or th7 - is not within the LCO Applicability.

If stto apro discoved tat requiroe ontry into mro ta on..e Condtio at a ti;.me within a single LCO (multiple Conditions),8) th~e Requi-red. ActionsR for each Cond4ition must b;e performed withinthe associated Completion Timo. 4 multiple Conditions, separate Co.pletion Times are tracke.d for each Condition starting from the time of discovery of the si*tuation tha r...u entry int-o t Condition Once A Con;dition; has; be)en ent#erýed, subsequent4 trains, ubsystoms* , compon.ent.s, or vari.abl.e.s exipressed in the Condition, discovered te be inoperable or not within limits,

.. i. rsut i. separate entry into the Condition, unless specifically stated. The Required Actions of the Condition ntinu......

to. apply to eaci o.al. failure, i nth Coempletioen Ti4mes basqedi on iitia entr-y into th1e Cond4itin (continued)

SAN ONOFRE--UNIT 3 1.3-1 Amendment No. 116

Spent Fuel Assembly Storage

ý 3.1313.1.

M*PLANT SYSTEMS 3-t Fuel Assembly Storage LCO 1The combination of initial enrichment and burnup of each SONGS 2 and 3 spent fuel assembly stored in Region I shall be within the acceptable burnup domain of Figure  ;.lap! or Figure - .7.9-2, or the fuel assembly shall be stored i I 131.3-2 accordance with Technical Specification 4.3.1.1.

The combination of initial enrichment and burnup of each SONGS 2 and 3 spent fuel assembly stored in Region II shall be within the acceptable burnup domain of Figure 3.; or

.. !@-4, or the fuel assembly shall be stored i .3.1.3-3 31.3-4 Figure accordaýnce with Technical Specification 4.3.1.1.

Each SONGS 1 uranium dioxide spent fuel assembly stored in Region II shall be stored in accordance with Technical Specification 4.3.1.1.

APPLICABILITY: Whenever any fuel assembly is stored in the fuel storage pool.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Requirements of the A.1 ---- NOTE-----------

LCO not met. LCO 3.0.3 is nct Initiate action to bring Immediately the noncomplying fuel assembly into compliance.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR a.7 10.I Verify by administrative means the initial Prior to moving a enrichment, burnup, and cooling time of the fuel assembly to fuel assembly are in accordance with LCO any spent fuel

@, or Design Features 4.3.1.1, or ;r-& pool storage 100. Rev 2, dated 09/27/07. location.

[0k Licensee Controlled Specification (LCS) H SAN ONOFRE--UNIT 3 Amendment No. 205

[3.1.3-1

ATTACHMENT C Replacement Pages Proposed Permanently Defueled Technical Specifications, Clean San Onofre Nuclear Generating Station (SONGS), Units 2 and 3

Completion Times 1.3 1.0 USE AND APPLICATION 1.3 Completion Times PURPOSE The purpose of this section is to establish the Completion Time convention and to provide guidance for its use.

BACKGROUND Limiting Conditions for Operation (LCOs) specify minimum requirements for ensuring safe storage of fuel assemblies. The ACTIONS associated with an LCO state Conditions that typically describe the ways in which the requirements of the LCO can fail to be met. Specified with each stated Condition are Required Action(s) and Completion Time(s).

DESCRIPTION The Completion Time is the amount of time allowed for completing a Required Action. It is referenced to the time of discovery of a situation (e.g., inoperable equipment or variable not within limits) that requires entering an ACTIONS Condition unless otherwise specified, providing the facility is in a specified condition stated in the Applicability of the LCO.

Required Actions must be completed prior to the expiration of the specified Completion Time. An ACTIONS Condition remains in effect and the Required Actions apply until the Condition no longer exists or the facility is not within the LCO Applicability.

EXAMPLE The following example illustrates the use of Completion Times.

EXAMPLE 1.3-1 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME B. Required B.1 Verify... 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> Action and associated AND Completion Time not met. B.2 Restore... 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> Condition B has two Required Actions. Each Required Action has its own separate Completion Time. Each Completion Time is referenced to the time that Condition B is entered.

The Required Actions of Condition B are to perform the verification within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> AND perform the restoration within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. A total of 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> is allowed for performing the verification and a total of 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> (not 42 hours4.861111e-4 days <br />0.0117 hours <br />6.944444e-5 weeks <br />1.5981e-5 months <br />) is allowed performing the restoration from the time that Condition B was entered. If verification is performed within 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />, the Unit 2 - Amendment XXX San Onofre - Draft 1.3-1 Unit 3 - Amendment XXX

Spent Fuel Assembly Storage 3.1.3 3.1 PLANT SYSTEMS 3.1.3 Spent Fuel Assembly Storage LCO 3.1.3 The combination of initial enrichment and burnup of each SONGS 2 and 3 spent fuel assembly stored in Region 1 shall be within the acceptable burnup domain of Figure 3.1.3-1 or Figure 3.1.3-2 or in accordance with Technical Specification 4.3.1.1.

The combination of initial enrichment and burnup of each SONGS 2 and 3 spent fuel assembly stored in Region II shall be within the acceptable burnup domain of Figure 3.1.3-3 or Figure 3.1.3-4, or in accordance with Technical Specification 4.3.1.1.

Each SONGS 1 uranium dioxide spent fuel assembly stored in Region II shall be stored in accordance with Technical Specification 4.3.1.1.

APPLICABILITY: Whenever any fuel assembly is stored in of the fuel storage pool.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Requirements of the A.1 Initiate action to bring the Immediately LCO not met. noncomplying fuel assembly into compliance.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.1.3.1 Verify by administrative means the initial Prior to moving a enrichment, burnup, and cooling time of the fuel fuel assembly to assembly are in accordance with LCO 3.1.3, or any spent fuel Design Features 4.3.1.1, or Licensee Controlled pool storage Specification (LCS) 4.0.100. Rev 2, dated 09/27/07. location Unit 2 - Amendment XXX San Onofre - Draft 3.1.3-1 Unit 3 - Amendment XXX

ENCLOSURE 3 LIST OF REGULATORY COMMITMENTS PERMANENTLY DEFUELED TECHNICAL SPECIFICATIONS SAN ONOFRE UNITS 2 AND 3

LIST OF REGULATORY COMMITMENTS No. Commitment Due Date/Event SCE will ensure licensee-controlled Prior to implementation of documents are in place to require the Permanently Defueled continuing performance of the Hazardous Technical Specifications Cargo Traffic Report. The report will include hazardous cargo traffic on Interstate 5 and the adjacent railway line and be submitted to the NRC regional administrator every three years.

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