ML15058A033

Response to a Request for Additional Information and Supplement 3 Amendment Applications 266 and 251 Permanently Defueled Technical Specifications

ML15058A033
Person / Time
Site:	San Onofre
Issue date:	02/25/2015
From:	Thomas J. Palmisano Southern California Edison Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
TAC MF3774, TAC MF3775
Download: ML15058A033 (9)

Text

I SOUTHERN CALIFORNIA Thomas 1. Palmisano EDISON Vice President & Chief Nuclear Officer An EDISON INTERNATIONAL Company 10 CFR 50.90 February 25, 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 3 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 Document Control Desk (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 Document Control Desk (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) Letter from T. J. Palmisano (SCE) to Document Control Desk (NRC) dated February 23, 2015;

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

4) E-mail from T. Wengert (NRC) to A. Sterdis (SCE) dated January 6, 2015;

Subject:

SONGS - Revised Draft SRXB/RASB RAI RE: Permanently Defueled Technical Specifications License Amendment Request (TAC Nos. MF3774 and MF3775) (ADAMS Accession No. ML1505OA191)

Dear Sir or Madam:

By letter dated March 21, 2014 (Reference 1), as supplemented by letters dated October 1, 2014 (Reference 2) and February 23, 2015 (Reference 3), 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-1 5 for San Onofre Nuclear Generating Station (SONGS) Units 2 and 3, respectively.

The LAR proposed to revise the Operating License and the associated Technical P.O. Box 128 San Clemente. CA 92672 (949) 368-6575 PAX 86575 Fax: (949) 368-6183 Tom.Palhnisano@sce.com

Document Control Desk February 25, 2015 Specifications (TS) to reflect the permanent cessation of reactor operation for SONGS Units 2 and 3.

By e-mail dated January 6, 2015 (Reference 4), the NRC provided a draft Request for Additional Information (RAI) regarding Reference 1. Enclosure 1 to this letter provides a response to the draft RAI. The response provided in Enclosure 1 proposes a new license condition for the SONGS 2 and 3 licenses. A draft proposed License Condition is provided as a Supplement to Reference 1 and is included in Attachments A and B to the Enclosure to this letter.

The responses provided in Enclosure 1 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 to this letter.

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 -*-:/-z3-/'2-1; <

(Date Sincerely, : Response to Request for Additional Information Attachment A: Unit 2 License Condition Markup Attachment B: Unit 3 License Condition Markup 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 REQUEST FOR ADDITIONAL INFORMATION PROPOSED PERMANENTLY DEFUELED TECHNICAL SPECIFICATIONS SAN ONOFRE UNITS 2 AND 3

Request for Additional Information In its application, the licensee does not describe what actions it will take to maintain the SFP in a safe condition, i.e., how it intends to monitor and maintain the intended function of passive, long-lived SCs (e.g., the neutron absorbing materials) in the SFP, the fire protection system, and the radiation protection system beyond the normal licensed operating period of 40 years. Accordingly, the NRC staff requests that the licensee provide the following information:

RAI-SRXB-01 Identify and list the long-lived, passive SCs (e.g., neutron absorbing materials) in the SFP, the fire protection system and the radiation protection system that are needed, pursuant to the provisions of 10 CFR 50.51 (b), to provide reasonable assurance that safe condition of the spent fuel will be monitored and maintained during the decommissioning period.

SCE Response:

As described in the Southern California Edison (SCE) response to SRXB-02 below, the current plans are to have all the spent fuel onsite stored in the Independent Spent Fuel Storage Installation (ISFSI) by the end of 2018. This date is well before the operating license for either Unit 2 or Unit 3 expires. However, SCE will develop a list of long-lived, passive Structures and Components (SCs) as noted in the RAI if unforeseen circumstances threaten to extend the period of fuel storage in the SFP beyond the current licensed period. SCE will develop the list and an associated aging-management program for those components if all of the spent fuel has not been removed from the SFP by February 16, 2021. Further information regarding this position is provided in the SCE response to SRXB-02, below.

Relative to the example provided in the NRC's RAI of neutron absorbing materials as long-lived, passive SCs, the racks in the San Onofre Nuclear Generating Station (SONGS)

SFPs do contain Boraflex, a neutron-absorbing material. However, no credit is taken in SONGS accident analyses or licensing basis for the existence of the Boraflex.

In addition, per SONGS current Technical Specifications 4.3 and 3.7.18, and Licensee Controlled Specification 4.0.100, borated stainless steel rods [Guide Tube (GT) Inserts]

may be placed in fuel assembly guide tubes for reactivity control. This feature has not been implemented. If implemented in the future, SONGS will institute a surveillance program where, at 5-year intervals, one percent of the GT-Inserts will be inspected for any material degradation. The allowance for GT-Inserts and the commitment to the associated inspection program are described in Section 2.3.3.1.2.4.2 of the Safety Evaluation for Amendments 213 and 205 for Units 2 and 3, respectively (ADAMS Accession No. ML072550175).

1

RAI-SRXB-02 Provide a summary description of actions that will be taken to monitor and maintain the performance or condition of long-lived, passive SCs, identified in the response to Request 1, to provide reasonable assurance that the long-lived, passive SCs are capable of fulfilling their intended functions during the decommissioning period.

SCE Response:

The transition to an ISFSI-only configuration is currently forecast to be completed by the end of 2018. The expiration date of the Unit 2 Operating License (that is, the end of the initial 40-year period of operation) is February 16, 2022. The expiration date of the Unit 3 Operating License is November 15, 2022. As a result, all spent fuel onsite is expected to be moved to the ISFSI approximately three years prior to the expiration of the initial 40-year period of operation for both Units 2 and 3. The SONGS ISFSI license is a general license that was issued in accordance with 10 CFR 72.

Therefore, for the Units 2 and 3 SFPs, there is no anticipated need for long-lived, passive SCs beyond the 40-year period of operation for Units 2 and 3, nor is there an anticipated need to monitor or maintain such SCs beyond the licensed 40-year period of operation.

There are approximately three years between the date that all spent fuel will be removed from the spent fuel pool and the expiration date of the current Unit 2 operating license.

Should the transition of fuel to the ISFSI be delayed by unforeseen events, it is possible but unlikely, that spent fuel could remain in the SFPs beyond the expiration of the 40-year operating period. SCE therefore proposes a license condition for SONGS Units 2 and 3.

The proposed license condition will require that by February 16, 2021, if all spent fuel has not been removed from the Units 2 and 3 SFPs, an aging management program, including a list of long-lived, passive structures and components to which the program will be applicable, will be submitted to the NRC for approval. Following approval, this program will be described in the SONGS Updated Final Safety Analysis Report, and will be maintained until such time that all spent fuel has been removed from the SFPs.

Markups of the SONGS 2 and 3 licenses containing the text of the proposed license condition are provided in Attachments A and B of this Enclosure.

2

ATTACHMENT A MARKUP OF PROPOSED LICENSE CONDITION PERMANENTLY DEFUELED TECHNICAL SPECIFICATIONS SAN ONOFRE UNIT 2

6. Training on integrated fire response strategy

7. Spent fuel pool mitigation measures (c) Actions to minimize release to include consideration of:

1. Water spray scrubbing

2. Dose to onsite responders (27) Upon implementation of Amendment No. 214 adopting TSTF-448, Revision 3, the determination of control room envelope (CRE) unfiltered air inleakage as required by SR 3.7.11.4, in accordance with TS 5.5.2.16.c(i), the assessment of CRE habitability as required by Specification 5.5.2.16.c(ii), and the measurement of CRE pressure as required by Specification 5.5.2.16.d, shall be considered met. Following implementation:

(a) The first performance of SR 3.7.11.4, in accordance with Specification 5.5.2.16.c(i), shall be within the specified frequency of 6 years, plus the 18-month allowance of SR 3.0.2, as measured from May 18, 2004, the date of the most recent successful tracer gas test, as stated in the September 17, 2004 letter response to Generic Letter 2003-01, or within the next 18 months if the time period since the most recent successful tracer gas test is greater than 6 years.

(b) The first performance of the periodic assessment of CRE habitability, Specification 5.5.2.16.c(ii), shall be within 3 years, plus the 9-month allowance of SR 3.0.2, as measured from May 18, 2004, the date of the most recent successful tracer gas test, as stated in the September 17, 2004, letter response to Generic Letter 2003-01, or within the next 9 month if the time period since the most recent successful tracer gas is greater than 3 years.

(c) The first performance of the periodic measurement of CRE pressure, Specification 5.5.2.16.d, shall be within 6 months.

(28) Prior to February 16, 2021, if all spent fuel has not been removed from the Unit 2 spent fuel pool, an aging-management program shall be submitted for NRC approval. The scope of the program shall include those long-lived, passive structures and components that are needed to provide reasonable assurance of the safe condition of the spent fuel in the spent fuel pool. Once approved, the program shall be described in the Updated Final Safety Analysis Report and shall remain in effect for Unit 2 until such time that all spent fuel has been removed from the Unit 2 spent fuel pool.

D. Exemptions to certain requirements of Appendices G, H and J to 10 CFR Part 50 are described in the Office of Nuclear Reactor Regulation's Safety Evaluation Report. These exemptions are authorized by law and will not endanger life or property or the common defense and security and are otherwise in the public interest. Therefore, these exemptions are hereby granted. The facility will operate, to the extent authorized herein, in conformity with the application, as amended, the provisions of the Act, and the regulations of the Commission.

Amendment No. XXX Revised by letter dated July 26, 2007

ATTACHMENT B MARKUP OF PROPOSED LICENSE CONDITION PERMANENTLY DEFUELED TECHNICAL SPECIFICATIONS SAN ONOFRE UNIT 3

(27) Mitigation Strategy License Condition Develop and maintain strategies for addressing large fires and explosions and that include the following key areas:

(a) Fire fighting response strate y with the following elements:

1. Pre-defined coordinated fire response strategy and guidance

2. Assessment of mutual aid fire fighting assets

3. Designated staging areas for equipment and materials

4. Command and control

5. Training of response personnel (b) Operations to mitigate fuel damage considering the following:

1. Protection and use of personnel assets

2. Communications

3. Minimizing fire spread

4. Procedures for implementing integrated fire response strategy

5. Identification of readily-available pre-staged equipment

6. Training on integrated fire response strategy

7. Spent fuel pool mitigation measures (c) Actions to minimize release to include consideration of:

1. Water spray scrubbing

2. Dose to onsite responders (28) Upon implementation of Amendment No. 206 adopting TSTF-448, Revision 3, the determination of control room envelope (CRE) unfiltered air inleakage s required by SR 3.7.11.4, in accordance with TS 5.5.2.16.c*i), the assessment of CRE habitability as required by Specification 5.5.2.16.c1ii) and the measuremenT of CRE pressure as required by Specification 5.;.2.16.d, shall be considered met.

Following imp ementation:

(a) The first performance of SR 3.7.11.4, in accordance with Specification 5.5.2.16.c(i) shall be within the specified frequency of 6 years, plus the 18-month allowance of SR 3.0.2, as measured from May 18, 2004, the date of the most recent successful tracer gas test, as stated in the September 17, 2004 letter response to Generic Letter 2003-01, or within the next 18 months if the time period since the most recent successful tracer gas test is greater than 6 years.

(b) The first performance of the periodic assessment of CRE habitability Specification 5.5.2.16.c ii) shall be within 3 ears plus the 9-month allowance of SR 3.0.2, as measured from May 18, 2004 the date of the most recent successful tracer gas test, as stated in the September 17 2004 letter response to Generic letter 2003-01, or within the next 9 months if the time Veriod since the most recent successful tracer gas is greater han 3 years.

(c) The first performance of the periodic measurement of CRE pressure, Specification 5.5.2.16.d, shall be within 6 months.

(29) Prior to February 16 2021, if all spent fuel has not been removed from the Unit 3 spent fuel pool, an aging-management program shall be submitted for NRC approval. The scope of the program shall include those long-lived, passive structures and components that are needed to provide reasonable assurance of the safe condition of the spent fuel in the spent fuel pool. Once approved, the program shall be described in the Updated Final Safet Analysis Report and shall remain in effect for Unit 3 until such Time that all spent fuel has been removed from the Unit 3 spent fuel pool.

D. Exemptions to certain requirements of Appendices G, H and J to 10 CFR Part 50 are described in the Office of Nuclear Reactor Regulation's Safety Evaluation Amendment No. XXX Revised by letter dated July 26, 2007