ML13240A125

Request for Relaxation of Commission Orders EA-12-049 and EA-12-051

ML13240A125
Person / Time
Site:	San Onofre
Issue date:	08/26/2013
From:	Peter Dietrich Southern California Edison Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-12-049, EA-12-051
Download: ML13240A125 (3)

Text

SOUTHERN CALIFORNIA Peter T. Dietrich.j EDISON Senior Vice President

& Chief Nuclear Officer An EDISON INTERNATIONAL Company SECURITY RELATED INFORMATION Withhold From Public Disclosure In Accordance With 10 CFR 2.390(d)(1) 10 CFR 2.202 10 CFR 2.390(d)(1)

August 26, 2013 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-001

SUBJECT:

Docket Nos. 50-361 and 50-362 License Nos. NPF-10 and NPF-15 Request for Relaxation of Commission Order Number EA-12-049 Request for Relaxation of Commission Order Number EA-12-051 And First 6 Month Status Report on Implementation of EA-12-049 and EA-12-051 San Onofre Nuclear Generating Station, Units 2 and 3

References:

1. NRC Order Number EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events dated March 12, 2012. [ADAMS Accession Number ML12054A735]

2. NRC Order Number EA-12-051, Order Modifying Licenses with Regard to Requirements for Reliable Spent Fuel Pool Instrumentation dated March 12, 2012 [ADAMS Accession Number ML12054A679]

3. Southern California Edison (SCE) letter to NRC, SCE's Overall Integrated Plan in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (EA-12-049), dated February 27, 2013 [ADAMS Accession Number ML13066A036]

4. SCE letter to NRC, SCE's Overall Integrated Plan in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Reliable Spent Fuel Pool Instrumentation (Order EA-12-051), dated February 27, 2013 [ADAMS Accession Number ML13064A353]

5. SCE letter to NRC, Permanent Cessation of Operations dated June 12, 2013 [ADAMS Accession Number ML131640201]

6. SCE letter to NRC, Permanent Removal of Fuel from the Reactor Vessel, SONGS Unit 3, dated June 28, 2013 [ADAMS Accession Number ML13183A391]

7. SCE letter to NRC, Permanent Removal of Fuel from the Reactor Vessel, SONGS Unit 2, dated July 23, 2013 [ADAMS Accession Number ML13204A304]

8. NEI 12-02, Revision 1, Industry Guidance for Compliance with NRC Order EA-12-051, "To Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation" SECURITY RELATED INFORMATION Withhold From Public Disclosure In Accordance With 10 CFR 2.390(d)(1)

P.O. Box 128 Decontrolled when separated from Enclosure San Clemente, CA 92672 1 (949) 368-6255 PAX 86255 Fax: (949) 368-6183 Pete.Dietrich@sce.com SECURITY RELATED INFORMATION Withhold From Public Disclosure In Accordance With 10 CFR 2.390(d)(1)

Document Control Desk August 26, 2013 9. JLD-ISG-2012-03, Revision 0, NRC Interim Staff Guidance for Compliance with Order EA-12-051 Reliable Spent Fuel Pool Instrumentation

Dear Sir or Madam:

On March 12, 2012, the Nuclear Regulatory Commission (NRC) issued Reference 1 and Reference 2 to Southern California Edison (SCE). Reference 1 was immediately effective and directed SCE to develop, implement, and maintain guidance and strategies to maintain or restore core cooling, containment, and spent fuel pool (SFP) cooling capabilities in the event of a beyond-design-basis external event.Reference 2 was immediately effective and directed SCE to provide reliable SFP level indications.

Implementation of both orders was required to be completed no later than two (2) refueling cycles after submittal of the respective overall integrated plan, or December 31, 2016, whichever comes first.On February 27, 2013, SCE submitted the overall integrated plans for implementation of Orders EA-12-049 and EA-12-051 (References 3 and 4, respectively).

Subsequently, SCE certified to the NRC that it had permanently ceased operations at San Onofre Nuclear Generating Station (SONGS) Units 2 and 3 (Reference

5) and that it had permanently removed the fuel from the SONGS Unit 3 reactor vessel (Reference

6) and SONGS Unit 2 reactor vessel (Reference 7).In light of the permanently defueled status of SONGS Units 2 and 3, SCE hereby requests relaxation of the requirements in Orders EA-12-049 and EA-12-051.

With respect to the requirements of Order EA-12-049, SCE requests relaxation of the requirements of Reference 1 Attachment 2 for guidance and strategies to maintain or restore core cooling and containment at SONGS. SCE is not seeking relaxation of the requirements for SFP strategies.

The basis for this request is as follows: Guidance and strategies to maintain or restore core cooling and containment are no longer necessary at SONGS because the nuclear fuel has been permanently removed from the SONGS Units 2 and 3 reactor vessels and containments.

All nuclear fuel at SONGS is in the Units 2 and 3 SFPs or the Independent Spent Fuel Storage Installation (ISFSI).With respect to the requirements of Order EA-12-051, SCE requests full relaxation of the requirements of Reference 2 for SFP level instrumentation at SONGS. The basis for this request is as follows: Implementation of the requirements of Reference 2 Attachment 2 is no longer necessary at SONGS because of the decay time of the irradiated fuel in the SONGS Units 2 and 3 SFPs that will be achieved by December 31, 2016, together with implementation of alternative level indication as part of SCE's response to Order EA-12-049.

Section 2.3 of the applicable industry guidance for SFP level instrumentation (Reference 8, which was endorsed by Reference 9), states that for implementation of the order, a SFP "is a water filled structure housing storage racks that contain irradiated fuel discharged from the reactor vessel that has been used for power generation within the last five years". The nuclear fuel most recently discharged from the SONGS Units 2 and 3 reactor vessels will have reached five years of decay time shortly after December 31, 2016 (in early and late January 2017, respectively).

The decay heat load at this time will be less than 5% of the design basis heat load for the SFPs.SECURITY RELATED INFORMATION Withhold From Public Disclosure In Accordance With 10 CFR 2.390(d)(1)

Decontrolled when separated from Enclosure SECURITY RELATED INFORMATION Withhold From Public Disclosure In Accordance With 10 CFR 2.390(d)(1)

Document Control Desk August 26, 2013 In addition, as described in the Enclosure to this letter, SCE currently plans to install mechanical level (pressure) gages on the SFP cooling pump suction piping as part of the response to Order EA-12-049.

These mechanical level gages will provide remote monitoring capability for SFP level in support of the SFP cooling strategies.

The gages will be seismically mounted in the Fuel Handling Buildings, plant elevation 30 ft, which are protected from the design basis external events applicable to the site, and separated by 2 building floors from the SFP operating deck areas to ensure continued accessibility should the respective SFP operating deck area itself become inaccessible due to steam or radiation.

A spare (uninstalled) gage will be provided as a backup. The gages will have a range which is functionally adequate to determine when makeup water must be added to the SFPs to restore or maintain normal water level, and when makeup flow must be stopped to prevent overflow (i.e., from the level at the bottom of the suction connection on the side of the pool to the overflow level).Measurement of SFP water level below the bottom of the suction connection is not needed in the defueled condition, for two reasons: (1) reactor and containment strategies would not be implemented and hence SFP makeup would not be deferred; and (2) pre-deployment and use of the SFP spray strategy ensures that the spent fuel would remain cooled irrespective of the water level in the pool.The first 6 month status update in accordance with Reference 1 Section IV.C.2 and Reference 2 Section IV.C.2 is enclosed.

The update consists of Revision 1 to the Overall Integrated Plan for implementation of Order EA-12-049, including the alternate SFP level indication discussed above.The Enclosure contains Security Related Information.

SCE requests that the Enclosure be withheld from public disclosure in accordance with 10 CFR 2.390(d)(1).

A version of this letter edited for public disclosure was signed and submitted to the NRC on this date.This letter contains no new regulatory commitments.

If there are any questions regarding this plan, please contact Mr. Steven D. Root at 949-368-6480.

I declare under penalty of perjury that the foregoing is true and correct.Executed on 7..I,

Enclosure:

SONGS Overall Integrated Plan in Response to NRC Orders EA-12-049 and EA-12-051 cc: Director, Office of Nuclear Reactor Regulation S. A. Reynolds, Regional Administrator, NRC Region IV G. G. Warnick, NRC Senior Resident Inspector, San Onofre Units 2 and 3 R. Hall, NRC Project Manager, San Onofre Units 2 and 3 B. Benney, NRC Project Manager, San Onofre Units 2 and 3 SECURITY RELATED INFORMATION Withhold From Public Disclosure In Accordance With 10 CFR 2.390(d)(1)

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