ML14161A464

San Onofre, Units 2 and 3, 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:	Palmisano T J Southern California Edison Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
TAC MF2954, TAC MF2955
Download: ML14161A464 (17)

Text

SOUTHERN CALIFORNIAEDISONAn EDISON INTERNATIONAL CompanyThomas I. PalmisanoVice President & Chief Nuclear OfficerJune 5, 201410 CFR 50-90U. S. Nuclear Regulatory CommissionATTN: Document Control DeskWashington, D.C. 20555Subject:Reference:Docket No. 50-361 and 50-362Response to Request for Additional Informationand Supplement I to Amendment Application Numbers 265 and 250Responsibility, Organization, and QualificationsSan Onofre Nuclear Generating Station, Units 2 and 3(1) Letter from P. T. Dietrich (SCE) to the U.S. Nuclear RegulatoryCommission (NRC) dated October 21, 2013; Subject: AmendmentApplication Numbers 265 and 250, Responsibility, Organization, andQualifications, San Onofre Nuclear Generating Station, Units 2 and 3(2) Letter from M. H. Chernoff (NRC) to T. J. Palmisano (SCE) datedJune 5, 2014; Subject: San Onofre Nuclear Generating Station, Units2 and 3, Request for Additional Information re: License AmendmentRequest to Revise Technical Specifications to Reflect ReducedStaffing/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-10and NPF-15 for San Onofre Nuclear Generating Station (SONGS) Units 2 and 3,respectively. Amendment Applications 265 and 250 consisted of proposed changes toAdministrative Technical Specifications related to Responsibility, Organization, andQualifications. The purpose of the proposed changes was to reflect the appropriatestaffing and training requirements for the permanently defueled condition of SONGSBy letter dated June 5, 2014 (Reference 2), the NRC requested additional informationrelated to Amendment Applications 265 and 250. The response to the NRC request foradditional information is contained in the Enclosure to this letter. The response resultsin changes to the proposed Technical Specifications of Reference 1. The revisedP.O. Box 128 ASan Clemente, CA 92672(949) 36-655-b/ IPAX 86575:Fax: (949) 368-6183Tom. Palmisano@sce.comu Lrc Document Control Desk-2-June 5, 2014Technical Specification pages are provided as a Supplement to Reference 1 and areincluded as attachments to the Enclosure to this letter.The changes to the proposed Technical Specifications do not affect the conclusions ofthe No Significant Hazards Consideration or the Environmental Consideration providedin Reference 1.There are no new regulatory commitments in this letter or the Enclosure.Should you have any questions, or require additional information, please contactMr. Mark Morgan at (949) 368-6745.I declare under penalty of perjury that the foregoing is true and correct.Executed on -, 4Sincerely,Enclosure:Response to NRC Request for Additional Informationcc: M. L. Dapas, Regional Administrator, NRC Region IVM. H. Chernoff, NRC Project Manager, SONGS Units 2 and 3R. E. Lantz, NRC Region IV, San Onofre Units 2 and 3G. G. Warnick, NRC Senior Resident Inspector, SONGS Units 2 and 3S. Y. Hsu, California Department of Public Health, Radiologic Health Branch ENCLOSUREResponse to NRC Request for Additional InformationRegarding Amendment Applications 265 and 250Responsibility, Organization, and QualificationsSan Onofre Units 2 and 3 NRC Request for Additional InformationBy letter dated June 5, 2014, the NRC requested additional information regardingAmendment Applications 265 and 250 for the San Onofre Nuclear Generating Station(SONGS) Units 2 and 3, respectively. Provided below are the NRC questions and theSouthern 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 decisionauthority 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 forthe 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 thesereactors. Since the Units are not in an operating status, please provide a basis forretention 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 NuclearGenerating Station Units 2 and 3. The term has been deleted from proposed TechnicalSpecification 5.1.2. See attachments for revised markup and clean page of proposedTechnical 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. Theposition 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 forunexpected absence, provided immediate action is taken to fill the requiredposition."SCE stated that this paragraph is being deleted because this requirement only applieswhen fuel is in the reactor.The regulations in Title 10 of the Code of Federal Regulations (10 CFR) paragraph50.36(c)(5) state that TS Administrative Controls "are the provisions relating toorganization and management... necessary to assure operation of the facility in a safePage 1 manner." The U.S. Nuclear Regulatory Commission (NRC) staff believes it is prudent tohave an individual qualified in radiation protection procedures on site during fuelhandling operations or during movements of loads over storage racks containing fuel.This staff position is consistent with the proposed TSs for permanently defueledWestinghouse plants contained in draft NUREG-1625, "Proposed Standard TechnicalSpecifications for Permanently Defueled Westinghouse Plants." This draft requires inTS 5.2.2.c that:"c. An individual qualified in radiation protection procedures shall be on siteduring fuel handling operations or movement of loads over storage rackscontaining fuel;Please provide the Administrative Controls necessary to ensure an individual qualifiedin radiation protection techniques is onsite during fuel movement or movement of loadsover the spent fuel storage racks.SCE Response:SCE will include a requirement for an individual qualified in radiation protectionprocedures to be on site during fuel handling operations or during movements of loadsover storage racks containing fuel. The requirement has been added as proposedTechnical Specification 5.2.2.e. See the attachments to this Enclosure for revisedmarkup 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 positiondescribed as a "Certified Operator". Please describe the minimum qualifications andduties 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 thetraining program shall be in accordance with ANSI N 18.1-1971 and that the systemsapproach to training (SAT) process will be used for initial and continuing training ofcertified operators. The Certified Operator Training Program Description procedureidentifies entry level requirements, initial training requirements, and continuing trainingrequirements. The certified operator is an "operator" as described in ANSI N18.1-1971Section 3.2.4, "Operators -Technicians -Repairmen," which says that "operators" are"persons principally involved in the.. .operation of plant equipment."Page 2

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AReplacement PagesProposed Technical Specifications, Redline and StrikeoutSan Onofre Unit 2 Responsibility5.15.0 ADMINISTRATIVE CONTROLS5.1 Responsibility5.1.1 The corporate officer with direct responsibility for the plant shallbe responsible for overall unit operation and maintenamie ofmanagement of the Units 2 and 3 at San Onofre Nuclear GeneratingStation, and all site support functions. He shall delegate inwriting the succession to this responsibility during his absence.5.1.2 The Shift Manager shall be responsible for the ultimate commanddecision authority for all unit activities and operations whichaffect the safety of the plant, site personnel, and/or the generalpublic. A m..nagement dire"tive to this effect, signed by the-corporate officcr with direet responsibility for the plant shall beIeissued to all site/station personnel an an annual basis..5.. The Control Room Supervisor (CRS) shall be responsible for theControl Room command function. A mnanagement directive to thiseffect, signed by the corporate;.. offlicer with direet responsibilityfor the plant, shall be. iu to all siteII stationpersonn...el. The connes of t Contrl Room Area shall be definedas depicted in the Licensee Controlled Specification (LCS). Duringany absence of the CRS froeI the Contr!l Room Area while the Unit isIin MODE 1, 2, 3, or 4, an individual with an active Senior ReactorOperator's (SRO) license shall be designated to assumne the ControlRaoom cofmamad function. During any absencc of the CRS from theControl Room Area while the Unit is in MODE 5 or 6, an individualwith an active SRO license or Reactor Operator's license shall bedesignated to assume the Control Room command function.1 5.P. 1SAN ONOFRE--UNIT 25.0-1Amendment No. H-7_ XXX I Organization5.25.2 Organization (continued)5.2.2 U*FT FACILITY STAFFThe tft4 facility staff organization shall include the following:a. A ano Liensed Operator shall be assigned to ea-h reactor c.ntainifgtfuel and an additional mom-Licensed Operator shall be assigned foreach unit when a reactor is operating in MODES 1, 2, 3, or 4. Eachon duty shift shall be composed of at least the minimum shift crewcomposition shown in Table 5.2.2-1.With both units shutdown or defueled, a total of three men Licensedoperators are required for the two units.b-- At least one licensed Reactor Operator (RO) shall be in the ControlRoom when fuel is in the reactor. In addition, while the unit is inMODE 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 of10 CFR , 0.54,)(),)and 5.2.2.a Table 5.2.2-1 for a period of timenot 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 ofon-duty shift crew members provided immediate action is taken torestore the shift crew composition to within the minimumrequirements.d-.c. A radiation protection technician shall be on site when fuel is inthe reactor. The position fmay be vacant for not more thanM "2 hovur-s,in order to provide for unexpected absence, provided im....ediateaction is taken to fill the required position. Oversight of fuelhandling operations shall be provided by a Certified Fuel Handler.t-7 Deleted-f-.d. The Shift Manager, ,lant Operations (at time of appoi-,ntent), ShiftManagers, and Control Room Supervisors. shall held be a Seniorr Operator's license. Certified Fuel Handler.g--e. The Shift Technical Advisor (STA) shall provide advisory technicalsupport to the Shift Manager in the areas of thermal hydraulics,reacto. engineering, and plant analysis with regard to the safeoperation of the unit. The STA shall have a Bachelor's Degree orequivalent in a scientific or engineering discipline woith specifictraining in plant design and in the response and analysis of theplant for transients and accidents.An individual qualified inradiation protection procedures shall be on site during fuelhandling operations or movement of loads over storage rackscontaining fuel.(conti nued)SAN ONOFRE--UNIT 2 5.0-3 Amendment No. -22-1 XXX

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BReplacement PagesProposed Technical Specifications, Redline and StrikeoutSan Onofre Unit 3 Responsibility5.15.0 ADMINISTRATIVE CONTROLS5.1 Responsibility5.1.15.1.2The corporate officer with direct responsibility for the plant shallbe responsible for overall unit operation and .ofmanagement of the Units 2 and 3 at San Onofre Nuclear GeneratingStation, and all site support functions. He shall delegate inwriting the succession to this responsibility during his absence.The Shift Manager shall be responsible for the ultimate commanddecision authority for all unit activities an ...per.t.i- whichaffect the safety of the plant, site personnel, and/or the generalpublic. A management directive to this effect, signed by thec.rp.rate "ffic.r with direct responsibility for the plant shall bereissued to all site/station personnel an an annual basis.The Contral Room Supervisor (CRS) shall be responsible for theContral Room command function. A managem ..nt dire-tiv- to thiseffect, signed by the corporatc officer with direct responsibilityfor the plant, shall be issued annually to all site,'statiopersonnel. The confines of the Contral Room Area shall be definedas depicted in the Licensee Controlled Specification (LCS). Duringany absence of the CRS fromf the Control Room Area while the Unit is7in MODE 1, 2, 3, or 4, an individual with an active Senior ReactorOperator's (SRO) license shall be designated to assume the ControlRoom command function. During any absence of the CRS from theControl Room Area while the Unit is in MODE 5 or 6, an individualwith an active SRO license or Reactor Operator's license shall beto assume the Control Room command function.SAN ONOFRE--UNIT 35.0-1Amendment No. -1-99 XXX I Organization5.25.2 Organization (continued)5.2.2 U1N+/-+/- FACILITY STAFFThe utt+ facility staff organization shall include the following:a. A men Licensed Operator shall be assigned to ea.h reactor c.ntainin.gfuel and an additional non Licensed Operator shall be assigned foreach unit when a reaater is operating in MODES 1, 2, 3, or 4. Eachon duty shift shall be composed of at least the minimum shift crewcomposition shown in Table 5.2.2-1.With both units shutdown or defueled, a total of three man Liensedoperators are required for the two units.b-. At least one licensed Reactor Operator (RO) shall be in the ControlRoom when fuel is in the reactor. in addition., while the unit is intMODE 1, 2, 3 or 4, at least one licensu r Reactr Operator(SRO shal in^ the Contra Roar Area^ .'Ib otoShift crew composition may be less than the minimum requirement of10 CFR 50.54(m)(2)(i) and 5.2.2.a Table 5.2.2-1 for a period of timenot 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 ofon-duty shift crew members provided immediate action is taken torestore the shift crew composition to within the minimumrequirements.4--c. A radiation protection technician shall be on site when fuel is inthe 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 iffmnediateaction is taken to fill the required position. Oversight of fuelhandling operations shall be provided by a Certified Fuel Handler.e-- Deleted-f-.d. The Shift Manager, Plant Operations (at time of appointm.ent), ShiftManagers, and Control Room Supervisors. shall ho-l-d be a SeniorOperator's license. Certified Fuel Handler.g--e. The Shift Technical Advisor (STA) shall provide advisory technicalsupport to the Shift Manager in the areas of thermal hydraulics,reactor -."d .-4.img, and plant analysis with regard to the safeoperation of thc unit. The STA shall have a Bachloelr's Degree orequialen in scintifc orengieering discipline with specifictraining in plant design and in the response and analysis ofthplant for transients and accidents.An individual qualified inradiation protection procedures shall be on site during fuelhandling operations or movement of loads over storage rackscontaining fuel.(conti nued)SAN ONOFRE--UNIT 3 5.0-3 Amendment No. 2-14 XXX

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CReplacement PagesProposed Technical Specifications, CleanSan Onofre Unit 2 Responsibility5.15.0 ADMINISTRATIVE CONTROLS5.1 Responsibility5.1.1 The corporate officer with direct responsibility for the plant shallbe responsible for overall management of the San Onofre NuclearGenerating Station, and all site support functions. He shalldelegate in writing the succession to this responsibility during hisabsence.5.1.2 The Shift Manager shall be responsible for the ultimate commanddecision authority for all unit activities which affect the safetyof the plant, site personnel, and/or the general public.SAN ONOFRE--UNIT 25.0-1Amendment No.

Organization5.25.2 Organization (continued)5.2.2 FACILITY STAFFThe facility staff organization shall include the following:a. Each on duty shift shall be composed of at least the minimumshift crew composition shown in Table 5.2.2-1.b. Shift crew composition may be less than the minimumrequirement of Table 5.2.2-1 for a period of time not toexceed 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 ofon-duty shift crew members provided immediate action is takento restore the shift crew composition to within the minimumrequirements.c. Oversight of fuel handling operations shall be provided by aCertified Fuel Handler.d. The Shift Manager shall be a Certified Fuel Handler.e. An individual qualified in radiation protection proceduresshall be on site during fuel handling operations or movementof loads over storage racks containing fuel.:1.(continued)SAN ONOFRE--UNIT 25.0-3Amendment No.

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DReplacement PagesProposed Technical Specifications, CleanSan Onofre Unit 3 Responsibility5.15.0 ADMINISTRATIVE CONTROLS5.1 Responsibility5.1.1 The corporate officer with direct responsibility for the plant shallbe responsible for overall management of the San Onofre NuclearGenerating Station, and all site support functions. He shalldelegate in writing the succession to this responsibility during hisabsence.5.1.2 The Shift Manager shall be responsible for the ultimate commanddecision authority for all unit activities which affect the safetyof the plant, site personnel, and/or the general public.SAN ONOFRE--UNIT 35.0-1Amendment No.

Organization5.25.2 Organization (continued)5.2.2 FACILITY STAFFThe facility staff organization shall include the following:a. Each on duty shift shall be composed of at least the minimumshift crew composition shown in Table 5.2.2-1.b. Shift crew composition may be less than the minimumrequirement of Table 5.2.2-1 for a period of time not toexceed 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 ofon-duty shift crew members provided immediate action is takento restore the shift crew composition to within the minimumrequirements.c. Oversight of fuel handling operations shall be provided by aCertified Fuel Handler.d. The Shift Manager shall be a Certified Fuel Handler.e. An individual qualified in radiation protection proceduresshall be on site during fuel handling operations or movementof loads over storage racks containing fuel.Sup.(continued)SAN ONOFRE--UNIT 35.0-3Amendment No.