ML12310A408

Response to Request for Additional Information Regarding License Amendment Request for Permanent Use of Areva Fuel and for Permanent Exemption to Use M5 Cladding

ML12310A408
Person / Time
Site:	San Onofre
Issue date:	11/05/2012
From:	St.Onge R J Southern California Edison Co
To:	Office of Nuclear Reactor Regulation, Document Control Desk
References
TAC ME6820, TAC ME6821, TAC ME6822, TAC ME6823
Download: ML12310A408 (5)

Text

SOUTHERN CALIFORNIA EDISONRi chard J.St.Onge Director, NuclearRegulatoryAffairsand

.Emergency Planning An ED ISO N I NTER NATlO NALCompanyU.S.Nuclear Regulatory Commission ATTN: Document Control Desk Washington

, DC 20555-0001 November 5, 2012

Subject:

DocketNos.50-361and50-362 Response to Request for Additional Information Regarding License Amendment Request for PermanentUseof AREVAFuelandfor PermanentExemptiontoUseM5 Cladding(TACNos.ME6820,ME6821,ME6822,AND ME6823)SanOnofre Nuclear GeneratingStation,Units2and3

References:

1.LetterfromN.Kalyanam (NRC)toP.T.Dietrich (SCE)dated August1,2012;

Subject:

San Onofre Nuclear Generatinq Station,Units2and 3 License Amendment RequestRE:Useof AREVA Fuel (TAC Nos.ME6820,ME6821,ME6822, AND ME6823)2.LetterfromD.Bauder (SCE)toJ.Sebrosky (NRC)dated July 29, 2011;

Subject:

San Onofre Nuclear Generating Station ,Units2and3 Proposed Permanent Exemption Request and Proposed Change, Number (PCN)600, Amendment Application Numbers261and249, Request for UnrestrictedUseof AREVA Fuel.

Dear Sir or Madam:

By request dated October 9 ,2012, the Nuclear Regulatory Commissionissueda Request for Additional Information (RAI)regarding unrestricteduseof AREVAfueland permanent exemptiontouseM5 cladding.TheRAI requested a response on October 15 ,2012.NRC staff agreed by phonethatSCEmay submit the response by November 8 , 2012.The enclosureofthis submittal contains the responsetothe request for additional information.

Thereareno new regulatory commitments containedinthisletter.Ifyouhave any questions or require additional information, please contactMs.LindaT.

Conklin, Licensing Manager, at (949)368-9443.Sincerely, P.O.Box 128SanClemente, CA 92672 Document Control Desk-2-November 5, 2012

Enclosure:

Response to Request for Additional Information (RAI)regarding unrestricteduseof AREVAfueland permanent exemptiontouseM5 cladding cc:E.E.Collins, Regional Administrator,NRCRegionIVR.Hall,NRC Project Manager, San OnofreUnits2and3G.G.Warnick, NRC Senior Resident Inspector, San OnofreUnits2and3

ENCLOSURE 1 Response to Request for Additional Information (RAI) regarding unrestricted use of AREVA fuel and permanent exemption to use M5 cladding

The NRC staff has determined that the following information is required to complete its review.

1. Has the licensee identified any impact to operator interfaces associated with the proposed LAR, such as:

a. Changes, additions, or deletions of operator actions?

SCE Response: No.

b. Changes to the timing of actions or the time available for actions?

SCE Response: Yes. As identified in PCN-600 Attachment D, item D.56, the existing operator action to trip the Reactor Coolant Pumps on loss of net positive suction head now has a 7 minute time requirement associated with its performance. This 7 minute time requirement is being added to a new procedure, SO123-0-A9, "Time Critical Action Program." This program will validate and document the actual timing of the operator actions.

c. Changes, additions, or deletions to emergency or abnormal operating procedures?

SCE Response: Yes. As identified in PCN-600 Attachment D, item D.56 the Emergency Operating Instructions will be updated as needed to incorporate the 7

minute time requirement.

d. Changes, additions, or deletions control room controls, displays (including the safety parameter display system) or alarms?

SCE Response: No.

e. Changes, additions, or deletions to the control room plant reference simulator?

SCE Response: No

f. Changes, additions, or deletions to the operator training program?

SCE Response: Yes. As identified in PCN-600 Attachment D, item D.56 the operator training to support the 7 minute time requirement is being tracked as a requirement for implementation of this PCN. Operator training will incorporate SO123-0-A9, "Time Critical Action Program", to ensure the 7 minute time requirement will be met during simulator scenario exercises and dynamic tests.

If yes to any of the above, describe and justify acceptability. If no to all, stop here and respond to this question only.

2. Does the licensee intend to resolve the issues identified in Item 1. above (including the training of operators, if required), prior to operation using AREVA fuel? If no, justify why this is acceptable.

SCE Response: Yes. A formal training request is in place to train on the new time requirement to secure the Reactor Coolant Pumps (RCPs) within 7 minutes of losing RCP net positive suction head during a Small Break LOCA. This training w ill be completed prior to use of AREVA fuel per this PCN