ML14351A078

San Onofre, Units 1, 2 and 3 - Redacted Version of Response to Request for Additional Information Proposed Exemptions from Certain Portions of 10 CFR 50.47 and Appendix E

ML14351A078
Person / Time
Site:	San Onofre
Issue date:	12/15/2014
From:	Palmisano T J Southern California Edison Co
To:	Document Control Desk, Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation
References
Download: ML14351A078 (18)

Text

SOUIHERN CALIFORNIAEDISON'An EDISON INTERNATIONALT, CompanyThomas 1. PalmisanoVice President & Chief Nuclear Officer10 CFR 50.1210 CFR 50.47December 15, 2014U. S. Nuclear Regulatory CommissionATTN: Document Control DeskWashington, D.C. 20555

Subject:

Docket No. 50-206, 50-361 and 50-362; and 72-041Redacted Version of Response to Request for Additional InformationProposed Exemptions from Certain Portions of 10 CFR 50.47 and Appendix E

References:

(1)Letter from Tom Palmisano (SCE), to the U. S. Nuclear RegulatoryCommission (NRC), dated October 6, 2014,

Subject:

Response to Requestfor Additional Information, Proposed Exemptions from Certain Portions of10 CFR 50.47 and Appendix E, San Onofre Nuclear Generating Station,Units 1, 2, and 3 and Independent Spent Fuel Storage Installation

Dear Sir or Madam:

By letter dated October 6, 2014 (Reference 1), Southern California Edison (SCE) providedresponses to an NRC request for additional information (RAI) concerning requested exemptionsfrom certain requirements of 10 CFR 50.47, "Emergency plans," and 10 CFR Part 50, AppendixE, "Emergency Planning and Preparedness for Production and Utilization Facilities," for SanOnofre Nuclear Generating Station (SONGS) Units 1, 2 and 3, and the Independent Spent FuelStorage Installation. The SCE responses to the RAIs were provided in Enclosures 1 and 2 tothe Reference 1 letter. This submittal provides a redacted version of the RAI responses whichdo not contain security-related information and is suitable for public disclosure.The attachment to Enclosure 1 contains the redacted version of the Unit 2 Spent Fuel PoolFigure. The redacted version does not contain security-related information. Enclosures 1 and 2,with the exception of the redacted version of the attachment, are the same as the versionsprovided in the Reference 1 letter.There are no new regulatory commitments in this letter or the Enclosure.P.O. Box 128San Clemente, CA 92672(949) 368-6575 PAX 86575Fax: (949) 368-6183Tom.Palmisano@sce.com4'v1L45 Document Control Desk-2-Should you have any questions, or require additional information, please contactMs. Andrea Sterdis at (949) 368-9985.I declare under penalty of perjury that the foregoing is true and correct.Executed on ,/ 4(DaterSincerely,

Enclosures:

1. Response to NRC Request for Additional Information Regarding Emergency PlanningExemption RequestsAttachment, Unit 2 Spent Fuel Pool Figure (Redacted)2. Correspondence Documenting SCE Commitment to Fund Local, County and State Agenciesin Accordance with California Government Code Section 8610.5cc: M. L. Dapas, Regional Administrator, NRC Region IVT. J. Wengert, 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 ENCLOSURE 1Response to NRC Request for Additional Information (RAI) RegardingEmergency Planning Exemptions RequestsSan Onofre Units 1, 2 and 3 and Independent Spent Fuel Storage InstallationPage 1 of 16 Note, the NRC Requests for Additional Information are provided below in italic text. The SCEresponses are provided in plain text.RAI-010 (Revision 1)Exemption from emergency planning requirements, as requested, is dependent on the ability ofthe licensee to promptly mitigate the consequences of applicable design basis and beyonddesign basis accidents resulting in a loss of spent fuel pool (SFP) water inventory.Please describe the actions SONGS would take to mitigate the consequences of an eventinvolving a catastrophic loss of water inventory from the SFP.In the event of a catastrophic loss of SFP water inventory, SFP normal make-up as described inUFSAR Section 9.1 would be utilized. If normal makeup is unavailable, the SONGS mitigatingstrategies include an internal strategy which relies on installed Fire Water Pumps and Serviceand Firewater Storage Tanks. In addition, there are external mitigating strategies that useportable pumps to initiate make-up flow into the pools through a seismic standpipe located nearthe stairway outside the Spent Fuel Building and standard fire hoses routed either over thepool's edge or to a spray monitor (spray nozzle) that directs flow from its location immediatelyoutside the door to the SFP operating deck into the adjacent pool. The variables in this processinclude the water source and its motive force described in more detail in this RAI response. TheSFP Normal Makeup, Internal Makeup Mitigation Strategy, External Makeup Mitigation Strategy,and External Spray Mitigation Strategy are depicted on the Unit 2 Spent Fuel Pool Figure in theAttachment to this Enclosure.Include in the description (SCE responses follow each item identified):0 Permanently installed equipment available to fill or spray the SFP;In addition to the SFP cooling and fill systems (UFSAR Section 9.1) there are two motor-drivenFire Water Pumps capable of delivering 1500 gpm (P221 and P222) and one diesel-driven FireWater Pump capable of delivering 2500 gpm (P222). The Fire Water Pumps take suction fromtwo Service and Firewater Storage Tanks. Each tank has a design capacity of 375,000 gallons.Fire water can be used to refill the SFP by routing fire hoses from two permanently installed firehose stations on the spent fuel pool operating deck or though the spray monitor (spray nozzle)into the SFP.* On-site portable equipment available to fill or spray the SFP;Two engine-driven pumps are maintained as part of SONGS mitigation strategies. One skid-mounted pump (P1058) capable of delivering 500 gpm, is pre-positioned in the Protected Area(PA) near where it would be connected and placed in-service. The additional trailer-mountedpump (P1065) capable of delivering 2500 gpm, is located inside the Owner Controlled Area(OCA) but outside the PA. It can be connected from its normal location or brought into the PAand connected to available water sources and to the SFPs if warranted. Either pump can beused to feed the seismic standpipe located near the stairway outside the Spent Fuel Building.Page 2 of 16 In addition to the permanently installed seismic standpipe, sufficient hoses, fittings, spraymonitors (spray nozzles), and other equipment are available to support strategy implementationfor one or both pools. The equipment is pre-deployed or stored and controlled at a location nearthe connection points for refill of the SFP.* Available water sources;SONGS make-up water sources include two Service and Firewater Storage Tanks. Each tankhas a design capacity of 375,000 gallons. There are three Demineralized Water Storage Tanks.Each tank has a design capacity of 535,000 gallons.* Written procedures to perform the mitigation strategies and how they are maintained;See the attached list of current mitigating strategy references which includes applicableprocedures. Mitigating strategy procedures are maintained as quality affecting proceduresunder QA program requirements.* The on-shift personnel who would perform these mitigation strategies and how they aretrained;SONGS has performed an ERO On-Shift Staffing Analysis to validate the time required toimplement the SFP Mitigation Strategies. The staff credited in this ERO On-Shift StaffingAnalysis is limited to those required by the proposed SONGS Post Defueled Emergency Plan(PDEP) currently undergoing NRC review. Specifically, the PDEP minimum on-shift staff (ShiftManager, Certified Operator and Shift Radiation Protection Technician) is tasked withimplementation of the mitigating strategy. The Shift Manager remains in the Command Center.The Certified Operator and the Shift Radiation Protection Technician complete all in-plantmitigating actions. In addition to these credited on-shift staff positions, a second on-shiftCertified Operator (not credited in the staffing analysis) is required by the proposed SONGSPermanently Defueled Technical Specifications currently undergoing NRC review and isavailable to assist in the implementation of the mitigating strategy tasks. The staffing analysisvalidates acceptable implementation without crediting the second on-shift Certified Operator.Successful implementation of the mitigating strategy does not require mobilization of off-siteresources.Current SONGS staff that will implement mitigating strategies have been trained to perform thetasks. Newly assigned staff will be trained prior to being assigned these new tasks. Trainingincludes initial and periodic requalification training. Training is conducted in accordance withthe following procedures:!, S023-XXI-TPD-CO, "Certified Operator Training Program Description") S023-XXI-TPD-SMCFH, "Shift Manager/Certified Fuel Handler Training ProgramDescription"Page 3 of 16

• How the equipment used in the mitigating strategies are stored, maintained and tested;Excluding pump P1065, mitigating strategy equipment is stored in controlled locations (cargocontainers for each unit) in the PA. The equipment is tested in accordance with plantprocedures including:S023-XV-4.67, "Surveillance Requirement Seismic Trailer and Pump Inspection"requires monthly pump test and annual comprehensive flow test for P1065.S023-XIII-73, "Skid Mounted Pump Test" requires monthly pump test and annualcomprehensive flow test for P1058.S0123-XIII-44, "Surveillance Requirement- Hydrostatic Fire Hose Test" requires annualhydrostatic hose testing.S0123-XIII-54 "Surveillance Requirement Fire Equipment Inspection" requires monthlyinspection of equipment and appliances associated with Mitigating Strategies.Any required maintenance would be controlled under standard plant processes.Approximate times it would take to deliver, setup, and start delivering makeup/spray to theSFP using portable equipment; andAn ERO On-Shift Staffing Analysis focused solely on SFP Mitigation Strategies was performed.The analyses included a detailed table-top task review and analysis, a time-motion study and afield walk-down. The on-site portable equipment described in the preceding responses wasused in these analyses. The analyses conservatively estimate the time required to deliver flowto one pool at approximately 55 minutes with an additional 35 minutes to provide water to thesecond pool. Water is supplied to both pools within a total of 90 minutes.* How makeup/spray could be delivered to the SFP in the event that radiation levels at theSFP prohibited entry to the area.The SONGS SFP external make-up strategy requires limited access to hose stations on thespent fuel operating deck to drop the hose end into the pool and initiate flow locally. Actualdose rates on the spent fuel pool operating decks are not expected to increase above20 mrem/hr until the SFP water reaches a level of less than10 feet above the stored fuel.The external spray/refill strategy requires opening a door to the spent fuel operating deck areato initiate flow from the spray monitors (spray nozzles) or to verify coverage but does not requireaccess to the operating deck if dose rates are prohibitively high.PDEP RAI-013Please describe the actions SONGS could take to mitigate the consequences of an eventinvolving a catastrophic loss of water inventory concurrently from both Units 2 and 3 SFPs.Include in the description:Page 4 of 16 The information provided in the responses to RAI-010 above is applicable for a catastrophic lossof water inventory from a single pool or a catastrophic loss of water inventory concurrently fromboth pools. Clarifications applicable to a concurrent loss of inventory from both pools areprovided below.* On-site portable equipment available to fill or spray both of the SFPs;There are two portable pumps available (P1058 and P1065). As described above, Pump P1058is pre-staged in the PA while Pump P1065 is trailer-mounted and located outside the PA. PumpP1058 can supply significant flow (-500 gpm total; split as warranted) to both poolssimultaneously. Pump P1065 can supply 2500 gpm which can also be split as warranted.0 Availability of on-shift personnel who would perform these mitigation strategies;SONGS has performed an ERO On-Shift Staffing Analysis to validate the time required toimplement the SFP Mitigation Strategies. The staff credited in this ERO On-Shift StaffingAnalysis is limited to those required by the proposed SONGS Post Defueled Emergency Plan(PDEP) currently undergoing NRC review. Specifically, the PDEP minimum on-shift staff (ShiftManager, Certified Operator and Shift Radiation Protection Technician) is tasked withimplementation of the mitigating strategy. The Shift Manager remains in the Command Center.The Certified Operator and the Shift Radiation Protection Technician complete all in-plantmitigating actions. In addition to these credited on-shift staff positions, a second on-shiftCertified Operator (not credited in the staffing analysis) is required by the proposed SONGSPermanently Defueled Technical Specifications currently undergoing NRC review and isavailable to assist in the implementation of the mitigating strategy tasks. The staffing analysisvalidates acceptable implementation without crediting the second on-shift Certified Operator.The successful implementation of mitigating strategies does not require utilization of otherpotential SONGS on-shift personnel resources or the mobilization of off-site personnel orequipment.How the equipment would be deployed during this type of event; andIn the two-pool case, pump P1 058 would be initially aligned to both SFPs through availablecross-tie lines. Otherwise deployment is the same as for a single pool. If the flow from a singlepump is insufficient to refill both pools (SFP leakage exceeds pump flow) the pump P1065 couldbe relocated into the PA and put in-service, or could be put in-service from its normal locationvia additional hose lengths depending on site circumstances.* Approximate times it would take to deliver, set-up and start delivering makeup/spray to bothof the SFPs using portable equipment.As described above it would take approximately 90 minutes to initiate flow to both SFPs withoutrelocating pump P1065. Relocation of the pump P1065, if required, takes approximately 30additional minutes.Page 5 of 16

• In addition, if using a series style of deployment of makeup! to the SFPs, what would be theimpact of changing radiation levels at the SFP due to a delay in deployment on entry to theareas and how would those impacts be managed.As noted in the response to RAI-010, SFP operating deck dose levels do not reach prohibitivelyhigh radiation levels until the pools are substantially drained. Even when the SFP water level isreduced to 10 feet above the spent fuel, the calculated dose rate is 20 mrem/hr or less.Therefore, makeup strategies that require access to the SFP operating deck are expected to beutilized for most events.If high radiation levels do prevent operating deck access, there is an existing spray/refill strategythat does not require SFP operating deck access to provide water to one or both SFPs. Thedifference in strategies simply involves different methods of discharging the water into the SFPonce the fire system is pressurized by the portable engine-driven pump(s) (P1058 and P1065).When operating deck access is not available, a spray monitor (spray nozzle) connected to thefire system outside the SFP operating deck, is placed in the open doorway to the SFP. Water isthen sprayed over the operating deck and into the SFP.If makeup to both SFPs is necessary, the preliminary steps of hooking up the portable engine-driven fire pump(s) (P1058 and P1065) to the existing Fire Protection System to pressurize theMain Fire Loop need not be re-performed to provide makeup to the second pool. Initiatingmakeup to the second SFP consists of hooking up a second spray monitor (spray nozzle) in thesecond SFP doorway and initiating flow to that SFP. The time to initiate makeup to the secondSFP following initiation of flow to the first SFP is approximately 35 minutes (i.e., a total ofapproximately 90 minutes for both SFPs); therefore there is no appreciable delay betweeninitiation of makeup to the first SFP relative to the second SFP. Therefore, there is a minimalimpact on achieving successful implementation for both pools.RAI-014The response to the RAI provided in Enclosure I to the letter dated September 9, 2014,provided a summary of a calculation to evaluate air cooling of spent fuel in SONGS Unit 2 andUnit 3 spent fuel pools in lieu of the results to a seismic checklist. The NRC staff found that thesummary information was not sufficiently clear for the staff to complete its technical review.Please provide clarifying information for the following:Use of guidance from NUREG-0800 ASB 9-2 to determine spent fuel pool heat generationrate: The guidance from NUREG-0800 ASB 9-2 was intended to evaluate accident decayheat rates close to the time of reactor shutdown and contains few representative decay heatgroups for the fission and activation products present 31 months following shutdown. Justifythe use of this guidance in the air cooling calculation or reference alternate decay heatmodels.The use of ASB 9-2 is part of the SONGS current design and licensing basis for equivalentapplications (bulk pool heat-up) and has been validated against a SONGS Unit 2 Spent FuelPool (SFP) heat load measurement performed in 2011. For that measurement, the most recentPage 6 of 16 refueling load (109 fuel assemblies) was cooled for about 24 months. The measured SFP heatload was 2.4 MBTU/hr. The calculated heat load based on ASB 9-2 was 2.27 MBTU/hr (about5.5% lower than measured). Based on the comparison, a conservative multiplier of 1.10 wasdeveloped for applying to SFP decay heat calculation using ASB 9-2. For the SFP air coolingcalculation, the calculated SFP heat load based on ASB 9-2, after applying a 10% multiplier is2.77 MBTU/hr. This SFP heat load value was used in a GOTHIC computer code simulation toobtain boundary condition input (air temperature) for COBRA-SFS calculation only. Fuelassembly decay heat rates for the COBRA-SFS model were obtained from ORIGEN-ARP/ORIGEN-S calculations.* Consideration of fuel handling building ventilation subsystem: Clarify the operating state ofthe ventilation system used in the GOTHIC analysis. Provide justification for the selectedoperating state considering the seismic hazard present at the SONGS site.The calculation assumes the Fuel Handling Building Ventilation System is in its normaloperating state (in operation). The design basis of the system is Seismic Category Il/I so it isunlikely to fail due to the most likely event to cause of loss of inventory. The purpose of theSONGS air cooling calculation is to provide SONGS specific results for the air cooling scenariodiscussed in NUREG-1738, "Technical Study of Spent Fuel Pool Accident Risk atDecommissioning Nuclear Power Plants". The air-cooled analysis, along with SONGS adiabaticheat-up results support a favorable conclusion that there is sufficient time to initiate mitigatingactions consistent with plant conditions. The analytical results show that there is sufficient timefor offsite authorities to take protective actions in the highly unlikely event such actions arenecessary.The COBRA model considered one assembly from the Cycle 16 discharge and twoassemblies from earlier discharges on two faces, with no heat transfer from these threeassemblies to adjacent assemblies or structures: Clarify the power history for the fuelassemblies and the heat generation model used to determine the representative decay heatrates cited in the list of inputs. Provide justification for the configuration as a realistic orconservative representation of the most limiting actual fuel storage pattern.The spent fuel storage configuration model utilized is more conservative that the most limitingactual fuel storage pattern in the SONGS SFPs.Assembly heat rates for the COBRA model were generated using the ORIGEN-ARP/ORIGEN-Smodules within the SCALE 6 computer code package. Input parameters to ORIGEN-ARP/ORIGEN-S include: fuel type, initial uranium mass, initial U-235 enrichment, fuel assemblyburn-up, specific power, light element weights, and cooling time. A flat power history consistentwith core average power density was used in the ORIGEN-S input. This approach isconservative since the assembly power density for high decay heat assemblies is lower thancore average. Additional details and sample input are provided in SCE response to (MF3835)RAI-012 (Reference 2, Enclosure 1, Attachment B).This analysis uses a three assembly model to simulate heat transfer from one assembly toadjacent assemblies. Per the spent fuel pool maps, the most recently offloaded assembliesPage 7 of 16 (Cycle 16) are typically arranged so there are only a few Cycle 16 assemblies that are notadjacent to two assemblies that are Cycle 13 or older (also referred to as "cooler") assemblies.The Cycle 16 assemblies not adjacent to two cooler assemblies were identified based on theSFP maps. These assemblies (e.g. S2S555 and S3S553) have a heat rate of at least 17%lower than the maximum heat rate assembly (S2RO13). Since the results of this analysis showthat the heat transferred from the maximum heat rate assembly to adjacent assemblies isroughly 17%, the three assembly model with the limiting assembly adjacent to two assembliesfrom earlier discharges remain bounding. For this analysis three assemblies are modeled: theworst case Cycle 16 assembly is between two limiting Cycle 13 assemblies (i.e., those with thehighest heat rate). This bounding condition is illustrated in Figure RAI-14-1.This method is conservative for two key reasons. First, it assumes that there is no heat transferto the other two adjacent assemblies. This is equivalent to modeling the other two adjacentassemblies as also being bounding Cycle 16 assemblies. Second, it assumes that the third andfourth highest heat generation assemblies touching the bounding Cycle 16 assembly are boththe worst case Cycle 13 heat assemblies. In reality the fourth adjacent assembly would have aneven lower heat rate resulting in more heat transfer from the central Cycle 16 assembly.Page 8 of 16 Figure RAI-014-1Configuration modeled in COBRANote: Only the middle Cycle 16 assembly and the two Cycle 13 assemblies are modeled. The diagonallines represent the boundary of the COBRA model and are assumed to be adiabatic.Page 9 of 16 RAI-01 5For comparison purposes, please provide the numeric result of the adiabatic heatup timeanalysis based on the same decay heat information used in the air cooling analysis (i.e., specifictime to reach 900 degrees Celsius based on decay heat on August 31, 2014).The adiabatic heat-up calculation models the bounding (highest heat rate) assembly in theSpent Fuel Pool. Heat rate for the bounding assembly was calculated using ORIGEN-ARP/ORIGEN-S modules within the SCALE 6 computer code package. Details of the caseinput have been provided in SCE response to (MF3835) RAI-012 (Reference 2, Attachment B).Heat-up time for July 25, 2013 was 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br />. Based on the heat rate on August 31, 2014, theheat-up time to reach 900 degrees Celsius is greater than 17 hours1.967593e-4 days <br />0.00472 hours <br />2.810847e-5 weeks <br />6.4685e-6 months <br />.The Table below provides heat-up times for a number of adiabatic cases at two temperatures ofinterest taken from various NRC sources.TABLE RAI-015-1DATE Decay Time Heat-up Time to Heat-up Time to(months) 5650C (hours)1 9000C (hours)2June 12, 2013 17 5.6 9.4October 12, 2013 21 6.8 11.3February 12, 2014 25 8.0 13.4June 12, 2014 29 9.3 15.5October 12, 2014 33 10.7 17.8February 12, 2015 37 12.0 20.0June 12, 2015 41 13.4 22.3December 12, 2015 47 15.4 25.6June 12, 2016 53 17.3 28.7December 12, 2016 59 19.0 31.6Note 1 5650C was selected to reflect time to incipient fuel damage (clad swelling and/or creep rupture) andpossible release (NUREG/CR6451 and SECY 99-168)Note 2 9000C was selected based on NRC guidance to determine time to self-sustaining zirconium oxidation(NUREG-1738)Page 10 of 16 MITGATION STRATEGY REFERENCESProcedures) S023-V-5.100, SONGS B.5.b Mitigation Strategies> SO123-XIII-54, Surveillance Requirement Fire Equipment Inspection> S023-3-2.11, Spent Fuel Pool Operations> S023-3-2.11.1, SFP Level Change and Purification Crosstie Operations> S023-13-20, Fuel Handling Accidents or Loss of SFP Level Control> S023-13-21, Fire; S023-13-23, Loss Of Spent Fuel Pool CoolingS023-13-25, Operator Actions During Security EventsGuidelines; SOG-TR-0029, Blitzfire Monitor> SOG-TR-0032, Seismic Trailer Pump (SA2301MP1 065) Operations)ý SOG-AD-0023, Fire Department SOG Revisions -EP B.5.b Mitigating Strategies Books> SOG-EO-0001, Firewater to Plant Systems -Spent Fuel Pool (SFP) Makeup (Internal /External) and Spent Fuel Pool (SFP) Spray -External Strategies> SOG-EO-0003, Water Spray Scrubbing -Fog Stream Applications> SOG-EO-0004, Casualty Collection Centers> SOG-EO-0009, SOFD Response to Large-Scale Accelerant Fed Fire Event in ProtectedAreaSystem Descriptionso- SD- S023-430, Fuel Handling and Refueling System> SD- S023-590, Fire Protection SystemPage 11 of 16 SECURITY RELATED INFORMATION WITHHOLD UNDER 10 CFR 2.390ENCLOSURE 1ATTACHMENTFigureUNIT 2 SPENT FUEL POOLPage 12 of 16 CECtI IDITV DCI ATCrfl IRICnORfA ATIfnl iAIITUUnCU- flAIRWCD In1 fC:0 ) :)nnUNIT 2 SPENT FUEL POOLPage 13 of 16 ENCLOSURE2Correspondence Documenting SCE Commitment to Fund Local, County and StateAgencies in Accordance withCalifornia Government Code Section 8610.51. May 7, 2014 Letter from the Jeremy Kirchner, Chairman, Interjurisdictional PlanningCommittee (IPC) to SCE2. June 3, 2014 Letter from J. Chris Thompson, Vice President, Decommissioning, SCE to theIPCPage 14 of 16

[Interjurisdictional Planning CommitteeCounty of Orange-County of San Diego-City of San Clernente.City of San Juan CapistranoCity of Dana Point.California State Parks.U. S. Marine Corps-Southern California EdisonMay 7, 2014Tom PalmisanoVice President/Chief Nuclear OfficerSan Onofre Nuclear Generating StationSouthern California EdisonP.O. Box 128San Clemente CA 92674-0128

Dear Mr. PaLmisano:

I am writing on behalf of the Lnterju.risdictional Planning Committee and the emergency managers whoplan and prepare for the offsite response to an emergency at the San Onofre Nuclear Generating Station.As you know, Southern California Edison provides reimbursement for SONGS-related preparednessactivities to several local, county, and state agencies. With the plant now starting the decommissioningprocess, there have been questions regarding future offsite nuclear preparedness activities, and thereimbursement available to support them.Earlier this year, we were informed of SCE's plans to conthiue reimbursing SONGS-related offsite activitiesaccording to current arrangements, based on the nuclear power plant funding provisions of CaliforniaGovernment Code section 8610.5 until that section expires in July, 2019. The IPC appreciates your supportof the activities we perform to protect the health and safety of the public.Because the budgeting process for the plannting, response, and support activities these agencies undertakerelated to SONGS is started well in advance of each fiscal year, the IPC agencies are looking fordocumented assurance of that funding arrangement, which can be used to support our budget requests.Therefore, on behalf of the [PC, I am requesting verification of your funding commitment in writing. Thiswill provide the IPC agencies with the confirmation we need to support our nuclear preparednessprograms, and will help to prevent any misunderstanding as decommissioning activities continue over thenext few years.I look forward to continuing our work together to ensure the safety of the local population. If you have anyquestions, or if I can clarify anything for you, please feel free to contact me.Sincerely,jb nreyK~ircnerjhair, Interjurisdictional Planning CommitteeComitePage 15 of 16 Aj SOUTHERN CALIFORNIAEDISONAn EDISON INTERNATIONALO Company1. Christopher ThompsonVice PresidentDeconmissioningJune 3, 2014Mr. Jeremy KirchnerChair, Interjurlsdlctional Planning CommitteeCity of Dana Point, Emergency Services Division33282 Golden LanternDana Point, CA 92629-1805

Dear Mr. Kirchner:

Thank you for your letter dated May 7, 2014 regarding funding under California GovernmentCode Section 8610.5 for local, county, and state agencies for emergency preparednessactivities. We appreciate the long-standing collaborative relationship that Southern CaliforniaEdison (SCE) has enjoyed with the lnterjurisdictional Planning Committee (IPC) and look forwardto a continued cooperative relationship to protect the health and safety of the public. We wantto assure you and the IPC that we Intend to fully comply with the requirements set forth inSection 8610.5 and provide continued funding for emergency preparedness. We will not seekchanges to funding levels without prior consultation with the IPC.Again, I want to emphasize how much we appreciate the long-standing collaborativerelationship SCE has had with the IPC. We look forward to continuing to work together toprotect the health and safety of our local communities.Kind regards,9.4ýP.O. Box 8002244 WMInut Grove AveRo..enmead, CA 91770626-302- 1363Fax 626-302-9213Page 16 of 16