ML061990071

Response to Request for Additional Information and Submittal of Proposed Technical Specifications Change Number (Pcn) 572 Steam Generator Tube Surveillance Program, Tube Repair

ML061990071
Person / Time
Site:	San Onofre
Issue date:	07/14/2006
From:	Katz B Southern California Edison Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
GL-04-001
Download: ML061990071 (33)

Text

SOUTHIERN CALIFORNIA Brian Katz EDISON ,, Vice President An EDISON INTERNATIONALR', Company Withhold from Public Disclosure Under 10 CFR 2.390 When Separated from the Proprietary Enclosure (Enclosure

5) This document is Decontrolled.July 14, 2006 U. S. Nuclear Regulatory Commission Document Control Desk Washington, D. C. 20555

References:

San Onofre Nuclear Generating Station, Units 2 and 3 Docket Nos. 50-361 and 50-362 Response to Request for Additional Information and Submittal of Proposed Technical Specification Change Number (PCN) 572 Steam Generator Tube Surveillance Program, Tube Repair 1. Letter from A. E. Scherer (SCE) to Document Control Desk dated October 26, 2004,

Subject:

Docket Nos. 50-361 and 50-362, NRC Generic Letter 2004-01 Requirements for Steam Generator Tube Inspections, San Onofre Nuclear Generating Station, Units 2 and 3 2. Letter from A. E. Scherer (SCE) to Document Control Desk dated November 23, 2005,

Subject:

Docket Nos. 50-361 and 50-362, NRC Generic Letter 2004-01 Requirements for Steam Generator Tube Inspections, Additional Information, San Onofre Nuclear Generating Station, Units 2 and 3 3. Letter from N. Kalyanam (NRC) to Mr. Richard M. Rosenblum (SCE) dated January 18, 2006,

Subject:

San Onofre Nuclear Generating Station (SONGS), Unit 2 -Request for Additional Information Concerning Response to Generic Letter 2004-01,"Requirements for Steam Generator Tube Inspections" (TAC NO.MC4849)

Dear Sir or Madam:

By Reference 1, Southern California Edison (SCE) submitted a required response to NRC Generic Letter GL-2004-01.

Subsequently, NRC staff requested certain additional information.

This information was provided in Reference

2. The object of this letter is to provide other additional information that has been requested by the staff in Reference 3 and to submit the resulting Proposed Technical Specification (TS) Change Number PCN-572 "Steam Generator Tube Surveillance Program, Tube Repair" for San Onofre Units 2 and 3.P.O. Box 128 San Clemente, CA 92674-0128 949-368-9275 Fax 949-368-9881 A 1 is n #

• I n L,-I,-* II I H, IV I.,, July 14, 2006 This TS change request is provided as Enclosure 2, License Amendment Request, Proposed Change Number PCN-572. Enclosure 3 is the SCE response to the NRC request for additional information (RAI).Enclosure 4 is a Westinghouse authorization letter CAW-06-2168 with accompanying affidavit, Proprietary Information Notice, and Copyright Notice.Enclosure 5 is a proprietary copy of Westinghouse Topical Report SG-SGDA-05-48-P Revision 1, WOG PA-MSC-0190, Revision 1, "Test Results Related to TIG and Alloy 800 Sleeve Installation in 3/4 Inch and 7/8 Inch OD SG Tubing In-Service Inspection Requirements." Enclosure 6 is a non-proprietary copy of Westinghouse Topical Report SG-SGDA 48-NP Revision 1, WOG PA-MSC-0190, Revision 1, "Test Results Related to TIG and Alloy 800 Sleeve Installation in 3/4 Inch and 7/8 Inch OD SG Tubing In-Service Inspection Requirements." The Enclosure 4 affidavit sets forth the basis on which the information may be withheld from public disclosure by the Commission and addresses with specificity the considerations listed in paragraph (b) (4) of Section 2.390 of the Commission's regulations.

Accordingly, it is respectfully requested that the information which is proprietary to Westinghouse be withheld from public disclosure in accordance with 10 CFR Section 2.390 of the Commission's regulations.

Correspondence with respect to the copyright or proprietary aspects of Enclosures 4 and 5 should be addressed to J. A.Gresham, Manager, Regulatory Compliance and Plant Licensing, Westinghouse Electric Company LLC, P.O. Box 355, Pittsburgh, Pennsylvania 15230-0355.

If you have any questions, or would like additional information concerning this subject, please contact Mr. Jack Rainsberry at (949) 368-7420.Sincerely, Document Control Desk-3-July 14, 2006 Enclosures

1. Notarized Affidavits

2. Proposed License Amendment Request, Proposed Change Number PCN-572, with Attachments A-F (modifications to the Technical Specification pages)3. Response to NRC Request for Additional Information (RAI) (Reference 3)4. Proprietary Affidavit 5. Westinghouse Proprietary Topical Report SG-SGDA-05-48-P Revision 1, (CEN-630-P Revision 2 Addendum), "WOG PA-MSC-01 90, Revision 1: Test Results Related to TIG and Alloy 800 Sleeve Installation in 3/4 Inch and 7/8 Inch OD SG Tubing In-Service Inspection Requirements" 6. Westinghouse Non-proprietary Topical Report SG -SGDA-05-48-NP Revision 1, (CEN-630-NP Revision 2 Addendum), "WOG PA-MSC-0190, Revision 1: Test Results Related to TIG and Alloy 800 Sleeve Installation in 3/4 Inch and 7/8 Inch OD SG Tubing In-Service Inspection Requirements" cc: B. S. Mallett, Regional Administrator, NRC Region IV N. Kalyanam, NRC Project Manager, San Onofre Units 2 and 3 C. C. Osterholtz, NRC Senior Resident Inspector, San Onofre Units 2 and 3 S. Y. Hsu, California Department of Health Services, Radiologic Health Branch Enclosure I Page 1 of 2 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Application of SOUTHERN CALIFORNIA EDISON COMPANY, ET AL. for a Class 103 License to Acquire, Possess, and Use a Utilization Facility as Part of Unit No. 2 of the San Onofre Nuclear Generating Station))))))Docket No. 50-361 Amendment Application No. 245 SOUTHERN CALIFORNIA EDISON COMPANY, ET AL. pursuant to 10 CFR 50.90, hereby submit Amendment Application No. 245. This amendment application consists of Proposed Change No. PCN-572 to Facility Operating License NPF-10. Proposed Change No. PCN-572 is a request to revise Facility Operating License NPF-1 0 to revise the Technical Specification steam generator Tube Surveillance Program tube repair discussion.

State of California County of San Diego Brian Katz, Vice President Subscribed and sworn to (e-af a~med) before me on this _ 4A_ day of By £ýYNtauI 4Z personally known to me -r-edtr person who appeared before me.Notary Public th, bsis of ,,,t ,,a,,r, ,,,,iden,,to be the Enclosure I Page 2 of 2 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Application of SOUTHERN CALIFORNIA EDISON COMPANY, ET AL. for a Class 103 License to Acquire, Possess, and Use a Utilization Facility as Part of Unit No. 3 of the San Onofre Nuclear Generating Station))))))Docket No. 50-362 Amendment Application No. 230 SOUTHERN CALIFORNIA EDISON COMPANY, ET AL. pursuant to 10 CFR 50.90, hereby submit Amendment Application No. 230. This amendment application consists of Proposed Change No. PCN-572 to Facility Operating License NPF-15. Proposed Change No. PCN-572 is a request to revise Facility Operating License NPF-1 5 to revise the Technical Specification steam generator Tube Surveillance Program tube repair discussion.

State of California County of San Diego 1rian Katz, Vice Presiddn4 Subscribed and sworn to (or affirmed) before me on this 1444Ln. day of By?'r~iVo~

personally known to me or p,.ved to me on thc bacic of satisfocte.y evidenc to be the person who appeared before me.O Ntw-A Julic Notary Public--RAM A- MAR Mt-Co"nMion

• 1623105 Notary PjWC -Cdftffw SM DWQ0 CouritV 1MyCwmEW1rwNov20.2009 I0 Enclosure 2 License Amendment Request, Proposed Change Number PCN-572 with Attachments A -F (proposed Technical Specification change pages)

LICENSEE'S EVALUATION DESCRIPTION FOR PROPOSED TECHNICAL SPECIFICATION CHANGE PCN-572 STEAM GENERATOR TUBE SURVEILLANCE PROGRAM, TUBE REPAIR San Onofre Nuclear Generating Station Units 2 and 3 EXISTING TECHNICAL SPECIFICATIONS See Attachments A and B PROPOSED TECHNICAL SPECIFICATIONS (highlight for additions, strikeout for deletions)

See Attachments C and D PROPOSED TECHNICAL SPECIFICATIONS (with changes)See Attachments E and F

1.0 INTRODUCTION

This proposed Technical Specification change incorporates a description of the parent tube inspection limitation adjacent to the nickel band portion of the lower sleeve joint and provides the basis for the structural and leakage integrity of the joint being ensured with the existing inspection of the parent tube adjacent to the nickel band region.

2.0 PROPOSED CHANGE

The following change is proposed: It is proposed to add the following paragraph to Section 5.5.2.11 ..1 .j to provide a description of the parent tube inspection limitation adjacent to the nickel band and to provide the basis for the structural and leakage integrity: "In a part of the repair pressure boundary, there is a limitation in nondestructive examination.

The part of the repair pressure boundary is the parent tube adjacent to the nickel band portion (the lower half) of the lower joint that is formed by hard rolling. The limitation is that nondestructive examination may not be capable of detecting any type of degradation that may be present and may exceed the repair limit. The limitation does not affect structural integrity and leakage performance, based on design review and laboratory testing documented in ABB/CE Topical Report CEN-630-P, Rev. 2, Addendum dated January 2006." Page 1 of 4

3.0 BACKGROUND

This proposed change responds to Reference

7.1 which

requested Southern California Edison to submit an amendment request demonstrating that structural and leakage integrity of the steam generator sleeve joint is ensured with the existing inspection of the parent tube behind (i.e., adjacent to) the nickel band region. [Alternatively, Southern California Edison (SCE) could have either (1) demonstrated that the techniques being used for tube inspection are capable of finding the forms of degradation that could be in the parent tube behind the nickel band region, or (2) commit to remove all sleeves with a nickel band from service.]4.0 TECHNICAL ANALYSIS SCE has selected the option to submit this amendment to demonstrate that structural and leakage integrity of the steam generator sleeve joint is ensured with the existing inspection of the parent tube adjacent to the nickel band region. This option is supported by Westinghouse Topical Report SG-SGDA-05-48-P Revision 1, WOG PA-MSC-0190, Revision 1, "Test Results Related to TIG and Alloy 800 Sleeve Installation in 3/4 Inch and 7/8 Inch OD SG Tubing In-Service Inspection Requirements," Reference 7.2.5.0 REGULATORY SAFETY ANALYSIS 5.1 No Significant Hazards Consideration Southern California Edison (SCE) has evaluated whether or not a significant hazards consideration is involved with the proposed amendment by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of Amendment", as discussed below: 1. Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?

Response:

No.This proposed change revises the San Onofre Units 2 and 3 Technical Specifications (TS) Section 5.5.2.1 l.f.l.j to provide a description of the parent tube inspection limitation adjacent to the nickel band and to provide the basis for the structural and leakage integrity.

This is supported by Westinghouse Topical Report SG-SGDA-05-48-P Revision 1, "WOG PA-MSC-0190, Revision 1: Test Results Related to TIG and Alloy 800 Sleeve Installation in 3/4 Inch and 7/8 Inch OD SG Tubing In-Service Inspection Requirements." Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

Page 2 of 4

2. Does the proposed change create the possibility of a new or different kind of accident from any accident previously evaluated?

Response:

No.Steam generator tube leakage and structural integrity will be maintained during all plant conditions upon implementation of the proposed inspection scope and repair limit changes to the San Onofre Units 2 and 3 Technical Specifications.

This change does not introduce any new mechanisms that might result in a different kind of accident from those previously evaluated.

Therefore, the proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

3. Does the proposed change involve a significant reduction in a margin of safety?Response:

No Structural and leakage integrity of the steam generator sleeve joint is ensured with the existing inspection of the parent tube adjacent to the nickel band region.Therefore, the proposed change does not involve a significant reduction in a margin of safety.Based on the above, SCE concludes that the proposed amendments present no significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and accordingly, a finding of "no significant hazards consideration" is justified.

5.2 Applicable

Regulatory Requirements/Criteria Regulatory Guide 1.83, Revision 1, titled Inservice Inspection of Pressurized Water Reactor Steam Generator Tubes, provides guidance on steam generator tubing inspection and repair. The proposed change will continue to meet the intent of this Regulatory Guide.In conclusion, based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense or security or to the health and safety of the public.6.0 ENVIRONMENTAL CONSIDERATION A review has determined that the proposed amendment would change a requirement with respect to installation or use of a facility component, the steam generators, located within Page 3 of 4 the restricted area, as defined in 10 CFR 20 or would change an inspection or surveillance requirement.

However, the proposed amendment does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluent that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure.

Accordingly, the proposed amendments meet the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22 (c)(9). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with this proposed amendment.

7.0 REFERENCES

7.1 NRC to SCE letter dated January 18, 2006, San Onofre Nuclear Generating Station (SONGS), Unit 2 -Request for Additional Information Concerning Response to Generic Letter 2004-01, "Requirements for Steam Generator Tube Inspections" (TAC NO. MC4849)7.2 Westinghouse Proprietary Topical Report SG-SGDA-05-48-P Revision 1, (CEN-630-P Revision 2 Addendum), "WOG PA-MSC-0190, Revision 1: Test Results Related to TIG and Alloy 800 Sleeve Installation in 3/4 Inch and 7/8 Inch OD SG Tubing In-Service Inspection Requirements" Page 4 of 4 PCN-572 Attachment A (Existing Page)SONGS Unit 2 Procedures, Programs, and Manuals 5.5 5.5 Procedures, Programs, and Manuals (continued) 5.5.2.11 Steam Generator (SG) Tube Surveillance Program (continued) j) Tube Repair -refers to a process that reestablishes tube serviceability.

Acceptable tube repairs will be performed by the following process: TIG welded sleeving as described in ABB/CE Topical Report, CEN-630-P, Rev. 2, is currently approved by the NRC.Tube repair includes the installation by welding of the sleeves, heat treatment in accordance with CEN-630-P, Rev. 2, to remove the stresses that are introduced by the sleeve installation, acceptance testing of the sleeve, and nondestructive examination for future comparison.

Tube repair can be performed on certain tubes that have been previously plugged as a corrective or preventive measure. A tube inspection of the full length of the tube shall be performed on a previously plugged tube prior to returning the tube to service.2. The SG shall be determined OPERABLE after completing the corresponding actions (plug or repair all tubes exceeding the repair limit and all tubes containing through-wall cracks, and plug all sleeved tubes that exceed the repair criteria) required by Tables 5.5.2.11-1 and 5.5.2.11-2.

g. Reports The content and frequency of written reports shall be in accordance with Technical Specification 5.7.2, "Special Reports." (continued)

SAN ONOFRE--UNIT 2 5.0-19 Amendment No. +2 140 PCN-572 Attachment B (Existing Page)SONGS Unit 3 Procedures, Programs, and Manuals 5.5 5.5 Procedures, Programs, and Manuals (continued) 5.5.2.11 Steam Generator (SG) Tube Surveillance Program (continued) j) Tube Repair -refers to a process that reestablishes tube serviceability.

Acceptable tube repairs will be performed by the following process: TIG welded sleeving as described in ABB/CE Topical Report, CEN-630-P, Rev. 2, is currently approved by the NRC.Tube repair includes the installation by welding of the sleeves, heat treatment in accordance with CEN-630-P, Rev. 2, to remove the stresses that are introduced by the sleeve installation, acceptance testing of the sleeve, and nondestructive examination for future comparison.

Tube repair can be performed on certain tubes that have been previously plugged as a corrective or preventive measure. A tube inspection of the full length of the tube shall be performed on a previously plugged tube prior to returning the tube to service.2. The SG shall be determined OPERABLE after completing the corresponding actions (plug or repair all tubes exceeding the repair limit and all tubes containing through-wall cracks, and plug all sleeved tubes that exceed the repair criteria) required by Tables 5.5.2.11-1 and 5.5.2.11-2.

g. Reports The content and frequency of written reports shall be in accordance with Technical Specification 5.7.2, "Special Reports." (continued)

SAN ONOFRE--UNIT 3 5.0-19 Amendment No. 4-1-6 132 PCN-572 Attachment C (Proposed Page)(Redline and Strikeout)

SONGS Unit 2 Procedures, Programs, and Manuals 5.5 5.5 Procedures, Programs, and Manuals (continued) 5.5.2.11 Steam Generator (SG) Tube Surveillance Program (continued) j) Tube Repair -refers to a process that reestablishes tube serviceability.

Acceptable tube repairs will be performed by the following process: TIG welded sleeving as described in ABB/CE Topical Report, CEN-630-P, Rev. 2, is currently approved by the NRC.Tube repair includes the installation by welding of the sleeves, heat treatment in accordance with CEN-630-P, Rev. 2, to remove the stresses that are introduced by the sleeve installation, acceptance testing of the sleeve, and nondestructive examination for future comparison.

Tube repair can be performed on certain tubes that have been previously plugged as a corrective or preventive measure. A tube inspection of the full length of the tube shall be performed on a previously plugged tube prior to returning the tube to service.In a Dart of the repair pressure boundarv, there is a limitation in nondestructive examination.

The Dart of the repair pressure boundarv is the Darent tube adiacent to the nickel band Dortion (the lower half) of the lower joint that is formed bv hard rollina. The limitation is that nondestructive examination mav not be caDable of detectina anv tvDe of dearadation that mav be Dresent and mav exceed the reDair limit. The limitation does not affect structural intearitv and leakaae Derformance.

based on desian review and laboratory testina documented in ABB/CE Topical Report CEN-630-P, Rev. 2, Addendum dated January 2006.2. The SG shall be determined OPERABLE after completing the corresponding actions (plug or repair all tubes exceeding the repair limit and all tubes containing through-wall cracks, and plug all sleeved tubes that exceed the repair criteria) required by Tables 5.5.2.11-1 and 5.5.2.11-2.

g. Reports The content and frequency of written reports shall be in accordance with Technical Specification 5.7.2, "Special Reports." (continued)

SAN ONOFRE--UNIT 2 5.0-19 Amendment No. 127,40 PCN-572 Attachment D (Proposed Page)(Redline and Strikeout)

SONGS Unit 3 Procedures, Programs, and Manuals 5.5 5.5 Procedures, Programs, and Manuals (continued) 5.5.2.11 Steam Generator (SG) Tube Surveillance Program (continued) j) Tube Repair -refers to a process that reestab ishes tube serviceability.

Acceptable tube repairs will be performed by the following process: TIG welded sleeving as described in ABB/CE Topical Report, CEN-630-P, Rev. 2, is currently approved by the NRC.Tube repair includes the installation by welding of the sleeves, heat treatment in accordance with CEN-630-P, Rev. 2, to remove the stresses that are introduced by the sleeve installation, acceptance testing of the sleeve, and nondestructive examination for future comparison.

Tube repair can be performed on certain tubes that have been previously plugged as a corrective or preventive measure. A tube inspection of the full length of the tube shall be performed on a previously plugged tube prior to returning the tube to service.In a Dart of the repair pressure boundarv, there is a limitation in nondestructive examination.

The Dart of the reDair pressure boundarv is the Darent tube adjacent to the nickel band oortion (the lower half) of the lower joint that is formed bv hard rollina. The limitation is that nondestructive examination mav not be capable of detectino anv tvDe of dearadation that may be Dresent and mav exceed the reDair limit. The limitation does not affect structural intearitv and leakaae Derformance.

based on desion review and laboratorv testina documented in ABB/CE ToDical Report CEN-630-P, Rev. 2, Addendum dated January 2006.2. The SG shall be determined OPERABLE after completing the corresponding actions (plug or repair all tubes exceeding the repair limit and all tubes containing through-wall cracks, and plug all sleeved tubes that exceed the repair criteria) required by Tables 5.5.2.11-1 and 5.5.2.11-2.

g. Reports The content and frequency of written reports shall be in accordance with Technical Specification 5.7.2, "Special Reports." (continued)

SAN ONOFRE--UNIT 3 5.0-19 Amendment No. 116 132 PCN-572 Attachment E (Proposed Page)SONGS Unit 2 Procedures, Programs, and Manuals 5.5 5.5 Procedures, Programs, and Manuals (continued) 5.5.2.11 Steam Generator (SG) Tube Surveillance Program (continued) j) Tube Repair -refers to a process that reestab ishes tube serviceability.

Acceptable tube repairs will be performed by the following process: TIG welded sleeving as described in ABB/CE Topical Report, CEN-630-P, Rev. 2, is currently approved by the NRC.Tube repair includes the installation by welding of the sleeves, heat treatment in accordance with CEN-630-P, Rev. 2, to remove the stresses that are introduced by the sleeve installation, acceptance testing of the sleeve, and nondestructive examination for future comparison.

Tube repair can be performed on certain tubes that have been previously plugged as a corrective or preventive measure. A tube inspection of the full length of the tube shall be performed on a previously plugged tube prior to returning the tube to service.In a part of the repair pressure boundary, there is a limitation in nondestructive examination.

The part of the repair pressure boundary is the parent tube adjacent to the nickel band portion (the lower half) of the lower joint that is formed by hard rolling. The limitation is that nondestructive examination may not be capable of detecting any type of degradation that may be present and may exceed the repair limit. The imitation does not affect structural integrity and leakage performance, based on design review and laboratory testing documented in ABB/CE Topical Report CEN-630-P, Rev. 2, Addendum dated January 2006.2. The SG shall be determined OPERABLE after completing the corresponding actions (plug or repair all tubes exceeding the repair limit and all tubes containing through-wall cracks, and plug all sleeved tubes that exceed the repair criteria) required by Tables 5.5.2.11-1 and 5.5.2.11-2.

g. Reports The content and frequency of written reports shall be in accordance with Technical Specification 5.7.2, "Special Reports." (continued)

SAN ONOFRE-UNIT 2 5.0-19 Amendment No.

PCN-572 Attachment F (Proposed Page)SONGS Unit 3 Procedures, Programs, and Manuals 5.5 5.5 Procedures, Programs, and Manuals (continued) 5.5.2.11 Steam Generator (SG) Tube Surveillance Program (continued) j) Tube Repair -refers to a process that reestab ishes tube serviceability.

Acceptable tube repairs will be performed by the following process: TIG welded sleeving as described in ABB/CE Topical Report, CEN-630-P, Rev. 2, is currently approved by the NRC.Tube repair includes the installation by welding of the sleeves, heat treatment in accordance with CEN-630-P, Rev. 2, to remove the stresses that are introduced by the sleeve installation, acceptance testing of the sleeve, and nondestructive examination for future comparison.

Tube repair can be performed on certain tubes that have been previously plugged as a corrective or preventive measure. A tube inspection of the full length of the tube shall be performed on a previously plugged tube prior to returning the tube to service.In a part of the repair pressure boundary, there is a imitation in nondestructive examination.

The part of the repair pressure boundary is the parent tube adjacent to the nickel band portion (the lower half) of the lower joint that is formed by hard rolling. The limitation is that nondestructive examination may not be capable of detecting any type of degradation that may be M resent and may exceed the repair limit. The imitation does not affect structural integrity and leakageperformance, based on design review and laboratory testing documented in ABB/CE Topical Report CEN-630-P, Rev. 2, Addendum dated January 2006.2. The SG shall be determined OPERABLE after completing the corresponding actions (plug or repair all tubes exceeding the repair limit and all tubes containing through-wall cracks, and plug all sleeved tubes that exceed the repair criteria) required by Tables 5.5.2.11-1 and 5.5.2.11-2.

g. Reports The content and frequency of written reports shall be in accordance with Technical Specification 5.7.2, "Special Reports." (continued)

SAN ONOFRE--UNIT 3 5.0-19 Amendment No.

Enclosure 3 Response to NRC Request for Additional Information (RAI)

Enclosure 3 NRC Request for Additional Information and SCE Responses NRC Request: By letter dated October 26, 2004 (Agencywide Documents Access and Management System (ADAMS) Accession Number ML043020250), as supplemented by letter dated November 23, 2005 (ADAMS Accession Number ML05332021 0), Southern California Edison, the licensee for San Onofre Nuclear Generating Station, Unit No. 2, submitted a response to GL 2004-01. The NRC staff has reviewed these letters and has determined that additional information is needed in order for the NRC staff to complete a review. The NRC staff requests that the licensee respond to the following:

In its response to GL 2004-01, the licensee indicated the following concerning inspections of the parent tube behind (i.e., adjacent to) the nickel band portion of Combustion Engineering Alloy 690 tungsten inert gas welded sleeves: (1) the inspections adjacent to the nickel band are limited; (2) completion of the ongoing evaluation and technical basis development is expected within the next year; (3) this issue is being tracked within their corrective action program; and (4) flaws in the parent tube adjacent to the nickel band are not safety significant.

Given that it is not clear whether inspection techniques are capable of finding the forms of degradation that could be occurring in the parent tube adjacent to the nickel band and the licensee is relying on a safety assessment indicating that inspections in this region are not needed to ensure structural and leakage integrity, it would appear that a license amendment is required consistent with the NRC staff position outlined in GL 2004-01.With respect to the qualification of a technique for inspecting the parent tube adjacent to the nickel band, the NRC staff notes that existing analysis is based on electro-discharged machined (EDM) notches with adjustments to account for differences between cracks and EDM notches. As discussed in Regulatory Issue Summary 2000-22, "Issues Stemming from NRC Staff Review of Recent Difficulties Experienced in Maintaining Steam Generator Tube Integrity," the NRC staff position is that technique qualifications based on EDM notched specimens do not provide an adequate basis for evaluating the technique capability since EDM notched specimens produce much larger amplitude signals and have better signal-to-noise levels. EDM notches may also produce different signal response characteristics.

As a result of the above, we request the licensee discuss their plans (and schedule) for submitting an amendment demonstrating that structural and leakage integrity of the joint are ensured without inspecting the parent tube behind (i.e., adjacent to) the nickel band region. Alternatively, the licensee could either (1) demonstrate that the techniques they are using are capable of finding the forms of degradation that could be in the parent tube behind the nickel band region, or (2) commit to remove all sleeves with a nickel band from service.Page 1 of 3 SCE Response: Proposed amendment PCN-572 addresses a limitation in nondestructive examination that is present in sleeved tubes in the portion of the parent tube that is adjacent to the nickel band. This limitation is acceptable because design review and laboratory testing have demonstrated that structural integrity and leakage performance of the sleeved joint are within acceptable limits. The proposed amendment also includes a supporting addendum to the previously submitted Sleeving Topical Report CEN-630-P Revision 2.Discussion:

In earlier correspondence on this topic (Reference

2) an item in SCE's corrective action program was open to track ongoing work to enhance inspection capabilities in the area of the sleeve lower joint, specifically in the tubing adjacent to a nickel band. Work did not result in demonstration that the technique being used is capable of finding the forms of degradation that could be in the parent tube behind the nickel band region. SCE closed its action item on this approach.Additional work has been performed to demonstrate that structural and leakage integrity are maintained with existing inspection behind the nickel band and assuming credible forms of degradation of the tubing adjacent to the nickel band. This is contained in Westinghouse Owners Group (WOG) Project MSC-0190, (see Enclosures 5 and 6). This work was performed as an extension of earlier qualification testing in the Sleeving Topical Report and WOG document number WOG-05-388 that were previously provided to NRC (ADAMS Accession Numbers ML003737130 and ML052220335).

Enclosures 5 and 6 are addenda to the Sleeving Topical Reports CEN-630-P Rev. 2 and CEN-630-NP Rev. 2, the latter being the nonproprietary version. The Sleeving Topical Report has been reviewed by NRC staff.The results of the Enclosures 5 and 6 reports represent SCE's basis for its determination of joint integrity with existing inspection behind the nickel band and assuming the existence of postulated flaws in this location.

SCE is submitting Enclosures 5 and 6 for NRC review as addenda to the Sleeving Topical Reports CEN-630-P Rev. 2 and CEN-630-NP Rev. 2, the latter being the nonproprietary version. The data contained in the Enclosures 5 and 6 reports do not alter any conclusion developed within the design documents.

Safety Assessment The parent tube adjacent to the sleeve hardroll must be present in order for the sleeve hardroll joint to perform as designed.

Thus, the parent tube in this region should be inspected so that parent tube conditions that could challenge structural and leakage integrity of the sleeve are detected.

However, for a postulated condition of degradation Page 2 of 3 in the parent tube radially adjacent to the sleeve's nickel band, the remaining tube/sleeve hardroll joint length above the nickel band will provide anchorage consistent with the design requirement.

Therefore, in-service inspection capabilities within the parent tube due to the presence of the sleeve nickel band are not required to ensure structural or leakage integrity of the tube/sleeve hardroll joint. The technical basis for this position is CEN-630-P Revision 2 Addendum.In conclusion, steam generator operability is maintained because the plant is in compliance with the steam generator program elements of NEI 97-06 Revision 2, dated May 2005; specifically:

structural integrity performance criterion, accident induced leakage performance criterion, and operational leakage performance criterion.

References

1. Letter from A. E. Scherer (SCE) to Document Control Desk dated October 26, 2004,

Subject:

Docket Nos. 50-361 and 50-362, NRC Generic Letter 2004-01 Requirements for Steam Generator Tube Inspections, San Onofre Nuclear Generating Station, Units 2 and 3 2. Letter from A. E. Scherer (SCE) to Document Control Desk dated November 23, 2005,

Subject:

Docket Nos. 50-361 and 50-362, NRC Generic Letter 2004-01 Requirements for Steam Generator Tube Inspections, Additional Information, San Onofre Nuclear Generating Station, Units 2 and 3 Page 3 of 3 Enclosure 4 Proprietary Affidavit

( Westinghouse Westinghouse Electric Company Nuclear Services P. 0. Box 355 Pittsburgh, Pennsylvania 15230-0355 USA Directtel:

412-374-4643 Direct fax: 412-374-4211 e-mail: greshaja@westinghouse.com Our ref: CAW-06-2168 June 21, 2006 U.S. Nuclear Regulatory Commission Document Control Desk Washington, DC 20555-0001 APPLICATION FOR WITHHOLDING PROPRIETARY INFORMATION FROM PUBLIC DISCLOSURE

Reference:

SG-SGDA-05-48-P, "WOG PA-MSC-0190, Revision 1: Test Results Related to TIG and Alloy 800 Sleeve Installation in 3/4 Inch and 7/8 Inch OD SG Tubing In-Service Inspection Requirements" (Proprietary/Non-Proprietary)

The proprietary information for which withholding is being requested is contained in the above referenced document which is further identified in CAW-06-2168 signed by the owner of the proprietary information, Westinghouse Electric Company LLC (Westinghouse).

The affidavit, which accompanies this letter, sets forth the basis on which the information may be withheld from public disclosure by the Commission and addresses with specificity the considerations listed in paragraph (b)(4) of 10 CFR Section 2.390 of the Commission's regulations.

Accordingly, this letter authorizes the utilization of the accompanying affidavit by Southern California Edison.Correspondence with respect to the proprietary aspects of the application for withholding or the Westinghouse affidavit should reference this letter, CAW-06-2168, and should be addressed to: J. A. Gresham Manager, Regulatory Compliance and Plant Licensing Westinghouse Electric Company LLC P.O. Box 355 Pittsburgh, Pennsylvania 15230-0355.

Very truly yours, SJa s .Gresha Manager, Regulatory Compliance and Plant Licensing

Enclosure:

As stated A BNFL Group Company CAW-06-2168 Page I CAW-06-2 168 Page 1 AFFIDAVIT STATE OF CONNECTICUT

)) ss: WINDSOR, CT COUNTY OF HARTFORD)Before me, the undersigned authority, personally appeared Ian C. Rickard, who, being by me duly sworn according to law, deposes and says that he is authorized to execute this Affidavit on behalf of Westinghouse Electric Company LLC ("Westinghouse"), and that the averments of fact set forth in this Affidavit are true and correct to the best of his knowledge, information, and belief: Ian(C. Rickarýdg Project Manager Systems and Safety Analysis, Nuclear Services Westinghouse Electric Company, LLC Sworn to and subscribed before me this 21st day of June 2006.My commission expires-.. ..

CAW-06-2168 Page 2 (1) 1, Ian C. Rickard, depose and say that I am the Licensing Project Manager, Systems and Safety Analysis, in Nuclear Services, Westinghouse Electric Company LLC ("Westinghouse"), and as such I have been specifically delegated the function of reviewing the proprietary information sought to be withheld from public disclosure in connection with nuclear power plant licensing and rule making proceedings, and am authorized to apply for its withholding on behalf of the Westinghouse Electric Company LLC.(2) 1 am making this Affidavit in conformance with the provisions of 10 CFR Section 2.390 of the Commidssion's regulations and in conjunction with the Westinghouse application for withholding accompanying this Affidavit.

(3) 1 have personal knowledge of the criteria and procedures utilized by the Westinghouse Electric Company LLC in designating information as a trade secret, privileged or as confidential commercial or financial information.

(4) Pursuant to the provisions of paragraph (b)(4) of 10 CFR Section 2.390 of the Commission's regulations, the following is furnished for consideration by the Commission in determining wvhether the information sought to be withheld from public disclosure should be withheld.(i) The information sought to be withheld from public disclosure is owned and has been held in confidence by Westinghouse.(ii) The information is of a type customarily held in confidence by Westinghouse and not customarily disclosed to the public. Westinghouse has a rational basis for determining the types of information customarily held in confidence by it and, in that connection, utilizes a system to determine when and whether to hold certain types of information in confidence.

The application of that system and the substance of that system constitute Westinghouse policy and provide the rational basis required.Under that system, information is held in confidence if it falls in one or more of several types, the release of which might result in the loss of an existing or potential competitive advantage, as follows: (a) The information reveals the distinguishing aspects of a process (or component, structure, tool, method, etc.) where prevention of its use by any of Westinghouse's competitors without license from Westinghouse constitutes a competitive economice advantage over other companies.(b) It consists of supporting data, including test data, relative to a process (or component, structure, tool, method, etc.), the application of which data secures a competitive economic advantage, e.g., by optimization or improved marketability.(c) Its use by a competitor would reduce his expenditure of resources or improve his competitive position in the design, manufacture, shipment, installation, assurance of quality, or licensing a similar product.(d) It reveals cost or price information, production capacities, budget levels, or commercial strategies of Westinghouse, its customers or suppliers.(e) It reveals aspects of past, present, or future Westinghouse or customer funded development plans and programs of potential commercial value to Westinghouse.(f) It contains patentable ideas, for which patent protection may be desirable.(iii) There are sound policy reasons behind the Westinghouse system for classification of proprietary information, which include the following: (a) The use of such information by Westinghouse gives Westinghouse a competitive advantage over its competitors.

It is, therefore, withheld from disclosure to protect the Westinghouse competitive position.

CAW-06-2168 Page 3 (b) It is information that is marketable in many ways. The extent to which such information is available to competitors diminishes the Westinghouse ability to sell products and services involving the use of the information.(c) Use of this information by our competitors would put Westinghouse at a competitive disadvantage by reducing their expenditure of resources at our expense.(d) Each component of proprietary information pertinent to a particular competitive advantage is potentially as valuable as the total competitive advantage.

If competitors acquire components of proprietary information, any one component may be the key to the entire puzzle, thereby depriving Westinghouse of a competitive advantage.(e) Unrestricted disclosure of this information would jeopardize the position of prominence of Westinghouse in the world market, and thereby give a market advantage to the competition of those countries.(f) The Westinghouse capacity to invest corporate assets in research and development depends upon the success in obtaining and maintaining a competitive advantage.(iv) The information is being transmitted to the Commission in confidence and, under the provisions of 10 CFR Section 2.390; it is to be received in confidence by the Commission.(v) The information sought to be protected is not available in public sources or available information has not been previously employed in the same original manner or method to the best of our knowledge and belief.(vi) The proprietary information sought to be withheld by this submittal is that which is contained in "SG-SGDA-05-48-P, WOG PA-MSC-0190, Revision 1: Test Results Related to TIG and Alloy 800 Sleeve Installation in 3/4 Inch and 7/8 Inch OD SG Tubing In-Service Inspection Requirements", dated January 2006 (Proprietary), being transmitted by Southern California Edison letter and Westinghouse Application for Withholding Proprietary Information from Public Disclosure, to the NRC Document Control Desk. The proprietary information as submitted for use by San Onofre Units 2 and 3 is expected by Westinghouse to be applicable in other licensee submittals in response to certain NRC requirements for justification of the application of in-service inspection requirements for TIG and Alloy 800 steam generator sleeve installations.

This information is part of that which will enable Westinghouse to: (a) Install and perform in-service inspection requirements for TIG and Alloy 800 steam generator sleeves.(b) Support licensees in justification of the application of in-service inspection requirements for TIG and Alloy 800 steam generator sleeve installations.

Further this information has substantial commercial value as follows: (a) Westinghouse plans to sell the use of similar information to its customers for purposes of meeting NRC requirements for licensing documentation.(b) Westinghouse can sell support and defense of the in-service inspection requirements for TIG and Alloy 800 steam generator sleeve installations.(c) The information requested to be withheld reveals the distinguishing aspects of a methodology which was developed by Westinghouse Public disclosure of this proprietary information is likely to cause substantial harm to the competitive position of Westinghouse because it would enhance the ability of competitors to provide similar advanced nuclear power plant designs and to provide licensing defense services for commercial power reactors without commensurate expenses.

Also, public disclosure of the information would enable others to use the information to meet NRC requirements for licensing documentation without purchasing the right to use the information.

CAW-06-2168 Page 4 The development of the technology described in part by the information is the result of applying the results of many years of experience in an intensive Westinghouse effort and the expenditure of a considerable sum of money.In order for competitors of Westinghouse to duplicate this information, similar technical programs would have to be performed and a significant manpower effort, having the requisite talent and experience, would have to be expended.Further the deponent sayeth not.

PROPRIETARY INFORMATION NOTICE Transmitted herewith are proprietary and non-proprietary versions of documents furnished to the NRC in connection with requests for generic and/or plant-specific review and approval.

In order to conform to the requirements of 10 CFR 2.390 of the Commission's regulations concerning the protection of proprietary information so submitted to the NRC, the information which is proprietary in the proprietary versions is contained within brackets, and where the proprietary information has been deleted in the non-proprietary versions, only the brackets remain (the information that was contained within the brackets in the proprietary versions having been deleted).

The justification for claiming the information so designated as proprietary is indicated in both versions by means of lower case letters (a)through (0 located as a superscript immediately following the brackets enclosing each item of information being identified as proprietary or in the margin opposite such information.

These lower case letters refer to the types of information Westinghouse customarily holds in confidence identified in Sections (4)(ii)(a) through (4)(ii)(f) of the affidavit accompanying this transmittal pursuant to 10 CFR 2.390(b)(1).

COPYRIGHT NOTICE The reports transmitted herewith each bear a Westinghouse copyright notice. The NRC is permitted to make the number of copies of the information contained in these reports which are necessary for its internal use in connection with generic and plant-specific reviews and approvals as well as the issuance, denial, amendment, transfer, renewal, modification, suspension, revocation, or violation of a license, permit, order, or regulation subject to the requirements of 10 CFR 2.390 regarding restrictions on public disclosure to the extent such information has been identified as proprietary by Westinghouse, copyright protection notwithstanding.

With respect to the non-proprietary versions of these reports, the NRC is permitted to make the number of copies beyond those necessary for its internal use which are necessary in order to have one copy available for public viewing in the appropriate docket files in the public document room in Washington, DC and in local public document rooms as may be required by NRC regulations if the number of copies submitted is insufficient for this purpose. Copies made by the NRC must include the copyright notice in all instances and the proprietary notice if the original was identified as proprietary.