ML12348A507
| ML12348A507 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 12/13/2012 |
| From: | Burdick S, Frantz S, Porter D Morgan, Morgan, Lewis & Bockius, LLP, Southern California Edison Co |
| To: | Atomic Safety and Licensing Board Panel |
| SECY RAS | |
| References | |
| RAS 23881, 50-361-CAL, 50-362-CAL, ASLBP 13-924-01-CAL-BD01 | |
| Download: ML12348A507 (25) | |
Text
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
)
In the Matter of )
) Docket Nos. 50-361-CAL & 50-362-CAL SOUTHERN CALIFORNIA EDISON COMPANY )
)
(San Onofre Nuclear Generating Station, ) December 13, 2012 Units 2 and 3) )
)
SOUTHERN CALIFORNIA EDISON COMPANYS ANSWER OPPOSING PETITIONERS MOTION TO AMEND THE BOARDS DECEMBER 7, 2012 ORDER I. INTRODUCTION On December 7, 2012, the Atomic Safety and Licensing Board (Board) issued an order in this proceeding with a briefing schedule and obligations for Southern California Edison Company (SCE) to disclose certain proprietary documents to Friends of the Earth (FOE).1 On December 11, 2012, FOE filed Petitioners Motion to Amend the Proposed Scheduling Order and Clarify Scope of Disclosure (Motion), requesting that the Board modify the December 7 Order to require the disclosure of additional proprietary documents and extend the briefing schedule.
Pursuant to 10 C.F.R. § 2.323(c) and the Boards December 12, 2012 order,2 SCE submits this Answer opposing FOEs Motion. As discussed below, the Boards December 7 Order clearly identifies the proprietary documents that must be disclosed, and SCE disclosed those documents on December 12, 2012 shortly after FOE executed its initial Non-Disclosure 1
Order (Conference Call Summary and Directives Relating to Briefing) (Dec. 7, 2012) (December 7 Order)
(unpublished).
2 Order (Directing SCE and NRC Staff to File Expedited Answers to Petitioners Extension and Clarification Request) (Dec. 12, 2012) (unpublished).
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Affidavits (NDAs) required by the December 10, 2012 Protective Order.3 FOEs request for additional documents beyond the Boards December 7 Order is an unauthorized discovery request, and those documents are unnecessary for FOE to brief the issues within the scope of this proceeding and to respond to the Boards questions. Additionally, FOE has not demonstrated good cause or unavoidable and extreme circumstances for an extension of the briefing schedule.
FOE has had access to the Confirmatory Action Letter (CAL) since March 2012, and has had access to the public version of SCEs CAL Restart Plan since October 2012.4 Most of the proprietary documents included in the CAL response include only minimal redacted information, and the vast majority of the information in those documents has been publicly available for months. Any delay in obtaining the proprietary information in those documents was due to delay in FOEs execution of the NDAs. The type of delay requested by FOE in this proceeding could significantly harm SCEs efforts to restart San Onofre Nuclear Generating Station (SONGS) Unit 2. In addition, the CAL and Restart Plan describe in detail the requirements imposed by the CAL and the responsive actions being taken by SCE, and therefore include all the information needed for a determination as to whether the CAL is a de facto license amendment.
For these reasons, the Motion should be rejected in its entirety and the disclosure obligations and briefing schedule should proceed according to the Boards December 7 Order.
3 Order (Granting Joint Motion for Entry of a Protective Order and Non-Disclosure Agreement) (Dec. 10, 2012)
(Protective Order) (unpublished).
4 See Letter from P. Dietrich, SCE, to E. Collins, NRC, Confirmatory Action Letter - Actions to Address Steam Generator Tube Degradation (Oct. 3, 2012) (Restart Plan), available at ADAMS Accession No. ML122850320.
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II. BACKGROUND On March 27, 2012, the Nuclear Regulatory Commission (NRC or Commission) issued the CAL to SCE regarding the SONGS Units 2 and 3 steam generator degradation issues.
SCE submitted the Restart Plan on October 3, 2012 responding to the CAL with the plan for restart of SONGS Unit 2.
FOE submitted a Petition to Intervene and Request for Hearing (Petition) to the NRC on June 18, 2012. On November 8, 2012, the Commission issued decision CLI-12-20, which rejected FOEs request for hearing on whether the replacement steam generators required a license amendment and referred to the Atomic Safety and Licensing Board Panel that portion of the Petition related to the CAL.5 The Board held a conference call with counsel for SCE, FOE, and the NRC staff on December 3, 2012 to discuss scheduling and management of this proceeding.6 The Board issued the December 7 Order a few days later, which requires that SCE disclose the proprietary versions of the October 3 Restart Plan documents to FOE and specifies a briefing schedule concluding on January 14, 2013.7 Last week, FOE proposed a briefing schedule to SCE that would extend the briefing until March 1, 2013 and submitted a document request to SCE for 60 items.8 SCE rejected the document request as beyond the scope of the Boards directions and unnecessary for this proceeding. Additionally, SCE rejected the briefing schedule extension as excessive and 5
Southern California Edison Co. (San Onofre Nuclear Generating Station, Units 2 and 3), CLI-12-20, 76 NRC
__, slip op. at 3-5 (Nov. 8, 2012).
6 Order (Scheduling Conference Call) (Nov. 26, 2012) (unpublished).
7 December 7 Order at 4-5.
8 See Letter from R. Ayres, FOE Counsel, to SCE Counsel, Proposed Briefing Schedule and Request for Documents (Dec. 4, 2012). FOE provided the Board members with copies of this letter via email.
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unnecessary because the requested extension was based on FOEs review of the 60 requested documents. SCE stated that it was willing to consider any other reasonable proposals from FOE, but did not receive any further proposals from FOE.
Additionally, as discussed on the conference call and in the December 7 Order, SCE and FOE coordinated to prepare a proposed protective order and NDA for approval by the Board.
SCE and FOE filed these with the Board on December 7, 2012.9 The Board issued the Protective Order on December 10, 2012.10 FOE filed its Motion the next day. The Motion requests an extension of the briefing schedule to February 22, 2013, and requests the Board order SCE to disclose 126 items to FOE.
III. FOES REQUEST TO EXPAND DISCLOSURE REQUIREMENTS SHOULD BE REJECTED A. FOEs Request Is Contrary to the December 7 Order In the December 7 Order, the Board directed SCE to disclose certain proprietary documents to FOE following approval of the Protective Order and execution of an NDA.11 FOE seeks the disclosure of over one hundred additional non-public items.12 FOE explains that its view is that its request is not a discovery request, but rather a clarification of items the Board has already ordered to be produced.13 FOEs Motion should be rejected as contrary to the December 7 Order.
The December 7 Order identified very specific proprietary documents that must be disclosed to FOE. The Order states:
9 Joint Motion for Entry of a Protective Order (Dec. 7, 2012).
10 Order (Granting Joint Motion for Entry of a Protective Order and Non-Disclosure Agreement) (Dec. 10, 2012)
(unpublished).
11 See December 7 Order at 4.
12 See Motion, Attachments 1 and 2.
13 Id. at 2 n.1.
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Counsel for SCE is therefore directed, in coordination with counsel for Friends of the Earth, to effect the preparation and execution of a Joint Non-Disclosure Agreement regarding (1) the proprietary versions of the documents in SCEs response to the CAL (supra note 5), and (2) the proprietary versions of the other documents SCE generated pursuant to the CAL that are located in SCEs Restart Plan (supra note 6).14 Consistent with this paragraph, the two categories of documents are those described in footnotes 5 and 6 of the December 7 Order.
The first category is the proprietary documents in SCEs response to the CAL.
Footnote 5 explains that this is the October 3, 2012 letter from SCE to the NRC found at ADAMS Accession No. ML12285A263, including the two enclosures to the letter.15 The second category is the proprietary documents in SCEs Restart Plan. Footnote 6 states that the Restart Plan consists of documents (including SCEs response to the CAL) generated by SCE pursuant to the CAL. The redacted versions of these documents are located in a package in ADAMS at ML122850320.16 In other words, the proprietary documents that must be disclosed are all of the proprietary versions of SCEs October 3 Restart Plan documents that included redacted information.
FOEs Motion requests documents well beyond those specified in the December 7 Order.
The Order only requires the disclosure of the proprietary versions of the eight documents identified in Table 1 of Attachment 1 to FOEs Motion. It does not require disclosure of the other 118 items identified in the attachments to FOEs Motion. Therefore, FOEs request for the Board to interpret (or amend) the December 7 Order to require disclosure of these documents should be rejected.
14 December 7 Order at 4.
15 Id. at 4 n.5.
16 Id. at 4 n.6.
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SCE transmitted the proprietary versions of the documents in the October 3 Restart Plan to FOE on December 12, 2012, shortly after FOE executed NDAs pursuant to the December 10, 2012 Protective Order. FOE stated that SCE has so far delivered no documents under the Boards Order.17 At the time FOE made this statement, it had not yet executed the NDA required by the Protective Order.18 Until FOE did so, SCE could not disclose the proprietary documents.
B. FOEs Request Seeks Unauthorized Document Discovery FOEs request for access to over one hundred additional non-public items is an improper discovery request. The document disclosure requirements for NRC adjudicatory proceedings are found in 10 C.F.R. § 2.336, and only require document disclosures following granting of a hearing request or petition to intervene. The Board has not granted FOEs Petition, and therefore these disclosure obligations have not yet begun. The Commission has addressed similar requests in the context of proposed contentions and has concluded that such requests are contrary to our rules and longstanding precedent barring discovery in connection with the preparation of proposed contentions.19 Similarly, the Commission has stated: We have long precluded petitioners from using discovery as a device to uncover additional information supporting the admissibility of contentions.20 The briefing at issue in this proceeding is directly relevant to whether the proposed contention in FOEs Petition is admissible. Therefore, the Commissions prohibition on discovery at the pleading stage applies.
17 Motion at 6.
18 See Protective Order at 2 (allowing access to Protected Information to specified personnel only if they execute and file the attached Non-Disclosure Affidavit).
19 AmerGen Energy Co., LLC (Oyster Creek Nuclear Generating Station), CLI-08-28, 68 NRC 658, 676 (2008).
20 Consumers Energy Co. (Palisades Nuclear Power Plant), CLI-07-18, 65 NRC 399, 416 (2007).
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Because FOEs request for access to additional non-public documents is an unauthorized discovery request, it should be rejected. The Board already has taken the extraordinary action of requiring SCE to disclose the proprietary versions of the documents in the October 3 Restart Plan. At this stage of the proceeding, FOE is not entitled to any further documents.
C. FOE Has Not Justified Access to Additional Documents Even if a document request were permissible, FOE has not justified the need for access to the documents. Rather than explain why the documents are needed, FOE concludes: Since these documents are quoted or referred by SCE in support of the companys response to the CAL and restart plan, there can be no argument regarding their relevance to this proceeding.21 Contrary to FOEs arguments, a document is not relevant to this proceeding merely because it is referenced in the various documents in SCEs Restart Plan. FOE has not justified its need for the documents, and therefore its request should be rejected.
The scope of this proceeding is narrow. The Commission in CLI-12-20 directed the Board to consider whether the Confirmatory Action Letter issued to SCE constitutes a de facto license amendment that would be subject to a hearing opportunity under Section 189a.22 The Boards December 7 Order explains that the issues we must consider include whether the CAL granted SCE any greater operating authority and whether the activities authorized in the CAL extended beyond the ambit of the prescriptive authority granted under the license.23 The Board has further explained that the scope of this proceeding is not whether the restart plan is adequate or appropriate, but whether the CAL itself is a de facto license amendment.24 21 Motion at 3.
22 San Onofre, CLI-12-20, slip op. at 5.
23 December 7 Order at 3 (quoting Cleveland Elec. Illuminating Co. (Perry Nuclear Power Plant, Unit 1), CLI-96-13, 44 NRC 315, 327 (1996)).
24 Id. at 4.
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Given this scope, the March 27, 2012 CAL and SCEs October 3, 2012 Restart Plan should be more than sufficient for FOE to prepare its brief. In particular, Sections 7, 8, and 9 of the Return to Service Report contain a detailed description of the restart actions for Unit 2, and none of that information is proprietary or redacted.25 As the Board has stated, FOE need not determine whether the restart plan is adequate or appropriate, only whether the CAL granted SCE any greater operating authority and whether any activities authorized in the CAL extended beyond those granted under the current operating licenses. FOE need not evaluate every document remotely connected to the Restart Plan to do this.
FOE identifies three examples of additional documents that it claims to need. None of these examples, however, supports FOEs position:
- FOE first claims that it needs the identity of Reactor A, because [n]either the Board nor Petitioner will be able to assess whether running San Onofre Unit 2 will cause a more than minor increase in the risk of damage to the steam generator unless we know the identity of Reactor A.26 Initially, it should be noted that such a request is in the nature of an interrogatory, not a document request. Even if FOE were admitted as a party, it would be prohibited from submitting interrogatories pursuant to 10 C.F.R. § 2.336(g). In any event, FOE has not explained why it needs this information to determine whether the CAL or any activity authorized by the CAL is a de facto license amendment. Instead, this issue goes directly to the question of whether the restart plan is adequate, which the Board explained is outside the scope of this proceeding.27 25 Restart Plan, Enclosure 2.
26 Motion at 3.
27 December 7 Order at 4.
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- FOE seeks access to SCEs 50.59 analysis in order to respond to the Boards Question (iii).28 Question (iii), however, questions the extent to which 10 C.F.R. § 50.59(c)(1) and (c)(2) apply to this proceeding, not whether SCEs 50.59 analysis was performed correctly.29 In any event, as discussed above, Sections 7, 8, and 9 of the publicly-available Return to Service Report contain a detailed description of the restart actions for Unit 2. That information is sufficient for FOE to perform its own evaluations and prepare its own brief on whether the restart actions require a license amendment under 10 C.F.R.
§ 50.59.
- FOE seeks access to the Final Safety Analysis Report (FSAR) in order to respond to Board Question (iv) related to a steam generator tube rupture (SGTR).30 FOE did not previously request SCE to provide FOE with a copy of the FSAR section that pertains to SGTR, and the first time that FOE raised this matter was in its Motion. SCE is willing to make this FSAR section available to FOE, and is providing it as Attachment 1 to this Answer.
Aside from these examples, FOE alleges that the documents are needed to respond to Questions (iv) - (vii) posed by the Board in the December 7 Order.31 Question (iv) is addressed above. Questions (v) - (vii) identify specific questions about information in the Tube-to-Tube Report,32 and Tables 3 and 4 in Attachment 1 to the Motion identify the documents requested by FOE to answer the Boards questions related to the Tube-to-Tube Report (which is 28 Motion at 4.
29 December 7 Order at 6.
30 Motion at 4.
31 Id.
32 December 7 Order at 6-7.
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Attachment 6, Appendix B, of the Return to Service Report). However, as is indicated in Tables 3 and 4 of the Motion, the vast majority of the documents requested by FOE are not referenced in the Tube-to-Tube Report, and FOE does not even attempt to demonstrate that they have any relevance to the Boards questions on the Tube-to-Tube Report. Thus, FOE simply has not demonstrated a need for all of these documents.
Furthermore, it appears that FOE is engaged in a fishing expedition and trying to delay this proceeding. In total, the documents requested by FOE amount to many thousands of pages.
Most of the documents requested by FOE have no apparent relevance to whether the CAL constitutes a de facto license amendment. For example:
- FOE requests numerous documents that pertain to the original design and manufacturing of the replacement steam generators, including the procurement specification.33 Those documents have no apparent relevance to whether the CAL and SCEs restart actions require a license amendment. Furthermore, such topics appear to address FOEs claims that the replacement steam generators needed an additional license amendment, which is an issue explicitly excluded from the scope of this proceeding by the Commission decision in CLI-12-20.34
- FOE requests a number of documents that are publicly available through the NRCs web site.35 33 See, e.g., Motion, Attachment 1, Table 3, Items 13, 22, 23, 26, 27, 28, 32, 33; Attachment 1, Table 4, Item 59; Attachment 2, Items 1, 3, 4, 5, 6, 8, 10, 11, 12, 13, 14, 15, 16, 17, 18, 19, 20, 21, 22, 23, 24, 25, 26, 27, 29, 30, 31, 32, 33, 34, 35, 36, 37, 38, 39, 40, 41, 44, 45, 46, 48, 50, 51, 52, 53, 55, 56, 57, 59.
34 San Onofre, CLI-12-20, slip op. at 3-4.
35 See, e.g., Motion, Attachment 1, Table 4, Items 46, 47, 48; Attachment 2, Item 58.
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- FOE requests an entire copy of the SONGS Updated FSAR, most of which is not relevant to the steam generators.36 In summary, even if FOE had a right to additional documents in this proceedingwhich it does notFOE has not demonstrated a need for those documents. The CAL and the Restart Plan provide sufficient information for FOE to brief the issues within the scope of this proceeding and to respond to the Boards questions directed to FOE. Therefore, FOEs expansive document request should be rejected.
IV. FOES REQUEST TO DELAY THIS PROCEEDING SHOULD BE REJECTED FOE seeks a significant extension in the briefing schedule for this proceeding. Under the December 7 Order, the briefing would be completed on January 14, 2013.37 Under FOEs briefing schedule, the briefing would not be completed until February 22, 2013 (assuming FOE receives its requested documents by December 14).38 FOE bases its extension request on the need to obtain and review additional non-public documents.39 The NRC regulations, 10 C.F.R. § 2.307(a), only allow extensions for good cause. The Commission has explained that good cause, in the context of adjudicatory filings, requires a showing of unavoidable and extreme circumstances.40 As the Commission stated in its 1998 Policy Statement: The Commission, of course, recognizes that the boards may grant extensions of time under some circumstances, but 36 Motion, Attachment 2, Item 28.
37 December 7 Order at 5.
38 Motion at 6.
39 See id. at 5-6.
40 See Balt. Gas & Elec. Co. (Calvert Cliffs Nuclear Power Plant, Units 1 & 2), CLI-98-25, 48 NRC 325, 342 (1998) (holding that construction of good cause to require a showing of unavoidable and extreme circumstances constitutes a reasonable means of avoiding undue delay); see also Hydro Res., Inc. (2929 Coors Road Suite 101, Albuquerque, NM 87210), CLI-99-1, 49 NRC 1, 3 n.2 (1999) (We caution all parties in this case, however, to pay heed to the guidance in our policy statement that ordinarily only unavoidable and extreme circumstances provide sufficient cause to extend filing deadlines.).
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this should be done only when warranted by unavoidable and extreme circumstances.41 Because no such circumstances are present here, FOE has not demonstrated good cause for its extension request, and any extension should be rejected.
As discussed above, the proprietary documents that must be disclosed to FOE are specifically identified in the Boards December 7 Order. These are the proprietary versions of the October 3 Restart Plan, including the enclosures and attachments. FOE states that SCE has so far delivered no documents under the Boards Order.42 As discussed above, SCE transmitted these documents to FOE on December 12, 2012, shortly after FOE executed the NDA required by the December 10, 2012 Protective Order. Any delay in executing the NDA can only be attributed to FOE, and does not provide good cause for any briefing schedule extension.
Additionally, FOE and its experts already have had a significant amount of time to review the CAL and SCEs Restart Plan. The CAL is dated March 27, 2012, and is publicly available in its entirety. The Restart Plan was submitted on October 3, 2012, and most of it, including a description of the actions SCE intends to take to comply with the CAL, is publicly available. The CAL response letter itself, Enclosure 1 (list of commitments), the main report of the Return to Service Report (RTSR) in Enclosure 2 (which identifies SCEs restart actions for Unit 2), and RTSR Attachment 1 (SONGS Unit 2 Relevant Technical Specifications) are publicly available in their entirety. Other documents, such as RTSR Attachment 2 (SONGS 2C17 Steam Generator Condition Monitoring Report), Attachment 3 (SONGS Unit 3 February 2012 Leaker Outage Steam Generator Condition Monitoring Report), Attachment 5 (Screening Criteria for Susceptibility to In-Plane Tube Motion), and Attachment 6 (U2C17 Steam Generator 41 Statement of Policy on Conduct of Adjudicatory Proceedings, CLI-98-12, 48 NRC 18, 21 (1998).
42 Motion at 6.
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Operational Assessment) were minimally redacted. Most of the redactions were in RTSR Attachment 4 (Tube Wear of Unit-3 RSG Technical Evaluation Report), and focused primarily on figures and tables. Nonetheless, the vast majority of the October 3 Restart Plan and its enclosures and attachments have been publicly available since October, and were available for review by FOE and its experts. In particular, SCE estimates that more than 80% of the October 3 Restart Plan was unredacted and available to the public. Therefore, any extension request based on the need to review this information is without good cause.
Furthermore, FOE bases its extension request on the need for it and its experts to review the additional non-public documents that it requested in its Motion.43 As discussed above in Section III, FOE does not have a right to documents beyond those the Board required to be disclosed in the December 7 Order. Therefore, the need for time to review those additional documents does not exist, and does not provide good cause for any extension. Even if FOE had a right to these documents, the excessive extension it requests would not be justified. FOE has presented no unavoidable and extreme circumstances for a lengthy delay.
Any delay in this proceeding could result in significant harm to SCE. SCE has submitted its Restart Plan for SONGS Unit 2 to the NRC, and is awaiting a decision on restart. Completion of this proceeding is not a prerequisite to the NRC staff authorizing restart of Unit 2 under the CAL. However, FOE has already filed one unsuccessful request to stay restart,44 and SCE cannot predict what other pretense FOE may raise to interfere with authorization of restart of the facility. Therefore, any delay in this proceeding could have a direct consequence on SCE. This harm weighs in favor of rejecting the extension request.
43 Id. at 5-6.
44 See San Onofre, CLI-12-20, slip op. at 5-6.
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V. CONCLUSIONS As demonstrated above, FOEs Motion should be rejected. FOEs request for access to additional proprietary documents seeks documents outside the Boards December 7 Order on this topic, is an unauthorized discovery request, and is unsupported. Additionally, FOE has not provided any good cause for its request for an extension to its briefing schedule. For these reasons, the document disclosures and briefing schedule should proceed according to the Boards December 7 Order.
Respectfully submitted, Executed in Accord with 10 C.F.R. § 2.304(d)
Steven P. Frantz Stephen J. Burdick Morgan, Lewis & Bockius LLP 1111 Pennsylvania Avenue, NW Washington, DC 20004 Phone: 202-739-5460 E-mail: sfrantz@morganlewis.com Douglas Porter Director and Managing Attorney Generation Policy and Resources Law Department Southern California Edison Company 2244 Walnut Grove Avenue GO1, Q3B, 335C Rosemead, CA 91770 Phone: 626-302-3964 E-mail: Douglas.Porter@sce.com Counsel for Southern California Edison Company Dated in Washington, D.C.
this 13th day of December 2012 DB1/ 72473685.3 14
Attachment 1 San Onofre 2&3 FSAR Updated TRANSIENT ANALYSIS The offsite radiological doses for the Primary Sample or Instrument Line Break with an accident-induced iodine spike are a small fraction (i.e., do not exceed 10%) of the 10 CFR 100 exposure guidelines, and the Control Room radiological doses are within the 10 CFR 50 Appendix A General Design Criterion 19 exposure guidelines.
15.10.6.3.2 Steam Generator Tube Rupture with Concurrent Loss of AC Power Introduction A Steam Generator Tube Rupture (SGTR) event is a penetration of the barrier between the Reactor Coolant System (RCS) and the main steam system via the double-ended break of a U-tube. This causes highly radioactive RCS fluid to contaminate the secondary side. The radioactivity is released via the condenser air ejectors, the Main Steam Safety Valves (MSSVs),
and the Atmospheric Dump Valves (ADVs).
This event is analyzed with a concurrent loss of AC power, which increases the radiological release to the environment (see section 15.6.3.2.5). It is this analysis which is presented below.
If the primary to secondary leak is beyond the capacity of the charging pumps, the reactor will eventually trip on a low pressure trip signal. As a result of the loss of AC, the electrical power would be unavailable for the station auxiliaries such as the Reactor Coolant Pumps (RCPs) and the Main Feed Water (MFW) pumps. Under such circumstances, the plant would experience a simultaneous loss of load, normal feed water flow, forced reactor coolant flow and steam generator blowdown capability.
When the reactor is off line, stored energy and fission product decay energy must be dissipated by the reactor coolant and main steam systems. In the absence of forced reactor coolant flow, convective heat transfer is supported by natural circulation reactor coolant flow. Initially, the liquid inventory in the steam generators is used and the resultant steam is released to the atmosphere via the MSSVs. With the availability of stand-by power provided by the automatic start-up of the diesel generators, Auxiliary (emergency) Feed Water (AFW) flow is initiated on a low steam generator level signal.
When the reactor plant has been stabilized in Mode 3, the operator achieves plant cool down using remotely operated ADVs. The plant is cooled to 350°F at a nominal rate of 75°F/hr. At this time, Shut Down Cooling (SDC) is initiated.
The analysis of record conservatively assumes the operator action to isolate the affected steam generator is delayed until 30 minutes after initiation of the event. The operators diagnosis of the SGTR event is facilitated by the radiation monitors which initiate alarms and signal the existence of abnormal radioactivity levels.
Radiation monitors are found in the blowdown sample lines from each steam generator, in the blowdown processing system neutralization sump discharge sea line which processes blowdown from both steam generators, and in the condenser air ejector discharge line. Additional 15.10-177 Rev: 44
San Onofre 2&3 FSAR Updated TRANSIENT ANALYSIS diagnostic information is provided by RCS pressure and pressurizer level response indicating a loss of primary coolant. Level in the affected steam generator increases as the primary fluid enters the steam generator driven by the substantially higher primary pressure.
The offsite and control room dose consequences of the postulated steam generator tube rupture are analyzed for the assumed conditions of no iodine spike, a pre-accident iodine spike, and an accident initiated iodine spike in the reactor coolant.
Summary of Methods The CESEC-III code is used to simulate the transient for the first 1800 seconds (i.e., 30 minutes).
The output of the code provides the amount of primary to secondary leak, the amount of steam transported from the steam generators through the MSSVs and the overall Nuclear Steam Supply System (NSSS) response to the event. This information is then used to derive the radiological releases and accompanying doses.
This analysis is primarily performed to establish the parameters, such as the primary to secondary mass transferred during the event, by which the radiological releases are calculated.
There is no specific acceptance criteria for the mass releases.
One computer case was run for this analysis. This was an 1800 seconds CESEC-III simulation of a double-ended SGTR in the right hand (arbitrary designation) steam generator. This case utilizes a 15% MSSV blowdown model to determine the impact on steam released to atmosphere.
The primary transient analysis inputs and assumptions for the analysis are presented below in Table 15.10.6.3.2-1. The sequence of events is provided in Table 15.10.6.3.2-2.
The dose methodology for this event is described in Appendices 15B and 15.10.B. Using this methodology, design basis 0-2 hour Exclusion Area Boundary, 0-30 day Low Population Zone, and 0-30 day Control Room doses were calculated with and without consideration of pre-existing and accident induced iodine spikes.
The following release mechanisms that can disperse radioactive material into the atmosphere have been evaluated:
- 1. Reactor coolant releases via the ruptured tube into the affected steam generator, and eventually to the outside environment.
- 2. Normal primary to secondary leakage releases into the affected and intact steam generators, and eventually to the outside environment.
- 3. Main steam safety valve releases from the affected and intact steam generators to the outside environment.
15.10-178 Rev: 44
San Onofre 2&3 FSAR Updated TRANSIENT ANALYSIS
- 4. Turbine-driven auxiliary feed water pump venting of secondary steam from the affected and intact steam generators to the outside environment.
- 5. Atmospheric dump valve releases of secondary steam from the intact steam generator to the outside environment.
- 6. Leakage past one or more of the affected steam generator MSSVs and/or its ADV (subsequent to operator action to isolate the affected steam generator).
Conservatively, the total leakage is modeled as being equivalent to the flow capacity of a MSSV.
The principal assumptions and inputs for the dose analysis are presented below in Table 15.10.6.3.2-3.
15.10-179 Rev: 44
San Onofre 2&3 FSAR Updated TRANSIENT ANALYSIS Table 15.10.6.3.2-1 Principal Assumptions and Inputs for SGTR Parameter Unit 2 Unit 3 Core Power 3478 MWth 3478 MWth Inlet Temperature 560°F 560°F RCS Pressure 2300 psia 2300 psia SG Pressure 900 psia 900 psia Core Flow, Total 376,200 gpm 376,200 gpm BOC Doppler Uncertainty Multiplier 0.86 0.86 Moderator Temperature Coefficient -3.7 x 10-4 'U/°F -3.7 x 10-4 'U/°F SCRAM Worth -6.0 % 'U -6.0 % 'U CPC (range - low pressure) Trip Set Point 1785 psia 1785 psia Loss of AC Power Coincident with Coincident with Reactor Trip Reactor Trip Steam Generator (S/G) U-Tube Break Size 45% Double 45% Double Ended Guillotine Ended Guillotine Safety Injection Actuation System - Set 1785 psia 1785 psia Point High Pressure Safety Injection - Response 15.0 seconds 15.0 seconds Time Main Feed Water (MFW) - Flow Rate 102% of Design 102% of Design Main Feed Water (MFW) - Enthalpy 425 Btu/lbm 425 Btu/lbm (pre-trip) (pre-trip)
Auxiliary Feed Water (AFW) - Response 57.7 secs. electric 57.7 secs. electric Time and steam driven and steam driven Auxiliary Feed Water (AFW) - Flow Rate 601 gpm at 1000 601 gpm at 1000 psia psia Auxiliary Feed Water (AFW) - Enthalpy 68 Btu/lbm 68 Btu/lbm Charging Flow Rate 135 gpm 135 gpm Letdown Flow Rate 0.0 gpm 0.0 gpm 15.10-180 Rev: 44
San Onofre 2&3 FSAR Updated TRANSIENT ANALYSIS Table 15.10.6.3.2-1 (continued)
Principle Assumptions and Inputs for SGTR Parameter Unit 2 Unit 3 Main Steam Safety Valves (MSSV) - 1067 to 1120.4 1067 to 1120.4 Opening Set Points psia psia (9 valves at 7 psi increments. -3% Tolerance -3% Tolerance Includes set point tolerance)
MSSV Accumulation Set Point 0% 0%
MSSV Blow Down 15% (to fully 15% (to fully close) close)
Atmospheric Dump Valves (ADVs) Inoperative Inoperative Feed Water Control System (FWCS) Not Required to Not Required to Mitigate Event Mitigate Event Pressurizer Pressure Control System (PPCS) Not Required to Not Required to Mitigate Event Mitigate Event Steam Bypass Control System (SBCS) Inoperative Inoperative 15.10-181 Rev: 44
San Onofre 2&3 FSAR Updated TRANSIENT ANALYSIS Table 15.10.6.3.2-2a Sequence of Events for SGTR, Unit 2 Time Chronological Event Set Point or Value (Seconds) 0.0 S/G Tube rupture occurs ----
1329.4 CPC Reactor Trip (low pressurizer pressure) 1785 psia setpoint reached, SIAS initiated 1330.3 Reactor Trip breakers open ----
Turbine Stop Valves close Loss of Normal AC 1333.1 MSSVs begin to open on both S/Gs 1067 psia 1337.9 Maximum S/G pressure on both generators 1112 psia 1356.1 Low S/G level signal generated, AFW initiated 115,610 lbm 1795.8 MSSVs close on both S/Gs 907 psia 1800.0 Damaged S/G isolated, ----
ADV on unaffected S/G opened to begin system cool down to Shut Down Cooling (SDC) 11880.0 Shut Down Cooling (SDC) initiated Temperature 350°F Total steam release 739,034 lbm 15.10-182 Rev: 44
San Onofre 2&3 FSAR Updated TRANSIENT ANALYSIS Table 15.10.6.3.2-2b Sequence of Events for SGTR, Unit 3 Time Chronological Event Set Point or Value (Seconds) 0.0 S/G Tube rupture occurs ----
1329.4 CPC Reactor Trip (low pressurizer pressure) 1785 psia setpoint reached, SIAS initiated 1330.3 Reactor Trip breakers open ----
Turbine Stop Valves close Loss of Normal AC 1333.1 MSSVs begin to open on both S/Gs 1067 psia 1337.9 Maximum S/G pressure on both generators 1112 psia 1356.1 Low S/G level signal generated, AFW initiated 115,610 lbm 1795.8 MSSVs close on both S/Gs 907 psia 1800.0 Damaged S/G isolated, ----
ADV on unaffected S/G opened to begin system cool down to Shut Down Cooling (SDC) 11880.0 Shut Down Cooling (SDC) initiated Temperature 350°F Total steam release 739,034 lbm 15.10-183 Rev: 44
San Onofre 2&3 FSAR Updated TRANSIENT ANALYSIS Table 15.10.6.3.2-3 Principal Assumptions and Inputs for Steam Generator Tube Rupture Dose Analysis Parameter Unit 2 Unit 3 AC Availability Loss of AC Loss of AC Power Power RCS Iodine Activity (Dose Equivalent I-131), Ci/gm 1.0 1.0 Increase in Iodine Release Rate from Fuel for Accident 500 500 Induced Iodine Spike RCS Pre-Existing Iodine Spike Iodine Activity (Dose 60 60 Equivalent I-131), Ci/gm RCS Non-Iodine Activity, Ci/gm 100/ 100/
Secondary Liquid Iodine Activity (Dose Equivalent 0.1 0.1 I-131), Ci/gm Steam Generator Iodine Partition Coefficient 0.01 0.01 Primary to Secondary Leak Rate into each SG, gpm 0.5 0.5 Integrated primary to secondary rupture flow, lbm 70,563 70,563 (1,800 seconds)
Additional primary to secondary rupture and normal 150,000 150,000 leakage flow available for release from 30 minutes to shut down cooling due to MSSV/ADV valve seat leakage, lbm Integrated MSSV flow, lbm (1,800 seconds)
LH - Unaffected 57,560 57,560 RH - Affected 57,664 57,664 Total MSSV Flow 115,224 115,224 AFW Flow (steam driven pump), lbm (1,800 seconds) 4,922 4,922 Steam Release (30 - 120 minutes), lbm 331,547 331,547 Total steam release (0 - 120 minutes), lbm 451,693 451,693 Total steam release to Shut Down Cooling, lbm 739,034 739,034 Additional affected steam generator steam release from 2,400,000 2,400,000 30 minutes to shut down cooling due to MSSV/ADV valve seat leakage, lbm Control Room Isolation Signal High Radiation High Radiation Control Room Isolation Time, min 3 3 Offsite Dose Evaluation Model Appendix 15B Appendix 15B and Appendix and Appendix 15.10B 15.10B Control Room Dose Evaluation Model Appendix 15B Appendix 15B and Appendix and Appendix 15.10B 15.10B 15.10-184 Rev: 44
San Onofre 2&3 FSAR Updated TRANSIENT ANALYSIS Results The primary to secondary mass transfer and steam release data required to perform radiological calculations for the steam generator tube rupture event are presented in Table 15.10.6.3.2-3.
The RCS and secondary system pressures remain below the 110% of the design pressure limits, thus, assuring the integrity of these systems.
The results of the most recent analysis of the potential off site and control room personnel doses from a steam generator tube rupture with concurrent loss of normal AC power are presented in Table 15.10.6.3.2-4. These results are compared against the NRC approved acceptance criteria in section 15.6.3.2.
15.10-185 Rev: 44
San Onofre 2&3 FSAR Updated TRANSIENT ANALYSIS Table 15.10.6.3.2-4 Results for Steam Generator Tube Rupture Analysis Results Parameter Acceptance Criteria Unit 2 Unit 3 Design Basis Case with No Iodine Spike 0-2 hr EAB Doses, Rem Thyroid 30 0.8 0.8 Beta Skin N/A 0.1 0.1 Whole Body 2.5 0.2 0.2 0-30 day LPZ Doses, Rem Thyroid 30 <0.1 <0.1 Beta Skin N/A <0.1 <0.1 Whole Body 2.5 <0.1 <0.1 0-30 day Control Room Doses, Rem Thyroid 30 1.8 1.8 Beta Skin 30 1.6 1.6 Whole Body 5 <0.1 <0.1 Design Basis Case with Pre-Existing Iodine Spike 0-2 hr EAB Doses, Rem Thyroid 300 8.2 8.2 Beta Skin N/A 0.1 0.1 Whole Body 25 0.2 0.2 0-30 day LPZ Doses, Rem Thyroid 300 0.2 0.2 Beta Skin N/A <0.1 <0.1 Whole Body 25 <0.1 <0.1 0-30 day Control Room Doses, Rem Thyroid 30 2.0 2.0 Beta Skin 30 1.6 1.6 Whole Body 5 <0.1 <0.1 Design Basis Case with Accident Induced Iodine Spike 0-2 hr EAB Doses, Rem Thyroid 30 4.1 4.1 Beta Skin N/A 0.1 0.1 Whole Body 2.5 0.2 0.2 0-30 day LPZ Doses, Rem Thyroid 30 0.1 0.1 Beta Skin N/A <0.1 <0.1 Whole Body 2.5 <0.1 <0.1 0-30 day Control Room Doses, Rem Thyroid 30 1.9 1.9 Beta Skin 30 1.6 1.6 Whole Body 5 <0.1 <0.1 15.10-186 Rev: 44
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
)
In the Matter of )
) Docket Nos. 50-361-CAL & 50-362-CAL SOUTHERN CALIFORNIA EDISON COMPANY )
)
(San Onofre Nuclear Generating Station, ) December 13, 2012 Units 2 and 3) )
)
CERTIFICATE OF SERVICE I hereby certify that, on this date, a copy of Southern California Edison Companys Answer Opposing Petitioners Motion to Amend the Boards December 7, 2012 Order was filed through the E-Filing system.
Signed (electronically) by Stephen J. Burdick Stephen J. Burdick Morgan, Lewis & Bockius LLP 1111 Pennsylvania Avenue, N.W.
Washington, D.C. 20004 Phone: 202-739-5059 Fax: 202-739-3001 E-mail: sburdick@morganlewis.com Counsel for Southern California Edison Company DB1/ 72473685.3