ML13014A251

Response to Request for Additional Information (RAI 30) Regarding Confirmatory Action Letter Response

ML13014A251
Person / Time
Site:	San Onofre
Issue date:	01/09/2013
From:	St.Onge R Southern California Edison Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
TAC ME9727, CAL 4-12-001
Download: ML13014A251 (10)

Text

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SOUTHERN CALIFORNIA J EDISON° An EDISON INTERNATIONAL Company Proprietary Information Withhold from Public Disclosure Richard J. St. Onge Director, Nuclear Regulatory Affairs and Emergency Planning January 9, 2013 10 CFR 50.4 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001

Subject:

Docket No. 50-361 Response to Request for Additional Information (RAI 30)

Regarding Confirmatory Action Letter Response (TAC No. ME 9727)

San Onofre Nuclear Generating Station, Unit 2

References:

1. Letter from Mr. Elmo E. Collins (USNRC) to Mr. Peter T. Dietrich (SCE), dated March 27, 2012, Confirmatory Action Letter 4-12-001, San Onofre Nuclear Generating Station, Units 2 and 3, Commitments to Address Steam Generator Tube Degradation

2. Letter from Mr. Peter T. Dietrich (SCE) to Mr. Elmo E. Collins (USNRC), dated October 3, 2012, Confirmatory Action Letter - Actions to Address Steam Generator Tube Degradation, San Onofre Nuclear Generating Station, Unit 2

3. Letter from Mr. James R. Hall (USNRC) to Mr. Peter T. Dietrich (SCE), dated December 26, 2012, Request for Additional Information Regarding Response to Confirmatory Action Letter, San Onofre Nuclear Generating Station, Unit 2

Dear Sir or Madam,

On March 27, 2012, the Nuclear Regulatory Commission (NRC) issued a Confirmatory Action Letter (CAL) (Reference 1) to Southern California Edison (SCE) describing actions that the NRC and SCE agreed would be completed to address issues identified in the steam generator tubes of San Onofre Nuclear Generating Station (SONGS) Units 2 and 3. In a letter to the NRC dated October 3, 2012 (Reference 2), SCE reported completion of the Unit 2 CAL actions and included a Return to Service Report (RTSR) that provided details of their completion.

By letter dated December 26, 2012 (Reference 3), the NRC issued Requests for Additional Information (RAIs) regarding the CAL response. Enclosure 2 of this letter provides the response to RAI 30. of this submittal contains proprietary information. SCE requests that this proprietary enclosure be withheld from public disclosure in accordance with 10 CFR 2.390(a)(4). provides a notarized affidavit from Mitsubishi Heavy Industries (MHI), which sets Proprietary Information Withhold from Public Disclosure Decontrolled Upon Removal From Enclosure 2 P.O. Box 128 San Clemente, CA 92672

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Proprietary Information Withhold from Public Disclosure Document Control Desk January 9, 2013 forth the basis on which the information in Enclosure 2 may be withheld from public disclosure by the NRC and addresses with specificity the considerations listed by paragraph (b)(4) of 10 CFR 2.390. Enclosure 3 provides the non-proprietary version of Enclosure 2.

There are no new regulatory commitments contained in this letter. If you have any questions or require additional information, please call me at (949) 368-6240.

Sincerely,

Enclosures:

1. Notarized Affidavits

2. Response to RAI 30 (Proprietary)

3. Response to RAI 30 (Non-proprietary) cc:

E. E. Collins, Regional Administrator, NRC Region IV R. Hall, NRC Project Manager, San Onofre Units 2 and 3 G. G. Warnick, NRC Senior Resident Inspector, San Onofre Units 2 and 3 R. E. Lantz, Branch Chief, Division of Reactor Projects, NRC Region IV Proprietary Information Withhold from Public Disclosure Decontrolled Upon Removal From Enclosure 2

ENCLOSURE 1 Notarized Affidavits

MITSUBISHI HEAVY INDUSTRIES, LTD.

AFFIDAVIT I, Jinichi Miyaguchi, state as follows:

1. I am Director, Nuclear Plant Component Designing Department, of Mitsubishi Heavy Industries, Ltd. ("MHI"), and have been delegated the function of reviewing the referenced AREVA's technical documentations to determine whether they contain MHI's information that should be withheld from public disclosure pursuant to 10 C.F.R. § 2.390 (a)(4) as trade secrets and commercial or financial information that is privileged or confidential.

2. In accordance with my responsibilities, I have reviewed MHI's letter "MHI/SCE-1 2-0161:

Figure of Percentage of Tube Wear vs. Maximum Interstitial Velocity (Reply to RAI #30)"

and have determined that it contains MHI proprietary information that should be withheld from public disclosure. Those pages containing proprietary information have been bracketed with an open and closed bracket as shown here "[ I" / and should be withheld from public disclosure pursuant to 10 C.F.R. § 2.390 (a)(4).

3. The information identified as proprietary in the documents has in the past been, and will continue to be, held in confidence by MHI and its disclosure outside the company is limited to regulatory bodies, customers and potential customers, and their agents, suppliers, and licensees, and others with a legitimate need for the information, and is always subject to suitable measures to protect it from unauthorized use or disclosure.

4.

The basis for holding the referenced information confidential is that it describes unique design, manufacturing, experimental and investigative information developed by MHI and not used in the exact form by any of MHI's competitors.

This information was developed at significant cost to MHI, since it is the result of an intensive MHI effort.

5. The referenced information was furnished to the Nuclear Regulatory Commission

("NRC") in confidence and solely for the purpose of information to the NRC staff.

6. The referenced information is not available in public sources and could not be gathered readily from other publicly available information.

Other than through the provisions in paragraph 3 above, MHI knows of no way the information could be lawfully acquired by organizations or individuals outside of MHI.

7.

Public disclosure of the referenced information would assist competitors of MHI in their design and manufacture of nuclear plant components without incurring the costs or risks associated with the design and the manufacture of the subject component. Therefore, disclosure of the information contained in the referenced document would have the following negative impacts on the competitive position of MHI in the U.S. and world nuclear markets:

A.

Loss of competitive advantage due to the costs associated with development of technologies relating to the component design, manufacture and examination.

Providing public access to such information permits competitors to duplicate or mimic the methodology without incurring the associated costs.

B.

Loss of competitive advantage of MHI's ability to supply replacement or new heavy components such as steam generators.

I declare under penalty of perjury that the foregoing affidavit and the matters stated therein are true and correct to the best of my knowledge, information and belief.

Executed on this _-,___

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Jinichi Miyaguchi,

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ENCLOSURE 3 SOUTHERN CALIFORNIA EDISON RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION REGARDING RESPONSE TO CONFIRMATORY ACTION LETTER DOCKET NO. 50-361 TAC NO. ME 9727 Response to RAI 30 (NON-PROPRIETARY)

Page 1

RAI 30

Reference 1, Figure 8 Provide similar figure for maximum interstitial velocities.

Response

The following figure shows the percentage of tubes with tube-to-tube wear (TTW) indications at each range of maximum interstitial velocity at 100% power. In the figure, 2A, 2B, 3A and 3B represent steam generators (SGs) 2E089, 2E088, 3E089 and 3E088, respectively. As indicated in Table 8-3 of Reference 1, operating Unit 2 at 70% power reduces the maximum interstitial velocity in the SG secondary side to well below the velocities which resulted in TTW at 100%

power.

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