ML13080A407
| ML13080A407 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 03/20/2013 |
| From: | St.Onge R Edison International Co, Southern California Edison Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| TAC ME9727 | |
| Download: ML13080A407 (17) | |
Text
SOUTHERN CALIFORNIA EDISON° An EDISON INTERNATIONAL Company Richard J. St. Onge Director, Nuclear Regulatory Affairs and Emergency Planning Proprietary Information Withhold from Public Disclosure March 20, 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 (RAIs 37 and 56)
Regarding Confirmatory Action Letter Response (TAC No. ME 9727)
San Onofre Nuclear Generating Station, Unit 2
- 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
References:
- 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 March 18, 2013, Second 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 March 18, 2013 (Reference 3), the NRC issued Requests for Additional Information (RAIs) regarding the CAL response. Enclosure 2 of this letter provides the response to RAIs 37 and 56.
Proprietary Information Withhold from Public Disclosure Decontrolled Upon Removal From Enclosure 2 Av~
P.O. Box 128 San Clemente, CA 92672
Document Control Desk March 20, 2013 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 AREVA NP Inc., which sets 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.
Proprietary information identified in Enclosure 2 was extracted from AREVA document 51-9197672-002, SONGS Probability of FEI Operational Assessment RAI Responses, which is addressed in the affidavit. 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 Affidavit
- 2. Response to RAI 37 and 56 (Proprietary)
- 3. Response to RAI 37 and 56 (Non-Proprietary) cc:
E. E. Collins, Regional Administrator, NRC Region IV J. R. Hall, NRC Project Manager, SONGS Units 2 and 3 G. G. Warnick, NRC Senior Resident Inspector, SONGS 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 Affidavit
AFFIDAVIT STATE OF NORTH CAROLINA
)
) ss.
COUNTY OF MECKLENBURG
- 1.
My name is Dennis C. Williford. I am Manager, Product Licensing, for AREVA NP Inc. (AREVA NP) and as such I am authorized to execute this Affidavit.
- 2.
I am familiar with the criteria applied by AREVA NP to determine whether certain AREVA NP information is proprietary. I am familiar with the policies established by AREVA NP to ensure the proper application of these criteria.
- 3.
I am familiar with the AREVA NP information contained in the document titled "51-9197672-002, 'SONGS Unit 2 Probability of FEI Operational Assessment RAI Responses',"
and referred to herein as "Document." Information contained in this Document has been classified by AREVA NP as proprietary in accordance with the policies established by AREVA NP for the control and protection of proprietary and confidential information.
- 4.
This Document contains information of a proprietary and confidential nature and is of the type customarily held in confidence by AREVA NP and not made available to the public. Based on my experience, I am aware that other companies regard information of the kind contained in this Document as proprietary and confidential.
- 5.
This Document has been made available to the U.S. Nuclear Regulatory Commission in confidence with the request that the information contained in this Document be withheld from public disclosure. The request for withholding of proprietary information is made in accordance with 10 CFR 2.390. The information for which withholding from disclosure is
requested qualifies under 10 CFR 2.390(a)(4) "Trade secrets and commercial or financial information":
- 6.
The following criteria are customarily applied by AREVA NP to determine whether information should be classified as proprietary:
(a)
The information reveals details of AREVA NP's research and development plans and programs or their results.
(b)
Use of the information by a competitor would permit the competitor to significantly reduce its expenditures, in time or resources, to design, produce, or market a similar product or service.
(c)
The information includes test data or analytical techniques concerning a process, methodology, or component, the application of which results in a competitive advantage for AREVA NP.
(d)
The information reveals certain distinguishing aspects of a process, methodology, or component, the exclusive use of which provides a competitive advantage for AREVA NP in product optimization or marketability.
(e)
The information is vital to a competitive advantage held by AREVA NP, would be helpful to competitors to AREVA NP, and would likely cause substantial harm to the competitive position of AREVA NP.
The information in the Document is considered proprietary for the reasons set forth in paragraphs 6(c) and 6(d) above.
- 7.
In accordance with AREVA NP's policies governing the protection and control of information, proprietary information contained in this Document has been made available, on a limited basis, to others outside AREVA NP only as required and under suitable agreement providing for nondisclosure and limited use of the information.
- 8.
AREVA NP policy requires that proprietary information be kept in a secured file or area and distributed on a need-to-know basis.
- 9.
The foregoing statements are true and correct to the best of my knowledge, information, and belief.
SUBSCRIBED before me this _________
day of_
2013.
Thomas A. Casias NOTARY PUBLIC, STATE OF NORTH CAROLINA, COUNTY OF MECKLENBURG MY COMMISSION EXPIRES: 14 December 2014
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 RAIs 37 and 56 (NON-PROPRIETARY)
RAI 37
Reference 1, Section 8.0, page 107 of 129, and Figure 8-3 indicate that Unit 2 can be operated for 8 months after BOC 17 before exceeding the 5% probability limit. What is the sensitivity of this estimate to a higher assumed value of median contact force for support effectiveness?
[Only Figure 8-3 is proprietary, the question is not.]
RESPONSE
Note: Request for Additional Information (RAI) Reference 1 is "SONGS U2C17 Steam Generator Operational Assessment for Tube-to-Tube Wear," Areva NP Inc. Document No.
51-9187230-000, Revision 0, October 2012.
Page 2 of 11 Page 3 of 11
Updated Figure 8-3: Probability of FEI vs. Operating Time, 0.95 Probability Stability Ratios, Updated with Unit 3 Results at 5 Months of Operation Page 4 of 11
Figure 1: Unit 2, Probability of FEI vs Operating Time, SR = 1.0, 99th Percentile Stability Ratios, Various Support Effectiveness Criteria Page 5 of 11
Figure 2: Unit 3, Probability of FEI vs. Operating Time, SR = 1.0, 99th Percentile Stability Ratios, Various Support Effectiveness Page 6 of 11
Figure 3: Probability of FEI vs. Operating Time, SR = 1.0 at 100% Power, SR = 0.75 at 70% Power, 95th Percentile Stability Ratios, Various Support Effectiveness Criteria Page 7 of 11
RAI 56
For Reference 10, Figure 8-3, provide an assessment of the robustness of the Figure 8-3 predictions of the probability of instability versus time in terms of how well it accommodates uncertainty in these predictions for purposes of ensuring acceptable tube integrity margins during the planned 5-month inspection interval for Unit 2. Robustness refers in part to accommodating increases or decreases in the rate at which instability increases with time and the calculated value of the probability of instability at the beginning of cycle (BOC) 16 for Units 2 and 3 and BOC 17 for Unit 2. Robustness also considers the time interval between onset of instability and the loss of acceptable tube integrity margins.
RESPONSE
Page 8 of 11 Page 9 of 11
Updated Figure 8-3: Probability of FEI vs. Operating Time, 0.95 Probability Stability Ratios, Updated with Unit 3 Results at 5 Months of Operation Page 10 of 11
Figure 1: Probability of FEI vs. Operating Time, SR = 1.0 at 100% Power, SR = 0.75 at 70% Power, 95th Percentile Stability Ratios, Various Support Effectiveness Criteria Page 11 of 11