ML13080A411

Response to Request for Additional Information (RAIs 33, 34, 35, 36, and 55) Regarding Confirmatory Action Letter Response

ML13080A411
Person / Time
Site:	San Onofre
Issue date:	03/20/2013
From:	St.Onge R Southern California Edison Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
TAC ME9727
Download: ML13080A411 (16)

Text

I , SOUTHERN CALIFORNIA Richard I. St. Onge EDISON Director, Nuclear Regulatory Affairs and Emergency Planning An EDISON INTERNATIONAL Company 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 33, 34, 35, 36, and 55)

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. Email from Mr. James R. Hall (USNRC) to Mr. Ryan Treadway (SCE), dated February 1, 2013, Request for Additional Information (RAIs 33-37) Regarding Response to Confirmatory Action Letter, San Onofre Nuclear Generating Station, Unit 2

4. Email from Mr. James R. Hall (USNRC) to Mr. Ryan Treadway (SCE), dated February 21, 2013, Request for Additional Information (RAIs 53-67) 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.

Proprietary Information ADi Withhold from Public Disclosure P.O. Box 128 Decontrolled Upon Removal From Enclosure 2 San Clemente. CA 92672

Document Control Desk March 20, 2013 By email dated February 1, 2013 (Reference 3), the NRC issued Requests for Additional Information (RAIs) 33-37 regarding the CAL response. By email dated February 21, 2013 (Reference 4), the NRC issued RAts 53-67 regarding the CAL response. Enclosure 2 of this letter provides the response to RAIs 33, 34, 35, 36, and 55. 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 Unit 2 Probability of FEI Operational Assessment RAI Responses, which is addressed in the affidavit. Enclosure 3 provides the non-proprietary version of .

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.

cerely,

Enclosures:

1. Notarized Affidavit

2. Response to RAI 33, 34, 35, 36, and 55 (Proprietary)

3. Response to RAI 33, 34, 35, 36, and 55 (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 //_/-7/_

day of ____A, _ _'_ 2013.

Thomas A. Casias NOTARY PUBLIC, STATE OF NORTH CAROLINA, COUNTY OF MECKLENBURG MY COMMISSION EXPIRES: 14 December 2014

Proprietary Information Withhold from Public Disclosure 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 33, 34, 35, 36, and 55 (NON-PROPRIETARY)

Proprietary Information Withhold from Public Disclosure

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RAI 33

Reference 1, Figure 5-5:

] [Proprietary]

RESPONSE

Note: Request for Additional Information (RAI) Reference 1 is "SONGS U2C1 7 Steam Generator Operational Assessment for Tube-to-Tube Wear," prepared by Areva NP Inc.

Document No. 51-9187230-000, Revision 0, October 2012.

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RAI 34

Reference 1, Section 6.4.2, page 60 of 129: [

] [Proprietary]

RESPONSE

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RAI 35

Reference 1, Section 7.3, page 98 of 129: The "upper bound contact forces" shown in Figure 7-2 are average values. Clarify whether these "average values" are averages of the upper bound contact forces for each tube in the bundle at each AVB. Why is it acceptable that the calculated upper bound contact force prevents motion for only 97.7 percent of the force spectrum from turbulence? Finally, why has only turbulence excitation been considered in the development of these upper bound contact forces? [Only Figure 7-2 is proprietary, the question is not.]

RESPONSE

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RAI 36

Reference 1, Section 7.4, page 98 of 129:

I

[Proprietary]

RESPONSE

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RAI 55

In Reference 2, page 107 of 129, second to last paragraph, did total gap also include wear of the anti-vibration bars (AVBs) themselves? If not, explain why the approach is conservative. If so, how was wear of the AVBs determined? (This question is a follow-up on RAI No. 26 from the NRC's December 26, 2012, letter).

RESPONSE

Note: RAI Reference 2 is "SONGS U2C1 7 Steam Generator Operational Assessment for Tube-to-Tube Wear," prepared by Areva NP Inc. Document No. 51-9187230-000, Revision 0, October 2012.

Wear at tube to anti-vibration bar (AVB) intersections was included in the calculations of gaps and contact forces in RAI Reference 1. Both wear of the tube and wear of the AVB were included. Based on wear test data, the wear volume of the AVB is [ ] of the corresponding wear volume of the tube. Increased gaps due to wear were added to the ABAQUS quarter model input in addition to the random selection of gaps from the manufacturing gap distributions.

The sizes of wear induced gaps were based on eddy current inspection data for the worst case steam generators, Unit 2 SG E-089 and Unit 3 SG E-089. The wear gaps were placed at the same locations as found in the eddy current inspection.

The wear level at any given location was adjusted for different time periods using the assumption that the work rate at that location was constant over time. The wear volume loss rate is constant over time at a given location. The wear volume loss rate at different locations is calculated from the eddy current inspection wear depth and the total operating time at End of Cycle 16.

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