ML20128B711
| ML20128B711 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 01/29/1993 |
| From: | Marsh W SOUTHERN CALIFORNIA EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML19303F252 | List: |
| References | |
| GL-92-01, GL-92-1, NUDOCS 9302030154 | |
| Download: ML20128B711 (9) | |
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- f Southom Califomia Edison Company 23 PARKl~Il hiTREET h'
IRVINE, CALIFORNIA 92716 3
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January 29, 1993'
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4 U. S. Nuclear Regulatory Commission U
Attention: Document ~ Control Desk Washington, D. C.
20555 y
Gentlemen:
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Subject:
Docket Nos. 50-361 and 50-362 Supplemental. Response to Generic Letter 92-01, Revision 1,
" Reactor Vessel Structural Integrity,10 CFR 50.54(f)"
San-Onofre Nuclear Generating Station Units 2 and 3.
Reference:
R. M. Rosenblum to U. S. Faclear Regulatory Commission Document Control Desk, Response to Generic Letter 92-01, Revision 1,
" Reactor Vessel Structural Integrity,10 CFR 50.54(f)", San Onofre Nuclear Generating Station, Units 2 and 3, July 6,' 1992 On March 6,-1992, NRC issued Generic Letter.92-01, Revision 1, to obtain information needed to' assess compliance with the requirements and commitments regarding-reactor vessel integrity. The' referenced' letter provided our initial response to Generic Letter 92-01 and indicated that additional information needed to complete.our response-would be provided by
' January 29, 1993. This letter provides the required additional information, i"
' The' updated reports provided in the enclosures of this letter incorporate:-
(1) additional materials-data'obtained from Combustion Engineering, (2) the results of calculations performed by SCE' to<better characterize weld fluence conditions at 8-203, and (3).the results from calculations performed to-1 evaluate the: upper shelf toughness for weld 8-203. Specifically, the updated j
reports-incorporate the following items (all' report revisions have been 4
denoted with' side bars):
e.
For San Onofre Unit 2
- (1);
Resolution-ofinconsistenciesinthe.reportedcopper(Cu)_
end nickel (Ni) contents for both the beltline weld 9-203 cand the surveillance weld, e
-(2)
T Additional materialicertification reports for beltline weld-LO10061L Properties, and (3)-
Verification of the fluence at weld 8-203.
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4 Document Control Desk i e
for San Onofre Unit 3, (1)
Resolution of inconsistencies in M reported Cu and Ni contents and Charpy impact properties for both the beltline weld 9-203 and the surveillance weld, (2)
Additional material certification reports for beltline weld properties, (3)
Identification of the Charpy impact properties and chemistry for weld 8-203, (4)
Verification of the fluence at weld 8-203, (5)
Resolution of inconsistencies between the Charpy impact properties reported in the MCRs and the wrveillance baseline records for the longitudinal (LT) orientation in shell plate C6802-1.
In preparing the enclosed revisions of the subject reports, it was determined that additional information will be required to confirm heat numbers for weld 24203 and the surveillance weld for Unit 2.
For Unit 3, additional information will be required to confirm the heat numbers for the surveillance weld material and to identify the heat number for the unidentified girth weld chemistry. SCE is working with the Combustion Engineering Reactor Vessel Owners Group to obtain this information. The Owners Group anticipates completion of this follow-up activity in sufficient time for SCE to submit this remaining information to the NRC by February 2,1994.
The referenced letter noted we were evaluating the presence of water in some of the surveillance capsule chambers. On August 12, U92, Westinghouse informed SCE that they evaluated the capsule test specimens and concluded that the test specimen material condition was acceptable, 'and that the test results obtained were valid. SCE is continuing its evaluation and will inform the NRC, under separate correspondence, if any significant findings are
' identified.
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Document Control Desk Please note that the reports enclosed in Attachments A and B contain pro)rietary information from Combustion Engineering, Inc., (CE) and should be wit 1 held from public disclosure.the considerations in 10 CFR 2.790(b)(gned affidavit fro A si
- 4) and supports the request for non-public disclosure is provided in Enclosure C of this letter.
Thus, we respectfully request that the reports containing information proprietary to CE-be withheld from public disclosure in accordance with 10 CFR 2.790.
Separate non-proprietary versions of the reports are provided in Attachments D and E.
If you have questions or require further information, please let me know.
Respectfully submitted, SOUTHERN CALIFORNIA EDISON YWh State of California County.of Or nge on VII (0 before me, kil00kJ ($N10 WW, perschally abpeared h/d (4 v /n IT 1(i i <;l l.
, personally known to me to be the person w1ose name is subscribed to the within instrument and acknowledged to me that he executed the same in his authorized capacity, and that by his signature on the instrument, the person, or the entity upon behalf of which the person acted, executed the instrument.
WITNESS my~ hand and official seal.
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Signature />
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U Attachments cc: J. B. Martin, Regional Administrator, NRC Region V Mel B. Fields, NRC Project Manager, San Onofre Units 2 & 3 C. W. Caldwell, NRC Senior Resident Inspector, San Onofre Units 1, 2&3
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ATTACHMENT C Affidavit from Combustion Engineering, Inc., Requesting Proprietary Treatment of Infonnation In Attachments A and B i
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i AFFIDAVIT PITRSUAliT To 10 CPR 2.790 Combustion Engineering, Inc.
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State of Connecticut
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County of Hartford
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SS.:
I, S.
A.
Toolle, depose and say that I am the Manager, Nuclear Licensing, of Combustion Engineering, Inc., duly authorized to make this affidavit, and have reviewed or causcd to have reviewed the information which is identified as proprietary and referenced in the paragraph immediately below.
I am submitting this affidavit in conformance with the provisions of 10 CFR 2.790 of the Commission's regulations in conjunction with Southern California Edison Company for withholding this information.
The information for which proprietary treatment is sought is contained in the following documents attached to Southern California
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Edison Company Letter AD12S023 dated January 29, 1993:
Appendices B,
C, D,
and E of Attachment A,
" San Onofre Nuclear Generating Station, Unit 2 Response to Generic Letter 92-01, Revision 1,
January 22, 1993."
Appendices B,
C, D,
and E of Attachment B,
" San Onofre Nuclear Generating Station, Unit 3 Response to Generic Letter 92-01, Revision 1,
January 22, 1993."
These documents have been appropriately designated as proprietary.
I have personal knowledge of the criteria and procedures utilized by Combustion Engineering in designating information as a trade secret, privileged or as confidential commercial or financial information.
y.
- 4. - Pursuant to the provisions of paragraph (b) (4) of Section 2.790 1
.o_f the Commission's regulations, the following is furnished for consideration by the Commission in determining whether the information sought to be withheld from public disclosure, included in the above referenced document, should be withheld.
1.
The information sought to be withheld from public disclosure, which is owned and has been held in confidence by Combustion Engineering, is the fabrication spec'ifications, material-certifications, and chemical analysis for the reactor vessel plate and welding materials.
2.
The information consists of test data or other similar data concerning a process, method or component, the application of which results in substantial competitive advantage to Combustion Engineering.
3.
The information is of a type customarily held in confidence by Combustion Engineering and not customarily disclosed' to the public.
Combustion Engineering has a rational basis for determining the types _of information customarily ~ hel'd in confidence by it and, in that connection, utilizes a system tol determine when.and whether to hold certain types of.information L
in confidence.
The details of the' aforementioned system were-L h
provided to the m mlear Regulatory Commission'via letter DP-537 from F. M.
Stet.
. rank Schroeder dated December 2, 1974.
.. 1 This system was applied in determining that the subject document herein is proprietary.
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4.
The information is being transmitted to the Commission in
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confidence under the provisions of 10 CFR 2.790 with the understanding that it is to be received in confidence by the Commission.
5.
The information, to the best of my knowledge and belief, is not available in public sources, and any disclosure to third parties has been made pursuant to regulatory provisions or proprietary.
agreements which provide for maintenance of the information-in confidence.
6.
Public disclosure of the information-is likely-to cause substantial harm to the competitive position of Combustion Engineering because:
a.
A similar product is manufactured and sold-by major pressurized water reactor competitors of -Combustion-Engineering.
b.
Development of-this information by C-E required thousands of manhours and millions of dollars.
To the best of my-knowledge-and belief, a competitor would have-to undergo.
similar expense in generating equivalent information.
c.
In order to acquire such information, a competitor would also require considerable time and inconvenience to develop I
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.- similar fabrication specifications, material certifications, and chemical analysis for the. reactor vessel plate and welding materials.
d.
The information required significant effort and expense to obtain the licensing approvals necessary for application of the information.
Avoidanc<a of this expense would decrease a
competitor's cost.
in applying the information and marketing the product to which the information is i
applicable.
e.
The information consists of the fabrication specifications, material certifications, and chemical analysis for the reactor vessel plate and welding materials, the application of which_provides a competitive economic advantage.
The availability of such information to competitors would enable them to modify their product to better compete with Combustion Engineering, take marketing or other actions to improve their product's position or impair the position of Combustion Engineering's prod *1ct,
and avoid developing similar data and analyses in support of their processes, 1
methods or apparatus.
f.
In pricing Combustion Engineering's products and services, significant research, development, engineering, analytical, I
manufacturing, licensing, quality assurance and other costs and expenses must be included.
The ability of Combustion-Engineering's competitors to utilize such information without similar expenditure of resources may enable them to i
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sell at prices reflecting significantly lower ccets.
g.
Use of the information by competitors in the international' marketplace would increase their ability to market nuclear steam supply systems by reducing the costs associated with their technology development.
In addition, disclosure would have an adverse economic impact on Combustion Engineering's potential for obtaining or maintaining foreign licensens.
Further the deponent sayeth not.
0 S. A.
I S. A. Toolle Manager Nuclear Licensing Sworn to before me r^y this M Y^
day of'- M
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' Notary Public My commission expires:
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