ML13085A039

Response to Request for Additional Information (RAIs 46 - 49, 51, and 52) Regarding Confirmatory Action Letter Response

ML13085A039
Person / Time
Site:	San Onofre
Issue date:	03/22/2013
From:	St.Onge R Southern California Edison Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
TAC ME9727
Download: ML13085A039 (58)

Text

Proprietary Information Richard 1. St. Onge J EDISON SOUTHERN CALIFORNIA Withhold from Public Disclosure Director, Nuclear Regulatory Affairs and Emergency Planning An EDISON INTERNATIONAL Company March 22, 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 46 - 49, 51, and 52)

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 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 46 - 49, 51, and 52.

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

Proprietary Information Withhold from Public Disclosure Document Control Desk March 22, 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 notarized affidavits from Westinghouse, 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. 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 RAIs 46 - 49, 51, and 52 (Proprietary)

3. Response to RAIs 46 - 49, 51, and 52 (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 of Enclosure 2

ENCLOSURE 1 Notarized Affidavits

Westinghouse Electric Company

( Westinghouse Nuclear Services 1000 Westinghouse Drive Cranberry Township, Pennsylvania 16066 USA U.S. Nuclear Regulatory Commission Direct tcl: (412) 374-4643 Document Control Desk Direct fax: (724) 720-0754 11555 Rockville Pike e-mail: greshaja@westinghouse.com Rockville, MD 20852 Proj letter: CONO- 13-22 CAW-13-3657 March 15, 2013 APPLICATION FOR WITHHOLDING PROPRIETARY INFORMATION FROM PUBLIC DISCLOSURE

Subject:

LTR-SGDA-13-28 P-Attachment, "San Onofre Nuclear Generating Station Unit 2 MHI Replacement Steam Generator Response to RAI 46" (Proprietary)

The proprietary information for which withholding is being requested in the above-referenced report is further identified in Affidavit CAW-13-3657 signed by the owner of the proprietary information, Westinghouse Electric Company LLC. The affidavit, which accompanies this letter, sets forth the basis on which the information may be withheld from public disclosure by the Commission and addresses with specificity the considerations listed in paragraph (b)(4) of 10 CFR Section 2.390 of the Commission's regulations.

Accordingly, this letter authorizes the utilization of the accompanying affidavit by Southern California Edison.

Correspondence with respect to the proprietary aspects of the application for withholding or the Westinghouse affidavit should reference CAW-I 3-3657 and should be addressed to James A. Gresham, Manager, Regulatory Compliance, Westinghouse Electric Company, Suite 428, 1000 Westinghouse Drive, Cranberry Township, Pennsylvania 16066.

Very truly yours, Gresham, Manager Regulatory Compliance Enclosures

CAW-13-3657 AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA:

ss COUNTY OF BUTLER:

Before me, the undersigned authority, personally appeared James A. Gresham, who, being by me duly sworn according to law, deposes and says that he is authorized to execute this Affidavit on behalf of Westinghouse Electric Company LLC (Westinghouse), and that the averments of fact set forth in this Affidavit are true and correct to the best of his knowledge, information, and belief:

/James A. Gresham, Manager Regulatory Compliance Sworn to and subscribed before me this 15 "hday of March 2013 t

Notary Public COMMONWEALTH OF PENNSYLVANIA Notarial Seal Anne M.Stegman, Notary Public Unity Twp., Westmoreland County My Commission Expires Aug. 7, 2016 ME'BER. PENNSYLVANIA ASSOCIATION OF NOTARIES

2 CAW- 13-3657 (1) 1 am Manager, Regulatory Compliance, in Nuclear Services, Westinghouse Electric Company LLC (Westinghouse), and as such, I have been specifically delegated the function of reviewing the proprietary information sought to be withheld from public disclosure in connection with nuclear power plant licensing and rule making proceedings, and am authorized to apply for its withholding on behalf of Westinghouse.

(2) I am making this Affidavit in conformance with the provisions of 10 CFR Section 2.390 of the Commission's regulations and in conjunction with the Westinghouse Application for Withholding Proprietary Information from Public Disclosure accompanying this Affidavit.

(3) 1 have personal knowledge of the criteria and procedures utilized by Westinghouse in designating information as a trade secret, privileged or as confidential commercial or financial information.

(4) Pursuant to the provisions of paragraph (b)(4) of Section 2.390 of 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 should be withheld.

(i) The information sought to be withheld from public disclosure is owned and has been held in confidence by Westinghouse.

(ii) The information is of a type customarily held in confidence by Westinghouse and not customarily disclosed to the public. Westinghouse has a rational basis for determining the types of information customarily held in confidence by it and, in that connection, utilizes a system to determine when and whether to hold certain types of information in confidence. The application of that system and the substance of that system constitutes Westinghouse policy and provides the rational basis required.

Under that system, information is held in confidence if it falls in one or more of several types, the release of which might result in the loss of an existing or potential competitive advantage, as follows:

(a) The information reveals the distinguishing aspects of a process (or component, structure, tool, method, etc.) where prevention of its use by any of

3 CAW-13-3657 Westinghouse's competitors without license from Westinghouse constitutes a competitive economic advantage over other companies.

(b) It consists of supporting data, including test data, relative to a process (or component, structure, tool, method, etc.), the application of which data secures a competitive economic advantage, e.g., by optimization or improved marketability.

(c) Its use by a competitor would reduce his expenditure of resources or improve his competitive position in the design, manufacture, shipment, installation, assurance of quality, or licensing a similar product.

(d) It reveals cost or price information, production capacities, budget levels, or commercial strategies of Westinghouse, its customers or suppliers.

(e) It reveals aspects of past, present, or future Westinghouse or customer funded development plans and programs of potential commercial value to Westinghouse.

(f) It contains patentable ideas, for which patent protection may be desirable.

There are sound policy reasons behind the Westinghouse system which include the following:

(a) The use of such information by Westinghouse gives Westinghouse a competitive advantage over its competitors. It is, therefore, withheld from disclosure to protect the Westinghouse competitive position.

(b) It is information that is marketable in many ways. The extent to which such information is available to competitors diminishes the Westinghouse ability to sell products and services involving the use of the information.

(c) Use by our competitor would put Westinghouse at a competitive disadvantage by reducing his expenditure of resources at our expense.

4 CAW-13-3657 (d) Each component of proprietary information pertinent to a particular competitive advantage is potentially as valuable as the total competitive advantage. If competitors acquire components of proprietary information, any one component may be the key to the entire puzzle, thereby depriving Westinghouse of a competitive advantage.

(e) Unrestricted disclosure would jeopardize the position of prominence of Westinghouse in the world market, and thereby give a market advantage to the competition of those countries.

(f) The Westinghouse capacity to invest corporate assets in research and development depends upon the success in obtaining and maintaining a competitive advantage.

(iii) The information is being transmitted to the Commission in confidence and, under the provisions of 10 CFR Section 2.390, it is to be received in confidence by the Commission.

(iv) The information sought to be protected is not available in public sources or available information has not been previously employed in the same original manner or method to the best of our knowledge and belief.

(v) The proprietary information sought to be withheld in this submittal is that which is appropriately marked in LTR-SGDA-13-28 P-Attachment, "San Onofre Nuclear Generating Station Unit 2 MHI Replacement Steam Generator Response to RAI 46,"

dated March 14, 2013, for submittal to the Commission, being transmitted by Southern California Edison Letter and Application for Withholding Proprietary Information from Public Disclosure, to the Document Control Desk. The proprietary information as submitted by Westinghouse is that associated with the calculation of fluidelastic excitation of steam generator tubes and may be used only for that purpose.

5 CAW-13-3657 This information is part of that which will enable Westinghouse to:

(a) Respond to a Nuclear Regulatory Commission (NRC) Request for Additional Information regarding the justification for selection of the threshold value of the fluidelastic instability constant, and to provide an explanation why it is a conservative selection considering the thermal hydraulic conditions and size of the San Onofre Nuclear Generating Station Unit 2 replacement steam generators.

Further this information has substantial commercial value as follows:

(a) Westinghouse plans to sell the use of similar information to its customers for the purpose of evaluating the impact of fluidelastic excitation on steam generator tube integrity.

(b) Westinghouse can sell support and defense of the thermal hydraulic analysis of secondary side flow field in the steam generator shell.

(c) The information requested to be withheld reveals the distinguishing aspects of a methodology which was developed by Westinghouse.

Public disclosure of this proprietary information is likely to cause substantial harm to the competitive position of Westinghouse because it would enhance the ability of competitors to provide similar information and licensing defense services for commercial power reactors without commensurate expenses. Also, public disclosure of the information would enable others to use the information to meet NRC requirements for licensing documentation without purchasing the right to use the information.

The development of the technology described in part by the information is the result of applying the results of many years of experience in an intensive Westinghouse effort and the expenditure of a considerable sum of money.

6 CAW-13-3657 In order for competitors of Westinghouse to duplicate this information, similar technical programs would have to be performed and a significant manpower effort, having the requisite talent and experience, would have to be expended.

Further the deponent sayeth not.

_)Westinghouse Westinghouse Electric Company Nuclear Services 1000 Westinghouse Drive Cranberry Township, Pennsylvania 16066 USA U.S. Nuclear Regulatory Commission Direct tel:. (412) 374-4643 Document Control Desk Direct fax: (724) 720-0754 11555 Rockville Pike e-mail: greshaja@westinghouse.com Rockville, MD 20852 Proj letter: CONO-13-22 CAW-13-3658 March 15, 20 13 APPLICATION FOR WITHHOLDING PROPRIETARY INFORMATION- FROM PUBLIC DISCLOSURE

Subject:

LTR-SGDA-13-26 P-Attachment, "San Onofre Generating Station Unit 2 MHI Replacement Steam Generator Response to RAI 47" (Proprietary)

The proprietary information for which withholding is being requested in the above-referenced report is further identified in Affidavit CAW-13-3658 signed by the owner of the proprietary information, Westinghouse Electric Company LLC. The affidavit, which accompanies this letter, sets forth the basis on which the information may be withheld from public disclosure by the Commission and addresses with specificity the considerations listed in paragraph (b)(4) of 10 CFR Section 2.390 of the Commission's regulations.

Accordingly, this letter authorizes the utilization of the accompanying affidavit by Southern California Edison.

Correspondence with respect to the proprietary aspects of the application for withholding or the Westinghouse affidavit should reference CAW-13-3658 and should be addressed to James A. Gresham, Manager, Regulatory Compliance, Westinghouse Electric Company, Suite 428, 1000 Westinghouse Drive, Cranberry Township, Pennsylvania 16066.

Very truly yours, J .Gresham, Manager Regulatory Compliance Enclosures

CAW-13-3658 AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA:

ss COUNTY OF BUTLER:

Before me, the undersigned authority, personally appeared James A. Gresham, who, being by me duly sworn according to law, deposes and says that he is authorized to execute this Affidavit on behalf of Westinghouse Electric Company LLC (Westinghouse), and that the averments of fact set forth in this Affidavit are true and correct to the best of his knowledge, information, and belief:

James A. Gresham, Manager Regulatory Compliance, Sworn to and subscribed before me this 15 th day of March 2013 Notary Public COMMONWEALTH OF PENNSYLVANIA i Notaral Seal Anne M.Stegman, Notary Public Unity Twp., Westmoreland County My Commission Expires Aug. 7, 2016 MEMSER.PENNSYLVANIA ASSOCIATION OF NOTARIES

2 CAW-13-3658 (1) I am Manager, Regulatory Compliance, in Nuclear Services, Westinghouse Electric Company LLC (Westinghouse), and as such, I have been specifically delegated the function of reviewing the proprietary information sought to be withheld from public disclosure in connection with nuclear power plant licensing and rule making proceedings, and am authorized to apply for its withholding on behalf of Westinghouse.

(2) I am making this Affidavit in conformance with the provisions of 10 CFR Section 2.390 of the Commission's regulations and in conjunction with the Westinghouse Application for Withholding Proprietary Information from Public Disclosure accompanying this Affidavit.

(3) I have personal knowledge of the criteria and procedures utilized by Westinghouse in designating information as a trade secret, privileged or as confidential commercial or financial information.

(4) Pursuant to the provisions of paragraph (b)(4) of Section 2.390 of 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 should be withheld.

(i) The information sought to be withheld from public disclosure is owned and has been held in confidence by Westinghouse.

(ii) The information is of a type customarily held in confidence by Westinghouse and not customarily disclosed to the public. Westinghouse has a rational basis for determining the types of information customarily held in confidence by it and, in that connection, utilizes a system to determine when and whether to hold certain types of information in confidence. The application of that system and the substance of that system constitutes Westinghouse policy and provides the rational basis required.

Under that system, information is held in confidence if it falls in one or more of several types, the release of which might result in the loss of an existing or potential competitive advantage, as follows:

(a) The information reveals the distinguishing aspects of a process (or component, structure, tool, method, etc.) where prevention of its use by any of

3 CAW-13-3658 Westinghouse's competitors without license from Westinghouse constitutes a competitive economic advantage over other companies.

(b) It consists of supporting data, including test data, relative to a process (or component, structure, tool, method, etc.), the application of which data secures a competitive economic advantage, e.g., by optimization or improved marketability.

(c) Its use by a competitor would reduce his expenditure of resources or improve his competitive position in the design, manufacture, shipment, installation, assurance of quality, or licensing a similar product.

(d) It reveals cost or price information, production capacities, budget levels, or commercial strategies of Westinghouse, its customers or suppliers.

(e) It reveals aspects of past, present, or future Westinghouse or customer funded development plans and programs of potential commercial value to Westinghouse.

(f) It contains patentable ideas, for which patent protection may be desirable.

There are sound policy reasons behind the Westinghouse system which include the following:

(a) The use of such information by Westinghouse gives Westinghouse a competitive advantage over its competitors. It is, therefore, withheld from disclosure to protect the Westinghouse competitive position.

(b) It is information that is marketable in many ways. The extent to which such information is available to competitors diminishes the Westinghouse ability to sell products and services involving the use of the information.

(c) Use by our competitor would put Westinghouse at a competitive disadvantage by reducing his expenditure of resources at our expense.

4 CAW-13-3658 (d) Each component of proprietary information pertinent to a particular competitive advantage is potentially as valuable as the total competitive advantage. If competitors acquire components of proprietary information, any one component may be the key to the entire puzzle, thereby depriving Westinghouse of a competitive advantage.

(e) Unrestricted disclosure would jeopardize the position of prominence of Westinghouse in the world market, and thereby give a market advantage to the competition of those countries.

(f) The Westinghouse capacity to invest corporate assets in research and development depends upon the success in obtaining and maintaining a competitive advantage.

(iii) The information is being transmitted to the Commission in confidence and, under the provisions of 10 CFR Section 2.390, it is to be received in confidence by the Commission.

(iv) The information sought to be protected is not available in public sources or available information has not been previously employed in the same original manner or method to the best of our knowledge and belief.

(v) The proprietary information sought to be withheld in this submittal is that which is appropriately marked in LTR-SGDA-13-26 P-Attachment, "San Onofre Generating Station Unit 2 MHI Replacement Steam Generator Response to RAI 47" dated March 14, 2013, for submittal to the Commission, being transmitted by Southern California Edison Letter and Application for Withholding Proprietary Information from Public Disclosure, to the Document Control Desk. The proprietary information as submitted by Westinghouse is that associated with the calculation of fluidelastic excitation of steam generator tubes and may be used only for that purpose.

5 CAW-13-3658 This information is part of that which will enable Westinghouse to:

(a) Respond to a Nuclear Regulatory Commission (NRC) Request for Additional Information regarding the development of damping used in the straight leg of the steam generator and how the effects of void fraction are addressed.

Further this information has substantial commercial value as follows:

(a) Westinghouse plans to sell the use of similar information to its customers for the purpose of evaluating the impact of fluidelastic excitation on steam generator tube integrity.

(b) Westinghouse can sell support and defense of the thermal hydraulic analysis of secondary side flow field in the steam generator shell.

(c) The information requested to be withheld reveals the distinguishing aspects of a methodology which was developed by Westinghouse.

Public disclosure of this proprietary information is likely to cause substantial harm to the competitive position of Westinghouse because it would enhance the ability of competitors to provide similar information and licensing defense services for commercial power reactors without commensurate expenses. Also, public disclosure of the information would enable others to use the information to meet NRC requirements for licensing documentation without purchasing the right to use the information.

The development of the technology described in part by the information is the result of applying the results of many years of experience in an intensive Westinghouse effort and the expenditure of a considerable sum of money.

6 CAW-13-3658 In order for competitors of Westinghouse to duplicate this information, similar technical programs would have to be performed and a significant manpower effort, having the requisite talent and experience, would have to be expended.

Further the deponent sayeth not.

Westinghouse Westinghouse Electric Company Nuclear Services 1000 Westinghouse Drive Cranberry Township, Pennsylvania 16066 USA U.S. Nuclear Regulatory Commission Direct tel:- (412) 374.4643 Document Control Desk Direct fax: (724) 720-0754 11555 Rockville Pike e-mail: greshaja@westinghousecom Rockville, MD 20852 Proj letter: CONO-13-22 CAW-13-3659 March 15, 2013 APPLICATION FOR WITHHOLDING PROPRIETARY INFORMATION FROM PUBLIC DISCLOSURE

Subject:

LTR-SGDA-13-27 P-Attachment, "San Onofre Nuclear Generating Unit 2 MHI Replacement Steam Generator Reponses to RAIs 48 and 49" (Proprietary)

The proprietary information for which withholding is being requested in the above-referenced report is further identified in Affidavit CAW-1 3-3659 signed by the owner of the proprietary information, Westinghouse Electric Company LLC. The affidavit, which accompanies this letter, sets forth the basis on which the information may be withheld from public disclosure by the Commission and addresses with specificity the considerations listed in paragraph (b)(4) of 10 CFR Section 2.390 of the Commission's regulations.

Accordingly, this letter authorizes the utilization of the accompanying affidavit by Southern California Edison.

Correspondence with respect to the proprietary aspects of the application for withholding or the Westinghouse affidavit should reference CAW-13-3659 and should be addressed to James A. Gresham, Manager, Regulatory Compliance, Westinghouse Electric Company, Suite 428, 1000 Westinghouse Drive, Cranberry Township, Pennsylvania 16066.

Very truly yours, James A. Gresham, Manager Regulatory Compliance Enclosures

CAW-13-3659 AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA:

ss COUNTY OF BUTLER:

Before me, the undersigned authority, personally appeared James A. Gresharn, who, being by me duly sworn according to law, deposes and says that he is authorized to execute this Affidavit on behalf of Westinghouse Electric Company LLC (Westinghouse), and that the averments of fact set forth in this Affidavit are true and correct to the best of his knowledge, information, and belief:

/James A Gresham, Manager Regulatory Compliance Sworn to and subscribed before me this 15 'h day of March 2013 Notary Public COMMONWEALTH OF PENNSYLVANIA l Anne M.Stegman, Notary Public Notarial seal Unity TWp., Westmoreland County My Commission Expires Aug. 7, 2016 MEMBER. PENNSYLVANIA ASSOCIATION OF NOTARIES

2 CAW-13-3659 (1) 1 am Manager, Regulatory Compliance, in Nuclear Services, Westinghouse Electric Company LLC (Westinghouse), and as such, I have been specifically delegated the function of reviewing the proprietary information sought to be withheld from public disclosure in connection with nuclear power plant licensing and rule making proceedings, and am authorized to apply for its withholding on behalf of Westinghouse.

(2) 1 am making this Affidavit in conformance with the provisions of 10 CFR Section 2.390 of the Commission's regulations and in conjunction with the Westinghouse Application for Withholding Proprietary Information from Public Disclosure accompanying this Affidavit.

(3) I have personal knowledge of the criteria and procedures utilized by Westinghouse in designating information as a trade secret, privileged or as confidential commercial or financial information.

(4) Pursuant to the provisions of paragraph (b)(4) of Section 2.390 of 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 should be withheld.

(i) The information sought to be withheld from public disclosure is owned and has been held in confidence by Westinghouse.

(ii) The information is of a type customarily held in confidence by Westinghouse and not customarily disclosed to the public. Westinghouse has a rational basis for determining the types of information customarily held in confidence by it and, in that connection, utilizes a system to determine when and whether to hold certain types of information in confidence. The application of that system and the substance of that system constitutes Westinghouse policy and provides the rational basis required.

Under that system, information is held in confidence if it falls in one or more of several types, the release of which might result in the loss of an existing or potential competitive advantage, as follows:

(a) The information reveals the distinguishing aspects of a process (or component, structure, tool, method, etc.) where prevention of its use by any of

3 CAW-13-3659 Westinghouse's competitors without license from Westinghouse constitutes a competitive economic advantage over other companies.

(b) It consists of supporting data, including test data, relative to a process (or component, structure, tool, method, etc.), the application of which data secures a competitive economic advantage, e.g., by optimization or improved marketability.

(c) Its use by a competitor would reduce his expenditure of resources or improve his competitive position in the design, manufacture, shipment, installation, assurance of quality, or licensing a similar product.

(d) It reveals cost or price information, production capacities, budget levels, or commercial strategies of Westinghouse, its customers or suppliers.

(e) It reveals aspects of past, present, or future Westinghouse or customer funded development plans and programs of potential commercial value to Westinghouse.

(f) It contains patentable ideas, for which patent protection may be desirable.

There are sound policy reasons behind the Westinghouse system which include the following:

(a) The use of such information by Westinghouse gives Westinghouse a competitive advantage over its competitors. It is, therefore, withheld from disclosure to protect the Westinghouse competitive position.

(b) It is information that is marketable in many ways. The extent to which such information is available to competitors diminishes the Westinghouse ability to sell products and services involving the use of the information.

(c) Use by our competitor would put Westinghouse at a competitive disadvantage by reducing his expenditure of resources at our expense.

4 CAW-13-3659 (d) Each component of proprietary information pertinent to a particular competitive advantage is potentially as valuable as the total competitive advantage. If competitors acquire components of proprietary information, any one component may be the key to the entire puzzle, thereby depriving Westinghouse of a competitive advantage.

(e) Unrestricted disclosure would jeopardize the position of prominence of Westinghouse in the world market, and thereby give a market advantage to the competition of those countries.

(f) The Westinghouse capacity to invest corporate assets in research and development depends upon the success in obtaining and maintaining a competitive advantage.

(iii) The information is being transmitted to the Commission in confidence and, under the provisions of 10 CFR Section 2.390, it is to be received in confidence by the Commission.

(iv) The information sought to be protected is not available in public sources or available information has not been previously employed in the same original manner or method to the best of our knowledge and belief.

(v) The proprietary information sought to be withheld in this submittal is that which is appropriately marked in LTR-SGDA- 13-27 P-Attachment, "San Onofre Nuclear Generating Unit 2 MHI Replacement Steam Generator Reponses to RAIs 48 and 49,"

dated March 14, 2013, for submittal to the Commission, being transmitted by Southern California Edison Letter and Application for Withholding Proprietary Information from Public Disclosure, to the Document Control Desk. The proprietary information as submitted by Westinghouse is that associated with the calculation of fluidelastic excitation of steam generator tubes and may be used only for that purpose.

5 5CAW-13-3659 This information is part of that which will enable Westinghouse to:

(a) Respond to a Nuclear Regulatory Commission (NRC) Request for Additional Information regarding the Westinghouse damping correlation and specifically how it relates to regions in the steam generator with high void fractions.

Further this information has substantial commercial value as follows:

(a) Westinghouse plans to sell the use of similar information to its customers for the purpose of evaluating the impact of fluidelastic excitation on steam generator tube integrity.

(b) Westinghouse can sell support and defense of the thermal hydraulic analysis of secondary side flow field in the steam generator shell.

(c) The information requested to be withheld reveals the distinguishing aspects of a methodology which was developed by Westinghouse.

Public disclosure of this proprietary information is likely to cause substantial harm to the competitive position of Westinghouse because it would enhance the ability of competitors to provide similar information and licensing defense services for commercial power reactors without commensurate expenses. Also, public disclosure of the information would enable others to use the information to meet NRC requirements for licensing documentation without purchasing the right to use the information.

The development of the technology described in part by the information is the result of applying the results of many years of experience in an intensive Westinghouse effort and the expenditure of a considerable sum of money.

6 CAW-13-3659 In order for competitors of Westinghouse to duplicate this information, similar technical programs would have to be performed and a significant manpower effort, having the requisite talent and experience, would have to be expended.

Further the deponent sayeth not.

S Westinghouse Westinghouse Electric Company Nuclear Services 1000 Westinghouse Drive Cranberry Township, Pennsylvania 16066 USA U.S. Nuclear Regulatory Commission Direct tel: (412) 374-4643 Document Control Desk Direct fax: (724) 720-0754 11555 Rockville Pike e-mail: greshaj a@westinghouse.com Rockville, MD 20852 Proj letter: CONO-13-22 CAW-13-3660 March 15, 2013 APPLICATION FOR WITHHOLDING PROPRIETARY INFORMATION FROM PUBLIC DISCLOSURE

Subject:

LTR-SGDA-13-23 P-Attachment, "San Onofre Nuclear Generating Station Unit 2 MHI Replacement Steam Generator Response to RAI 51" (Proprietary)

The proprietary information for which withholding is being requested in the above-referenced report is further identified in Affidavit CAW-13-3660 signed by the owner of the proprietary information, Westinghouse Electric Company LLC. The affidavit, which accompanies this letter, sets forth the basis on which the information may be withheld from public disclosure by the Commission and addresses with specificity the considerations listed in paragraph (b)(4) of 10 CFR Section 2.390 of the Commission's regulations.

Accordingly, this letter authorizes the utilization of the accompanying affidavit by Southern California Edison.

Correspondence with respect to the proprietary aspects of the application for withholding or the Westinghouse affidavit should reference CAW-13-3660 and should be addressed to James A. Gresham, Manager, Regulatory Compliance, Westinghouse Electric Company, Suite 428, 1000 Westinghouse Drive, Cranberry Township, Pennsylvania 16066.

Very truly yours, Jmes A. Gresham, Manager Regulatory Compliance Enclosures

CAW-13-3660 AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA:

ss COUNTY OF BUTLER:

Before me, the undersigned authority, personally appeared James A. Gresham, who, being by me duly sworn according to law, deposes and says that he is authorized to execute this Affidavit on behalf of Westinghouse Electric Company LLC (Westinghouse), and that the averments of fact set forth in this Affidavit are true and correct to the best of his knowledge, information, and belief:

j/ames &A.Gresham,Manager Regulatory Compliance Sworn to and subscribed before me this 15 "h day of March 2013 Notary Public COMMONWEALTH OF PENNSYLVANLA INotariai Seal Anne M.Stegman, Notary Public unity TWp., Westmoretand 4ESC'ommwsson Expires Aug. County 7, 201/6 1"EtPee KINNLVANtA ASSOaA-nON OF NOTARIES

2 CAW- 13-3660 (1) 1am Manager, Regulatory Compliance, in Nuclear Services, Westinghouse Electric Company LLC (Westinghouse), and as such, I have been specifically delegated the function of reviewing the proprietary information sought to be withheld from public disclosure in connection with nuclear power plant licensing and rule making proceedings, and am authorized to apply for its withholding on behalf of Westinghouse.

(2) 1 am making this Affidavit in conformance with the provisions of 10 CFR Section 2.390 of the Commission's regulations and in conjunction with the Westinghouse Application for Withholding Proprietary Information from Public Disclosure accompanying this Affidavit.

(3) 1 have personal knowledge of the criteria and procedures utilized by Westinghouse in designating information as a trade secret, privileged or as confidential commercial or financial information.

(4) Pursuant to the provisions of paragraph (b)(4) of Section 2.390 of 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 should be withheld.

(i) The information sought to be withheld from public disclosure is owned and has been held in confidence by Westinghouse.

(ii) The information is of a type customarily held in confidence by Westinghouse and not customarily disclosed to the public. Westinghouse has a rational basis for determining the types of information customarily held in confidence by it and, in that connection, utilizes a system to determine when and whether to hold certain types of information in confidence. The application of that system and the substance of that system constitutes Westinghouse policy and provides the rational basis required.

Under that system, information is held in confidence if it falls in one or more of several types, the release of which might result in the loss of an existing or potential competitive advantage, as follows:

(a) The information reveals the distinguishing aspects of a process (or component, structure, tool, method, etc.) where prevention of its use by any of

3 CAW-13-3660 Westinghouse's competitors without license from Westinghouse constitutes a competitive economic advantage over other companies.

(b) It consists of supporting data, including test data, relative to a process (or component, structure, tool, method, etc.), the application of which data secures a competitive economic advantage, e.g., by optimization or improved marketability.

(c) Its use by a competitor would reduce his expenditure of resources or improve his competitive position in the design, manufacture, shipment, installation, assurance of quality, or licensing a similar product.

(d) It reveals cost or price information, production capacities, budget levels, or commercial strategies of Westinghouse, its customers or suppliers.

(e) It reveals aspects of past, present, or future Westinghouse or customer funded development plans and programs of potential commercial value to Westinghouse.

(f) It contains patentable ideas, for which patent protection may be desirable.

There are sound policy reasons behind the Westinghouse system which include the following:

(a) The use of such information by Westinghouse gives Westinghouse a competitive advantage over its competitors. It is, therefore, withheld from disclosure to protect the Westinghouse competitive position.

(b) It is information that is marketable in many ways. The extent to which such information is available to competitors diminishes the Westinghouse ability to sell products and services involving the use of the information.

(c) Use by our competitor would put Westinghouse at a competitive disadvantage by reducing his expenditure of resources at our expense.

4 CAW-13-3660 (d) Each component of proprietary information pertinent to a particular competitive advantage is potentially as valuable as the total competitive advantage. If competitors acquire components of proprietary information, any one component may be the key to the entire puzzle, thereby depriving Westinghouse of a competitive advantage.

(e) Unrestricted disclosure would jeopardize the position of prominence of Westinghouse in the world market, and thereby give a market advantage to the competition of those countries.

(f) The Westinghouse capacity to invest corporate assets in research and development depends upon the success in obtaining and maintaining a competitive advantage.

(iii) The information is being transmitted to the Commission in confidence and, under the provisions of 10 CFR Section 2.390, it is to be received in confidence by the Commission.

(iv) The information sought to be protected is not available in public sources or available information has not been previously employed in the same original manner or method to the best of our knowledge and belief.

(v) The proprietary information sought to be withheld in this submittal is that which is appropriately marked in LTR-SGDA-1 3-23 P-Attachment, "San Onofre Nuclear Generating Unit 2 MHI Replacement Steam Generator Response to RAI 51," dated March 14, 2013, for submittal to the Commission, being transmitted by Southern California Edison Letter and Application for Withholding Proprietary Information from Public Disclosure, to the Document Control Desk. The proprietary information as submitted by Westinghouse is that associated with the calculation of fluidelastic excitation of steam generator tubes and may be used only for that purpose.

5 CAW- 13-3660 This information is part of that which will enable Westinghouse to:

(a) Respond to Nuclear Regulatory Commission (NRC) Request for Additional Information on intermediate details of the Westinghouse flow induced vibration (FIV) calculations for several limiting tubes. The information provided will enable the NRC to perform a comparison between Westinghouse and Mitsubishi Heavy Metal Industries (MHI) FIV methods and results.

Further this information has substantial commercial value as follows:

(a) Westinghouse plans to sell the use of similar information to its customers for the purpose of evaluating the impact of fluidelastic excitation on steam generator tube integrity.

(b) Westinghouse can sell support and defense of the thermal hydraulic analysis of secondary side flow field in the steam generator shell.

(c) The information requested to be withheld reveals the distinguishing aspects of a methodology which was developed by Westinghouse.

Public disclosure of this proprietary information is likely to cause substantial harm to the competitive position of Westinghouse because it would enhance the ability of competitors to provide similar information and licensing defense services for commercial power reactors without commensurate expenses. Also, public disclosure of the information would enable others to use the information to meet NRC requirements for licensing documentation without purchasing the right to use the information.

The development of the technology described in part by the information is the result of applying the results of many years of experience in an intensive Westinghouse effort and the expenditure of a considerable sum of money.

6 CAW- 13-3660 In order for competitors of Westinghouse to duplicate this information, similar technical programs would have to be performed and a significant manpower effort, having the requisite talent and experience, would have to be expended.

Further the deponent sayeth not.

• WestinghouseWestin house1000 Westinghouse Electric Company Nuclear Services Westinghouse Drive Cranberry Township, Pennsylvania 16066 USA U.S. Nuclear Regulatory Commission Direct tel: (412) 374-4643 Document Control Desk Direct fax: (724) 720-0754.

11555 Rockville Pike e-mail: greshaja@westinghouse.com Rockville, MD 20852 Proj letter: CONO-13-22 CAW-13-3661 March 15, 2013 APPLICATION FOR WITHHOLDING PROPRIETARY INFORMATION FROM PUBLIC DISCLOSURE

Subject:

LTR-SGDA-I 3-29 P-Attachment, "San Onofre Nuclear Generating Station Unit 2 MHI Replacement Steam Generator Response to RAI 52" (Proprietary)

The proprietary information for which withholding is being requested in the above-referenced report is further identified in Affidavit CAW-13-3661 signed by the owner of the proprietary information, Westinghouse Electric Company LLC. The affidavit, which accompanies this letter, sets forth the basis on which the information may be withheld from public disclosure by the Commission and addresses with specificity the considerations listed in paragraph (b)(4) of 10 CFR Section 2.390 of the Commission's regulations.

Accordingly, this letter authorizes the utilization of the accompanying affidavit by Southern California Edison.

Correspondence with respect to the proprietary aspects of the application for withholding or the Westinghouse affidavit should reference CAW-]13-3661 and should be addressed to James A. Gresham, Manager, Regulatory Compliance, Westinghouse Electric Company, Suite 428, 1000 Westinghouse Drive, Cranberry Township, Pennsylvania 16066.

Very truly yours, James A. Gresham, Manager Regulatory Compliance Enclosures

CAW-13-3661 AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA:

ss COUNTY OF BUTLER:

Before me, the undersigned authority, personally appeared James A. Gresham, who, being by me duly sworn according to law, deposes and says that he is authorized to execute this Affidavit on behalf of Westinghouse Electric Company LLC (Westinghouse), and that the averments of fact set forth in this Affidavit are true and correct to the best of his knowledge, information, and belief:

l mes A. Gresham, Manager Regulatory Compliance Sworn to and subscribed before me this 15 Ih day of March 2013 Notary Public COMMONWEALTH OF PENNSYLVANIA I Notarial Anne M.Stegman,Seal Notary Public I Unity Twp., Westmoreland county My Commisson MEBE,ENSLVANIAEpiVres Au.- O, ASSOCMTON OF2016 l NOTARIES

2 CAW-13-3661 (1) 1 am Manager, Regulatory Compliance, in Nuclear Services, Westinghouse Electric Company LLC (Westinghouse), and as such, I have been specifically delegated the function of reviewing the proprietary information sought to be withheld from public disclosure in connection with nuclear power plant licensing and rule making proceedings, and am authorized to apply for its withholding on behalf of Westinghouse.

(2) I am making this Affidavit in conformance with the provisions of 10 CFR Section 2.3 90 of the Commission's regulations and in conjunction with the Westinghouse Application for Withholding Proprietary Information from Public Disclosure accompanying this Affidavit.

(3) I have personal knowledge of the criteria and procedures utilized by Westinghouse in designating information as a trade secret, privileged or as confidential commercial or financial information.

(4) Pursuant to the provisions of paragraph (b)(4) of Section 2.390 of 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 should be withheld.

(i) The information sought to be withheld friom public disclosure is owned and has been held in confidence by Westinghouse.

(ii) The information is of a type customarily held in confidence by Westinghouse and not customarily disclosed to the public. Westinghouse has a rational basis for determining the types of information customarily held in confidence by it and, in that connection, utilizes a system to determine when and whether to hold certain types of information in confidence. The application of that system and the substance of that system constitutes Westinghouse policy and provides the rational basis required.

Under that system, information is held in confidence if it falls in one or more of several types, the release of which might result in the loss of an existing or potential competitive advantage, as follows:

(a) The information reveals the distinguishing aspects of a process (or component, structure, tool, method, etc.) where prevention of its use by any of

3 CAW-13-3661 Westinghouse's competitors without license from Westinghouse constitutes a competitive economic advantage over other companies.

(b) It consists of supporting data, including test data, relative to a process (or component, structure, tool, method, etc.), the application of which data secures a competitive economic advantage, e.g., by optimization or improved marketability.

(c) Its use by a competitor would reduce his expenditure of resources or improve his competitive position in the design, manufacture, shipment, installation, assurance of quality, or licensing a similar product.

(d) It reveals cost or price information, production capacities, budget levels, or commercial strategies of Westinghouse, its customers or suppliers.

(e) It reveals aspects of past, present, or future Westinghouse or customer funded development plans and programs of potential commercial value to Westinghouse.

(f) It contains patentable ideas, for which patent protection may be desirable.

There are sound policy reasons behind the Westinghouse system which include the following:

(a) The use of such information by Westinghouse gives Westinghouse a competitive advantage over its competitors. It is, therefore, withheld from disclosure to protect the Westinghouse competitive position.

(b) It is information that is marketable in many ways. The extent to which such information is available to competitors diminishes the Westinghouse ability to sell products and services involving the use of the information.

(c) Use by our competitor would put Westinghouse at a competitive disadvantage by reducing his expenditure of resources at our expense.

4 CAW-13-3661 (d) Each component of proprietary information pertinent to a particular competitive advantage is potentially as valuable as the total competitive advantage. If competitors acquire components of proprietary information, any one component may be the key to the entire puzzle, thereby depriving Westinghouse of a competitive advantage.

(e) Unrestricted disclosure would jeopardize the position of prominence of Westinghouse in the world market, and thereby give a market advantage to the competition of those countries.

(f) The Westinghouse capacity to invest corporate assets in research and development depends upon the success in obtaining and maintaining a competitive advantage.

(iii) The information is being transmitted to the Commission in confidence and, under the provisions of 10 CFR Section 2.390, it is to be received in confidence by the Commission.

(iv) The information sought to be protected is not available in public sources or available information has not been previously employed in the same original manner or method to the best of our knowledge and belief.

(v) The proprietary information sought to be withheld in this submittal is that which is appropriately marked in LTR-SGDA-13-29 P-Attachment, "San Onofre Nuclear Generating Station Unit 2 MHI Replacement Steam Generator Response to RAI 52,"

dated March 14, 2013, for submittal to the Commission, being transmitted by Southern California Edison Letter and Application for Withholding Proprietary Information from Public Disclosure, to the Document Control Desk. The proprietary information as submitted by Westinghouse is that associated with the calculation of fluidelastic excitation of steam generator tubes and may be used only for that purpose.

5 CAW-13-3661 This information is part of that which will enable Westinghouse to:

(a) Respond to a Nuclear Regulatory Commission (NRC) Request for Additional Information regarding the design basis and methodology that was used by Westinghouse to evaluate the tube/anti-vibration bar (AVB) wear potential for steam generators in another plant that are most comparable to the replacement steam generators in San Onofre Nuclear Generating Station (SONGS) Unit 2.

Further this information has substantial commercial value as follows:

(a) Westinghouse plans to sell the use of similar information to its customers for the purpose of evaluating the impact of fluidelastic excitation on steam generator tube integrity.

(b) Westinghouse can sell support and defense of the thermal hydraulic analysis of secondary side flow field in the steam generator shell.

(c) The information requested to be withheld reveals the distinguishing aspects of a methodology which was developed by Westinghouse.

Public disclosure of this proprietary information is likely to cause substantial harm to the competitive position of Westinghouse because it would enhance the ability of competitors to provide similar information and licensing defense services for commercial power reactors without commensurate expenses. Also, public disclosure of the information would enable others to use the information to meet NRC requirements for licensing documentation without purchasing the right to use the information.

The development of the technology described in part by the information is the result of applying the results of many years of experience in an intensive Westinghouse effort and the expenditure of a considerable sum of money.

6 CAW-13-3661 In order for competitors of Westinghouse to duplicate this information, similar technical programs would have to be performed and a significant manpower effort, having the requisite talent and experience, would have to be expended.

Further the deponent sayeth not.

Proprietary Information Notice Transmitted herewith are proprietary and/or non-proprietary versions of documents furnished to the NRC in connection with requests for additional information regarding stability ratios calculated for certain anti-vibration bar (AVB) support conditions for the San Onofre Nuclear Generating Station Unit 2 steam generators.

In order to conform to the requirements of 10 CFR 2.390 of the Commission's regulations concerning the protection of proprietary information so submitted to the NRC, the information which is proprietary in the proprietary versions is contained within brackets, and where the proprietary information has been deleted in the non-proprietary versions, only the brackets remain (the information that was contained within the brackets in the proprietary versions having been deleted). The justification for claiming the information so designated as proprietary is indicated in both versions by means of lower case letters (a) through (f) located as a superscript immediately following the brackets enclosing each item of information being identified as proprietary or in the margin opposite such information. These lower case letters refer to the types of information Westinghouse customarily holds in confidence identified in Sections (4)(ii)(a) through (4)(ii)(f) of the affidavit accompanying this transmittal pursuant to 10 CFR 2.390(b)(1).

Copyright Notice The reports transmitted herewith each bear a Westinghouse copyright notice. The NRC is permitted to make the number of copies of the information contained in these reports which are necessary for its internal use in connection with generic and plant-specific reviews and approvals as well as the issuance, denial, amendment, transfer, renewal, modification, suspension, revocation, or violation of a license, permit, order, or regulation subject to the requirements of 10 CFR 2.390 regarding restrictions on public disclosure to the extent such information has been identified as proprietary by Westinghouse, copyright protection notwithstanding. With respect to the non-proprietary versions of these reports, the NRC is permitted to make the number of copies beyond those necessary for its internal use which are necessary in order to have one copy available for public viewing in the appropriate docket files in the public document room in Washington, DC and in local public document rooms as may be required by NRC regulations if the number of copies submitted is insufficient for this purpose. Copies made by the NRC must include the copyright notice in all instances and the proprietary notice if the original was identified as proprietary.

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 46-49, 51 and 52 (NON-PROPRIETARY)

SUBJECT PAGE RA146 2 RA147 6 RAI 48 and 49 7 RA151 15 RAI 52 19

RAI 46

In Reference 7, p. 15 of 131, please provide justification for selection of 13=5.0 for the threshold value of the fluid elastic instability constant, and explain why it is a conservative selection for this application, considering the T/H conditions and size of the SONGS replacement SGs.

RESPONSE

Note: Request for Additional Information (RAI) Reference 7 is the "Operational Assessment of Wear Indications In the U-Bend Region of San Onofre Unit 2 Replacement Steam Generators,"

WEC, Report No. SG-SGMP-1 2-10, Revision 3, October 2012.

Bases and Justification for Selection of 13 =5.0 for Threshold Instability Constant for SONGS:

Figure 1 shows the final results from WEC Reference 3

.1 SONGS steam generators have a smaller p/d ratio than the reference tests, so a scale factor based on available open literature and WEC proprietary tests was developed as shown on Figure 2.

In summary, the value of P3 selected for use in the analysis is a lower bound value that envelops responses at frequencies both lower and higher than the minimum value at about [ ] as shown on Figure 1. Since the SONGS steam generators have relatively large regions with very high void fractions, the U-bend tests conducted in air are applicable to the thermal-hydraulic conditions present in the SONGS steam generators.

Enclosure 3 Page 2 of 19

WEC References for RAI 46:

1.) SG-SGMP-1 2-10, Revision 3, "Operational Assessment of Wear Indications in the U-bend Region of San Onofre Nuclear Generating Station Unit 2 Replacement Steam Generators," October 2012.

2.) Westinghouse Letter LTR-SGDA-12-36, Revision 3, "Flow-Induced Vibration and Tube Wear Analysis of the San Onofre Nuclear Generating Station Unit 2 Replacement Steam Generators Supporting Restart," February 2013 3.) Westinghouse Document, 98-7TK0-TRIWK-R1, "Investigation of the Fluidelastic Vibration of U-Bend Tubes in a Triangular Pattern," September 1998, (originally provided via Preliminary Report 91-7TL3-TRIWK-R1, January 1991, for inclusion as Appendix B1 in Reference 4). [Proprietary]

Note that RAI Reference 7 and WEC Reference 1 are the same document.

Enclosure 3 Page 3 of 19

Figure 1 Threshold Instability Constants Obtained from WEC Wind Tunnel Tests for Various TubeIAVB Support Conditions in 1/4 Scale U-bend Tests for Triangular Array Pattern (Pitch/Diameter = 1.42 with Typical Straight-Leg Length Indexing) Page 4 of 19

r Figure 2 Effect of Pitch-to-Diameter Ratio on Fluidelastic Instability Threshold Constant in Triangular Array Pattern Steam Generators Page 5 of 19

RAI 47

In Reference 8, p. 87, Section 4.2.3, please explain how

[Proprietary]

RESPONSE

Note: RAI Reference 8 is "Flow-Induced Vibration and Tube Wear Analysis of the San Onofre Nuclear Generating Station Unit 2 Replacement Steam Generators Supporting Restart," WEC, Report No. SG-SGDA-12-36, Revision 3, February 2013.

[ I The straight leg damping correlation was not used in the U-bend Flow Induced Vibration (FIV) response. The damping correlation provided in Section 4.2.3 of RAI Reference 8 is applicable to active modes in the straight leg and is a function of frequency, but not void fraction.

The U-bend damping correlation provided in Section 4.2.4 of RAI Reference 8 is applicable to active modes in the U-bend and upper portion of the straight leg and as can be seen below is a function of both frequency and void fraction:

The straight leg damping correlation was not used in the calculation of the FIV response of U-bend modes. The U-bend damping correlation that was used is a function of both frequency and void fraction, not just frequency. The effects of low damping due to high void fraction in the top portion of the straight leg is accounted for through calculation of the full tube modal effective void fraction including both the U-bend and straight leg portions of the tube. Page 6 of 19

RAI 48

In Reference 8, p.88, Section 4.2.4, please provide information to demonstrate that the

[

][Proprietary]

RAI 49

In Reference 8, p. 95, Figure 4-3 is provided for

[Proprietary]

RESPONSE

Note: RAI Reference 8 is "Flow-Induced Vibration and Tube Wear Analysis of the San Onofre Nuclear Generating Station Unit 2 Replacement Steam Generators Supporting Restart," WEC, Report No. SG-SGDA-12-36, Revision 3, February 2013.

Demonstration that U-bend Damping Correlations are Appropriate for Very High-Void Conditions:

WEC Reference 1 provides an open literature overview of steam-water tests conducted by MHI at temperatures up to 522 0 F and pressures up to 840 psi. WEC Reference 2 describes additional steam-water tests conducted by MHI for conditions up to 540°F and 1015 psi. WEC References 3 and 4 explain how damping data from those tests were evaluated, along with earlier data from a larger bundle, as a function of slip void fraction and frequency to obtain design correlations for damping in the U-bend region of steam generators. The resulting correlations that were cited in RAI Reference 8 have been successfully used in WEC designed steam generators since the correlations were developed. They were derived using data that covered the [ ] range in slip void fraction from test programs as described in WEC Reference 4.

The raw data used in the WEC Reference 3 and Reference 4 analyses for pinned supports were documented in proprietary technical exchange meetings between WEC and MHI in September 1986 and November 1987.

The lower limit of damping recommended in WEC Reference 4 was a mathematical convenience that did not affect prior applications. [

] An additional study documented in WEC Enclosure 3 Page 7 of 19

Reference 5 used all the mechanical damping tests results from Section 8.0 of WEC Reference 4 to derive physically meaningful lower bounds. [

] Figure 2 taken from WEC Reference 5 illustrates the results of the final correlations for various pinned support conditions considered applicable in a pure steam environment with slip void fraction of 1.0.

Plots of U-bend Damping Correlations as a Function of Frequency and Void Fraction:

Figure 4 illustrates requested damping trends as a function of frequency for various void fractions between [ ] This plot represents results of the RAI Reference 8 WEC correlation for damping with pinned supports consistent with the two-phase steam environment of SONGS replacement steam generators (RSGs).

] RAI Reference 8 analyses consistently used this option as most representative of current conditions in the steam generators and therefore most applicable to future projections of tube wear.

The damping correlation is a straight-forward explicit function of frequency and void fraction.

However, each of those input values are modal effective characterizations of which part of the tube is moving and how much it is moving in the flow.

]1 This option is used for evaluation of design adequacy in WEC analyses, but the Figure 4 option is considered most representative of field conditions in the SONGS steam generators. It is important to note that at 70% power, very high-void conditions where two-phase damping would be expected to approach nil do not exist in the SONGS steam generators.

Note: [

Enclosure 3 Page 8 of 19

WEC References for RAIs 48 and 49 1.) T. Nakamura, K. Fujita, K. Kawanishi, N. Yamaguchi, and A. Tsuge, "Study on the Vibrational Characteristics of a Tube Array Caused by Two-Phase Flow, Part 1, Random Vibration," Flow-Induced Vibration and Wear, ASME PVP Vol. 206, June 1991, pp. 19-24.

2.) T. Nakamura, K. Fujita, K. Kawanishi, N. Yamaguchi, and A. Tsuge, "Study on the Vibrational Characteristics of a Tube Array Caused by Two-Phase Flow, Part 2, Fluidelastic Vibration," Flow-Induced Vibration and Wear, ASME PVP Vol. 206, June 1991, pp. 25-30.

3.) Westinghouse Calculation Note, SM-92-24, Rev. 0, "Development of Damping Models for Tsuruga U-Bend Evaluations," March 20, 1992. [Proprietary]

4.) Westinghouse Document, WCAP-1 3264, "Steam Generator Tube Integrity Study for the Japan Atomic Power Company Summary Report," "Section 7.1 Development of Damping for Tube U-bend Evaluations," and "Section 8.0 Task F - Mechanical Damping Tests,"

March 1992. [Proprietary]

5.) Westinghouse Calculation Note, CN-NEE-00-0023, "Minimum Damping for Evaluation of U-bend Tubing with Pinned Intersections," March 2000. [Proprietary] Page 9 of 19

Figure 1 U-bend Damping for Pinned Intersections for High Void Fraction Data from WEC References 1, and 2 for Frequencies Near 30 Hz Together with Correlation Trend Page 10 of 19

r Figure 2 U-bend Damping for Pinned Intersections as a Function of Frequency for Upper Limit Slip Void Fraction Value of 1.0 for Various Pinned Support Conditions that Correspond to the Various Values for Parameter A in the Inset Correlation (Figure 7 from WEC Reference 5) Page 11 of 19

r Figure 3 U-bend Damping for Pinned Intersections as a Function of Frequency for Lower Limit Slip Void Fraction Value of 0.80 for Various Pinned Support Conditions that Correspond to the Various Values for Parameter A in the Inset Correlation (Figure 8 from WEC Reference 5) Page 12 of 19

Figure 4 U-bend Damping for Pinned Intersections as a Function of Frequency for Various Void Fractions as Applied for SONGS Evaluation in RAI Reference 8 (Pinned Supports with Gaps are Assumed Consistent with ECT Indications of Tube/AVB Wear) Page 13 of 19

r Figure 5 U-bend Damping for Pinned Intersections as a Function of Frequency for Various Void Fractions (Pinned Supports with Small Preloads are Assumed for Estimate of Design Implications Page 14 of 19

RAI 51

In Reference 8, p. 101, in order for NRC staff to better understand the Westinghouse methodology and overall results, please provide a summary of analytic results that includes a breakdown of

][Proprietary]

RESPONSE

Note: RAI Reference 8 is "Flow-Induced Vibration and Tube Wear Analysis of the San Onofre Nuclear Generating Station Unit 2 Replacement Steam Generators Supporting Restart," WEC, Report No. SG-SGDA-12-36, Revision 3, February 2013.

The WEC method for calculating fluid elastic instability is similar in nature to the method used by MHI. However, some of the inputs and outputs used by the WEC method differ from the MHI method and therefore the tables providing the details of the stability ratio calculation differ. A summary of the differences in the inputs and outputs is explained in paragraphs (1) through (4) below.

(1) Damping Ratio Calculation:

The method of calculating the damping ratio differs between the WEC and MHI methods.

] Additional information on the WEC damping correlation is provided as a response to RAIs 48 and 49.

(2) Application of the Conners Coefificient:

The second difference between the WEC and MHI method is the application of the Connors coefficient.

Details of the derivation of the Connors coefficient are described in Section 4.2.5.2 of RAI Reference 8. Additional information on the WEC derivation of the Connors coefficient is contained in the response to RAI 46.

(3) Secondary Reference Densitiy (p0):

A third difference between the WEC and MHI methodology is in the use of the secondary reference density Po. This term appears in both the critical velocity and effective velocity calculation. In the final stability ratio calculation, the secondary reference density is divided out Enclosure 3 Page 15 of 19

of the equation so the differences in methodology have no impact on the stability ratio result.

The MHI method uses an average secondary density that is calculated for each tube; whereas, the WEC methodology uses a constant value of [ ] This accounts for differences in the results when comparing the MHI calculated critical velocity or effective velocity to the WEC counterpart. It should be noted that the actual density of the tube and surrounding fluid is included in the integration of the effective velocity as it changes around the tube and the secondary reference density only applies to the constant density term in the critical and effective velocity equations.

(4) Average Void Fraction:

The average void fraction, as referenced in the MHI report,

] Therefore, this value is not provided.

The details of the stability ratio calculation are provided for 10 limiting tubes in the out-of-plane direction in Table 1 and the in-plane direction in Table 2. Five of the tubes were chosen to be the limiting active tubes and the other five were chosen to be tubes plugged with a split cable stabilizer. The tubes provided in Table 1 and Table 2 were chosen from the subset of limiting tubes to provide a range of tube rows and support cases. The results for the tubes that contain a stabilizer include the added mass and additional damping provided by the split cable stabilizers. Details of the methodology used to model the split cable stabilizers are documented in Appendix C of RAI Reference 8. The detailed results in Table 1 and Table 2 were provided for the 70% power level. Page 16 of 19

Table 1 - Out-of-Plane Excitation Ratio Calculation Details TubeTube ConnorsReference Maximum Critical Effective Excitation Tube Mode Tubese coefficient Void Velocity Velocity Ratio Row Cae Status Frequency Ratio (Beta) i Fraction (f/s) (ft/s)

(Hz) QIb/ft3)

Enclosure 3 Page 17 of 19

Table 2 - In-Plane Stability Ratio Calculation Details TueTube Tube Connors Reference fluid Maximum Critical Effective RowCobSeCseMode Fui Stabilityig Natural Damping coefficient Denit Void Velocity Velocity Stability Tube Row Col Status Frequency Ratio (Beta) Density Fraction (fts) (fts) Ratio (Hz) (Ib/ft3)

___ JNI7_

Enclosure 3 Page 18 of 19

RAI 52

In Reference 8, p. 254, Section 7.2.2.1, [

[Proprietary]

Response

Note: RAI Reference 8 is "Flow-Induced Vibration and Tube Wear Analysis of the San Onofre Nuclear Generating Station Unit 2 Replacement Steam Generators Supporting Restart," WEC, Report No. SG-SGDA-12-36, Revision 3, February 2013.

Explanation of Differences in Wear Coefficients Between SONGS and Plant B:

The variables (including wear coefficients) that were used in Plant B wear calculations were adjusted as necessary to obtain the observed depths and distributions found by eddy current testing (ECT) (bobbin) examinations.

Plant B wear coefficients are not directly comparable to SONGS wear coefficients. The wear coefficients used in the Plant B calculations were used to project for a typical design calculation and were not used to match observed wear depth. The objectives of the SONGS wear calculations were to match the known wear depths and then project future wear.

Enclosure 3 Page 19 of 19