ML13155A004

San Onofre, Unit 2, Response to Request for Additional Information (RAI 73) Regarding Confirmatory Action Letter Response

ML13155A004
Person / Time
Site:	San Onofre
Issue date:	05/30/2013
From:	Onge R J Southern California Edison Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
TAC ME9727
Download: ML13155A004 (29)

Text

J SOUTHERN CALIFORNIAEDISON5An EDISON INTERNATIONAL@ CompanyProprietary InformationWithhold from Public DisclosureRichard St. OngeDirector, Nuclear Regulatory Affairs andEmergency PlanningMay 30, 201310 CFR 50.4U.S. Nuclear Regulatory CommissionATTN: Document Control DeskWashington, DC 20555-0001Subject:Docket No. 50-361Response to Request for Additional Information (RAI 73) RegardingConfirmatory Action Letter Response(TAC No. ME 9727)San Onofre Nuclear Generating Station, Unit 21. Letter from Mr. Elmo E. Collins (USNRC) to Mr. Peter T. Dietrich (SCE), datedMarch 27, 2012, Confirmatory Action Letter 4-12-001, San Onofre NuclearGenerating Station, Units 2 and 3, Commitments to Address Steam GeneratorTube DegradationReferences:2. Letter from Mr. Peter T. Dietrich (SCE) to Mr. Elmo E. Collins (USNRC), datedOctober 3, 2012, Confirmatory Action Letter -Actions to Address SteamGenerator Tube Degradation, San Onofre Nuclear Generating Station, Unit 23. Letter from Mr. Richard J. St. Onge (SCE) to Document Control Desk(USNRC), dated April 2, 2013, Response to Request for Additional Information(RAI 13), Revision 1 Regarding Confirmatory Action Letter Response, SanOnofre Nuclear Generating Station, Unit 24. Letter from Mr. James R. Hall (USNRC) to Mr. Peter T. Dietrich (SCE), datedMay 10, 2013, San Onofre Nuclear Generating Station, Unit 2 -Request forAdditional Information Regarding Response to Confirmatory Action LetterDear Sir or Madam,On March 27, 2012, the Nuclear Regulatory Commission (NRC) issued a Confirmatory ActionLetter (CAL) (Reference 1) to Southern California Edison (SCE) describing actions that the NRCand SCE agreed would be completed to address issues identified in the steam generator tubesof San Onofre Nuclear Generating Station (SONGS) Units 2 and 3. In a letter to the NRC datedOctober 3, 2012 (Reference 2), SCE reported completion of the Unit 2 CAL actions andincluded a Return to Service Report (RTSR) that provided details of their completion.SCE provided the response to Request for Additional Information (RAI) 13 in a letter datedApril 2, 2013 (Reference 3). By letter dated May 10, 2013 (Reference 4), the NRC issuedRAI 73 regarding the response to RAI 13. Enclosure 2 of this letter provides the response toRAI 73.Proprietary InformationWithhold from Public DisclosureDecontrolled Upon Removal of Enclosure 2P.O. Box 128San Clemente. CA 92674 Proprietary InformationWithhold from Public DisclosureDocument Control Desk-2-May 30, 2013Enclosure 2 of this submittal contains proprietary information. SCE requests that thisproprietary enclosure be withheld from public disclosure in accordance with 10 CFR 2.390(a)(4).Enclosure 1 provides notarized affidavits from Westinghouse, which sets forth the basis onwhich the information in Enclosure 2 may be withheld from public disclosure by the NRC andaddresses with specificity the considerations listed by paragraph (b)(4) of 10 CFR 2.390.Enclosure 3 provides the non-proprietary version of Enclosure 2.There are no new regulatory commitments contained in this letter. If you have any questions orrequire additional information, please call me at (949) 368-6240.Sincerely,Enclosures:1. Notarized Affidavits2. Response to RAI 73 (Proprietary)3. Response to RAI 73 (Non-Proprietary)cc: A. T. Howell Ill, Regional Administrator, NRC Region IVJ. R. Hall, NRC Project Manager, SONGS Units 2 and 3G. G. Warnick, NRC Senior Resident Inspector, SONGS Units 2 and 3R. E. Lantz, Branch Chief, Division of Reactor Projects, NRC Region IVProprietary InformationWithhold from Public DisclosureDecontrolled Upon Removal of Enclosure 2 ENCLOSURE 1Notarized Affidavits

• WestinghouseU.S. Nuclear Regulatory CommissionDocument Control Desk11555 Rockville PikeRockville, MD 20852Westinghouse Electric CompanyNuclear Services1000 Westinghouse DriveCranberry Township, Pennsylvania 16066USADirect tel: (412) 374-4643Direct fax: (724) 720-0754e-mail: greshaja@westinghouse.comProj letter: CONO-1 3-44CAW-13-3724May 23, 2013APPLICATION FOR WITHHOLDING PROPRIETARYINFORMATION FROM PUBLIC DISCLOSURESubject: LTR-LAM-13-34-P-Attachment, "Response to NRC Confirmatory Action Letter RAI #73 forSONGS Unit 2" (Proprietary)The proprietary information for which withholding is being requested in the above-referenced report isfurther identified in Affidavit CAW-13-3724 signed by the owner of the proprietary information,Westinghouse Electric Company LLC. The affidavit, which accompanies this letter, sets forth the basison which the information may be withheld from public disclosure by the Commission and addresses withspecificity the considerations listed in paragraph (b)(4) of 10 CFR Section 2.390 of the Commission'sregulations.Accordingly, this letter authorizes the utilization of the accompanying affidavit by Southern CaliforniaEdison.Correspondence with respect to the proprietary aspects of the application for withholding or theWestinghouse affidavit should reference CAW-13-3724, and should be addressed to James A. Gresham,Manager, Regulatory Compliance, Westinghouse Electric Company, Suite 310, 1000 WestinghouseDrive, Cranberry Township, Pennsylvania 16066.Very truly yours,e A. Gresham, ManagerRegulatory ComplianceEnclosures CAW-13-3724AFFIDAVITCOMMONWEALTH OF PENNSYLVANIA:ssCOUNTY OF BUTLER:Before me, the undersigned authority, personally appeared James A. Gresham, who, being by meduly sworn according to law, deposes and says that he is authorized to execute this Affidavit on behalf ofWestinghouse Electric Company LLC (Westinghouse), and that the averments of fact set forth in thisAffidavit are true and correct to the best of his knowledge, information, and belief:James A. Gresham, ManagerRegulatory ComplianceSworn to and subscribed before methis 23rd day of May 2013Notary PublicCOMMONWEALTH OF PENNSYLVANIAI Notarial SealAnne M. Stegman, Notary PublicUnity Twp., Westmoreland CountyMy Commlsslon Expires Aug, 7, 2016MEMBER, PENNSYLVANIA ASSOCIATION OF NOTARIES 2CAW-13-3724(1) I am Manager, Regulatory Compliance, in Nuclear Services, Westinghouse ElectricCompany LLC (Westinghouse), and as such, I have been specifically delegated the function ofreviewing the proprietary information sought to be withheld from public disclosure in connectionwith nuclear power plant licensing and rule making proceedings, and am authorized to apply forits withholding on behalf of Westinghouse.(2) 1 am making this Affidavit in conformance with the provisions of 10 CFR Section 2.390 of theCommission's regulations and in conjunction with the Westinghouse Application for WithholdingProprietary Information from Public Disclosure accompanying this Affidavit.(3) I have personal knowledge of the criteria and procedures utilized by Westinghouse in designatinginformation 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 theinformation 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 heldin confidence by Westinghouse.(ii) The information is of a type customarily held in confidence by Westinghouse and notcustomarily disclosed to the public. Westinghouse has a rational basis for determiningthe 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 inconfidence. The application of that system and the substance of that system constitutesWestinghouse policy and provides the rational basis required.Under that system, information is held in confidence if it falls in one or more of severaltypes, the release of which might result in the loss of an existing or potential competitiveadvantage, 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 3CAW-13-3724Westinghouse's competitors without license from Westinghouse constitutes acompetitive economic advantage over other companies.(b) It consists of supporting data, including test data, relative to a process (orcomponent, structure, tool, method, etc.), the application of which data secures acompetitive economic advantage, e.g., by optimization or improvedmarketability.(c) Its use by a competitor would reduce his expenditure of resources or improve hiscompetitive position in the design, manufacture, shipment, installation, assuranceof quality, or licensing a similar product.(d) It reveals cost or price information, production capacities, budget levels, orcommercial strategies of Westinghouse, its customers or suppliers.(e) It reveals aspects of past, present, or future Westinghouse or customer fundeddevelopment 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 thefollowing:(a) The use of such information by Westinghouse gives Westinghouse a competitiveadvantage over its competitors. It is, therefore, withheld from disclosure toprotect the Westinghouse competitive position.(b) It is information that is marketable in many ways. The extent to which suchinformation is available to competitors diminishes the Westinghouse ability tosell products and services involving the use of the information.(c) Use by our competitor would put Westinghouse at a competitive disadvantage byreducing his expenditure of resources at our expense.

4CAW-13-3724(d) Each component of proprietary information pertinent to a particular competitiveadvantage is potentially as valuable as the total competitive advantage. Ifcompetitors acquire components of proprietary information, any one componentmay be the key to the entire puzzle, thereby depriving Westinghouse of acompetitive advantage.(e) Unrestricted disclosure would jeopardize the position of prominence ofWestinghouse in the world market, and thereby give a market advantage to thecompetition of those countries.(f) The Westinghouse capacity to invest corporate assets in research anddevelopment depends upon the success in obtaining and maintaining acompetitive advantage.(iii) The information is being transmitted to the Commission in confidence and, under theprovisions of 10 CFR Section 2.390, it is to be received in confidence by theCommission.(iv) The information sought to be protected is not available in public sources or availableinformation has not been previously employed in the same original manner or method tothe best of our knowledge and belief.(v) The proprietary information sought to be withheld in this submittal is that which isappropriately marked in LTR-LAM-13-34-P Attachment, "Response to NRCConfirmatory Action Letter RAI #73 for SONGS Unit 2" (Proprietary), for submittal tothe Commission, being transmitted by Southern California Edison letter and Applicationfor Withholding Proprietary Information from Public Disclosure, to the DocumentControl Desk. The proprietary information as submitted by Westinghouse is thatassociated with a response to NRC RAI #73 and may be used only for that purpose.This information is part of that which will enable Westinghouse to:(a) Adequately support the response to the NRC RAI.

5CAW-13-3724Further this information has substantial commercial value as follows:(a) Westinghouse plans to sell the use of the information to its customers for thepurpose of supporting responses to NRC RAIs.(b) Westinghouse can sell support and defense of safety analysis services.(c) The information requested to be withheld reveals the distinguishing aspects of amethodology which was developed by Westinghouse.Public disclosure of this proprietary information is likely to cause substantial harm to thecompetitive position of Westinghouse because it would enhance the ability ofcompetitors to provide similar technical evaluation justifications and licensing defenseservices for commercial power reactors without commensurate expenses. Also, publicdisclosure of the information would enable others to use the information to meet NRCrequirements for licensing documentation without purchasing the right to use theinformation.The development of the technology described in part by the information is the result ofapplying the results of many years of experience in an intensive Westinghouse effort andthe expenditure of a considerable sum of money.In order for competitors of Westinghouse to duplicate this information, similar technicalprograms would have to be performed and a significant manpower effort, having therequisite talent and experience, would have to be expended.Further the deponent sayeth not.

PROPRIETARY INFORMATION NOTICETransmitted herewith are proprietary and/or non-proprietary versions of documents furnished to the NRCin connection with requests associated with a response to NRC RAI #73 and may be used only for thatpurpose.In order to conform to the requirements of 10 CFR 2.390 of the Commission's regulations concerning theprotection of proprietary information so submitted to the NRC, the information which is proprietary in theproprietary versions is contained within brackets, and where the proprietary information has been deletedin the non-proprietary versions, only the brackets remain (the information that was contained within thebrackets in the proprietary versions having been deleted). The justification for claiming the informationso 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 beingidentified as proprietary or in the margin opposite such information. These lower case letters refer to thetypes 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 NOTICEThe reports transmitted herewith each bear a Westinghouse copyright notice. The NRC is permitted tomake the number of copies of the information contained in these reports which are necessary for itsinternal 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 publicdisclosure to the extent such information has been identified as proprietary by Westinghouse, copyrightprotection notwithstanding. With respect to the non-proprietary versions of these reports, the NRC ispermitted to make the number of copies beyond those necessary for its internal use which are necessary inorder to have one copy available for public viewing in the appropriate docket files in the public documentroom in Washington, DC and in local public document rooms as may be required by NRC regulations ifthe number of copies submitted is insufficient for this purpose. Copies made by the NRC must includethe copyright notice in all instances and the proprietary notice if the original was identified as proprietary.

ENCLOSURE 3SOUTHERN CALIFORNIA EDISONRESPONSE TO REQUEST FOR ADDITIONAL INFORMATIONREGARDING RESPONSE TO CONFIRMATORY ACTION LETTERDOCKET NO. 50-361TAC NO. ME 9727Response to RAI 73(NON-PROPRIETARY)

RAI 73:In Section 4.2, "Impact of the RSGs on the SBLOCA AOR," of Reference 1, SCE assesses theeffects of differences between the original and replacement steam generators on the small-break loss of coolant accident (SBLOCA) analysis of record (AOR). Specifically, items (ii)through (vi) of Section 4.2 address the differences in tube geometry and material, primary andsecondary side liquid inventory, elevation of components, and total metal mass, and provide thelicensee's conclusions on the effects of each difference on the SBLOCA analysis, if any. TheNRC staff reviewed available documentation for the S2M evaluation model (Reference 2) anddid not identify a basis for these conclusions. Please provide the basis for these conclusions. Ifthe basis is completely described by the RAI response, please qualify the conclusions withsupplemental information.RESPONSE:Note: RAI Reference 1 is letter from SCE to NRC titled "Response to Request for AdditionalInformation (RAI 13) Regarding Confirmatory Action Letter Response," dated April 2, 2013. RAIReference 2 is Westinghouse document CENPD-1 37, Supplement 2-P-A, "Calculative Methodsfor the ABB CE Small Break LOCA Evaluation Model," dated April 1998.SBLOCA sensitivity studies were performed and the results are provided as follows:4.2 Impact of the Replacement Steam Generators (RSGs) on the SBLOCA AORii. Effect of the differences in SG tube geometry and material.R %,11 -Do 11ln DO)R 2k,,,,, Dwhere:Rwaii = tube wall resistance to heat transfer, (Btu/hr-ft2-oF)-1Do = tube outside diameter, ftD, = tube inside diameter, ftkwaii = tube material thermal conductivity, Btu/hr-ft-°Fshows[compared to the OSGs at 5500F. This [ ] since afterthe cessation of the subcooled forced convection mode of SG heat transfer early in the LOCAtransient, the [ ] is generally thelimiting resistance for SG heat transfer during a LOCA.Enclosure 3Page 1 of 18 The impact on the SONGS limiting SBLOCA case with OSGs due to the differences in the SGtube geometry and SG tube material between the OSGs (Inconel 600) and RSGs (Inconel 690)Note: The SONGS SBLOCA limiting case with OSGs is the 0.04 ft2 break with a PCT of2077 *F. The PCT for the SBLOCA analysis is calculated in two steps. First, a no-clad rupturebreak spectrum analysis is run to determine the limiting break size. The limiting PCT for the no-rupture analysis is 1926.4 *F. Then, a parametric study on gap pressure for the limiting breakcase is run to determine the maximum PCT. For the parametric study shown in this RAIresponse only the no-rupture part of the analysis was rerun.iii. Effect of the differences in SG primary side liquid inventory and heat transfer area.The RSGs with 8% Steam Generator Tube Plugging (SGTP) have approximately [] SG primary side than the OSGs with 21.4% SGTP. As noted in Item4.2.i [ ] in the primary sides of SGs for theRSGs [ ] of core uncovery and the subsequent less severe core uncoverydue to the decrease of the core decay heat at a later time.Evaluation of the impact of the increase in primary liquid inventoryIiv. Effect of the differences in SG secondary side liquid inventory.The nominal secondary side liquid inventory for the RSGs is approximately] SBLOCA calculations with the Supplement 2 Model (RAI Reference 2) areEnclosure 3Page 2 of 18 The impact of the difference on the SG heattransfer [ ] and its impact on core uncovery or time of core uncovery is [ I.The impact on the SONGS limiting SBLOCA case with OSGs due to the larger SG secondaryside liquid inventory for the RSGsv. Effect of the differences in elevation of SG components.The average SG tube length for the RSGs is [ ] Thevertical rise for the longest tube for the RSGs is [ ] the OSGs.These differences in elevation [ ] on a SBLOCA event since the impacton the elevation head difference between the hot and cold sides of the SGs is negligible.The impact of the increase in vertical elevation of the RSG primary side components on theSONGS limiting SBLOCA case with OSGsvi. Effect of the differences in SG total metal mass.The SG metal mass for the RSGs is [ ] OSGs. This [] ECCS performance analyses were performed with theSupplement 2 Model (RAI Reference 2). SG secondary side wall heat is] the secondary side and has [ ] on the RCS.The impact on the SONGS limiting SBLOCA case with OSGs due to the larger SG secondaryside metal massEnclosure 3Page 3 of 18 Figure 4.2-1. Effect of the Differences in SG Tube Geometry and Material.Core PressureEnclosure 3Page 4 of 18 Figure 4.2-2. Effect of the Differences in SG Tube Geometry and Material.Core Mixture LevelEnclosure 3Page 5 of 18 Figure 4.2-3. Effect of the Differences in SG Tube Geometry and Material.Hot Spot Cladding TemperatureEnclosure 3Page 6 of 18 Figure 4.2-4. Effect of the Differences in SG Primary Side Liquid Inventoryand Heat Transfer Area.Core PressureEnclosure 3Page 7 of 18 Figure 4.2-5. Effect of the Differences in SG Primary Side Liquid Inventoryand Heat Transfer Area.Core Mixture LevelEnclosure 3Page 8 of 18 Figure 4.2-6. Effect of the Differences in SG Primary Side Liquid Inventoryand Heat Transfer Area.Hot Spot Cladding TemperatureEnclosure 3Page 9 of 18 Figure 4.2-7. Effect of the Differences in SG Secondary Side Liquid Inventory.Core PressureEnclosure 3Page 10 of 18 Figure 4.2-8. Effect of the Differences in SG Secondary Side Liquid Inventory.Core Mixture LevelEnclosure 3Page 11 of 18 Figure 4.2-9. Effect of the Differences in SG Secondary Side Liquid Inventory.Hot Spot Cladding TemperatureEnclosure 3Page 12 of 18 Figure 4.2-10. Effect of the Differences in Elevation of SG Components.Core PressureEnclosure 3Page 13 of 18 Figure 4.2-11. Effect of the Differences in Elevation of SG Components.Core Mixture LevelEnclosure 3Page 14 of 18 Figure 4.2-12. Effect of the Differences in Elevation of SG Components.Hot Spot Cladding TemperatureEnclosure 3Page 15 of 18 Figure 4.2-13. Effect of the Differences in SG Total Metal Mass.Core PressureEnclosure 3Page 16 of 18 Figure 4.2-14. Effect of the Differences in SG Total Metal Mass.Core Mixture LevelEnclosure 3Page 17 of 18 Figure 4.2-15. Effect of the Differences in SG Total Metal Mass.Hot Spot Cladding TemperatureEnclosure 3Page 18 of 18