ML13022A413

San Onofre, Unit 2, Response to Request for Additional Information (RAIs 10 and 17) Regarding Confirmatory Action Letter Response

ML13022A413
Person / Time
Site:	San Onofre
Issue date:	01/17/2013
From:	St.Onge R J Southern California Edison Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
TAC ME9727
Download: ML13022A413 (10)

Text

J ISOUTHERN CALIFORNIAEDISONAn EDISON INTERNATIONAL CompanyRichard I. St. OngeDirector, Nuclear Regulatory Affairs andEmergency PlanningProprietary InformationWithhold from Public DisclosureJanuary 17, 201310 CFR 50.4U.S. Nuclear Regulatory CommissionATTN: Document Control DeskWashington, DC 20555-0001Subject:Docket No. 50-361Response to Request for Additional Information (RAIs 10 and 17)Regarding Confirmatory 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. James R. Hall (USNRC) to Mr. Peter T. Dietrich (SCE), datedDecember 26, 2012, Request for Additional Information Regarding Responseto Confirmatory Action Letter, San Onofre Nuclear Generating Station, Unit 2Dear 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 datedOttober 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.By letter dated December 26, 2012 (Reference 3), the NRC issued Requests for AdditionalInformation (RAIs) regarding the CAL response. Enclosure 2 of this letter provides theresponse to RAIs 10 and 17.Enclosure 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 a notarized affidavit from (Electric Power Research Institute), which setsforth the basis on which the information in Enclosure 2 may be withheld from public disclosureProprietary InformationWithhold from Public DisclosureDecontrolled Upon Removal From Enclosure 2P.O. Box 128San Clemente, CA 92672 Proprietary InformationWithhold from Public DisclosureDocument Control Desk-2-January 17, 2013by the NRC and addresses with specificity the considerations listed by paragraph (b)(4) of 10CFR 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.Enclosures:1. Notarized Affidavits2. Response to RAIs 10 and 17 (Proprietary)3. Response to RAIs 10 and 17 (Non-proprietary)cc:E. E. Collins, Regional Administrator, NRC Region IVR. Hall, NRC Project Manager, SONGS Units 2 and 3G. G. Warnick, NRC Senior Resident Inspector, SONGSUnits 2 and 3R. E. Lantz, Branch Chief, Division of Reactor Projects, NRC Region IVProprietary InformationWithhold from Public DisclosureDecontrolled Upon Removal From Enclosure 2 ENCLOSURE 1Notarized Affidavits I121 ELECTRIC POWERI RESEARCH INSTITUTEJanuary 14, 2013Document Control DeskOffice of Nuclear Reactor RegulationU.S. Nuclear Regulatory CommissionWashington, DC 20555-0001Subject: Request for Withholding Values in Table "AOI Steam Generator Tube Leak Actions" in SONGSResponse to NRC Request for Additional Information No. 10Reference: Steam Generator Management Program: PWR Primary-to-Secondary Leak Guidelines,Revision 4. EPRI, Palo Alto, CA: 2011. 1022832To Whom It May Concern:This is a request under 10 C.F.R. §2.390(a)(4) that the U.S. Nuclear Regulatory Commission ("NRC")withhold from public disclosure the information identified in the enclosed Affidavit consisting of thecommercial information owned by Electric Power Research Institute, Inc. ("EPRI") identified above (the"Table"). Copies of SONGS response to NRC RAI No. 10 and the Affidavit in support of this request areenclosed.EPRI desires to disclose values in the Table in confidence as a means of exchanging technical informationwith the NRC. The values in the Table are not to be divulged to anyone outside of the NRC nor shall anycopies be made of the values in the Table provided herein. EPRI welcomes any discussions and/orquestions relating to the information enclosed.If you have any questions about the legal aspects of this request for withholding, please do not hesitate tocontact me at (704) 595-2732. Questions on the content of the Table should be directed to Helen Cothronof EPRI at (865) 773-4033.Sincerely,Steven M. SwilleySenior Business Operations ManagerTogether ...Shaping the Future of ElectricityCHARLOTTE OFFICE1300 West W.T. Harris Boulevard, Charlotte, NC 28262-8550 USA

• 704.595.2000

• Fax 704.595.2860Customer Service 800.313.3774

• www.epri.com urnELECTRIC POWER* I12 I RESEARCH INSTITUTEAFFIDAVITRequest for Withholding Values in Table "AOI Steam Generator Tube Leak Actions" from SONGSResponse to NRC Request for Additional Information No. 10Reference: Steam Generator Management Program: PWR Primary-to-Secondary Leak Guidelines,Revision 4. EPRI, Palo Alto, CA: 2011. 1022832I, Steven M. Swilley, being duly sworn, depose and state as follows:I am the Senior Business Operations Manager at Electric Power Research Institute, Inc. whoseprincipal office is located at 1300 W WT Harris Blvd, Charlotte North Carolina ("EPRI") and I have beenspecifically delegated responsibility for the values in the above-listed Table that is sought under thisAffidavit to be withheld (the "Table"). I am authorized to apply to the U.S. Nuclear Regulatory Commission("NRC") for the withholding of the values in the Table on behalf of EPRI.EPRI requests that the values in the Table be withheld from the public on the following bases:Withholdinq Based Upon Privileged And Confidential Trade Secrets Or Commercial Or FinancialInformation:a. The values in the Table are taken from the referenced report that is owned byEPRI and constitutes commercial information which has not been placed in the public domain by EPRI.b. EPRI made a substantial economic investment to develop the values in the Tableand, by prohibiting public disclosure, EPRI derives an economic benefit in the form of fees charged for thesale of the information. The values in the Table are entitled to the protection of the United States copyrightlaws. If the values in the Table were publicly available to consultants and/or other businesses providingservices in the electric and/or nuclear power industry at no cost, these entities would be able to use thevalues in the Table for their own commercial benefit and profit and without expending the substantialeconomic resources required of EPRI to develop the values.c. EPRI made a substantial investment of both money and employee hours over anextended period of time in the development of the values in the Table. As a result of such effort and cost,both in terms of dollars spent and dedicated employee time, the values in the Table are highly valuable toEPRI.

d. A public disclosure of the values in the Table would be highly likely to causesubstantial harm to EPRI's competitive position and the ability of EPRI to sell the values in the Table bothdomestically and internationally. If a party does not purchase the referenced report from EPRI, it wouldrequire an investment of money, time and effort equivalent to that expended by EPRI for the party toduplicate the values in the Table.I have read the foregoing and the matters stated herein are true and correct to the best of my knowledge,information and belief. I make this affidavit under penalty of perjury under the laws of the United States ofAmerica and under the laws of the State of California.Executed at 1300 W WT Harris Blvd being the premises and place of business of Electric Power ResearchInstitute, Inc.Date: /Steven M. Swille'(State of North Carolina)(County of Mecklenburg)Subscribed and swom to (or affirmed) before me on this _,-day of Q.w, 20- by_____ .____ _ N414___, , proved to me on the basis of sfisfactorylevidence to be theperson(s) who appeared beforgfre.Signature f ,iA. AW -(Seal)My Commission Expires 24day of i, 20g_,V -

ENCLOSURE 3SOUTHERN CALIFORNIA EDISONRESPONSE TO REQUEST FOR ADDITIONAL INFORMATIONREGARDING RESPONSE TO CONFIRMATORY ACTION LETTERDOCKET NO. 50-361TAC NO. ME 9727Response to RAIs 10 and 17(NON-PROPRIETARY)Page 1 RAI 10Technical Specification (TS) 3.4.12.d allows 150 gallons per day primary to secondary leakage.The Return to Service Report (Enclosure 2 of Reference 1), Section 9.4.1 states, "The plantoperating procedure for responding to a reactor coolant leak has been modified to require plantOperators to commence a reactor shutdown upon a valid indication of a primary to secondarySG tube leak at a level less than allowed by the plant's TSs. This procedure change requiresearlier initiation of operator actions in response to a potential SG tube leak." Does this meanthat a reactor shutdown would be commenced upon any valid indication of primary to secondaryleakage? Provide a description of the action levels in the procedure. Discuss any additionalactions, planned or taken, such as simulator testing, operator training, and/or any evaluations toassess potential impacts of the revised procedure.RAI 17Reference 1, Section 9.4.1, page 50 -Provide the procedural action levels/statements (forS023-13-14, Reactor Coolant Leak).RESPONSEThe following discussion provides the response to RAIs 10 and 17.1. Does this mean that a reactor shutdown would be commenced upon any validindication of primary to secondary leakage?Yes, a reactor shutdown will be commenced upon a valid primary to secondary leak.2. Provide a description of the action levels in the procedure.The Abnormal Operating Instruction (AOI), "Reactor Coolant Leak" specifies actions to be takenin response to indications of a primary to secondary leak. The AOI includes standard actionsconsistent with Electric Power Research Institute (EPRI) guidelines and additional SONGSspecific administrative actions. The table below summarizes the required actions in the AOIfollowing a steam generator tube leak (SGTL). As shown on the table, the actions depend onthe leak rate, rate of change of the leak, and time and availability of radiation monitors.Page 2 Summary of AOI Steam Generator Tube Leak ActionsSGTL RATE: ACTION(S)*(1 gpm = 1440 gpd) (consistent with EPRI guidelines)Leakage is [ ] AND increasing by 1. INITIATE Attachments 1, 2 & 32. Concurrently COMMENCE shutdown to be[]perOR procedure, "Rapid Power Reduction" (RPR), Attachment forRPR at a rate of[Leakage is[ILeakage is [ ] and the rate of 1. INITIATE Attachments 1, 2 & 3change in leakage is increasing by [ 2. Concurrently COMMENCE shutdown to be in] per "Rapid Power Reduction" procedure,Attachment for RPR at a rate ofLeakage is [ ] sustained for [ 1. INITIATE Attachments 1, 2 & 3] AND increasing [ ] 2. Concurrently COMMENCE a controlled shutdown to bein[] per procedure, "Power Operations," Attachmentfor Power Descension3. Monitor [ IAny confirmed SG leakage 1. Contact Management2. INITIATE Attachments 1, 2 & 33.4. INITIATE a controlled shutdown per procedure, "PowerOperations," Attachment for Power Descension, and bein [ I* Attachments 1 and 2 are used to calculate SG tube leakage using RE-7870 and RE-7818A,respectively. Attachment 3 is used to minimize contamination during a SG tube leak.3. Discuss any additional actions, planned or taken, such as simulator testing, operatortraining, and/or any evaluations to assess potential impacts of the revised procedure.SONGS Operators have received additional classroom and simulator training to enhanceOperator response to a primary to secondary SGTL. The lessons learned from Operatorresponse to the Unit 3 SGTL, simulator tests and the new detection methods (Argon 40injection, Nitrogen 16 monitors) were incorporated into new training.To capture lessons learned, the plant operators involved in the Unit 3 SGTL onJanuary 31, 2012 were interviewed to identify strengths and improvement areas. Theenhancements identified by this process were incorporated into AOIs, "Reactor Coolant Leak"and "Rapid Power Reduction."Page 3 The training department Licensed Operator Requalification group performed classroom trainingsessions with licensed operators on the use of methods and techniques for detection of leaksusing Argon 40 injection and Nitrogen 16 monitors, calculation of low level tube leak events, andoperation at reduced power. In the classroom, AOIs "Reactor Coolant Leak" and "Rapid PowerReduction" were covered along with Operations Standard Manuals which were revised tocapture new steam generator tube leak practices.Simulator scenarios were conducted using the revised AOls, "Reactor Coolant Leak" and "RapidPower Reduction," which included the following:" SGTL of 50 gpd in Mode 4 at normal operating pressure (NOP)* Steam Generator Tube Rupture (SGTR) of 300 gpm in Mode 3 at NOP and normal.operating temperature (NOT)* SGTR of 12 gpm in Mode 2 at NOP/NOT" SGTR of 355 gpm in Mode 1, 69% powerTraining based on the Unit 3 SGTL event and plant upgrades was completed and isdocumented in the Nuclear Training Division Crew Performance Monitoring System.An additional SGTL Simulator session for Licensed Operator Continuing Training will becompleted prior to restart of Unit 2. This training session will include a small SGTL and use theAOI which specifies shutting down upon any confirmed SGTL. Additional Just-In-Timeclassroom training for operators will be completed prior to plant startup.Page 4