ML092600514

Root Cause Evaluation for Divider Plate Weld Joint Separation in the Replacement Steam Generators

ML092600514
Person / Time
Site:	San Onofre
Issue date:	09/11/2009
From:	Scherer A Southern California Edison Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
Download: ML092600514 (8)

Text

~II EDISON rD"fSO"N~

A. Edward Scherer A. Edward V SOUTHERN CALIFORNIA Director Director Scherer Nuclear Regulatory Affairs Nuclear Regulatory Affairs An INTERNATIONAL@ Company An EDISON INTERNATIONAL' Company Withhold from Withhold from Public Public Disclosure Disclosure Under Under 1010 CFR CFR 2.390 2.390 When Separated from the Proprietary When Separated Proprietary Enclosure Enclosure (Enc!osure document is Decontrolled (Enclosure 2), this document Decontrolled September 11, 2009 September 11, U.

U. S. Nuclear Nuclear Regulatory Commission Commission Document Control Desk ATTN: Document Washington, D.C. 20555

Subject:

Docket No. 50-362 50-362 Evaluation Root Cause Evaluation Joint Separation Divider Plate Weld Joint Separation in thethe Replacement Steam Replacement Generators Steam Generators San Onofre Nuclear San Onofre Generating Station, Unit 3 Nuclear Generating

Dear Sir or Madam:

Madam:

This letter provides the Root Cause Evaluation generator Evaluation for the replacement steam generator divider plate weld joint separation for San Onofre divider Onofre Nuclear Generating Station, Unit 3.

Nuclear Generating The Root Cause Evaluation was prepared by Mitsubishi Mitsubishi Heavy (MHI),

Heavy Industries, Ltd (MHI),

MHI. Southern information that is proprietary to MHI.

and the report contains information Southern California California Edison (SCE) Evaluation, (SCE) requests that the proprietary version of the Root Cause Evaluation, provided as Enclosure 2 to this letter, be withheld from public disclosure in accordance accordance with 10 CFR 2.390(a)(4).

Enclosure 1 of this letter provides an MHI affidavit, which sets forth the basis on which Enclosure information in Enclosure 2 may be withheld from public disclosure by the the information the paragraph (b)(4) considerations listed by paragraph Commission and addresses with specificity the considerations of 10 CFR 2.390.

Enclosure 2 provides the proprietary Enclosure proprietary version of the Root Cause Evaluation.

Enclosure 3 provides a non-proprietary version of the Root Cause Evaluation.

Enclosure commitments or required actions resulting from this letter.

There are no new commitments P.O. Box P.O. 128 Box 128 San San Clemente, Clemente, CA 92674 92674

Document Control Desk September 11, September 11, 2009 IfIf you have have any questions questions regarding regarding this information, please please feel free to contact contact Ms.

Linda T. Conklin at (949) 368-9443.

Sincerely, Enclosures Enclosures cc: E. E. Collins, Regional Administrator, NRC Region IV IV R. Hall, NRC Project Manager, San Onofre Units 2 and 3 No Enclosures Enclosures G. G.

G. Warnick, NRC Senior Resident Inspector, San Onofre Senior Resident Onofre Units 2 and 3

Enclosure 1 Enclosure Affidavit Affidavit For F or Withholding from Public Disclosure (5 pages)

MITSUBISHI INDUSTRIES, LTD MITSUBISHI HEAVY INDUSTRIES, LTD...

AFFIDAVIT AFFIDAVIT I,I, Hitoshi Kaguchi, Kaguchi, state as follows:

1. II am Manager, Nuclear

1. Nuclear Plant Component Component Designing Department, of Mitsubishi Heavy Industries, Ltd. ("MHI"),

("MHI"), and have been been delegated delegated the function of reviewing the the

• referenced MHI referenced MHI technical technical documentation documentation to to determine determine whether itit contains information information' that should be withheld from public public disclosure disclosure pursuant to 10 C.F.R.C.F.R.' § 2.390 (a)(4) as as commercial or financial, trade secrets and commercial financial information information that is privileged privileged or confidential. II am authorized authorized to apply for the withholding withholding of such information from public disclosure.

2. In In accordance accordance with my responsibilities, responsibilities, I have reviewed reviewed the enclosed document entitled entitled*

"San Onofre Onofre Nuclear Generating Station, Units 2 &

Nuclear Generating & 3 Replacement Replacement Steam Generators, Divider Plate Weld Joint Separation Root Cause Evaluation Evaluation Report",

Report", and have determined determined that portions of the document contain proprietary proprietary information information that should be be withheld from public disclosure. Those pages containing proprietary proprietary information are identified with the label "Proprietary" on the top of the page, and the proprietary information has been bracketed bracketed with an open and closed bracket bracket as shown here"[ here "[ ]"

]"

and marked with the basis for withholding (a and/or b, as described in paragraph paragraph 7 below). The first page document indicates that all information page of the document information identified as as "Proprietary" should be withheld withheld from public public disclosure pursuant pursuant to 10 10 C.F.R. § 2.390 (a)(4).

3. The information identified as proprietary proprietary in'the in the enclosed enclosed document document has in the past been, and will will' continue to be, held in in confidence confidence by MHI and its disclosuredisclosure outside the the company is limited to regulatory regulatory bodies, customers customers and potential customers, and their their agents, suppliers, and licensees, and others with a legitimate legitimate need for the information, always subject to suitable and is always* measures to protect it suitable measures it from unauthorized unauthorized use or or disclosure.

4. The basis for holding the referenced referenced information confidential confidential is that it it describes unique describes unique manufacturing, experimental design, manufacturing, experimental and investigative investigative information developed developed by MHI and not used used in the exact any of MHl's exact form by any' MHI's competitors. This information information was was developed at significant developed significant cost to MHI, since itit is the result of an intensive intensive MHI effort.

5. The

5. The referenced referenced information information isis being being furnished furnished toto the the Nuclear Nuclear, Regulatory Regulatory Commission Commission

("NRC") confidence and

("NRC") in confidence and solely for the the purpose information to the purpose of information the NRC staff.

6. The referenced available in public sources information is not available referenced information and could not be gathered sources and gathered readily other publicly readily from other available information.

publicly available information. Other thr~ugh the provisions Other than through provisions in paragraph paragraph 3 above, MHI knows of no MHI knows no way the information could be the information be lawfully acquired by lawfully acquired by organizations individuals outside of MHI.

organizations or individuals MHI.

7. Public disclosure disclosure of the referenced information would assist competitors referenced informa'tion competitors of MHI in their their design and manufacture of nuclear and manufacture nuclear plant components incurring the costs or risks components without incurring risks associated with the design associated with manufacture of the subject component. Therefore, design and the rnanufacture Therefore, disclosure information contained disclosure of the information document would have referenced document contained in the referenced ha~e the the negative impacts on the competitive following negative position of MHI in the U.S.

competitive position U.S. and world nuclear nuclear markets:

A. Loss of competitive advantage associated with development advantage due to the costs associated development of of welding technology, special examination processes,, and experimental examination processes, programs experimental programs relating to the component design and manufacture. Providing public access to competitors to duplicate or mimic permits competitors information permits such information mimic the methodology methodology without incurring associated costs.

incurring the associated B. Loss of competitive competitive advantage MHI's ability to supply replacement advantage of MHI's replacement or new heavy components such as steam generators.

II declare declare under penalty of perjury that the foregoing affidavit and the matters stated therein therein are true and correct to the best of my ,knowledge, . '

information and belief.

Executed Executed on this /0 day of

/9 >erie~v', 2009. 2009.'

Hitoshi Kaguchi, General Manager- Nuclear Plant Component Designing Department Mitsubishi Heavy Industries, LTD Sworn Sworn to and subscribed subscribed Before Before me this ./I' Q(7 day SEP. 10.2009 SEPt 0,2009 of Comsso xi2009 471~

.' TERUYUKI OODE Kobe Qistrict Legal Affairs Bureau Nc ry Public NOTARY 95 Edomachi 9 Ohuo-ku, Kobe. Japan

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NOTARIAL CERTIFICATE NOTARIAL CERTIFICATE This is is to certify certify that HITOSHI HITOSHI KAGUCHI KAGUCHI ,, General General Manager Manager -

Nuclear Plant Component Designing Nuclear Designing Department of MITSUBISHI MITSUBISHI HEAVY INDUSTRIES,LTD.

INDUSTRIES, LTD. has affixed affixed his signature in in my very very presence to presence to the attached document.

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TERUYUKI OODE

<TERUYUK100ODE Kobe District Legal Kobe 7District Legal Affa~irs Affairs Bureau Bureau NOTARY 95 Edomaohi, Edomachi, Chuo-ku, Chuo-ku, Kobe, Japan d/ll' Notary Notary 95 Edomachi,Chuo-Ku, Edomachi, Chuo-Ku, Kobe,Japan Kobe, Japan Kobe District Legal Affairs Bureau (fi 11- &2)