ML13085A039

San Onofre, Unit 2, 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 J Southern California Edison Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
TAC ME9727
Download: ML13085A039 (58)

Text

{{#Wiki_filter:J SOUTHERN CALIFORNIAEDISONAn EDISON INTERNATIONAL CompanyProprietary InformationWithhold from Public DisclosureRichard 1. St. OngeDirector, Nuclear Regulatory Affairs andEmergency PlanningMarch 22, 201310 CFR 50.4U.S. Nuclear Regulatory CommissionATTN: Document Control DeskWashington, DC 20555-0001Subject:References:Docket No. 50-361Response 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 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 Degradation2. 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), datedMarch 18, 2013, Second Request for Additional Information RegardingResponse to Confirmatory Action Letter, San Onofre Nuclear GeneratingStation, 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 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.By letter dated March 18, 2013 (Reference 3), the NRC issued Requests for AdditionalInformation (RAIs) regarding the CAL response. Enclosure 2 of this letter provides theresponse to RAIs 46 -49, 51, and 52.Proprietary InformationWithhold from Public DisclosureDecontrolled Upon Removal of Enclosure 2P.O. Box 128San Clemente, CA 92672 Proprietary InformationWithhold from Public DisclosureDocument Control Desk-2-March 22, 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 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 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 tcl: (412) 374-4643Direct fax: (724) 720-0754e-mail: greshaja@westinghouse.comProj letter: CONO- 13-22CAW-13-3657March 15, 2013APPLICATION FOR WITHHOLDING PROPRIETARYINFORMATION FROM PUBLIC DISCLOSURESubject: LTR-SGDA-13-28 P-Attachment, "San Onofre Nuclear Generating Station Unit 2 MHIReplacement Steam Generator Response to RAI 46" (Proprietary)The proprietary information for which withholding is being requested in the above-referenced report isfurther 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 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-I 3-3657 and should be addressed to James A. Gresham,Manager, Regulatory Compliance, Westinghouse Electric Company, Suite 428, 1000 WestinghouseDrive, Cranberry Township, Pennsylvania 16066.Very truly yours,Gresham, ManagerRegulatory ComplianceEnclosures CAW-13-3657AFFIDAVITCOMMONWEALTH 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 15"h day of March 2013Notary Public tCOMMONWEALTH OF PENNSYLVANIANotarial SealAnne M. Stegman, Notary PublicUnity Twp., Westmoreland CountyMy Commission Expires Aug. 7, 2016ME'BER. PENNSYLVANIA ASSOCIATION OF NOTARIES 2CAW- 13-3657(1) 1 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) I 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) 1 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-13-3657Westinghouse'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-13-3657(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-SGDA-13-28 P-Attachment, "San Onofre NuclearGenerating Station Unit 2 MHI Replacement Steam Generator Response to RAI 46,"dated March 14, 2013, for submittal to the Commission, being transmitted by SouthernCalifornia Edison Letter and Application for Withholding Proprietary Information fromPublic Disclosure, to the Document Control Desk. The proprietary information assubmitted by Westinghouse is that associated with the calculation of fluidelasticexcitation of steam generator tubes and may be used only for that purpose. 5CAW-13-3657This information is part of that which will enable Westinghouse to:(a) Respond to a Nuclear Regulatory Commission (NRC) Request for AdditionalInformation regarding the justification for selection of the threshold value of thefluidelastic instability constant, and to provide an explanation why it is aconservative selection considering the thermal hydraulic conditions and size ofthe 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 thepurpose of evaluating the impact of fluidelastic excitation on steam generatortube integrity.(b) Westinghouse can sell support and defense of the thermal hydraulic analysis ofsecondary side flow field in the steam generator shell.(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 information and licensing defense services for commercialpower reactors without commensurate expenses. Also, public disclosure of theinformation would enable others to use the information to meet NRC requirements forlicensing documentation without purchasing the right to use the information.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. 6 CAW-13-3657In 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. _)WestinghouseWestinghouse Electric CompanyNuclear Services1000 Westinghouse DriveCranberry Township, Pennsylvania 16066USAU.S. Nuclear Regulatory CommissionDocument Control Desk11555 Rockville PikeRockville, MD 20852Direct tel:. (412) 374-4643Direct fax: (724) 720-0754e-mail: greshaja@westinghouse.comProj letter: CONO-13-22CAW-13-3658March 15, 20 13APPLICATION FOR WITHHOLDING PROPRIETARYINFORMATION- FROM PUBLIC DISCLOSURESubject: LTR-SGDA-13-26 P-Attachment, "San Onofre Generating Station Unit 2 MHI ReplacementSteam Generator Response to RAI 47" (Proprietary)The proprietary information for which withholding is being requested in the above-referenced report isfurther 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 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-13-3658 and should be addressed to James A. Gresham,Manager, Regulatory Compliance, Westinghouse Electric Company, Suite 428, 1000 WestinghouseDrive, Cranberry Township, Pennsylvania 16066.Very truly yours,J .Gresham, ManagerRegulatory ComplianceEnclosures CAW-13-3658AFFIDAVITCOMMONWEALTH 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 Compliance,Sworn to and subscribed before methis 15th day of March 2013Notary PublicCOMMONWEALTH OF PENNSYLVANIAi Notaral SealAnne M. Stegman, Notary PublicUnity Twp., Westmoreland CountyMy Commission Expires Aug. 7, 2016MEMSER. PENNSYLVANIA ASSOCIATION OF NOTARIES 2CAW-13-3658(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) I 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-13-3658Westinghouse'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-13-3658(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-SGDA-13-26 P-Attachment, "San Onofre GeneratingStation Unit 2 MHI Replacement Steam Generator Response to RAI 47" dated March 14,2013, for submittal to the Commission, being transmitted by Southern California EdisonLetter and Application for Withholding Proprietary Information from Public Disclosure,to the Document Control Desk. The proprietary information as submitted byWestinghouse is that associated with the calculation of fluidelastic excitation of steamgenerator tubes and may be used only for that purpose. 5CAW-13-3658This information is part of that which will enable Westinghouse to:(a) Respond to a Nuclear Regulatory Commission (NRC) Request for AdditionalInformation regarding the development of damping used in the straight leg of thesteam 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 thepurpose of evaluating the impact of fluidelastic excitation on steam generatortube integrity.(b) Westinghouse can sell support and defense of the thermal hydraulic analysis ofsecondary side flow field in the steam generator shell.(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 information and licensing defense services for commercialpower reactors without commensurate expenses. Also, public disclosure of theinformation would enable others to use the information to meet NRC requirements forlicensing documentation without purchasing the right to use the information.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. 6 CAW-13-3658In 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. 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@westinghousecomProj letter: CONO-13-22CAW-13-3659March 15, 2013APPLICATION FOR WITHHOLDING PROPRIETARYINFORMATION FROM PUBLIC DISCLOSURESubject: LTR-SGDA-13-27 P-Attachment, "San Onofre Nuclear Generating Unit 2 MHI ReplacementSteam Generator Reponses to RAIs 48 and 49" (Proprietary)The proprietary information for which withholding is being requested in the above-referenced report isfurther 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 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-13-3659 and should be addressed to James A. Gresham,Manager, Regulatory Compliance, Westinghouse Electric Company, Suite 428, 1000 WestinghouseDrive, Cranberry Township, Pennsylvania 16066.Very truly yours,James A. Gresham, ManagerRegulatory ComplianceEnclosures CAW-13-3659AFFIDAVITCOMMONWEALTH OF PENNSYLVANIA:ssCOUNTY OF BUTLER:Before me, the undersigned authority, personally appeared James A. Gresharn, 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 15'h day of March 2013Notary PublicCOMMONWEALTH OF PENNSYLVANIANotarial seall Anne M. Stegman, Notary PublicUnity TWp., Westmoreland CountyMy Commission Expires Aug. 7, 2016MEMBER. PENNSYLVANIA ASSOCIATION OF NOTARIES 2CAW-13-3659(1) 1 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-13-3659Westinghouse'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-13-3659(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-SGDA- 13-27 P-Attachment, "San Onofre NuclearGenerating Unit 2 MHI Replacement Steam Generator Reponses to RAIs 48 and 49,"dated March 14, 2013, for submittal to the Commission, being transmitted by SouthernCalifornia Edison Letter and Application for Withholding Proprietary Information fromPublic Disclosure, to the Document Control Desk. The proprietary information assubmitted by Westinghouse is that associated with the calculation of fluidelasticexcitation of steam generator tubes and may be used only for that purpose. 55 CAW-13-3659This information is part of that which will enable Westinghouse to:(a) Respond to a Nuclear Regulatory Commission (NRC) Request for AdditionalInformation regarding the Westinghouse damping correlation and specificallyhow 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 thepurpose of evaluating the impact of fluidelastic excitation on steam generatortube integrity.(b) Westinghouse can sell support and defense of the thermal hydraulic analysis ofsecondary side flow field in the steam generator shell.(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 information and licensing defense services for commercialpower reactors without commensurate expenses. Also, public disclosure of theinformation would enable others to use the information to meet NRC requirements forlicensing documentation without purchasing the right to use the information.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. 6 CAW-13-3659In 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. S WestinghouseU.S. Nuclear Regulatory CommissionDocument Control Desk11555 Rockville PikeRockville, MD 20852Westinghouse Electric CompanyNuclear Services1000 Westinghouse DriveCranberry Township, Pennsylvania 16066USADirect tel:Direct fax:e-mail:Proj letter:(412) 374-4643(724) 720-0754greshaj a@westinghouse.comCONO-13-22CAW-13-3660March 15, 2013APPLICATION FOR WITHHOLDING PROPRIETARYINFORMATION FROM PUBLIC DISCLOSURESubject: LTR-SGDA-13-23 P-Attachment, "San Onofre Nuclear Generating Station Unit 2 MHIReplacement Steam Generator Response to RAI 51" (Proprietary)The proprietary information for which withholding is being requested in the above-referenced report isfurther 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 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-13-3660 and should be addressed to James A. Gresham,Manager, Regulatory Compliance, Westinghouse Electric Company, Suite 428, 1000 WestinghouseDrive, Cranberry Township, Pennsylvania 16066.Very truly yours,Jmes A. Gresham, ManagerRegulatory ComplianceEnclosures CAW-13-3660AFFIDAVITCOMMONWEALTH 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:j/ames &A.Gresham, ManagerRegulatory ComplianceSworn to and subscribed before methis 15"h day of March 2013Notary PublicCOMMONWEALTH OF PENNSYLVANLAINotariai SealAnne M. Stegman, Notary Publicunity TWp., Westmoretand County4ESC'ommwsson Expires Aug. 7, 201/61"EtPee KINNLVANtA ASSOaA-nON OF NOTARIES 2CAW- 13-3660(1) 1 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) 1 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-13-3660Westinghouse'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-13-3660(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-SGDA-1 3-23 P-Attachment, "San Onofre NuclearGenerating Unit 2 MHI Replacement Steam Generator Response to RAI 51," datedMarch 14, 2013, for submittal to the Commission, being transmitted by SouthernCalifornia Edison Letter and Application for Withholding Proprietary Information fromPublic Disclosure, to the Document Control Desk. The proprietary information assubmitted by Westinghouse is that associated with the calculation of fluidelasticexcitation of steam generator tubes and may be used only for that purpose. 5CAW- 13-3660This information is part of that which will enable Westinghouse to:(a) Respond to Nuclear Regulatory Commission (NRC) Request for AdditionalInformation on intermediate details of the Westinghouse flow induced vibration(FIV) calculations for several limiting tubes. The information provided willenable the NRC to perform a comparison between Westinghouse and MitsubishiHeavy 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 thepurpose of evaluating the impact of fluidelastic excitation on steam generatortube integrity.(b) Westinghouse can sell support and defense of the thermal hydraulic analysis ofsecondary side flow field in the steam generator shell.(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 information and licensing defense services for commercialpower reactors without commensurate expenses. Also, public disclosure of theinformation would enable others to use the information to meet NRC requirements forlicensing documentation without purchasing the right to use the information.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. 6 CAW- 13-3660In 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.

• Westinghouse Westinghouse Electric CompanyNuclear ServicesWestin house1000 Westinghouse DriveCranberry Township, Pennsylvania 16066USAU.S. Nuclear Regulatory Commission Direct tel: (412) 374-4643Document Control Desk Direct fax: (724) 720-0754.11555 Rockville Pike e-mail: greshaja@westinghouse.comRockville, MD 20852 Proj letter: CONO-13-22CAW-13-3661March 15, 2013APPLICATION FOR WITHHOLDING PROPRIETARYINFORMATION FROM PUBLIC DISCLOSURESubject: LTR-SGDA-I 3-29 P-Attachment, "San Onofre Nuclear Generating Station Unit 2 MHIReplacement Steam Generator Response to RAI 52" (Proprietary)The proprietary information for which withholding is being requested in the above-referenced report isfurther 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 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-]13-3661 and should be addressed to James A. Gresham,Manager, Regulatory Compliance, Westinghouse Electric Company, Suite 428, 1000 WestinghouseDrive, Cranberry Township, Pennsylvania 16066.Very truly yours,James A. Gresham, ManagerRegulatory ComplianceEnclosures CAW-13-3661AFFIDAVITCOMMONWEALTH 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:l mes A. Gresham, ManagerRegulatory ComplianceSworn to and subscribed before methis 15Ih day of March 2013Notary PublicCOMMONWEALTH OF PENNSYLVANIAI Notarial SealAnne M. Stegman, Notary Public IUnity Twp., Westmoreland countyMy Commisson EpiVres Au.- O, 2016 lMEBE, ENSLVANIA ASSOCMTON OF NOTARIES 2CAW-13-3661(1) 1 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) I am making this Affidavit in conformance with the provisions of 10 CFR Section 2.3 90 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 friom 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-13-3661Westinghouse'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-13-3661(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-SGDA-13-29 P-Attachment, "San Onofre NuclearGenerating Station Unit 2 MHI Replacement Steam Generator Response to RAI 52,"dated March 14, 2013, for submittal to the Commission, being transmitted by SouthernCalifornia Edison Letter and Application for Withholding Proprietary Information fromPublic Disclosure, to the Document Control Desk. The proprietary information assubmitted by Westinghouse is that associated with the calculation of fluidelasticexcitation of steam generator tubes and may be used only for that purpose. 5CAW-13-3661This information is part of that which will enable Westinghouse to:(a) Respond to a Nuclear Regulatory Commission (NRC) Request for AdditionalInformation regarding the design basis and methodology that was used byWestinghouse to evaluate the tube/anti-vibration bar (AVB) wear potential forsteam generators in another plant that are most comparable to the replacementsteam 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 thepurpose of evaluating the impact of fluidelastic excitation on steam generatortube integrity.(b) Westinghouse can sell support and defense of the thermal hydraulic analysis ofsecondary side flow field in the steam generator shell.(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 information and licensing defense services for commercialpower reactors without commensurate expenses. Also, public disclosure of theinformation would enable others to use the information to meet NRC requirements forlicensing documentation without purchasing the right to use the information.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. 6 CAW-13-3661In 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 for additional information regarding stability ratios calculated for certain anti-vibration bar (AVB) support conditions for the San Onofre Nuclear Generating Station Unit 2 steamgenerators.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 RAIs 46-49, 51 and 52(NON-PROPRIETARY)SUBJECT PAGERA146 2RA147 6RAI 48 and 49 7RA151 15RAI 52 19 RAI 46:In Reference 7, p. 15 of 131, please provide justification for selection of 13=5.0 for the thresholdvalue of the fluid elastic instability constant, and explain why it is a conservative selection forthis 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 ofWear 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 forSONGS:Figure 1 shows the final results from WEC Reference 3.1SONGS steam generators have a smaller p/d ratio than the reference tests, so a scale factorbased on available open literature and WEC proprietary tests was developed as shown onFigure 2.In summary, the value of P3 selected for use in the analysis is a lower bound value that envelopsresponses at frequencies both lower and higher than the minimum value at about [ ] asshown on Figure 1. Since the SONGS steam generators have relatively large regions with veryhigh void fractions, the U-bend tests conducted in air are applicable to the thermal-hydraulicconditions present in the SONGS steam generators.Enclosure 3Page 2 of 19 WEC References for RAI 46:1.) SG-SGMP-1 2-10, Revision 3, "Operational Assessment of Wear Indications in the U-bendRegion of San Onofre Nuclear Generating Station Unit 2 Replacement SteamGenerators," October 2012.2.) Westinghouse Letter LTR-SGDA-12-36, Revision 3, "Flow-Induced Vibration and TubeWear Analysis of the San Onofre Nuclear Generating Station Unit 2 Replacement SteamGenerators Supporting Restart," February 20133.) Westinghouse Document, 98-7TK0-TRIWK-R1, "Investigation of the Fluidelastic Vibrationof U-Bend Tubes in a Triangular Pattern," September 1998, (originally provided viaPreliminary Report 91-7TL3-TRIWK-R1, January 1991, for inclusion as Appendix B1 inReference 4). [Proprietary]Note that RAI Reference 7 and WEC Reference 1 are the same document.Enclosure 3Page 3 of 19 Figure 1 Threshold Instability Constants Obtained from WEC Wind Tunnel Testsfor 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)Enclosure 3Page 4 of 19 rFigure 2 Effect of Pitch-to-Diameter Ratio on Fluidelastic Instability Threshold Constantin Triangular Array Pattern Steam GeneratorsEnclosure 3Page 5 of 19 RAI 47In 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 OnofreNuclear Generating Station Unit 2 Replacement Steam Generators Supporting Restart," WEC,Report No. SG-SGDA-12-36, Revision 3, February 2013.[IThe 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 applicableto 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 toactive modes in the U-bend and upper portion of the straight leg and as can be seen below is afunction of both frequency and void fraction:The straight leg damping correlation was not used in the calculation of the FIV response ofU-bend modes. The U-bend damping correlation that was used is a function of both frequencyand void fraction, not just frequency. The effects of low damping due to high void fraction in thetop portion of the straight leg is accounted for through calculation of the full tube modal effectivevoid fraction including both the U-bend and straight leg portions of the tube.Enclosure 3Page 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 OnofreNuclear 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-VoidConditions:WEC Reference 1 provides an open literature overview of steam-water tests conducted by MHIat temperatures up to 5220F and pressures up to 840 psi. WEC Reference 2 describesadditional steam-water tests conducted by MHI for conditions up to 540°F and 1015 psi. WECReferences 3 and 4 explain how damping data from those tests were evaluated, along withearlier data from a larger bundle, as a function of slip void fraction and frequency to obtaindesign correlations for damping in the U-bend region of steam generators. The resultingcorrelations that were cited in RAI Reference 8 have been successfully used in WEC designedsteam generators since the correlations were developed. They were derived using data thatcovered the [ ] range in slip void fraction from test programs as described in WECReference 4.The raw data used in the WEC Reference 3 and Reference 4 analyses for pinned supports weredocumented in proprietary technical exchange meetings between WEC and MHI in September1986 and November 1987.The lower limit of damping recommended in WEC Reference 4 was a mathematicalconvenience that did not affect prior applications. [] An additional study documented in WECEnclosure 3Page 7 of 19

Reference

5 used all the mechanical damping tests results from Section 8.0 of WECReference 4 to derive physically meaningful lower bounds. [] Figure 2 taken from WEC Reference 5 illustrates the results of the final correlations forvarious pinned support conditions considered applicable in a pure steam environment with slipvoid 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 voidfractions between [ ] This plot represents results of the RAI Reference 8 WECcorrelation for damping with pinned supports consistent with the two-phase steam environmentof SONGS replacement steam generators (RSGs).] RAI Reference 8analyses consistently used this option as most representative of current conditions in the steamgenerators 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 thetube is moving and how much it is moving in the flow.]1This 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 SONGSsteam generators. It is important to note that at 70% power, very high-void conditions wheretwo-phase damping would be expected to approach nil do not exist in the SONGS steamgenerators.Note: [Enclosure 3Page 8 of 19 WEC References for RAIs 48 and 491.) T. Nakamura, K. Fujita, K. Kawanishi, N. Yamaguchi, and A. Tsuge, "Study on theVibrational Characteristics of a Tube Array Caused by Two-Phase Flow, Part 1, RandomVibration," 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 theVibrational 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 forTsuruga U-Bend Evaluations," March 20, 1992. [Proprietary]4.) Westinghouse Document, WCAP-1 3264, "Steam Generator Tube Integrity Study for theJapan Atomic Power Company Summary Report," "Section 7.1 Development of Dampingfor 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 ofU-bend Tubing with Pinned Intersections," March 2000. [Proprietary]Enclosure 3Page 9 of 19 Figure 1 U-bend Damping for Pinned Intersections for High Void Fraction Datafrom WEC References 1, and 2 for Frequencies Near 30 Hz Together with Correlation TrendEnclosure 3Page 10 of 19 rFigure 2 U-bend Damping for Pinned Intersections as a Function of Frequencyfor Upper Limit Slip Void Fraction Value of 1.0 for Various Pinned Support Conditionsthat Correspond to the Various Values for Parameter A in the Inset Correlation(Figure 7 from WEC Reference 5)Enclosure 3Page 11 of 19 rFigure 3 U-bend Damping for Pinned Intersections as a Function of Frequencyfor Lower Limit Slip Void Fraction Value of 0.80 for Various Pinned Support Conditionsthat Correspond to the Various Values for Parameter A in the Inset Correlation(Figure 8 from WEC Reference 5)Enclosure 3Page 12 of 19 Figure 4 U-bend Damping for Pinned Intersections as a Function of Frequencyfor 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)Enclosure 3Page 13 of 19 rFigure 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 ImplicationsEnclosure 3Page 14 of 19 RAI 51In Reference 8, p. 101, in order for NRC staff to better understand the Westinghousemethodology and overall results, please provide a summary of analytic results that includes abreakdown of][Proprietary]RESPONSE:Note: RAI Reference 8 is "Flow-Induced Vibration and Tube Wear Analysis of the San OnofreNuclear 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 byMHI. However, some of the inputs and outputs used by the WEC method differ from the MHImethod and therefore the tables providing the details of the stability ratio calculation differ. Asummary 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 aresponse 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 Connorscoefficient.Details of the derivation of the Connors coefficient are described in Section 4.2.5.2 of RAIReference 8. Additional information on the WEC derivation of the Connors coefficient iscontained 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 secondaryreference density Po. This term appears in both the critical velocity and effective velocitycalculation. In the final stability ratio calculation, the secondary reference density is divided outEnclosure 3Page 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 theresults when comparing the MHI calculated critical velocity or effective velocity to the WECcounterpart. It should be noted that the actual density of the tube and surrounding fluid isincluded in the integration of the effective velocity as it changes around the tube and thesecondary reference density only applies to the constant density term in the critical and effectivevelocity 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-planedirection in Table 1 and the in-plane direction in Table 2. Five of the tubes were chosen to bethe limiting active tubes and the other five were chosen to be tubes plugged with a split cablestabilizer. The tubes provided in Table 1 and Table 2 were chosen from the subset of limitingtubes to provide a range of tube rows and support cases. The results for the tubes that containa stabilizer include the added mass and additional damping provided by the split cablestabilizers. Details of the methodology used to model the split cable stabilizers are documentedin Appendix C of RAI Reference 8. The detailed results in Table 1 and Table 2 were providedfor the 70% power level.Enclosure 3Page 16 of 19 Table 1 -Out-of-Plane Excitation Ratio Calculation DetailsTubeTube ConnorsReference Maximum Critical Effective ExcitationTu bese Tube Mode coefficient Void Velocity Velocity RatioRow Cae Status Frequency Ratio (Beta) i Fraction (f/s) (ft/s)(Hz) QIb/ft3)Enclosure 3Page 17 of 19 Table 2 -In-Plane Stability Ratio Calculation DetailsTueTube ReferenceTube Connors fluid Maximum Critical EffectiveRowCobSeCseMode Stabilityig FuiTube Natural Damping coefficient Denit Void Velocity Velocity StabilityRow Col Status Frequency Ratio (Beta) Density Fraction (fts) (fts) Ratio(Hz) (Ib/ft3)JNI7_ ___Enclosure 3Page 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 OnofreNuclear 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 wereadjusted as necessary to obtain the observed depths and distributions found by eddy currenttesting (ECT) (bobbin) examinations.Plant B wear coefficients are not directly comparable to SONGS wear coefficients. The wearcoefficients used in the Plant B calculations were used to project for a typical design calculationand were not used to match observed wear depth. The objectives of the SONGS wearcalculations were to match the known wear depths and then project future wear.Enclosure 3Page 19 of 19 }}