ML13014A251

San Onofre, Unit 2, Response to Request for Additional Information (RAI 30) Regarding Confirmatory Action Letter Response

ML13014A251
Person / Time
Site:	San Onofre
Issue date:	01/09/2013
From:	St.Onge R J Southern California Edison Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
TAC ME9727, CAL 4-12-001
Download: ML13014A251 (10)

Text

., SOUTHERN CALIFORNIAJ EDISON°An EDISON INTERNATIONAL CompanyProprietary InformationWithhold from Public DisclosureRichard J. St. OngeDirector, Nuclear Regulatory Affairs andEmergency PlanningJanuary 9, 201310 CFR 50.4U.S. Nuclear Regulatory CommissionATTN: Document Control DeskWashington, DC 20555-0001Subject:Docket No. 50-361Response to Request for Additional Information (RAI 30)Regarding Confirmatory Action Letter Response(TAC No. ME 9727)San Onofre Nuclear Generating Station, Unit 2References:1. 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), 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 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 December 26, 2012 (Reference 3), the NRC issued Requests for AdditionalInformation (RAIs) regarding the CAL response. Enclosure 2 of this letter provides theresponse to RAI 30.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 Mitsubishi Heavy Industries (MHI), which setsProprietary InformationWithhold from Public DisclosureDecontrolled Upon Removal From Enclosure 2P.O. Box 128San Clemente, CA 92672~E7~ 4, Proprietary InformationWithhold from Public DisclosureDocument Control Desk-2-January 9, 2013forth the basis on which the information in Enclosure 2 may be withheld from public disclosureby the NRC and addresses with specificity the considerations listed by paragraph (b)(4) of10 CFR 2.390. Enclosure 3 provides the non-proprietary version of Enclosure 2.There are no new regulatory commitments contained in this letter. If you have any questions orrequire additional information, please call me at (949) 368-6240.Sincerely,Enclosures:1. Notarized Affidavits2. Response to RAI 30 (Proprietary)3. Response to RAI 30 (Non-proprietary)cc: E. E. Collins, Regional Administrator, NRC Region IVR. Hall, NRC Project Manager, San Onofre Units 2 and 3G. G. Warnick, NRC Senior Resident Inspector, San Onofre Units 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 MITSUBISHI HEAVY INDUSTRIES, LTD.AFFIDAVITI, Jinichi Miyaguchi, state as follows:1. I am Director, Nuclear Plant Component Designing Department, of Mitsubishi HeavyIndustries, Ltd. ("MHI"), and have been delegated the function of reviewing thereferenced AREVA's technical documentations to determine whether they contain MHI'sinformation that should be withheld from public disclosure pursuant to 10 C.F.R. § 2.390(a)(4) as trade secrets and commercial or financial information that is privileged orconfidential.2. In accordance with my responsibilities, I have reviewed MHI's letter "MHI/SCE-1 2-0161:Figure of Percentage of Tube Wear vs. Maximum Interstitial Velocity (Reply to RAI #30)"and have determined that it contains MHI proprietary information that should be withheldfrom public disclosure. Those pages containing proprietary information have beenbracketed with an open and closed bracket as shown here "[ I" / and should bewithheld from public disclosure pursuant to 10 C.F.R. § 2.390 (a)(4).3. The information identified as proprietary in the documents has in the past been, and willcontinue to be, held in confidence by MHI and its disclosure outside the company islimited to regulatory bodies, customers and potential customers, and their agents,suppliers, and licensees, and others with a legitimate need for the information, and isalways subject to suitable measures to protect it from unauthorized use or disclosure.4. The basis for holding the referenced information confidential is that it describes uniquedesign, manufacturing, experimental and investigative information developed by MHIand not used in the exact form by any of MHI's competitors. This information wasdeveloped at significant cost to MHI, since it is the result of an intensive MHI effort.5. The referenced information was furnished to the Nuclear Regulatory Commission("NRC") in confidence and solely for the purpose of information to the NRC staff.6. The referenced information is not available in public sources and could not be gatheredreadily from other publicly available information. Other than through the provisions inparagraph 3 above, MHI knows of no way the information could be lawfully acquired byorganizations or individuals outside of MHI.

7. Public disclosure of the referenced information would assist competitors of MHI in theirdesign and manufacture of nuclear plant components without incurring the costs or risksassociated with the design and the manufacture of the subject component. Therefore,disclosure of the information contained in the referenced document would have thefollowing negative impacts on the competitive position of MHI in the U.S. and worldnuclear markets:A. Loss of competitive advantage due to the costs associated with development oftechnologies relating to the component design, manufacture and examination.Providing public access to such information permits competitors to duplicate ormimic the methodology without incurring the associated costs.B. Loss of competitive advantage of MHI's ability to supply replacement or newheavy components such as steam generators.

I declare under penalty of perjury that the foregoing affidavit and the matters stated thereinare true and correct to the best of my knowledge, information and belief.Executed on this _-,___ day of ..2012.Jinichi Miyaguchi, /Director- Nuclear Plant Component Designing DepartmentMitsubishi Heavy Industries, LTDSworn to and subscribedBefore me this 2 Y dayof NotryMPu,2012Notary Publicy' /~aS~l~ii~fl K..;:.rtic ga a3 -I~ ~ -:N-1373DEC. 2 8, 2012My Commission Expires xIX.-x ---- -- ------ -------P$ 14-X. xf lif!xxý )11-- x-- ------E ~ --1 2..... .. ... .......10--- --- ----- ----x- -X --------------- -- --- ---- ---xx.--f z 'A 14T04----- ---- -- --- ------ -- ------- ---- ------- ----- ---- -------0 ..------ --- -- --- -- ----- --- -- -- --- ----- -- --- x--x1........X. .... -------------- -------19.4 q<x-0 0 0 0 0 0 0 0 0 0 0 0 0 --- ---- ---- -- ------ -- -----------------...... ....- ------ -- --x-----------On&

Registered Number 3 7 6! 1;Date D E C, L"NOTARIAL CERTIFICATEThis is to certify that JINICHI MIYAGUCHI , Director-Nuclear PlantComponent Designing Department MITSUBISHI HEAVY INDUSTRIES, LTDhas affixedhis signature in my verypresence to the attacheddocument.ý )4 11 AldI SN{f1irS &i1<~ obe, japaia'r/ t ,, 0, ý J-" ý' tL'14ýdoltocMASAHIKO KUBOTANotary44 Akashimachi, Chuo-Ku,Kobe, JapanKobe District Legal Affairs Bureau(fft-2)

ENCLOSURE 3SOUTHERN CALIFORNIA EDISONRESPONSE TO REQUEST FOR ADDITIONAL INFORMATIONREGARDING RESPONSE TO CONFIRMATORY ACTION LETTERDOCKET NO. 50-361TAC NO. ME 9727Response to RAI 30(NON-PROPRIETARY)Page 1 RAI 30Reference 1, Figure 8-2 -Provide similar figure for maximum interstitial velocities.ResponseThe following figure shows the percentage of tubes with tube-to-tube wear (TTW) indications ateach range of maximum interstitial velocity at 100% power. In the figure, 2A, 2B, 3A and 3Brepresent steam generators (SGs) 2E089, 2E088, 3E089 and 3E088, respectively. As indicatedin Table 8-3 of Reference 1, operating Unit 2 at 70% power reduces the maximum interstitialvelocity in the SG secondary side to well below the velocities which resulted in TTW at 100%power.Page 2