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| document type = Letter
| document type = Letter
| page count = 4
| page count = 4
| project = TAC:ME9727, TAC:ME9727
| project = TAC:ME9727
| stage = Response to RAI
| stage = Response to RAI
}}
}}


=Text=
=Text=
{{#Wiki_filter:V SOUTHERN CALIFORNIAEDISONAn EDISON INTERNATIONAL CompanyRichard I. St. OngeDirector, Nuclear Regulatory Affairs andEmergency PlanningFebruary 4, 201310 CFR 50.4U.S. Nuclear Regulatory CommissionATTN: Document Control Desk.Washington, DC 20555-0001Subject:Docket No. 50-361Response to Request for Additional Information (RAI 6)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 1 of this letter provides theresponses to RAI 6.P.O. Box 128San Clemente, CA 92672 Document Control Desk-2-February 4, 2013There 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,Enclosure:1. Response to RAl 6cc: 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 IV ENCLOSURE 1SOUTHERN CALIFORNIA EDISONRESPONSE TO REQUEST FOR ADDITIONAL INFORMATIONREGARDING RESPONSE TO CONFIRMATORY ACTION LETTERDOCKET NO. 50-361TAC NO. ME 9727Response to RAI 6Page 1 of 2 RAI 6Regarding Reference 4, page 4-5, it seems that depths of undetected flaws are assumed to beassociated with POD < 0.05. Why is this conservative? Is there a possibility that someundetected flaws may be associated with higher values of POD?RESPONSEIt is possible that there could exist some undetected wear above the 5% probability of detection(POD) performance level. However, the likelihood of any significant number of undetectedindications with depths that exceed the 5% POD at the beginning of the next operating cycle isvery low. This is based on the conditions following Southern California Edison's (SCE's)enhanced inspections and tube plugging for Unit 2 as discussed below:1) A large sample of tubes in the high-wear region underwent a double inspection, firstwith the bobbin probe followed later with +PointTM. The resulting POD performancewill be better than either technique.2) As discussed in RAI Reference 4, the threshold of detection for the +PointTM isapproximately 5% through wall (TW). Based on Examination TechniqueSpecification Sheet (ETSS) 27902.2 data for +PointTM, all indications above thisthreshold value were detected for the ETSS data set.3) Screening criteria were developed to identify tubes susceptible to tube-to-tube wear(TTW). These tubes were preventively plugged. These preventively plugged tubesare the most likely to have TTW.The use of POD thresholds for TTW and support wear are reasonable and conservative forassessing the mid-cycle operation for Unit 2. To evaluate the sensitivity of this assumption forundetected TTVV, the operational assessment (OA) model in RAI Reference 4 was evaluated fora higher threshold value for the +PointTM probe. This threshold value was conservatively takenas 0.95 instead of 0.05. The 0.95 POD detection limit is used in defining the worst-caseindication at beginning of the operating cycle when performing a deterministic single-tubeanalysis per the industry guidelines. This would effectively double the threshold depth for anundetected TTW indication from about 5% TW to 10% TW in the Unit 2 simulation based onFigure 4-3 of RAI Reference 4. The results from this analysis reduce the allowable inspectioninterval by less than 0.06 years at power. The selection of the threshold detection limit for TTWhas a minor impact on the probability of burst results shown in Figure 5-4 of RAI Reference 4even when a more conservative POD threshold value is assumed.The treatment of undetected tube support wear in the 1350 no degradation detected (NDD)tubes is very conservative. RAI Reference 4 assumes that every tube in this group hasundetected tube wear at both anti-vibration bar (AVB) and tube support plate (TSP) locations.The wear locations are assigned based on the distribution of tube support wear observed for thetube that had detected wear at the end of the previous operating cycle. The model algorithmassigns five active wear locations, on average, in each NDD tube (two minimum, one at AVBand one at TSP). This assumes that the presence of tube/support wear in the NDD tubesduring the mid-cycle will be the same as observed in the worn tubes in the first cycle.Additionally, the likelihood of having multiple NDD indications with significant depths at thebeginning of the next operating cycle is low. The process of assigning wear locations withdepths using a 5% POD threshold for the 1350 NDD tubes will result in a conservative estimateof wear index at the beginning of the next operating cycle.Page 2 of 2  
{{#Wiki_filter:V SOUTHERN CALIFORNIAEDISONAn EDISON INTERNATIONAL CompanyRichard I. St. OngeDirector, Nuclear Regulatory Affairs andEmergency PlanningFebruary 4, 201310 CFR 50.4U.S. Nuclear Regulatory CommissionATTN: Document Control Desk.Washington, DC 20555-0001
 
==Subject:==
Docket No. 50-361Response to Request for Additional Information (RAI 6)Regarding Confirmatory Action Letter Response(TAC No. ME 9727)San Onofre Nuclear Generating Station, Unit 2
 
==References:==
: 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 2
 
==Dear 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 1 of this letter provides theresponses to RAI 6.P.O. Box 128San Clemente, CA 92672 Document Control Desk February 4, 2013There 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,
 
==Enclosure:==
: 1. Response to RAl 6cc: 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 IV ENCLOSURE 1SOUTHERN CALIFORNIA EDISONRESPONSE TO REQUEST FOR ADDITIONAL INFORMATIONREGARDING RESPONSE TO CONFIRMATORY ACTION LETTERDOCKET NO. 50-361TAC NO. ME 9727Response to RAI 6Page 1 of 2 RAI 6Regarding Reference 4, page 4-5, it seems that depths of undetected flaws are assumed to beassociated with POD < 0.05. Why is this conservative? Is there a possibility that someundetected flaws may be associated with higher values of POD?RESPONSEIt is possible that there could exist some undetected wear above the 5% probability of detection(POD) performance level. However, the likelihood of any significant number of undetectedindications with depths that exceed the 5% POD at the beginning of the next operating cycle isvery low. This is based on the conditions following Southern California Edison's (SCE's)enhanced inspections and tube plugging for Unit 2 as discussed below:1) A large sample of tubes in the high-wear region underwent a double inspection, firstwith the bobbin probe followed later with +PointTM. The resulting POD performancewill be better than either technique.2) As discussed in RAI Reference 4, the threshold of detection for the +PointTM isapproximately 5% through wall (TW). Based on Examination TechniqueSpecification Sheet (ETSS) 27902.2 data for +PointTM, all indications above thisthreshold value were detected for the ETSS data set.3) Screening criteria were developed to identify tubes susceptible to tube-to-tube wear(TTW). These tubes were preventively plugged. These preventively plugged tubesare the most likely to have TTW.The use of POD thresholds for TTW and support wear are reasonable and conservative forassessing the mid-cycle operation for Unit 2. To evaluate the sensitivity of this assumption forundetected TTVV, the operational assessment (OA) model in RAI Reference 4 was evaluated fora higher threshold value for the +PointTM probe. This threshold value was conservatively takenas 0.95 instead of 0.05. The 0.95 POD detection limit is used in defining the worst-caseindication at beginning of the operating cycle when performing a deterministic single-tubeanalysis per the industry guidelines. This would effectively double the threshold depth for anundetected TTW indication from about 5% TW to 10% TW in the Unit 2 simulation based onFigure 4-3 of RAI Reference 4. The results from this analysis reduce the allowable inspectioninterval by less than 0.06 years at power. The selection of the threshold detection limit for TTWhas a minor impact on the probability of burst results shown in Figure 5-4 of RAI Reference 4even when a more conservative POD threshold value is assumed.The treatment of undetected tube support wear in the 1350 no degradation detected (NDD)tubes is very conservative. RAI Reference 4 assumes that every tube in this group hasundetected tube wear at both anti-vibration bar (AVB) and tube support plate (TSP) locations.The wear locations are assigned based on the distribution of tube support wear observed for thetube that had detected wear at the end of the previous operating cycle. The model algorithmassigns five active wear locations, on average, in each NDD tube (two minimum, one at AVBand one at TSP). This assumes that the presence of tube/support wear in the NDD tubesduring the mid-cycle will be the same as observed in the worn tubes in the first cycle.Additionally, the likelihood of having multiple NDD indications with significant depths at thebeginning of the next operating cycle is low. The process of assigning wear locations withdepths using a 5% POD threshold for the 1350 NDD tubes will result in a conservative estimateof wear index at the beginning of the next operating cycle.Page 2 of 2  
}}
}}

Revision as of 12:35, 5 April 2018

San Onofre Nuclear Generating Station, Unit 2, Response to Request for Additional Information (RAI 6) Regarding Confirmatory Action Letter Response (TAC ME9727)
ML13038A009
Person / Time
Site: San Onofre Southern California Edison icon.png
Issue date: 02/04/2013
From: St.Onge R J
Southern California Edison Co
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
TAC ME9727
Download: ML13038A009 (4)


Text

V SOUTHERN CALIFORNIAEDISONAn EDISON INTERNATIONAL CompanyRichard I. St. OngeDirector, Nuclear Regulatory Affairs andEmergency PlanningFebruary 4, 201310 CFR 50.4U.S. Nuclear Regulatory CommissionATTN: Document Control Desk.Washington, DC 20555-0001

Subject:

Docket No. 50-361Response to Request for Additional Information (RAI 6)Regarding Confirmatory Action Letter Response(TAC No. ME 9727)San Onofre Nuclear Generating Station, Unit 2

References:

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 2

Dear 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 1 of this letter provides theresponses to RAI 6.P.O. Box 128San Clemente, CA 92672 Document Control Desk February 4, 2013There 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,

Enclosure:

1. Response to RAl 6cc: 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 IV ENCLOSURE 1SOUTHERN CALIFORNIA EDISONRESPONSE TO REQUEST FOR ADDITIONAL INFORMATIONREGARDING RESPONSE TO CONFIRMATORY ACTION LETTERDOCKET NO. 50-361TAC NO. ME 9727Response to RAI 6Page 1 of 2 RAI 6Regarding Reference 4, page 4-5, it seems that depths of undetected flaws are assumed to beassociated with POD < 0.05. Why is this conservative? Is there a possibility that someundetected flaws may be associated with higher values of POD?RESPONSEIt is possible that there could exist some undetected wear above the 5% probability of detection(POD) performance level. However, the likelihood of any significant number of undetectedindications with depths that exceed the 5% POD at the beginning of the next operating cycle isvery low. This is based on the conditions following Southern California Edison's (SCE's)enhanced inspections and tube plugging for Unit 2 as discussed below:1) A large sample of tubes in the high-wear region underwent a double inspection, firstwith the bobbin probe followed later with +PointTM. The resulting POD performancewill be better than either technique.2) As discussed in RAI Reference 4, the threshold of detection for the +PointTM isapproximately 5% through wall (TW). Based on Examination TechniqueSpecification Sheet (ETSS) 27902.2 data for +PointTM, all indications above thisthreshold value were detected for the ETSS data set.3) Screening criteria were developed to identify tubes susceptible to tube-to-tube wear(TTW). These tubes were preventively plugged. These preventively plugged tubesare the most likely to have TTW.The use of POD thresholds for TTW and support wear are reasonable and conservative forassessing the mid-cycle operation for Unit 2. To evaluate the sensitivity of this assumption forundetected TTVV, the operational assessment (OA) model in RAI Reference 4 was evaluated fora higher threshold value for the +PointTM probe. This threshold value was conservatively takenas 0.95 instead of 0.05. The 0.95 POD detection limit is used in defining the worst-caseindication at beginning of the operating cycle when performing a deterministic single-tubeanalysis per the industry guidelines. This would effectively double the threshold depth for anundetected TTW indication from about 5% TW to 10% TW in the Unit 2 simulation based onFigure 4-3 of RAI Reference 4. The results from this analysis reduce the allowable inspectioninterval by less than 0.06 years at power. The selection of the threshold detection limit for TTWhas a minor impact on the probability of burst results shown in Figure 5-4 of RAI Reference 4even when a more conservative POD threshold value is assumed.The treatment of undetected tube support wear in the 1350 no degradation detected (NDD)tubes is very conservative. RAI Reference 4 assumes that every tube in this group hasundetected tube wear at both anti-vibration bar (AVB) and tube support plate (TSP) locations.The wear locations are assigned based on the distribution of tube support wear observed for thetube that had detected wear at the end of the previous operating cycle. The model algorithmassigns five active wear locations, on average, in each NDD tube (two minimum, one at AVBand one at TSP). This assumes that the presence of tube/support wear in the NDD tubesduring the mid-cycle will be the same as observed in the worn tubes in the first cycle.Additionally, the likelihood of having multiple NDD indications with significant depths at thebeginning of the next operating cycle is low. The process of assigning wear locations withdepths using a 5% POD threshold for the 1350 NDD tubes will result in a conservative estimateof wear index at the beginning of the next operating cycle.Page 2 of 2