ML12346A484

Petitioner'S Motion to Amend the Proposed Scheduling Order and Clarify Scope of Disclosure

ML12346A484
Person / Time
Site:	San Onofre
Issue date:	12/11/2012
From:	Ayres R, Olson J, Gladd K Ayres Law Group, Friends of the Earth
To:	Atomic Safety and Licensing Board Panel
SECY RAS
References
RAS 23871, 50-361-CAL, 50-362-CAL, ASLBP 13-924-01-CAL-BD01
Download: ML12346A484 (28)

Text

1 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD

) In the Matter of

) ) Docket Nos. 50

-361-CAL & 50-362-CAL SOUTHERN CALIFORNIA EDISON COMPANY

) ) (San Onofre Nuclear Generating Station, ) December 11, 2012 Units 2 and 3)

) ) PETITIONERS MOTION TO AMEND THE PROPOSED SCHEDULING ORDER AND CLARIFY SCOPE OF DISCLOSURE Petitioner Friends of the Earth (FoE) moves the Atomic Safety and Licensing Board (Licensing Board or Board) to clarify the scope of disclosure of documents and extend the briefing schedule proposed in the Boards December 7, 2012 Order. Consistent with that Order, Petitioner has attempted to negotiate an agreement among the parties that would (1) identify the proprietary documents the Board has ordered Respondent Southern California Edison Company (SCE) to provide the Board and the other parties; and (2) give a modest amount of time prior to briefing to allow counsel and their expert to review and evaluate the documents to be made available under the Boards Order. Unfortunately, these negotiations have been unsuccessful. In response to a proposal from Petitioner, Respondent has taken a very narrow view of its responsibilities to share proprietary documents and refused to consider any additional time for review of the proprietary documents the Board has ordered released to the Board and the parties.

Counsel for SCE oppose this motion. Counsel for NRC Staff do not oppose the Board ordering SCE to provide the documents requested in this motion, except with respect to the 2 documents related to the Augmented Inspection Team report, 1 nor do counsel for NRC Staff oppose a reasonable extension of time for Petitioner to file their initial brief.

BACKGROUND On November 8, 2012, the Nuclear Regulatory Commission (NRC or Commission) issued decision CLI 20 referring to the Atomic Safety and Licensing Board Panel a portion of Friends of the Earths (FoE) June 18, 2012 intervention petition. FoEs petition related to a March 27, 2012 Confirmatory Action Letter (CAL) issued by the Commission to SCE. On December 3, 2012, the participants in this proceeding, SCE, FoE, and the NRC Staff, participated in a conference call with the Licensing Board established for this proceeding to discuss scheduling and management issues.

On December 7, 2012, the Licensing Board issued an Order that directed SCE to disclose to the Board and FoE the numerous proprietary documents referred to in SCEs response to the CAL and . . . documents generated pursuant to the CAL in SCEs Restart Plan. Order at 4. The Order also contained a Proposed Scheduling Order, and invited the parties to negotiate an alternative schedule if the proposed schedule does not provide adequate time to prepare thorough, high

-quality briefs. Order at 5.

CLARIFICATION OF THE SCOPE OF DISCLOSURE In its December 7 Order, the Board directed SCE to make broad disclosure of proprietary versions of documents generated pursuant to the CAL in SCEs Restart Plan and the proprietary versions of the documents referred to in SCEs response to the CAL. Order at 4 [emphasis supplied]. These two groups documents referred to in SCEs response to the CAL

1 Counsel for NRC Staff do oppose what they describe as discovery against the government. Petitioners view is that its request is not a discovery request, but rather a clarification of items the Board has already ordered to be produced.

3 and the documents generated pursuant to the CAL are, in the Boards view, necessary to determine . . . whether the CAL itself is a de facto license amendment. Order at 4.

Based on an exhaustive review of the publicly available documents provided and referred to by SCE in its response to the CAL and restart plan, Petitioners experts have identified proprietary documents relied upon, but either redacted or simply referred to, in support of SCEs response to the CAL and restart plan. Since these documents are quoted or referred by SCE in support of the companys response to the CAL and restart plan, there can be no argument regarding their relevance to this proceeding. As the Board noted, these documents, incident to and subsequent to the CAL . . . will inform the Boards understanding of the CAL and its effect. Order at 3.

Respondent will no doubt make the argument that the publicly available documentation for the CAL response and restart plan is sufficient for Petitioner to understand the issues under consideration by the Board. The Board has made clear that it does not agree with this position. Much of the CAL response includes conclusory statements based on analyses and data from proprietary documents included by reference, but unavailable to Petitioner without disclosure by SCE. In order to illustrate for the Board the types of relevant information that is currently unavailable to the Petitioner and the Board, Petitioner notes the following:

¥ SCE claims to have benchmarked its analysis of whether 70% power would be safe by reference to another reactor, simply labeled Reactor A. To date, SCE has not revealed the identity of Reactor A.

Neither the Board nor Petitioner will be able to assess whether running San Onofre Unit 2 will cause a more than minor increase in the risk of damage to the steam generator unless we know the identity of Reactor A.

4 ¥ At its December 7, 2012 public meeting with SCE

, the NRC Staff inquired whether SCE had performed a Section 50.59 analysis of all the matters associated with the CAL response. SCE replied it had. In light of Question (iii) in the Boards Order, requesting the parties to address the extent to which the standards in 10 CFR 50.59(c)(1) and (c)(2) apply, it is obvious that SCEs Section 50.59 analysis is directly related to the CAL response and the restart plan and must be made available to the Board and the parties.

¥ The Board has asked (Question (iv)) whether the Final Safety Analysis Report (FSAR) analyzed a steam generator tube failure event, and directed that a copy be provided to the parties and the Board of the relevant section(s) of the FSAR. On December 10, 2012, a representative of FoE sought to obtain the most recent version (dated 2009 and subsequently revised) of the FSAR for San Onofre. An extensive search by an NRC librarian was unable to locate the most recent version of the FSAR even on the NRCs internal server, which contains documents that may not be publicly available on the NRCs ADAMS database.

Appended to this motion is a list of specific proprietary documents directly associated with or quoted or referred to by SCE in the response to the CAL and restart plan. These documents fall into three categories:

1. Documents included in the categories referred to in footnotes 5 and 6 on page 4 of the Boards December 7, 2012 Order;

2. Documents directly associated with, quoted, redacted, or referred to in support of the conclusions of the SCE response to the CAL and restart plan that are necessary in order for Petitioners experts to analyze and answer questions (iv)

(vii) posed by the Board in its December 7 Order, and other documents that are 5 necessary to determine . . . whether the CAL itself is a de facto license amendment. Order at 4;

3. Relevant SCE proprietary documents referred to in the Augmented Inspectio n Team Report.

Respondent SCE agrees that it is obligated to provide documents in Category 1. Petitioners experts have identified the specific documents listed in Categories 2 and 3 as relevant and probative with respect to the questions put by the Board, and the two issues referred by the Commission.

FoE therefore requests the Board to direct SCE and NRC Staff to disclose to FoE the propriety documents listed in the attachments. These documents are necessary to address the questions posed by the Board. NEED FOR REVISION OF PROPOSED SCHEDULE The proprietary documents requested by Petitioner contain a large amount of technical information that has not been made available to FoE and that is directly relevant to the questions before the Board. In its Order, the Board recognized that:

(1) [T]he issues underlying the questions referred by the Commission are several and complex, and (2) there are numerous proprietary documents that Friends of the Earth has not yet seen that, when released by SCE, will require time by counsel and their experts to review and evaluate.

Order at 5.

Additionally, the Board observed that this case will proceed with greater dispatch if the participants provide the Board with thoughtful, well analyzed, and well

-written briefs. I

d. Unless FoE is given time for its experts to review the proprietary documents the Board has directed SCE to provide, FoE will not be able to prepare the thorough, high quality briefs the 6 Board wishes to receive. As of this date, the Petitioners brief would be due under the Boards proposed schedule in only 10 days. SCE has so far delivered no documents under the Boards Order. Unless the due date for the opening brief is extended, it is not clear that Petitioner will have any meaningful opportunity to review the proprietary documents the Board wished Petitioner to see.

Therefore, FoE respectfully requests that time be provided to allow for expert review of these documents prior to preparation of briefs. FoE proposes to allow a three

-week period to review disclosed documents, beginning when the documents have been disclosed. Briefing would begin three weeks after that, on a schedule identical to the one proposed by the Board. For example, if all the documents were disclosed to FoE by December 14, 2012, the schedule would be as follows:

January 4, 2013 Review of documents January 25, 2013 Brief for Petitioner February 1, 2013 Brief for Amicus February 15, 2013 Brief for Respondent February 15, 2013 Brief for NRC Staff February 22, 2013 Reply brief for Petitioner The proposed schedule would not unduly delay the proceeding and is necessary to allow for thoughtful and accurate determination of the issues by the Board.

7 Signed (electronically) by Richard Ayres Richard E. Ayres Jessica L. Olson Kristin Hines Gladd Ayres Law Group 1707 L St., N.W., Suite 850 Washington, D.C. 20036 Phone: 202

-452-9200 E-mail: ayresr@ayreslawgroup.com; olsonj@ayreslawgroup.com; gladdk@ayreslawgroup.com Counsel for Friends of the Earth Dated in Washington, D.C.

this 11th day of December 2012

Attachment 1 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD Before Administrative Judges:

E. Roy Hawkens, Chairman Dr. Anthony J. Baratta Dr. Gary S. Arnold In the Matter of SOUTHERN CALIFORNIA EDISON CO.

(San Onofre Nuclear Generating Station, Units 2 and 3)

Docket Nos. 50

-361-CAL, 50-362-CAL ASLBP No. 13

-924-01-CAL-BD01 December __, 2012 MEMORANDUM AND ORDER Upon consideration of the December 11, 2012 Motion to Amend the Proposed Scheduling Order and Clarify Scope of Disclosure by Petitioner Friends of the Earth (FoE), we GRANT the Motion and issue this Amended Briefing Schedule and clarification to govern the adjudication of the issues referred by the Commission (CLI 20) to the Atomic Safety and Licensing Board (ASLB) on November 8, 2012 regarding a March 27, 2012 Confirmatory Action Letter (CAL) issued by the Nuclear Regulatory Commission (NRC) to SCE.

The Board recognizes that (1) the underlying issues in this matter are numerous and complex and (2) in order to prepare thoughtful, well

-analyzed, and well

-written briefs, the parties will need adequate time to disclose and consider the numerous proprietary documents ordered to be made available to the parties under a Non

-Disclosure Agreement. We hereby order that the documents to be disclosed shall include those documents described in the lists appended to Attachment 2 Petitioners December 11, 2012 Motion, as well as SCEs analysis of its restart plan performed pursuant to 10 C.F.R. 50.59. The Board also hereby amends the Proposed Scheduling Order to allow for a three

-week review period after all parties receive all documents ordered to be disclosed in this Order. For example, if all the documents were disclosed to FoE by December 14, 2012, the schedule would be as follows:

January 4, 2013 Review of documents January 25, 2013 Brief for Petitioner February 1, 2013 Brief for Amicus February 15, 2013 Brief for Respondent February 15, 2013 Brief for NRC Staff February 22, 2013 Reply brief for Petitioner It is so ORDERED.

FOR THE ATOMIC SAFETY AND LICENSING BOARD

______________________

E. Roy Hawkins CHAIRMAN Rockville, Maryland December __, 2012

Attachment 1 ATTACHMENT 1 DOCUMENTS DIRECTLY ASSOCIATED WITH, QUOTED, REDACTED, OR REFERRED TO IN SUPPORT OF THE CONCLUSIONS OF THE SCE RESPONSE TO THE CAL AND RESTART PLAN Table 1 Redacted Documents in ADAMS ML122850320 I TEM DOCUMENT FOR DISCLOSURE SOURCE DOCUMENT 1 ML12285A263

- San Onofre Nuclear Generating Station, Unit 2 - Confirmatory Action Letter

- Actions to Address Steam Generator Tube Degradation. (134 page(s), 10/3/2012)

NRC ADAMS ML122850320 2 ML12285A264

- Attachment 3

- AREVA Document 51

-9180143-001 - SONGS Unit 3 February 2012 Leaker Outage Steam Generator Condition Monitoring Report. (100 page(s), 10/1/2012)

NRC ADAMS ML122850320 3 ML12285A265

- Attachment 4

- MHI Document L5

-04GA564 - Tube Wear of Unit

-3 RSG, Technical Evaluation Report. (142 page(s), 10/1/2012)

NRC ADAMS ML122850320 4 ML12285A266

- Attachment 4: Appendix

-2 Attachment-1, Tube-to-TSP wear depth diagram for Unit

-2/3. (226 page(s), 10/1/2012)

NRC ADAMS ML122850320 5 ML12285A267

- Attachment 4: SG Tube Wear Analysis for Unit-2/3. (239 page(s), 10/1/2012)

NRC ADAMS ML122850320 6 ML12285A268

- Attachment 6

- Appendix B: SONGS U2C17

- Steam Generator Operational Assessment for Tube

-to-Tube Wear. (105 page(s), 10/2/2012)

NRC ADAMS ML122850320 7 ML12285A269

- Attachment 6: Appendix A: Estimates of FEI

-Induced TTW Rates. (209 page(s), 10/2/2012)

NRC ADAMS ML122850320 8 Enclosure 2

- San Onofre Nuclear Generating Station Unit 2 Return To Service Report October 3, 2012 Peter T. Dietrich, Senior Vice President & Chief Nuclear Officer, SCE, Letter to Elmo E. Collins, Regional Administrator, Region IV, US NRC, Docket No.

50-361, [CAL]

Actions to Address Steam Generator Tube Degradation [SONGS], Unit 2 (Oct. 3, 2012)

Attachment 2 Table 2 Documents Needed to Address ASLB Factual Issue (iv)

I TEM DOCUMENT FOR DISCLOSURE SOURCE DOCUMENT SOURCE D OCUMENT R EFERENCE COMMENTS 9 San Onofre 2&3 FSAR Updated NRC AIT Inspection Report 05000361/2012007 and 05000362/2012007 10 SONGS Steam Generator Program (SO23-SG-1) ENCLOSURE 2, San Onofre Nuclear Generating Station Unit 2 Return to Service Report, SCE October 3 1012 10 11 SONGS Technical Specifications Section 5.5.2.11, Steam Generator (SG) Program, Amendment 204

1) ATTACHMENT 2, AREVA Document 51

-9182368-003, SONGS 2C17 Steam Generator Condition Monitoring Report ATTACHMENT 3, AREVA Document 51

-9180143-001 SONGS Unit 3 February 2012 Leaker Outage Steam Generator Condition Monitoring Report 17 18 Latest amendment required 12 ECT Data for Input to Return to Service and Repair Design Documents (RSG

-SCE/MHI-12-5688), e-mail from SCEs Mr. Calhoun on March 23, 2012 (JST)

ATTACHMENT 4, MHI Document L5

-04GA564 Tube Wear of Unit

-3 RSG Technical Evaluation Report ATTACHMENT 5, MHI Document L5

-04GA571, Screening Criteria for Susceptibility to In

-Plane Tube Motion 3.1 P 89 2 Attachment 3 TABLE 3 Documents Needed to Address ASLB Factual Issue (v) and (v i) I TEM DOCUMENT FOR DISCLOSURE SOURCE DOCUMENT SOURCE D OCUMENT R EFERENCE COMMENTS 13 MHI Document L5

-04GA111, San Onofre Generating Station, Units 2 & 3 Replacement Steam Generators Vendor Manual, Rev 6 (SONGS Document SO23-617-1-M1273, Rev 6)

ATTACHMENT 2, AREVA Document 51

-9182368-003, SONGS 2C17 Steam Generator Condition Monitoring Report 22 14 MHI, SONGS Unit 2 & 3 RSGs, Regulatory Guide 1.121 Analysis, SO23-617-1-C1262, Rev. 4 ATTACHMENT 3, AREVA Document 51

-9180143-001 SONGS Unit 3 February 2012 Leaker Outage Steam Generator Condition Monitoring Report 12 15 AREVA Document 03

-9180130-000, SONGS 3F16B SSI Final Report ATTACHMENT 3, AREVA Document 51

-9180143-001 SONGS Unit 3 February 2012 Leaker Outage Steam Generator Condition Monitoring Report 22 16 MHI report, Case study of the input parameters and tube plugging impact on internal SG thermal hydraulic parameters, L5

-04GA566 the latest revision ATTACHMENT 4, MHI Document L5-04GA564 Tube Wear of Unit

-3 RSG Technical Evaluation Report ATTACHMENT 4, MHI Document L5-04GA564 Tube Wear of Unit

-3 RSG Technical Evaluation Report 5 21) pg.423 17 MHI report, Evaluation of Stability Ratio for Return to Service, L5

-04GA567 the latest revision SONGS Document SO23

-617-1-M1523 Rev. 5, Replacement Steam Generators, Evaluation of Stability Ratio for Return to Service ATTACHMENT 4, MHI Document L5-04GA564 Tube Wear of Unit

-3 RSG Technical Evaluation Report ATTACHMENT 6 Appendix B SONGS U2C17 Steam Generator Operational Assessment for Tube

-to-Tube Wear 6 20 Same document? 18 MHI report, Analytical Evaluations for Operating Assessment, L5

-04GA585 the latest revision ATTACHMENT 4, MHI Document L5-04GA564 Tube Wear of Unit

-3 RSG Technical Evaluation Report 10 19 MHI report, Screening Criteria for Susceptibility to In

-Plane Tube Motion, L5-04GA571 the latest revision ATTACHMENT 4, MHI Document L5-04GA564 Tube Wear of Unit

-3 RSG Technical Evaluation Report 8 Unredacted copy required 20 SCE project letter, Updated ECT Data for Input to Return to Service and Repair Design Documents, RSG

-SCE/MHI-12-5749, August 2012 ATTACHMENT 4, MHI Document L5-04GA564 Tube Wear of Unit

-3 RSG Technical Evaluation Report ATTACHMENT 5, MHI Document L5-04GA571, Screening Criteria for Susceptibility to In

-Plane Tube 11 1 Attachment 4 I TEM DOCUMENT FOR DISCLOSURE SOURCE DOCUMENT SOURCE D OCUMENT R EFERENCE COMMENTS Motion 3) L5-04FU001 the latest revision, Component and Outline Drawing 1/3 4) L5-04FU002 the latest revision, Component and Outline Drawing 2/3 5) L5-04FU003 the latest revision, Component and Outline Drawing 3/3 6) L5-04FU021 the latest revision, Tube Sheet and Extension Ring 1/3

7) L5-04FU022 the latest revision, Tube Sheet and Extension Ring 2/3

8) L5-04FU023 the latest revision, Tube Sheet and Extension Ring 3/3

9) L5-04FU051 the latest revision, Tube Bundle 1/3

10) L5-04FU052 the latest revision, Tube Bundle 2/3

11) L5-04FU053 the latest revision, Tube Bundle 3/3

12) L5-04FU111 the latest revision, AVB assembly 1/9

13) L5-04FU112 the latest revision, AVB assembly 2/9

14) L5-04FU113 the latest revision, AVB assembly 3/9

15) L5-04FU114 the latest revision, AVB assembly 4/9

16) L5-04FU115 the latest revision, AVB assembly 5/9

17) L5-04FU116 the latest revision, AVB assembly 6/9

18) L5-04FU117 the latest revision, AVB assembly 7/9

19) L5-04FU118 the latest revision, AVB assembly 8/9 20) L5-04FU119 the latest revision, AVB assembly 9/9 ATTACHMENT 4, MHI Document L5-04GA564 Tube Wear of Unit

-3 RSG Technical Evaluation Report 8.3) TO 20) P 141 21 WJS16263, MHI Test Report of Fluid Elastic Vibration ATTACHMENT 4, MHI Document L5-04GA564 Tube Wear of Unit

-3 RSG Technical Evaluation Report 8.30) P 141 22 1) L5-04FU051 Rev.1 Design drawing of Tube Bundle 1/3

2) L5-04FU052 Rev.1 Design drawing ATTACHMENT 4, MHI Document L5-04GA564 Tube Wear of Unit

-3 RSG Technical Evaluation Report 8.10 TO 8) P 363 Attachment 5 I TEM DOCUMENT FOR DISCLOSURE SOURCE DOCUMENT SOURCE D OCUMENT R EFERENCE COMMENTS of Tube Bundle 2/3

3) L5-04FU053 Rev.3 Design drawing of Tube Bundle 3/3

4) L5-04FU108 Rev.3 Design drawing of Tube Support Plate Assembly 3/3

5) L5-04FU111 Rev.2 Design drawing of Anti-Vibration Bar Assembly 1/9

6) L5-04FU112 Rev.1 Design drawing of Anti-Vibration Bar Assembly 2/9

7) L5-04FU118 Rev.3 Design drawing of Anti-Vibration Bar Assembly 8/9

8) L5-04FZ014 Rev.4, Purchase specification of heat transfer tubing 23 Design of AVB, L5

-04GA428 Rev.5 ATTACHMENT 4, MHI Document L 5-04GA564 Tube Wear of Unit

-3 RSG Technical Evaluation Report 8.7) P 407 24 L5-04GA510 the latest revision, Thermal and Hydraulic Parametric Calculations ATTACHMENT 4, MHI Document L5-04GA564 Tube Wear of Unit

-3 RSG Technical Evaluation Report

22) P 423 25 L5-04GA565 the latest revision, Selection of Thermal Hydraulic Analysis (ATHOS) Model ATTACHMENT 4, MHI Document L5-04GA564 Tube Wear of Unit

-3 RSG Technical Evaluation Report

20) P 423 26 MHI document, L5

-04GA401 Rev.7, Design Report of the Tubesheet Region (Tubesheet, Extension Ring, Lower Shell, Divider Plate). ATTACHMENT 4, MHI Document L5-04GA564 Tube Wear of Unit

-3 RSG Technical Evaluation Report

1) P456 27 MHI document, L5

-04GA411 Rev.7, Design Report of the Tubes Support Plate and Stay Rod. ATTACHMENT 4, MHI Document L5-04GA564 Tube Wear of Unit

-3 RSG Technical Evaluation Report

2) P456 28 MHI document, L5

-04GA418 Rev.5, Design Report of the Tube.

ATTACHMENT 4, MHI Document L5-04GA564 Tube Wear of Unit

-3 RSG Technical Evaluation Report

3) P 456 29 Root Cause Evaluation, San Onofre Nuclear Generating Station, Condition Report: 201836127, Unit 3 Steam Generator Tube Leak and Tube

-to-Tube Wear, Revision 0, 5/7/2012.

ATTACHMENT 6 Appendix A SONGS U2C17 Outage Steam Generator Operational Assessment 16 Complete copy, not internet-leaked version, required 30 AREVA Document 51

-9182833-002, SONGS 2C17 Outage Steam Generator Operational Assessment (SONGS Document 1814

-AU651-M0144 Rev. 1) ATTACHMENT 6 Appendix B SONGS U2C17 Steam Generato r Operational Assessment for Tube

-to-Tube Wear 6 31 [ REDACTED] , Simulation of Tube

-to-ATTACHMENT 6 Appendix B A.3.1 Attachment 6 I TEM DOCUMENT FOR DISCLOSURE SOURCE DOCUMENT SOURCE D OCUMENT R EFERENCE COMMENTS Tube Impact, Phase 2 Report, June 2012 (AREVA NP Document 38

-9191195-000). SONGS U2C17 Steam Generator Operational Assessment for Tube

-to-Tube Wear P129 32 SONGS Drawing SO23

-617-1-D507 Rev. 5, San Onofre Nuclear Generating Station Unit 2 & 3 Replacement Steam Generators Design Drawing Anti-Vibration Bar Assembly 1/9 (MHI Drawing L5

-04FU111 Rev. 2).

ATTACHMENT 6 Appendix B SONGS U2C17 Steam Generator Operational Assessment for Tube

-to-Tube Wear 9 33 SONGS Drawing SO23

-617-1-D542 Rev. 9, San Onofre Nuclear Generating Station Unit 2 & 3 Replacement Steam Generators Design Drawing Anti-Vibration Bar Assembly 7/9 (MHI Drawing L5-04FU117 Rev. 9)

ATTACHMENT 6 Appendix B SONGS U2C17 Steam Generator Operational Assessment for Tube

-to-Tube Wear 10 34 AREVA NP Document 51

-9188725-000, SONGS U2C17 and U3F16B AVB Gap and Tube-to-Tube Proximity Measurement Program (SONGS Document 1814-AU651-M0151 Rev. 0)

ATTACHMENT 6 Appendix B SONGS U2C17 Steam Generator Operational Assessment for Tube

-to-Tube Wear 14 35 SONGS Document 90200, Rev. 0. Average and Maximum Thermal

-Hydraulic Parameter Comparisons between Songs RSGs and Similar Plants. ATTACHMENT 6 Appendix B SONGS U2C17 Steam Generator Operational Assessment for Tube

-to-Tube Wear 18 36 SONGS Document SO23

-617-1-M1520 Rev. 6, Tube Wear of Unit

-3 RSG Technical Evaluation Report (MHI Document L5

-04GA564 Rev. 8).

ATTACHMENT 6 Appendix B SONGS U2C17 Steam Generator Operational Assessment for Tube

-to-Tube Wear 22 Unredacted copy required 37 SONGS Document SO23

-617-1-M1532 Rev. 2, Analytical Evaluations for Operational Assessment (MHI Document L5-04GA585 Rev. 2).

ATTACHMENT 6 Appendix B SONGS U2C17 Steam Generator Operational Assessment for Tube

-to-Tube Wear 26 38 AREVA NP Document 32

-9187024-000, SONGS Steam Generator Probability of Fluid Elastic Instability Calculation.

ATTACHMENT 6 Appendix B SONGS U2C17 Steam Generator Operational Assessment for Tube

-to-Tube Wear 27 39 Operational Assessment for SONGS Unit 2 Steam Generators for Upper Bundle Tube

-to-Tube Wear Degradation at End of Cycle 16, APTECH Report, AES 12068150

-2Q-1, September 2012.

ATTACHMENT 6 Appendix D Operational Assessment of Wear Indications In the U

-bend Region of San Onofre Unit 2 Replacement Steam Generators 3 40 SONGS 2C17 Steam Generator Operational Assessment for Tube

-to-Tube Wear, AREVA Report, 51

-9187230, September 2012.

ATTACHMENT 6 Appendix D Operational Assessment of Wear Indications In the U

-Bend Region of San Onofre Unit 2 Replacement Steam Generators ATTACHMENT 6 Appendix A SONGS U2C17 Outage Steam 4 15 Possible duplication

Attachment 7 I TEM DOCUMENT FOR DISCLOSURE SOURCE DOCUMENT SOURCE D OCUMENT R EFERENCE COMMENTS Generator Operational Assessment 41 Flow-Induced Vibration and Tube Wear Analysis of the San Onofre Nuclear Generating Station Unit 2 Replacement Steam Generators Supporting Restart, Westinghouse Report LTR

-SGDA-12-36, Revision 1, September 13, 2012.

ATTACHMENT 6 Appendix D Operational Assessment of Wear Indications In the U

-Bend Region of San Onofre Unit 2 Replacement Steam Generators ATTACHMENT 6 Appendix B SONGS U2C17 Steam Generator Operational Assessment for Tube

-to-Tube Wear 5 21 Possible duplication 42 SONGS Material Properties, E

-mail transmittal with Excel files SONGS2 CMTR.xlsx and SONGS3 CMTR.xlsx from Mr. David Calhoun of SCE to Vince Merritt of Westinghouse, June 22, 2012.

ATTACHMENT 6 Appendix D Operational Assessment of Wear Indications In the U

-Bend Region of San Onofre Unit 2 Replacement Steam Generators 8 43 San Onofre Nuclear Generating Station Units 2 and 3 Replacement Steam Generators Evaluation of Stability Ratio for Return to Service, Mitsubishi Heavy Industries Ltd., L5

-04GA567, Revision 4, July 21, 2012.

ATTACHMENT 6 Appendix D Operational Assessment of Wear Indications In the U

-Bend Region of San Onofre Unit 2 Replacement Steam Generators 9 44 SONGS Unit 2 Tube

-to-tube Wear Indication Data Westinghouse letter LTR-SGMP-12-80, October 2, 2012.

ATTACHMENT 6 Appendix D Operational Assessment of Wear Indications In the U

-Bend Region of San Onofre Unit 2 Replacement Steam Generators 27 Attachment 8 Table 4 Documents Needed to Address ASLB Factual Issue (vii) I TEM DOCUMENT FOR DISCLOSURE SOURCE DOCUMENT SOURCE D OCUMENT R EFERENCE COMMENTS 46 Unit 3 LER 2012

-002, dated May 10, 2012, SG Tube Degradation Indicated by Failed In-situ Pressure Testing as required by 10 CFR 50.73(a)(2)(ii)(A)

ENCLOSURE 2, San Onofre Nuclear Generating Station Unit 2 Return to Service Report, SCE October 3 1012 8 47 Letter from Elmo E. Collins (NRC) to Peter T. Dietrich (SCE), dated March 27, 2012, 2012 - Manual Reactor Trip Due to the SG Tube Leak as required by 10 CFR 50.73(a)(2)(iv)(A), actuation of the Reactor Protection System ENCLOSURE 2, San Onofre Nuclear Generating Station Unit 2 Return to Service Report, SCE October 3 1012 7 48 Special Reports relating to both Units 2 and 3 RSG inspections ATTACHMENT 1, SONGS Unit 2 Relevant Technical Specifications Reports of inspections as required by 10 CRF 5.7.2 c), submitted by SCE and held by Document Control Desk, Washington, D. C. 20555, with a copy to the Regional Administrator of the Regional Office of the NRC 49 AREVA Document 51

-9176667-001, SONGS 2C17 & 3C17 Steam Generator Degradation Assessment ATTACHMENT 2, AREVA Document 51-9182368-003, SONGS 2C17 Steam Generator Condition Monitoring Report 6 50 AREVA Document 51

-9104383-002, SONGS Units 2 & 3 Replacement Steam Generators Eddy Current Technique Validation ATTACHMENT 2, AREVA Document 51-9182368-003, SONGS 2C17 Steam Generator Condition Monitoring Report 7 51 AREVA Document 03

-9170186-003, Secondary Side Visual Inspection Plan and Procedure for SONGS 2C17 (SONGS Procedure Number SO23

-XXVII-25.36) ATTACHMENT 2, AREVA Document 51-9182368-003, SONGS 2C17 Steam Generator Condition Monitoring Report 8 52 SONGS Unit 2 Replacement Steam Generator Receipt Inspection QA Document Review Package, (statistics evaluated in Excel file CMTR Final with Stats.xlsx)

ATTACHMENT 2, AREVA Document 51-9182368-003, SONGS 2C17 Steam Generator 11 Attachment 9 I TEM DOCUMENT FOR DISCLOSURE SOURCE DOCUMENT SOURCE D OCUMENT R EFERENCE COMMENTS Condition Monitoring Report 53 AREVA Document 51

-9177395-000, In-Situ Pressure Test Summary for SONGS Unit 2 (Feb 2012)

ATTACHMENT 2, AREVA Document 51-9182368-003, SONGS 2C17 Steam Generator Condition Monitoring Report 12 54 AREVA Document 51

-9177491-001, SONGS 2C17 Steam Generator Condition Monitoring and Preliminary Operational Assessment ATTACHMENT 2, AREVA Document 51-9182368-003, SONGS 2C17 Steam Generator Condition Monitoring Report 14 55 AREVA Document 51

-9179808-000, In-Situ Pressure Test Results for SONGS U3F16B Outage.

ATTACHMENT 3, AREVA Document 51-9180143-001 SONGS Unit 3 February 2012 Leaker Outage Steam Generator Condition Monitoring Report 11 56 AREVA Document 51

-9179 946-001, Comparison of Bobbin and +Point POD for Tube-Tube Wear in SONGS Steam Generators ATTACHMENT 2, AREVA Document 51-9182368-003, SONGS 2C17 Steam Generator Condition Monitoring Report 16 57 AREVA Document 51

-9181604-000, SONGS Unit 2 Cycle 17 and U2 Return to Service Eddy Current Inspection Technical Summary ATTACHMENT 2, AREVA Document 51-9182368-003, SONGS 2C17 Steam Generator Condition Monitoring Report 23 58 AREVA Document 51

-9176667-001, SONGS 2C17 & 3C17 Steam Generator Degradation Assessment. ATTACHMENT 3, AREVA Document 51-9180143-001 SONGS Unit 3 February 2012 Leaker Outage Steam Generator Condition Monitoring Report 7 59 SONGS Unit 3 Replacement Steam ATTACHMENT 3, 10 Attachment 10 I TEM DOCUMENT FOR DISCLOSURE SOURCE DOCUMENT SOURCE D OCUMENT R EFERENCE COMMENTS Generator Receipt Inspection QA Document Review Package AREVA Document 51-9180143-001 SONGS Unit 3 February 2012 Leaker Outage Steam Generator Condition Monitoring Report 60 MHI report, Retainer Bar Tube Wear Report, L5

-04GA561 the latest revision ATTACHMENT 4, MHI Document L5

-04GA564 Tube Wear of Unit-3 RSG Technical Evaluation Report 4 61 SONGS 2C17 Steam Generator Condition Monitoring Report, Document No. 51

- 9182368-002, AREVA NP.

ATTACHMENT 6 Appendix C Operational Assessment for SONGS Unit 2 SG for Upper Bundle Tube

-to-Tube Wear Degradation at End of Cycle 16 3 62 Verification of Program TTWEAR_U2 for the Operational Assessment for SONGS Unit 2, Draft Calculation No, AES

-C-8150-1, Intertek APTECH, (September 2012)

ATTACHMENT 6 Appendix C Operational Assessment for SONGS Unit 2 SG for Upper Bundle T ube-to-Tube Wear Degradation at End of Cycle 16 5 63 Email from A. Brown (AREVA) to R. Cipolla (Intertek APTECH), SONGS Tube to-Tube Wear Indications, dated June 09, 2012, Attachments: a) SONGS3 AVB and TSP Wear Depth Distribution.xlxs b) SONGS2 AVB and TSP Wear Depth Distribution.xlxs ATTACHMENT 6 Appendix C Operational Assessment for SONGS Unit 2 SG for Upper Bundle Tube

-to-Tube Wear Degradation at End of Cycle 16 6 64 Email from A. Brown (AREVA) to R. Cipolla (Intertek APTECH), OA Data Request, dated June 14, 2012, Attachments: a) SONGS Wear Table w All Tubes.xlxs b) SONGS2 CMTR.xlxs ATTACHMENT 6 Appendix C Operational Assessment for SONGS Unit 2 SG for Upper Bundle Tube

-to-Tube Wear Degradation at End of Cycle 16 10 Attachment 11 I TEM DOCUMENT FOR DISCLOSURE SOURCE DOCUMENT SOURCE D OCUMENT R EFERENCE COMMENTS 65 Email from A. Brown (AREVA) to R. Cipolla (Intertek APTECH), AVB Wear Info, dated June 16, 2012, Attachments: a) SONGS2 AVB Wear Structural Dimensions.xlxs b) SONGS AVB Wear Length Review.xlxs ATTACHMENT 6 Appendix C Operational Assessment for SONGS Unit 2 SG for Upper Bundle Tube-to-Tube Wear Degradation at End of Cycle 16 11 66 Email from C. Waskey (AREVA) to R. Cipolla (Intertek APTECH), Dynamic Pressure Data for Power Reduction, (June 27, 2012) ATTACHMENT 6 Appendix C Operational Assessment for SONGS Unit 2 SG for Upper Bundle Tube-to-Tube Wear Degradation at End of Cycle 16 15 67 Emails from A. Brown (AREVA) to R. Cipolla (Intertek APTECH), SONGS Tube

-to-Tube Wear Indications, Attachment SONGS TTW Depth Distributions 2012.xlsx, (June 9, 2012)

ATTACHMENT 6 Appendix C Operational Assessment for SONGS Unit 2 SG for Upper Bundle Tube-to-Tube Wear Degradation at End of Cycle 16 16 Attachment 12 ATTACHMENT 2 RELEVANT SCE PROPRIETARY DOCUMENTS REFERRED TO IN AUGMENTED INSPECTION TEAM REPORT I TEM NRC/AIT REFERENCE DOCUMENT C ITATION IN AIT REPORT ALSB ISSUE COMMENTS 1 a) UHNR- SON-RSG-06N005 b) Work Order UHH

-G06A097 c) Sumitomo Corrective Action Plan UHCP

-07N004. ML12188A748 p40 A1-11 vii) Relates to quality control issues encountered during the manufacture of the RSG tubing by Sumuitomo 2 AREVA NP Document 51

-9176667-001, SONGS 2C17 & 3C17 Steam Generator Degradation Assessment.

ML12188A748 p42 vii) Seems to be a detailed assessment of the tube inspections for Units 2 and 3 following the Unit 3 forced shutdown of 31 January 2 012 this document is cited in SCE Attachment 6, Songs U2C17 Steam Generator Operational Assessment 3 Certified Design Specification of SONGS Unit 2&3 RSGs (SO23

-617-01, Revision 4) ML12188A748 p44 vii) Specified limiting design parameters for the RSG, leaving other unspecified parameters to be determined by the design process enables the MHI design approach to be evaluated in greater detail 4 a) b) Mitsubishi Document L5-04GA510, Thermal and Hydraulic Parametric Calculations, Revision 5. c) Mitsubishi Document L5-04GA521, 3D Thermal and Hydraulic Analysis, Revision 3.

d) Mitsubishi Document L5-04GA504 Evaluation of Tube Vibration, Revision 3.

ML12188A748 p48 iv), v), vi) Relates to the MHI FIT

-III code analysis of FEI conditions and tube vibration this document is cited in Attachment 4 MHI Document L5

-04GA564 Tube Wear of Unit-3 RSG Technical Evaluation Repo rt 5 Mitsubishi Document KAS

-20040253, FIVATS Code Validation and Qualification Report, ML12188A748 P51 iv), v), vi) Used in conjunction with FIT-III to determine the FEI Stability Ratio throughout the RSG.

6 Mitsubishi KAS

-20050201 FIT-III Code Validation ML12318A342 iv), v), vi) Relates to the MHI FIT

-III code analysis of FEI Attachment 13 I TEM NRC/AIT REFERENCE DOCUMENT C ITATION IN AIT REPORT ALSB ISSUE COMMENTS Report SUPPLEMENTAL INFORMATION conditions and tube vibration 7 Page 57 states that an NRC senior reactor analyst performed a preliminary risk assessment. The risk is composed of two parts: (1) a non-consequential steam line break that induces a steam generator tube rupture, specifically involving the degraded tubes; and (2) an elevated risk of a tube rupture as an initiating event.

ML12188A748 P57 vii) This analysis would be useful to determine what actions are assume of SCE in averting multiple tube ruptures during the postulated in the unpublished NRC analysis 8 SO23-617-01 Specifications for design and fabrication of RSG for Unit 2 and Unit 3 ML12188A748 PA1-4 v), vi) Should provide the geometric design of the tube banks, etc 9 SO23-617-1-M1562 Retainer Bar Tube Wear Report ML12188A748 PA1-5 v), vi) Details of the retainer bar assembly and location of worn tubes from RB wear 10 L5-04GA428 Design of Anti

-Vibration Bar ML12188A748 PA1-6 v), vi) Details of the anti

-vibration bar assembly 11 SDR-037 43366-06037 Tube-to-Tube Clearance in 2A RSG ML12188A748 PA1-6 v), vi) Tube layout 12 SDR-079 43366-08079 Statistical Size of Tube

-to-AVB Gap ML12188A748 PA1-6 v), vi) Tube to AVB geometry 13 SDR-086 10041870-09086 Specifications for Unit 3 RSG Tube Material ML12188A748 PA1-7 v), vi) Tube material specification 14 a) SO23-617-1-D115 b) SO23-617-1-D118 c) SO23-617-1-D118 Design Drawing Tube Bundle ML12188A748 PA1-8 v), vi) Tube Bundle design 15 a) SO23-617-1-D294 b) SO23-617-1-D295 c) SO23-617-1-Design Drawing Tube Support Plate Assembly ML12188A748 PA1-9 v), vi) Tube Support Plate

Attachment 14 I TEM NRC/AIT REFERENCE DOCUMENT C ITATION IN AIT REPORT ALSB ISSUE COMMENTS D296 16 a) SO23-617-1-D507 b) SO23-617-1-D508 c) SO23-617-1-D539 d) SO23-617-1-D540 e) SO23-617-1-D541 f) SO23-617-1-D542 g) SO23-617-1-D543 Design Drawing Anti

-Vibration Bar Assembly ML12188A748 PA1-9/10 v), vi) Anti-vibration assembly 17 a) L5-04FW111 b) L5-04FW112 c) L5-04FW113 d) L5-04FW114 e) L5-04FW115 AVB Detail ML12188A748 PA1-10 v), vi) AVB detail 18 SO23-617-1-C157 Evaluation of Tube Vibration ML12188A748 PA1-10 viii) Tube motion, should differentiate between FEI and other modes of fluid excitation 19 SO23-617-1-C749 Analytical Report of AVB Assembly ML12188A748 PA1-10 viii) AVB motion response, could give reason to the out of plane twisting of certain AVBs 20 SO23-617-01R3 Design Report of Tube ML12188A748 PA1-10 v), vi) May include dimensioning of ovoid distortion of tubes during bending and flowering and, from this, reduction in the inter-tube gapping in the U

-bend region 21 UGNR-SON2-RSG-038 Non-conformance Report Unacceptable local diameter change of tube holes ML12188A748 PA1-12 v), vi) Matter of detail on the TSP support restraint 22 UGNR-SON3-RSG-024 Non-conformance Report Some gaps between tubes and AVBs are larger than the criterion ML12188A748 PA1-12 viii) Matter of detail on the AVB degree of restraint 23 UGS-L5-050043 Anti-Vibration Bar Inspection Procedure (Individual Bar)

ML12188A748 PA1-12 v), vi) Could be pre

- or post-service inspection 24 UGS-L5-050045 Inspection Procedure for ML12188A748 v), vi) Could be pre

- or post-service Attachment 15 I TEM NRC/AIT REFERENCE DOCUMENT C ITATION IN AIT REPORT ALSB ISSUE COMMENTS Tube and Anti

-Vibration Bar Inspection PA1-12 inspection 25 UHH-G06A97 Stop Work Order for FMA (Final Mill Annealing) on Manufacturing of Heat Transfer Tubing for SONGS RSG ML12188A748 PA1-13 v) Could be tube manufacturing dimension compliance 26 SO23-617-01 Specification for Design and Fabrication of RSGs for Unit 2 and Unit 3 ML12188A748 PA1-13 v) Could indicate why and the approval of the dimensional changes instituted between the assembly of Unit 2 and 3 RSGs 27 SO23-617-02 Specification for Baseline Pre-Service Examination (PSE) on Tubing for Replacement Steam Generators ML12188A748 PA1-13 v) Could provide indication or evidence of tube geometry variations between the Units 2 and 3 RSGs 28 FSAR Updated Final Safety Analysis Report for San Onofre Units 2 and 3 April 2009 ML12188A748 PA1-13 iv) Important to determine which issue was in place at the time of the Unit 2 first start up and the Unit 3 forced shutdown 29 SMI-AQA-9041 Reply to Notice of Non

-conformance (99901 384/2009-201-01) ML12188A748 PA1-14 iv) Corrective measure implemented 30 SO23-617-1-M819 AVB Structure Assembly Procedure ML12188A748 PA1-16 v) Could provide indications of tolerancing and out

-of-plane (twisting) specification 31 SO23-617-1-M820 Tubing and AVB Installation Procedure ML12188A748 PA1-16 v) Matter of detail on the AVB degree of restraint 32 SO23-617-1-M821 Anti-Vibration Bar Inspection Procedure (After Assembly)

ML12188A748 PA1-16 v) Matter of detail on the AVB degree of restraint 33 51-9176667-001 Engineering Information Record, SONGS 2C17 & 3C17 Steam Generator Degradation Assessment ML12188A748 PA1-16 iv) Could indicate any similarity between OSGs and RSGs 34 UGNR-SON2-RSG-014 Discrepancy for tube thickness of TSP between Drawing and Purchase Specification ML12188A748 PA1-16 v) Could be tube manufacturing dimension non

-compliance 35 UGNR-SON2-RSG-058 Insufficient clearance between the tubes in Row N o. 28 and 30 in Column No. 22 ML12188A748 PA1-17 v) Could be tube manufacturing dimension or assembly non

-compliance 36 UGNR-SON2-RSG-059 Insufficient clearance between the tubes in Row N o 92 and 94 in Column No. ML12188A748 PA1-17 v) Could be tube manufacturing dimension or assembly non

-compliance

Attachment 16 I TEM NRC/AIT REFERENCE DOCUMENT C ITATION IN AIT REPORT ALSB ISSUE COMMENTS 34 37 UGNR-SON2-RSG-067 Unacceptable Gaps between Tubes and AVBs ML12188A748 PA1-17 v) Could be tube manufacturing dimension or assembly non

-compliance 38 UGNR-SON2-RSG-075 Unacceptable gaps between Tubes and AVBs ML12188A748 PA1-17 v) Could be tube manufacturing dimension or assembly non

-compliance 39 UGNR-SON3-RSG-024 Some Gaps between Tubes and AVBs are larger than the criterion ML12188A748 PA1-17 v) Could be tube manufacturing dimension or assembly non

-compliance 40 UGNR-SON3-RSG-030 Some gaps between tubes and AVBs are larger than the criterion ML12188A748 PA1-17 v) Could be tube manufacturing dimension or assembly non

-compliance 41 Fabrication Process Sheet 3901-SG-A-400E (Order 2563901/G101 Rework of AVB Insertion for SONGS Unit 2 Replacement Steam Generator #A Lower Portion ML12188A748 PA1-17 v) Could indicate inherent defect in assembly and/or assembly (insertion) procedure 42 NN 201843216 Root Cause Evaluation for Steam Generator Tube Wear SONGS 2 April 2, 2012 ML12318A342 SUPPLEMENTAL INFORMATION iv) This should be the complete SCE report being complete and more reliable than the present leaked report 43 SO23-617-1-M1520 Tube Wear of Unit 3 RSG

- Technical Evaluation Report ML12318A342 SUPPLEMENTAL INFORMATION iv), v), vi) There seems to be no similar evaluation report for Unit 2 44 SO23-617-1-M1310 Evaluation of PWHT ML12318A342 SUPPLEMENTAL INFORMATION v) Might relate to any weldments on the AVB and RB assemblies 4 5 DBD-SO23-365 SONGS Design Bases Document: Steam Generators and Secondary Side ML12318A342 SUPPLEMENTAL INFORMATION iv) Ambiguously titled 46 SO23-617-1-D781 Detail of Retaining Bar ML12318A342 SUPPLEMENTAL INFORMATION v) Matter of detail on the RB degree of restraint 47 51-9182368-002 AREVA - SONGS 2C17 Steam Generator Condition Monitoring Report ML12318A342 SUPPLEMENTAL INFORMATION iv), v) Ambiguously titled is this applicable to the OSG or RSG 48 SO23-617-1-M1265 Summary Design Report ML12318A342 SUPPLEMENTAL INFORMATION iv) Ambiguously titled 49 SO23-617-1-M1562 Retainer Bar Tube Wear Report ML12318A342 SUPPLEMENTAL iv), v) If for Units 2 and 3 RSGs than useful comparison of Attachment 17 I TEM NRC/AIT REFERENCE DOCUMENT C ITATION IN AIT REPORT ALSB ISSUE COMMENTS INFORMATION RB wear rates and advancement into slackening

-off phase for Unit 2 50 SO23-617-1-C749 Analytical Report of AVB Assembly ML12318A342 SUPPLEMENTAL INFORMATION v), vi) If for Units 2 and 3 RSGs than useful comparison of AVB wear rates and/or geometry (twisting, clearance, force loading, etc) and advancement into slackening-off phase for Unit 2 51 SO23-617-1-C1106 Thermal and Hydraulic Parametric Calculations ML12318A342 SUPPLEMENTAL INFORMATION iv) Could be the input parameters for either FIT

-III and/or ATHOS modelling 52 SO23-617-1-C683 Three-dimensional Thermal and Hydraulic Analysis (FIT-III Code Analysis)

ML12318A342 SUPPLEMENTAL INFORMATION iv) Could provide information about the shortfalls in FEI prediction of FIT

-III 53 SO23-617-1-C157 Evaluation of Tube vibration ML12318A342 SUPPLEMENTAL INFORMATION iv), v) Could include other modes of tube excitation as well as FEI 54 SO23-617-1-M1520 Tube Wear of Unit 3 RSG

-Technical Evaluation Report ML12318A342 SUPPLEMENTAL INFORMATION iv), v) If for Units 2 and 3 RSGs than useful comparison of tube wear rates and advancement into slackening

-off phase for Unit 2 55 SO23-617-1-M1530 Validity of Use of the FIT

-III Results during Design ML12318A342 SUPPLEMENTAL INFORMATION iv), v), vi) Could provide information about the shortfalls in FEI prediction of FIT

-III 56 SO23-61 7-1-M1231 Performance Analysis Report ML12318A342 SUPPLEMENTAL INFORMATION iv), v) Ambiguously titled 57 Attachment 12 Meeting Minutes of Design Review and Technical Meeting with MHI on Retainer Bar Design September 12

-15, 2006 ML12318A342 SUPPLEMENTAL INFORMATION This may be the precursor to the RB problems being recognized by SCE and/or MHI but with no effective action being taken subsequently.

58 Part Steam Generator Tube Wear Adjacent to Retainer Bars, October 5 2012, NRC Region 1, Defects and Non

-Compliance, 10 CFR NRC REGION 1 e-mail from MHI October 5 2012 This relates to a late submission by MHI directly to NRC stating the retainer bars to be unsafe and that these (smaller diameter RBs) should be removed.

Attachment 18 I TEM NRC/AIT REFERENCE DOCUMENT C ITATION IN AIT REPORT ALSB ISSUE COMMENTS 21.21(d)(3)(i) 59 SONGS RSG Project Meeting Notes October 23, 2009 ML12318A342 SUPPLEMENTAL INFORMATION These and all subsequent meeting notes between SCE and NRC should be disclosed 1 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD

) In the Matter of

) ) Docket Nos. 50

-361-CAL & 50-362-CAL SOUTHERN CALIFORNIA EDISON COMPANY

) ) (San Onofre Nuclear Generating Station, ) December 11 , 2012 Units 2 and 3)

) ) CERTIFICATE OF SERVICE I hereby certify that, on this date, a copy of Petitioners Motion to Amend the Proposed Scheduling Order and Clarify Scope of Disclosure was filed through the E

-Filing system.

Signed (electronically) by Richard Ayres Richard E. Ayres Jessica L. Olson Kristin Hines Gladd Ayres Law Group 1707 L St., N.W., Suite 850 Washington, D.C. 20036 Phone: 202

-452-9200 E-mail: ayresr@ayreslawgroup.com; olsonj@ayreslawgroup.com; gladdk@ayreslawgroup.com Counsel for Friends of the Earth