ML13037A112
| ML13037A112 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 01/31/2013 |
| From: | St.Onge R J Southern California Edison Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| TAC ME9727 | |
| Download: ML13037A112 (22) | |
Text
V SOUTHERN CALIFORNIAý 1EDISONAn EDISON INTERNATIONAL CompanyRichard I. St. OngeDirector, Nuclear Regulatory Affairs andEmergency PlanningProprietary InformationWithhold from Public DisclosureJanuary 31, 201310 CFR 50.4U.S. Nuclear Regulatory CommissionATTN: Document Control DeskWashington, DC 20555-0001Subject:Docket No. 50-361Response to Request for Additional Information (RAI 29)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 29.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 notarized affidavits from Mitsubishi Heavy Industries (MHI) andProprietary InformationWithhold from Public DisclosureP.O. Box 128 Decontrolled Upon Removal From Enclosure 2San Clemente, CA 92672ýaa Proprietary InformationWithhold from Public DisclosureDocument Control Desk-2-January 31, 2013Westinghouse Electric Company (WEC), which sets forth the basis on which the information inEnclosure 2 may be withheld from public disclosure by the NRC and addresses with specificitythe considerations listed by paragraph (b)(4) of 10 CFR 2.390. Proprietary information identifiedin Enclosure 2 was extracted from MHI Report L5-04GA585, "Analytical Evaluation forOperational Assessment," and from WEC Report LTG-SGDA-12-80, "San Onofre NuclearGenerating Station Unit 2 MHI Replacement Steam Generator Responses to RAI 29," which areaddressed in the affidavits. 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 29 (Proprietary)3. Response to RAI 29 (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 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 MHI technical documentation to determine whether it contains informationthat should be withheld from public disclosure pursuant to 10 C.F.R. § 2.390 (a)(4) astrade secrets and commercial or financial information that is privileged or confidential.2. In accordance with my responsibilities, I have determined that the following MHIdocuments and drawings contain MHI proprietary information that should be withheldfrom public disclosure pursuant to 10 C.F.R. § 2.390 (a)'(4),. The drawings in their entiretyare proprietary and those pages of the documents containing proprietary informationhave been bracketed with an open and closed bracket as shown here"[ ]" / and shouldbe withheld from public disclosure.MHI documents and drawingsDocument: L5-04GA561, L5-04GA564, L5-04GA571, L5-04GA585, L5-04GA591Drawings: L5-04FU101 thru 1083. The information identified as proprietary in the enclosed document has in the past been,and will continue to be, held in confidence by MHI and its disclosure outside thecompany is limited to regulatory bodies, customers and potential customers, and theiragents, suppliers, and licensees, and others with a legitimate need for the information,and is always subject to suitable measures to protect it from unauthorized use ordisclosure.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 2. dayof A&CO'L ,2012.Jinichi Miyaguchi,Director- Nuclear Plant Component Designing DepartmentMitsubishi Heavy Industries, LTD22 0 x.A 11 G 2 2' ,)] 2Sworn to and subscribedBefore me this -dayof A 3U St", 2012Notary PublicMy Commission Expires 3s X-- -------.-- --K k .-X ~ --Ri-_ -X- ______-- .- -, X-\ -X- 3, ,-_ _--) SN__A -__ -T-EXi>6 -X......... ._ .............4' / -,2/4>2.. ........ >>6~ ~~ ~~ ______________ ____5_ __44 -t-i............>............6>6.>IN-~~ -.>6.. ............... ..................... ....... ... ....-X.- -K )il ,z. .- --X. 1>....... ... .........'rL jj-rA ~[1: ~N ~
Registered Number 2 2 0 Date AUC, -2, 2012NOTARIAL CERTIFICATEThis is to certify that JINICHI MIYAGUCHI., Director-Nuclear PlantComponent Designing Department MITSUBISHI HEAVY INDUSTRIES, LTDhas affixed his signature in my very presence to the attacheddocument.MASAHIKO KUBOTANotary44 Akashimachi, Chuo-Ku,Kobe, japanKobe District Legal Affairs Bureau(f MiJM2)
CAW-13-3592AFFIDAVITCOMMONWEALTH 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: 21st day of January 2013Nota PublicCOMMONWEALTH OF PENNSYLVANIAI NOTARIAL SEAL IRenee Glampole, Notary PublicMPenn Township, Westmoreland County2[My commission Expires September 25, 2CAW-13-3592(1) I am Manager, Regulatory Compliance, in Nuclear Services, Westinghouse Electric* Company LLC (Westinghouse), and as such, I have been specifically delegated the function of* reviewing 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-13-3592Westinghouse'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-13-3592(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-12-80 P-Attachment, "San Onofre NuclearGenerating Station Unit 2 MIR Replacement Steam Generator Response to RAI 29,"dated January 21, 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-13-3592This information is part of that which will enable Westinghouse to:(a) Respond to Nuclear Regulatory Commission (NRC) Request for AdditionalInformation regarding stability ratios calculated for certain anti-vibration bar(AVB) support conditions for the San Onofre Nuclear Generating Station Unit 2steam 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-13-3592In 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.
ENCLOSURE 3SOUTHERN CALIFORNIA EDISONRESPONSE TO REQUEST FOR ADDITIONAL INFORMATIONREGARDING RESPONSE TO CONFIRMATORY ACTION LETTERDOCKET NO. 50-361TAC NO. ME 9727Response to RAI 29(NON-PROPRIETARY)Page 1 RAI 29Reference 5, Figures 2-12 and 2-13 -Provide similar figures for Case 78 (all A VBsmissing).RESPONSENote: Reference 5 is the Westinghouse Operational Assessment, SG-SGMP-12-10,Revision 3. Figures 2-12 and 2-13 of this report respectively contain the out-of-planeexcitation ratio and in-plane stability ratio maps for Case 60 (seven ineffective AVBsupports) at 70% power.The requested out-of-plane excitation ratio and in-plane stability ratio maps forWestinghouse Case 78 at 70% power are attached, representing the extreme conditionwhere all twelve anti-vibration bar (AVB) supports are ineffective. No Unit 2 steamgenerator tubes have this support condition; hence, there are no tubes with excitation orstability ratios as indicated in these figures. A comparison of in-plane stability ratioscalculated by Westinghouse and MHI shows that Westinghouse in-plane stability ratiosare higher for the hypothetical support condition represented by Case 78. However,over the range of actual AVB support conditions present in Unit 2 steam generators,in-plane stability ratios calculated by Westinghouse agree with those calculated by MHI.No Tubes in Unit 2 Have Twelve Ineffective AVB SupportsWestinghouse determined that there are no tubes in the Unit 2 steam generators withtwelve ineffective AVB supports from their review of the eddy current data forSG 2E-088 and SG 2E-089. The review included approximately 600 tubes inSG 2E-088 and approximately 800 tubes in SG 2E-089 with indications of tube-to-AVBwear. Westinghouse used the eddy current data to identify appropriate AVB supportcases for use in their flow-induced vibration (FIV) analysis. Defining ineffective AVBsupport locations as locations with AVB wear, Westinghouse determined the FIVanalysis case applicable to each tube according to the number of consecutiveineffective AVB support locations.The Westinghouse finding that there are no tubes in Unit 2 steam generators withtwelve ineffective AVB supports was independently corroborated by AREVA's analysisof probability of instability. For this analysis, AREVA performed Monte Carlosimulations of Unit 2 steam generators considering the variability of AVB supporteffectiveness at individual tube-to-AVB intersections in the steam generator. AREVAdetermined AVB support effectiveness from probabilistic distributions of tube-to-AVBPage 2 contact forces accounting for tube-to-AVB wear. The Monte Carlo simulations typicallyincluded 10,000 trials. Each trial individually modeled all tubes susceptible to in-planefluid-elastic instability at 100% power (the model included approximately 1/5 of thebundle) and probabilistically sampled the number of effective AVB supports at a givenoperating time. To envelop conditions for the next Unit 2 operating interval, separateMonte Carlo simulations were performed at the beginning of cycle and at 6 months afterthe beginning of cycle. AREVA has reviewed these simulations and determined thatthere were no instances of a tube with twelve ineffective AVB supports in any of the20,000 trials contained in these two simulations. AREVA's results demonstrate thatthere is no significant likelihood of Unit 2 steam generators having any tubes with theextreme AVB support condition represented by Case 78 at any time during the nextoperating interval.Comparison between Westinghouse and MHI In-Plane Stability Ratio ResultsWestinghouse compared the input parameters and methodology of their in-plane FIVanalysis to the corresponding elements of MHI's FIV. Differences between the methodsinclude:1) Differences in thermal-hydraulic calculation methods: Westinghouse usesproprietary ATHOS pre-processors and post-processors. MHI uses theEPRI-standard version of ATHOS.2) Differences in Connors' coefficient:3) Differences in calculation of effective velocity: Westinghouse's approachconservatively maximizes the energy added to the tube by considering theresultant velocity normal to the tube axis while minimizing the energyremoved by considering the velocity component in the direction of tubedisplacement. MHI's method calculates energy added to the tube usingthe component velocity in the direction of tube displacement andconsiders energy removed both axial and normal to the tube axis over thefull length of the tube.4) Differences in damping ratio:Page 3 Figure 1 shows the overall effect of these differences in input parameters andmethodology by comparing 100% power in-plane stability ratios calculated by MHI andWestinghouse for nine representative tube locations, considering the number ofineffective AVB supports to be the study parameter. With fewer than ten ineffectiveAVB supports, the two methods show reasonable agreement, both in the values ofin-plane stability ratio and in the rate of change in in-plane stability ratio with increasingnumber of ineffective AVB supports. MHI results are consistently conservativecompared to Westinghouse results in this range. However, for twelve ineffective AVBsupports, Westinghouse in-plane stability ratios for tubes above Row 100 are higherthan MHI in-plane stability ratios.Figure 2 compares MHI and Westinghouse in-plane stability ratios at 70% power. Withfewer than eight ineffective AVB supports, the two methods continue to agree. Thesame divergence at higher numbers of ineffective AVB supports observed at 100%power is also present at 70% power, affecting the in-plane stability ratios with greaterthan eight ineffective AVB supports.Page 4 aPage 5 The following table compares the Westinghouse and MHI in-plane stability ratios for the] tubes in Unit 2 with this support condition. The MHI in-plane stability ratios forthese support conditions are higher than the Westinghouse in-plane stability ratios.Figures 1 and 2 demonstrate that in-plane stability ratios for all remaining Unit 2 tubes,which have fewer than eight ineffective AVB supports, follow a similar pattern.Over the range of actual AVB support conditions present in Unit 2 steam generators,in-plane stability ratios calculated by Westinghouse agree with those calculated by MHI.Number ofTube Ineffective In-plane Stability Ratio at 70% PowerLocation SG AVB Supports Westinghouse MHI+ I I-4- I 4Page 6 Page 7 Page 8