ML13182A288: Difference between revisions

From kanterella
Jump to navigation Jump to search
(Created page by program invented by StriderTol)
(StriderTol Bot change)
 
(2 intermediate revisions by the same user not shown)
Line 16: Line 16:


=Text=
=Text=
{{#Wiki_filter:SOUTHERN CALIFORNIA EDISON'An EDISON Company Proprietary Information Withhold from Public Disclosure Douglas R. Bauder Site Vice President  
{{#Wiki_filter:I*
& Station Manager San Onofre Nuclear Generating Station 1 0CFR50.71 (e)June 7, 2013 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555  
SOUTHERN CALIFORNIA EDISON' An EDISON INTERNATIONAL0* Company Proprietary Information Withhold from Public Disclosure Douglas R. Bauder Site Vice President & Station Manager San Onofre Nuclear Generating Station 1 0CFR50.71 (e)
June 7, 2013 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555


==Subject:==
==Subject:==
Line 23: Line 24:


==Subject:==
==Subject:==
Docket Nos. 50-361 and 50-362, Updated Final Safety Analysis Report and Updated Fire Hazard Analysis, Revised April 2009, San Onofre Nuclear Generating Station, Units 2 and 3  
Docket Nos. 50-361 and 50-362, Updated Final Safety Analysis Report and Updated Fire Hazard Analysis, Revised April 2009, San Onofre Nuclear Generating Station, Units 2 and 3


==Reference:==
==Reference:==
==Dear Sir or Madam:==
==Dear Sir or Madam:==
In accordance with the requirements of 10 CFR 50.71(e), Southern California Edison hereby submits the biennial revisions to the Updated Final Safety Analysis Report (UFSAR) and the Updated Fire Hazard Analysis (UFHA), for San Ondfre Nuclear Generating Station (SONGS), Units 2 and 3.In addition, as required by 10 CFR 50.54(a), an update to the Quality Assurance Program Description for San Onofre Units 1, 2, and 3 is provided in accordance with 10 CFR 50.71(e).Topical Report, Quality Assurance Program SCE-1 is incorporated as Chapter 17 of the UFSAR with changes identified by change bars. A summary of the changes to the Topical Report, Quality Assurance Program SCE-1 since the last submittal, is provided in Attachment 1.Both updates are being provided within 24 months following the last update (Reference).
In accordance with the requirements of 10 CFR 50.71(e), Southern California Edison hereby submits the biennial revisions to the Updated Final Safety Analysis Report (UFSAR) and the Updated Fire Hazard Analysis (UFHA), for San Ondfre Nuclear Generating Station (SONGS),
Units 2 and 3.
In addition, as required by 10 CFR 50.54(a), an update to the Quality Assurance Program Description for San Onofre Units 1, 2, and 3 is provided in accordance with 10 CFR 50.71(e).
Topical Report, Quality Assurance Program SCE-1 is incorporated as Chapter 17 of the UFSAR with changes identified by change bars. A summary of the changes to the Topical Report, Quality Assurance Program SCE-1 since the last submittal, is provided in Attachment 1.
Both updates are being provided within 24 months following the last update (Reference).
Enclosures 1 and 2 are compact disks (CD) containing the SONGS Units 2 and 3 UFSAR and UFHA. To denote the changes from the previous submittals, a vertical change bar is located in the page margin adjacent to the revised information.
Enclosures 1 and 2 are compact disks (CD) containing the SONGS Units 2 and 3 UFSAR and UFHA. To denote the changes from the previous submittals, a vertical change bar is located in the page margin adjacent to the revised information.
The Enclosure 1 CD of this submittal contains information that is proprietary.
The Enclosure 1 CD of this submittal contains information that is proprietary. SCE requests that this proprietary Enclosure be withheld from public disclosure in accordance with 10 CFR 2.390(a)(4). Attachment 2 provides the notarized affidavit which set forth the basis on which the information in Enclosure 1 may be withheld from public disclosure by the Commission and addresses with specificity the considerations listed by paragraph (b)(4) of 10 CFR 2.390. CD contains the files listed in Attachment 3.
SCE requests that this proprietary Enclosure be withheld from public disclosure in accordance with 10 CFR 2.390(a)(4).
P.O. Box 128 San Clemente, CA 92672 (949) 368-9275 PAX 89275 Fax: (949) 368-9881 Doug.Bauder@sce.com Proprietary Information Withhold from Public Disclosure Decontrolled Upon Removal of Enclosure 1 D5-ýý 0 Pf, F-'w-
Attachment 2 provides the notarized affidavit which set forth the basis on which the information in Enclosure 1 may be withheld from public disclosure by the Commission and addresses with specificity the considerations listed by paragraph (b)(4) of 10 CFR 2.390.Enclosure 1 CD contains the files listed in Attachment 3.P.O. Box 128 San Clemente, CA 92672 (949) 368-9275 PAX 89275 Fax: (949) 368-9881 Doug.Bauder@sce.com Proprietary Information Withhold from Public Disclosure Decontrolled Upon Removal of Enclosure 1 D5-ýý0 Pf, F-'w-Proprietary Information Withhold from Public Disclosure Document Control Desk-2-June 7, 2013 Enclosure 2 provides the non-proprietary version of Enclosure
 
: 1. Enclosure 2 contains information that is deemed sensitive and the files on the CD are requested to be withheld from public disclosure in accordance with 10 CFR 2.390. Enclosure 2 CD contains the files listed in Attachment 4.There are no commitments contained in this letter or its enclosures.
Proprietary Information Withhold from Public Disclosure Document Control Desk June 7, 2013 provides the non-proprietary version of Enclosure 1. Enclosure 2 contains information that is deemed sensitive and the files on the CD are requested to be withheld from public disclosure in accordance with 10 CFR 2.390. Enclosure 2 CD contains the files listed in.
Should there be any questions regarding this submittal, please contact Mr. Mark Morgan, Licensing Lead, at (949) 368-6745.I declare under penalty of perjury that the foregoing is true and correct.(a//o3 Executed on By: _ _ _ _ _ _ _ _ _ _ _ouglas Bauder Site Vice President and Station Manager Attachment 1: Attachment 2: Attachment 3: Attachment 4: Enclosure 1: Enclosure 2: Summary of changes in the Topical Report Quality Assurance Program SCE-1 since the last submittal Notarized Affidavit Listing of Enclosure 1 SONGS Units 2 and 3 UFSAR and UFHA files, Proprietary Listing of Enclosure 2 SONGS Units 2 and 3 UFSAR and UFHA files, Non-Proprietary Proprietary Enclosure (Compact Disk -San Onofre Nuclear Generating Station, SONGS 2 & 3, UFSAR and UFHA, Amended May 2013)Non-Proprietary Enclosure (Compact Disk -San Onofre Nuclear Generating Station, SONGS 2 & 3, UFSAR and UFHA, Amended May 2013)cc: A. T. Howell III, Regional Administrator, NRC Region IV R. Hall, NRC Project Manager, SONGS Units 2 and 3 B. Benney, NRC Project Manager, SONGS Units 2 and 3 G. G. Warnick, NRC Senior Resident Inspector, SONGS Units 2 and 3 S. Y. Hsu, California Department of Public Health, Radiologic Health Branch Proprietary Information Withhold from Public Disclosure Decontrolled Upon Removal of Enclosure 1
There are no commitments contained in this letter or its enclosures.
Should there be any questions regarding this submittal, please contact Mr. Mark Morgan, Licensing Lead, at (949) 368-6745.
I declare under penalty of perjury that the foregoing is true and correct.
(a//o3 Executed on By:
ouglas Bauder Site Vice President and Station Manager : : : : : :
Summary of changes in the Topical Report Quality Assurance Program SCE-1 since the last submittal Notarized Affidavit Listing of Enclosure 1 SONGS Units 2 and 3 UFSAR and UFHA files, Proprietary Listing of Enclosure 2 SONGS Units 2 and 3 UFSAR and UFHA files, Non-Proprietary Proprietary Enclosure (Compact Disk - San Onofre Nuclear Generating Station, SONGS 2 & 3, UFSAR and UFHA, Amended May 2013)
Non-Proprietary Enclosure (Compact Disk - San Onofre Nuclear Generating Station, SONGS 2 & 3, UFSAR and UFHA, Amended May 2013) cc: A. T. Howell III, Regional Administrator, NRC Region IV R. Hall, NRC Project Manager, SONGS Units 2 and 3 B. Benney, NRC Project Manager, SONGS Units 2 and 3 G. G. Warnick, NRC Senior Resident Inspector, SONGS Units 2 and 3 S. Y. Hsu, California Department of Public Health, Radiologic Health Branch Proprietary Information Withhold from Public Disclosure Decontrolled Upon Removal of Enclosure 1
 
Attachment I Summary of changes to the Topical Report Quality Assurance Program SCE-1, since the last submittal:
Attachment I Summary of changes to the Topical Report Quality Assurance Program SCE-1, since the last submittal:
: 1. Changed TR Section 17.2.1.1, Scope, from stations to station.2. Changed TR Section 17.2.1.2, Responsibilities, to delete 17.2-1, 17.2-1 B, 17.2-1 C, and contain within single figure 17.2.1A.3. Changed TR Section 17.2.1.2, Responsibilities, to assign responsibly from Chief Executive Officer to SCE President.
: 1. Changed TR Section 17.2.1.1, Scope, from stations to station.
: 4. Changed TR Section 17.2.1.2, Responsibilities, to reflect the new reporting structure of station management to include, projects, nuclear safety culture, nuclear regulatory affairs and emergency planning, leadership and organizational effectiveness, nuclear strategic projects.5. Removed TR Section 17.2.1.2.1, Engineering and Technical Services and moved responsibilities for Engineering to section 17.2.1.2.2
: 2. Changed TR Section 17.2.1.2, Responsibilities, to delete 17.2-1, 17.2-1 B, 17.2-1 C, and contain within single figure 17.2.1A.
: 3. Changed TR Section 17.2.1.2, Responsibilities, to assign responsibly from Chief Executive Officer to SCE President.
: 4. Changed TR Section 17.2.1.2, Responsibilities, to reflect the new reporting structure of station management to include, projects, nuclear safety culture, nuclear regulatory affairs and emergency planning, leadership and organizational effectiveness, nuclear strategic projects.
: 5. Removed TR Section 17.2.1.2.1, Engineering and Technical Services and moved responsibilities for Engineering to section 17.2.1.2.2
: 6. Changed TR section 17.2.1.2.2, Site Management, to TR section 17.2.1.2.1, Station Management
: 6. Changed TR section 17.2.1.2.2, Site Management, to TR section 17.2.1.2.1, Station Management
: 7. Changed TR section 17.2.1.2.2, Site Management, to TR 17.2.1.2.1, Station Management include responsibility of Vice President  
: 7. Changed TR section 17.2.1.2.2, Site Management, to TR 17.2.1.2.1, Station Management include responsibility of Vice President & Station Manager.
& Station Manager.8. Changed TR section 17.2.1.2.2, Site Management, to TR 17.2.1.2.1, Station Management to reflect the new reporting structure to the Vice President  
: 8. Changed TR section 17.2.1.2.2, Site Management, to TR 17.2.1.2.1, Station Management to reflect the new reporting structure to the Vice President & Station Manager to remove, health physics, construction, testing, chemistry, and refueling, and to include radiation protection/health physics, chemistry and environmental, human performance and industrial safety, training, security and performance improvement.
& Station Manager to remove, health physics, construction, testing, chemistry, and refueling, and to include radiation protection/health physics, chemistry and environmental, human performance and industrial safety, training, security and performance improvement.
Added Fire Protection services and removed Independent Technical Review program and Nuclear Training functions, and handling and storage of material and equipment.
Added Fire Protection services and removed Independent Technical Review program and Nuclear Training functions, and handling and storage of material and equipment.
: 9. Changed TR section 17.2.1.2.2, Site Management, to TR 17.2.1.2.1, Station Management to reassign responsibilities to the Station Manager from the Plant Manager.10. Changed TR section 17.2.1.2.1, Engineering and Technical Services to TR section 17.2.1.2.2 to Engineering, Projects, and site Support Services, added engineering systems, programs, design, nuclear fuel management, projects and site support services (material support, documentation services, and facilities management.)
: 9. Changed TR section 17.2.1.2.2, Site Management, to TR 17.2.1.2.1, Station Management to reassign responsibilities to the Station Manager from the Plant Manager.
: 10. Changed TR section 17.2.1.2.1, Engineering and Technical Services to TR section 17.2.1.2.2 to Engineering, Projects, and site Support Services, added engineering systems, programs, design, nuclear fuel management, projects and site support services (material support, documentation services, and facilities management.)
: 11. Changed TR section 17.2.1.2.3, Site Support (moved to 17.2.1.2.2), to Nuclear Regulatory Affairs & Emergency Planning and defined responsibilities.
: 11. Changed TR section 17.2.1.2.3, Site Support (moved to 17.2.1.2.2), to Nuclear Regulatory Affairs & Emergency Planning and defined responsibilities.
: 12. Changed TR section 17.2.1.2.4, Nuclear Oversight to Nuclear Strategic Projects and defined responsibilities.
: 12. Changed TR section 17.2.1.2.4, Nuclear Oversight to Nuclear Strategic Projects and defined responsibilities.
Attachment 1 Pg 1 of 3
Pg 1 of 3
: 13. Changed TR section 17.2.1.2.5 Performance Improvement to Nuclear Oversight and changed manager and supervisors to managers only.14. Moved TR section 17.2.1.2.5, Performance Improvement, to 17.2.1.2.1 to reflect new reporting structure to the Vice President and Station Manager.15. Removed TR section 17.2.1.2.6 Nuclear Regulatory Affairs, and included responsibilities in section 17.2.1.2.3
: 13. Changed TR section 17.2.1.2.5 Performance Improvement to Nuclear Oversight and changed manager and supervisors to managers only.
: 14. Moved TR section 17.2.1.2.5, Performance Improvement, to 17.2.1.2.1 to reflect new reporting structure to the Vice President and Station Manager.
: 15. Removed TR section 17.2.1.2.6 Nuclear Regulatory Affairs, and included responsibilities in section 17.2.1.2.3
: 16. Changed TR section 17.2.1.2.7, Other Organizations, to Other Corporate SCE Organizations to 17.2.1.2.6.
: 16. Changed TR section 17.2.1.2.7, Other Organizations, to Other Corporate SCE Organizations to 17.2.1.2.6.
: 17. Changed TR section 17.2.1.2.6, Other Organizations, Shop Services and Instrumentation Department to include 'nuclear' before station and to change division managers to station management; removed the Manager OS SCM and Senior vice President, Safety, Operations support and chief Procurement Officer and added SCE Corporate Management; Removed Director, Site Support and added management responsible for site support services; Added responsibilities for Nuclear Procurement; Removed responsibilities for Business Resources to Corporate Records Center and added reporting structure to SCE Corporate Management, company records and an interfacing responsibility with site support services related to long term storage of nuclear records; Removed Business Integration from title of Information Technology and added responsibilities for managing, computing system and network.18. Changed TR section 17.2.1.4, Reporting, to reflect regular reporting to the SCE President and Chief Nuclear Officer on the adequacy of the SCE Quality Assurance Program.19. Changed TR section 17.2.4.2, Procurement Document Control, to add Nuclear before Procurement and to assign Procurement documents for Nuclear Fuel responsibilities to Engineering.
: 17. Changed TR section 17.2.1.2.6, Other Organizations, Shop Services and Instrumentation Department to include 'nuclear' before station and to change division managers to station management; removed the Manager OS SCM and Senior vice President, Safety, Operations support and chief Procurement Officer and added SCE Corporate Management; Removed Director, Site Support and added management responsible for site support services; Added responsibilities for Nuclear Procurement; Removed responsibilities for Business Resources to Corporate Records Center and added reporting structure to SCE Corporate Management, company records and an interfacing responsibility with site support services related to long term storage of nuclear records; Removed Business Integration from title of Information Technology and added responsibilities for managing, computing system and network.
: 20. Changed TR section17.2.5.2, Instructions, Procedures, and Drawings, second paragraph, to define procedure reviews will be performed by Nuclear Oversight personnel during periodic audits and to add, prior to issuance, determination of the adequacy of the quality control requirements to verify implementation of these requirements.
: 18. Changed TR section 17.2.1.4, Reporting, to reflect regular reporting to the SCE President and Chief Nuclear Officer on the adequacy of the SCE Quality Assurance Program.
Removed from third paragraph responsibility for review by Nuclear Oversight personnel documents prepared by outside contractors.
: 19. Changed TR section 17.2.4.2, Procurement Document Control, to add Nuclear before Procurement and to assign Procurement documents for Nuclear Fuel responsibilities to Engineering.
: 20. Changed TR section17.2.5.2, Instructions, Procedures, and Drawings, second paragraph, to define procedure reviews will be performed by Nuclear Oversight personnel during periodic audits and to add, prior to issuance, determination of the adequacy of the quality control requirements to verify implementation of these requirements. Removed from third paragraph responsibility for review by Nuclear Oversight personnel documents prepared by outside contractors.
: 21. Changed TR section 17.2.14.2, Inspection, Test and Operating Status, to assign responsibility to a Nuclear Oversight manager rather than a supervisor.
: 21. Changed TR section 17.2.14.2, Inspection, Test and Operating Status, to assign responsibility to a Nuclear Oversight manager rather than a supervisor.
: 22. Changed TR section 17.2.15.2, Nonconforming Materials, parts or Components, to clarify how Management representatives review and assess Nuclear Notifications and or Condition Reports. Conditions adverse to quality also added for clarification.
: 22. Changed TR section 17.2.15.2, Nonconforming Materials, parts or Components, to clarify how Management representatives review and assess Nuclear Notifications and or Condition Reports. Conditions adverse to quality also added for clarification.
Nonconformances processed through Nuclear Oversight through the use of Vendor Corrective Action Request process. Added the word pervasive to clarify specific Attachment 1 Pg 2 of 3 programmatic weaknesses.
Nonconformances processed through Nuclear Oversight through the use of Vendor Corrective Action Request process. Added the word pervasive to clarify specific Pg 2 of 3
Added nonconformances of unusual complexity or involvement may be submitted to the Onsite Review Committee for review.23. Changed TR section 17.2.16.2, Corrective Action, to clarify conditions adverse to quality.24. Changed TR section 17.2.16.2.1, Site Activities, to reference Condition Reports in addition to Nuclear Notifications.
 
Added pervasive to further clarify specific trends.25. Changed TR section 17.2.17.2, Quality Assurance Records, added Condition Reports, Cause Evaluations, Corrective Actions, and Effectiveness Reviews to be included as a quality record.26. Changed TR section 17.2.18.2, Audits, added Nuclear Oversight to perform. Moved Safeguards Contingency Plan from at least once per 24 months to at least once per 12 months for the audit period and added Emergency Plan to at least once per 12 months.27. Changed TR section 17.2.19.1, Organization, defined organizational responsibilities for fire protection, fire protection engineering and design and configuration, fire protection program materials, equipment and services.28. Changed TR section 17.2.20.2.2, Composition, added Radiation Protection to Health Physics and clarified Engineering.
programmatic weaknesses. Added nonconformances of unusual complexity or involvement may be submitted to the Onsite Review Committee for review.
: 23. Changed TR section 17.2.16.2, Corrective Action, to clarify conditions adverse to quality.
: 24. Changed TR section 17.2.16.2.1, Site Activities, to reference Condition Reports in addition to Nuclear Notifications. Added pervasive to further clarify specific trends.
: 25. Changed TR section 17.2.17.2, Quality Assurance Records, added Condition Reports, Cause Evaluations, Corrective Actions, and Effectiveness Reviews to be included as a quality record.
: 26. Changed TR section 17.2.18.2, Audits, added Nuclear Oversight to perform. Moved Safeguards Contingency Plan from at least once per 24 months to at least once per 12 months for the audit period and added Emergency Plan to at least once per 12 months.
: 27. Changed TR section 17.2.19.1, Organization, defined organizational responsibilities for fire protection, fire protection engineering and design and configuration, fire protection program materials, equipment and services.
: 28. Changed TR section 17.2.20.2.2, Composition, added Radiation Protection to Health Physics and clarified Engineering.
: 29. Changed TR section 17.2.20.2.6, Responsibilities, added responsibility for review of significant nonconformances of unusual complexity or involvement to the Onsite Review Committee.
: 29. Changed TR section 17.2.20.2.6, Responsibilities, added responsibility for review of significant nonconformances of unusual complexity or involvement to the Onsite Review Committee.
: 30. Changed TR section 17.2.20.3.1, Activities, (f) assigned responsibility for review of the Physical Security Plan to Security and the Site Emergency Plan to Nuclear Regulatory Affairs. Deleted item j reference to 17.2.20.5.
: 30. Changed TR section 17.2.20.3.1, Activities, (f) assigned responsibility for review of the Physical Security Plan to Security and the Site Emergency Plan to Nuclear Regulatory Affairs. Deleted item j reference to 17.2.20.5.
: 31. Changed TR section 17.2.20.5.2, Lifetime Quality Assurance Records, clarified records of inservice inspections performed as required by the Inservice Inspection Program procedures.
: 31. Changed TR section 17.2.20.5.2, Lifetime Quality Assurance Records, clarified records of inservice inspections performed as required by the Inservice Inspection Program procedures.
: 32. Changed TR section 17.2.20.6, Working Hours, added 10CFR 26.205 and removed the requirement for any deviation from the working hour guidelines to be in accordance with the Technical Specifications as the requirements no longer reside in the Technical Specifications.
: 32. Changed TR section 17.2.20.6, Working Hours, added 10CFR 26.205 and removed the requirement for any deviation from the working hour guidelines to be in accordance with the Technical Specifications as the requirements no longer reside in the Technical Specifications.
: 33. Changed TR Table 17.2.1, added 1OCFR26.205  
: 33. Changed TR Table 17.2.1, added 10CFR26.205 - Working Hours.
-Working Hours.Attachment 1 Pg 3 of 3 Attachment 2 NOTARIZED AFFIDAVIT W sig s Westinghouse Electric Company Nuclear Services 1000 Westinghouse Drive Cranberry Township, Pennsylvania 16066 USA U.S. Nuclear Regulatory Commission Direct tel: (412) 374-4643 Document Control Desk Direct fax: (724) 720-0754 11555 Rockville Pike e-mail: greshaja@westinghouse.com Rockville, MD 20852 Proj letter: CONO-13-36 CAW-13-3689 April 18, 2013 APPLICATION FOR WITHHOLDING PROPRIETARY INFORMATION FROM PUBLIC DISCLOSURE
Pg 3 of 3 NOTARIZED AFFIDAVIT
 
W sig s
Westinghouse Electric Company Nuclear Services 1000 Westinghouse Drive Cranberry Township, Pennsylvania 16066 USA U.S. Nuclear Regulatory Commission Direct tel: (412) 374-4643 Document Control Desk Direct fax: (724) 720-0754 11555 Rockville Pike e-mail: greshaja@westinghouse.com Rockville, MD 20852 Proj letter: CONO-13-36 CAW-13-3689 April 18, 2013 APPLICATION FOR WITHHOLDING PROPRIETARY INFORMATION FROM PUBLIC DISCLOSURE


==Subject:==
==Subject:==
Drawings: 1. 10050E91, Rev. 10, "SONGS Unit 2 Reactor Vessel Simplified Head Assembly Top Plate Grid Assembly" (Proprietary)
Drawings:
: 2. 10056E01, Rev. 2, "SONGS Unit 2 Reactor Vessel Simplified Head Assembly Head Assembly Package Field Assembly" (Proprietary)
: 1. 10050E91, Rev. 10, "SONGS Unit 2 Reactor Vessel Simplified Head Assembly Top Plate Grid Assembly" (Proprietary)
: 2.
10056E01, Rev. 2, "SONGS Unit 2 Reactor Vessel Simplified Head Assembly Head Assembly Package Field Assembly" (Proprietary)
: 3. E-1370-163-001, Rev. 09, "Magnetic Jack Assy" (Proprietary)
: 3. E-1370-163-001, Rev. 09, "Magnetic Jack Assy" (Proprietary)
: 4. E-1370-165-3 10, Rev. 09, Sheet I of 2, "In-Core Instrumentation Flange Assys" (Proprietary)
: 4.
: 5. E-1370-165-3 10 , Rev. 09, Sheet 2 of 2, "In-Core Instrumentation Flange Assys" (Proprietary)
E-1370-165-3 10, Rev. 09, Sheet I of 2, "In-Core Instrumentation Flange Assys" (Proprietary)
: 5. E-1370-165-3 10, Rev. 09, Sheet 2 of 2, "In-Core Instrumentation Flange Assys" (Proprietary)
: 6. J-1370-165-502, Rev. 05, "HJTC Probe Installation" (Proprietary)
: 6. J-1370-165-502, Rev. 05, "HJTC Probe Installation" (Proprietary)
: 7. E- 1470-165-310, Rev. 05, "In-Core Instrumentation Flange Assy" (Proprietary)
: 7. E-1470-165-310, Rev. 05, "In-Core Instrumentation Flange Assy" (Proprietary)
The proprietary information for which withholding is being requested in the above-referenced drawings is further identified in Affidavit CAW-13-3689 signed by the owner of the proprietary information, Westinghouse Electric Company LLC. The affidavit, which accompanies this letter, sets forth the basis on which the information may be withheld from public disclosure by the Commission and addresses with specificity the considerations listed in paragraph (b)(4) of 10 CFR Section 2.390 of the Commission's regulations.
The proprietary information for which withholding is being requested in the above-referenced drawings is further identified in Affidavit CAW-13-3689 signed by the owner of the proprietary information, Westinghouse Electric Company LLC. The affidavit, which accompanies this letter, sets forth the basis on which the information may be withheld from public disclosure by the Commission and addresses with specificity the considerations listed in paragraph (b)(4) of 10 CFR Section 2.390 of the Commission's regulations.
The subject drawings were prepared and classified as Westinghouse Proprietary Class 2. Westinghouse requests that the drawings be considered proprietary in their entirety.
The subject drawings were prepared and classified as Westinghouse Proprietary Class 2. Westinghouse requests that the drawings be considered proprietary in their entirety. As such, non-proprietary versions will not be issued.
As such, non-proprietary versions will not be issued.Accordingly, this letter authorizes the utilization of the accompanying affidavit by Southern California Edison.
Accordingly, this letter authorizes the utilization of the accompanying affidavit by Southern California Edison.
CAW-13-3689 Page 2 of 2 Correspondence with respect to the proprietary aspects of the application for withholding or the Westinghouse affidavit should reference CAW-13-3689 and should be addressed to James A. Gresham, Manager, Regulatory Compliance, Westinghouse Electric Company, Suite 428, 1000 Westinghouse Drive, Cranberry Township, Pennsylvania 16066.Very truly yours, si Manager Regulatory Compliance Enclosures CAW-1 3-3689 AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA:
 
ss COUNTY OF BUTLER: Before me, the undersigned authority, personally appeared James A. Gresham, who, being by me duly sworn according to law, deposes and says that he is authorized to execute this Affidavit on behalf of Westinghouse Electric Company LLC (Westinghouse), and that the averments of fact set forth in this Affidavit are true and correct to the best of his knowledge, information, and belief: Jame-es A. Gresham, Manager Regulatory Compliance Sworn to and subscribed before me this I 'day of April 201 Notary Public COMMONWEALTH OF PENNSYLVANIA I Notarial Seal I Anne M. Stegman, Notary Public Unity Twp., Westmomland ounty SMy Commission Expires Aug, 7, 2016 MmBF.R PENNSYLVANIA ASSOCIATION OF NOTARIEs 2 CAW-13-3689 (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 connection with nuclear power plant licensing and rule making proceedings, and am authorized to apply for its withholding on behalf of Westinghouse.
CAW-13-3689 Page 2 of 2 Correspondence with respect to the proprietary aspects of the application for withholding or the Westinghouse affidavit should reference CAW-13-3689 and should be addressed to James A. Gresham, Manager, Regulatory Compliance, Westinghouse Electric Company, Suite 428, 1000 Westinghouse Drive, Cranberry Township, Pennsylvania 16066.
(2) I am making this Affidavit in conformance with the provisions of 10 CFR Section 2.390 of the Commission's regulations and in conjunction with the Westinghouse Application for Withholding Proprietary Information from Public Disclosure accompanying this Affidavit.
Very truly yours, si Manager Regulatory Compliance Enclosures
(3) I have personal knowledge of the criteria and procedures utilized by Westinghouse in designating information 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 the information 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 held in confidence by Westinghouse.(ii) The information is of a type customarily held in confidence by Westinghouse and not customarily disclosed to the public. Westinghouse has a rational basis for determining the 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 in confidence.
CAW-1 3-3689 AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA:
The application of that system and the substance of that system constitutes Westinghouse policy and provides the rational basis required.Under that system, information is held in confidence if it falls in one or more of several types, the release of which might result in the loss of an existing or potential competitive advantage, 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 3 CAW-13-3689 Westinghouse's competitors without license from Westinghouse constitutes a competitive economic advantage over other companies.(b) It consists of supporting data, including test data, relative to a process (or component, structure, tool, method, etc.), the application of which data secures a competitive economic advantage, e.g., by optimization or improved marketability.(c) Its use by a competitor would reduce his expenditure of resources or improve his competitive position in the design, manufacture, shipment, installation, assurance of quality, or licensing a similar product.(d) It reveals cost or price information, production capacities, budget levels, or commercial strategies of Westinghouse, its customers or suppliers.(e) It reveals aspects of past, present, or future Westinghouse or customer funded development plans and programs of potential commercial value to Westinghouse.(f) It contains patentable ideas, for which patent protection may be desirable.
ss COUNTY OF BUTLER:
There are sound policy reasons behind the Westinghouse system which include the following: (a) The use of such information by Westinghouse gives Westinghouse a competitive advantage over its competitors.
Before me, the undersigned authority, personally appeared James A. Gresham, who, being by me duly sworn according to law, deposes and says that he is authorized to execute this Affidavit on behalf of Westinghouse Electric Company LLC (Westinghouse), and that the averments of fact set forth in this Affidavit are true and correct to the best of his knowledge, information, and belief:
It is, therefore, withheld from disclosure to protect the Westinghouse competitive position.(b) It is information that is marketable in many ways. The extent to which such information is available to competitors diminishes the Westinghouse ability to sell products and services involving the use of the information.(c) Use by our competitor would put Westinghouse at a competitive disadvantage by reducing his expenditure of resources at our expense.
Jame-es A. Gresham, Manager Regulatory Compliance Sworn to and subscribed before me this I 'day of April 201 Notary Public COMMONWEALTH OF PENNSYLVANIA I
4 CAW-13-3689 (d) Each component of proprietary information pertinent to a particular competitive advantage is potentially as valuable as the total competitive advantage.
Notarial Seal I
If competitors acquire components of proprietary information, any one component may be the key to the entire puzzle, thereby depriving Westinghouse of a competitive advantage.(e) Unrestricted disclosure would jeopardize the position of prominence of Westinghouse in the world market, and thereby give a market advantage to the competition of those countries.(f) The Westinghouse capacity to invest corporate assets in research and development depends upon the success in obtaining and maintaining a competitive advantage.(iii) The information is being transmitted to the Commission in confidence and, under the provisions of 10 CFR Section 2.390, it is to be received in confidence by the Commission.(iv) The information sought to be protected is not available in public sources or available information has not been previously employed in the same original manner or method to the best of our knowledge and belief.(v) The proprietary information sought to be withheld in this submittal is that which is appropriately marked in Westinghouse drawings:
Anne M. Stegman, Notary Public Unity Twp., Westmomland ounty SMy Commission Expires Aug, 7, 2016 MmBF.R PENNSYLVANIA ASSOCIATION OF NOTARIEs
10050E9 1, Rev. 10; 10056E01, Rev. 2, E-1370-163-001, Rev. 09; E-1370-165-310, Rev. 09; E-1370-165-310, Rev. 09; J-1370-165-502, Rev. 05; and E-1470-165-3 10, Rev. 05, for submittal to the Commission, being transmitted by Southern California Edison (SCE) Letter and Application for Withholding Proprietary Information from Public Disclosure, to the Document Control Desk. The proprietary information as submitted by Westinghouse is that which is associated with the designs of the San Onofre Nuclear Generating Station (SONGS) Units 2 and 3 Reactor Vessel Simplified Head Assembly (SHA), Magnetic Jack Assembly, In-Core Instrumentation (ICI) Flange Quickloc Assembly, and Heated Juncture Thermocouple (HJTC) Probe Assembly, and may be used only for that purpose.
 
5 CAW-13-3689 This information is part of that which will enable Westinghouse to: (a) Provide design, assembly, installation, and maintenance-related information for the aforementioned equipment.
2 CAW-13-3689 (1)
Release of this information would reveal to Westinghouse's competitors the distinguishing features of the assemblies depicted on these drawings.Further this information has substantial commercial value as follows: (a) Westinghouse plans to sell the use of similar information and services to its customers for the purpose of supplying equipment design upgrades or replacements.(b) Westinghouse can sell support and defense of its equipment with respect to the means by which these designs are uniquely assembled and installed in the field, or dis-assembled for service or maintainance.(b) Some of the information requested to be withheld provides distinguishing aspects of a methodology developed by Westinghouse and depicted in drawing form which provides a "simplified" functional layout of equipment that interfaces with the Reactor Vessel Head.Public disclosure of this proprietary information is likely to cause substantial harm to the competitive position of Westinghouse because it would enhance the ability of competitors to provide similar information and licensing defense services for commercial power reactors without commensurate expenses.
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 connection with nuclear power plant licensing and rule making proceedings, and am authorized to apply for its withholding on behalf of Westinghouse.
Also, public disclosure of the information would enable others to use the information to meet NRC requirements for licensing documentation without purchasing the right to use the information.
(2)
I am making this Affidavit in conformance with the provisions of 10 CFR Section 2.390 of the Commission's regulations and in conjunction with the Westinghouse Application for Withholding Proprietary Information from Public Disclosure accompanying this Affidavit.
(3)
I have personal knowledge of the criteria and procedures utilized by Westinghouse in designating information 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 the information 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 held in confidence by Westinghouse.
(ii)
The information is of a type customarily held in confidence by Westinghouse and not customarily disclosed to the public. Westinghouse has a rational basis for determining the 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 in confidence. The application of that system and the substance of that system constitutes Westinghouse policy and provides the rational basis required.
Under that system, information is held in confidence if it falls in one or more of several types, the release of which might result in the loss of an existing or potential competitive advantage, 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
 
3 CAW-13-3689 Westinghouse's competitors without license from Westinghouse constitutes a competitive economic advantage over other companies.
(b)
It consists of supporting data, including test data, relative to a process (or component, structure, tool, method, etc.), the application of which data secures a competitive economic advantage, e.g., by optimization or improved marketability.
(c)
Its use by a competitor would reduce his expenditure of resources or improve his competitive position in the design, manufacture, shipment, installation, assurance of quality, or licensing a similar product.
(d)
It reveals cost or price information, production capacities, budget levels, or commercial strategies of Westinghouse, its customers or suppliers.
(e)
It reveals aspects of past, present, or future Westinghouse or customer funded development 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 the following:
(a)
The use of such information by Westinghouse gives Westinghouse a competitive advantage over its competitors. It is, therefore, withheld from disclosure to protect the Westinghouse competitive position.
(b)
It is information that is marketable in many ways. The extent to which such information is available to competitors diminishes the Westinghouse ability to sell products and services involving the use of the information.
(c)
Use by our competitor would put Westinghouse at a competitive disadvantage by reducing his expenditure of resources at our expense.
 
4 CAW-13-3689 (d)
Each component of proprietary information pertinent to a particular competitive advantage is potentially as valuable as the total competitive advantage. If competitors acquire components of proprietary information, any one component may be the key to the entire puzzle, thereby depriving Westinghouse of a competitive advantage.
(e)
Unrestricted disclosure would jeopardize the position of prominence of Westinghouse in the world market, and thereby give a market advantage to the competition of those countries.
(f)
The Westinghouse capacity to invest corporate assets in research and development depends upon the success in obtaining and maintaining a competitive advantage.
(iii)
The information is being transmitted to the Commission in confidence and, under the provisions of 10 CFR Section 2.390, it is to be received in confidence by the Commission.
(iv)
The information sought to be protected is not available in public sources or available information has not been previously employed in the same original manner or method to the best of our knowledge and belief.
(v)
The proprietary information sought to be withheld in this submittal is that which is appropriately marked in Westinghouse drawings: 10050E9 1, Rev. 10; 10056E01, Rev. 2, E-1370-163-001, Rev. 09; E-1370-165-310, Rev. 09; E-1370-165-310, Rev. 09; J-1370-165-502, Rev. 05; and E-1470-165-3 10, Rev. 05, for submittal to the Commission, being transmitted by Southern California Edison (SCE) Letter and Application for Withholding Proprietary Information from Public Disclosure, to the Document Control Desk. The proprietary information as submitted by Westinghouse is that which is associated with the designs of the San Onofre Nuclear Generating Station (SONGS) Units 2 and 3 Reactor Vessel Simplified Head Assembly (SHA), Magnetic Jack Assembly, In-Core Instrumentation (ICI) Flange Quickloc Assembly, and Heated Juncture Thermocouple (HJTC) Probe Assembly, and may be used only for that purpose.
 
5 CAW-13-3689 This information is part of that which will enable Westinghouse to:
(a)
Provide design, assembly, installation, and maintenance-related information for the aforementioned equipment. Release of this information would reveal to Westinghouse's competitors the distinguishing features of the assemblies depicted on these drawings.
Further this information has substantial commercial value as follows:
(a)
Westinghouse plans to sell the use of similar information and services to its customers for the purpose of supplying equipment design upgrades or replacements.
(b)
Westinghouse can sell support and defense of its equipment with respect to the means by which these designs are uniquely assembled and installed in the field, or dis-assembled for service or maintainance.
(b)
Some of the information requested to be withheld provides distinguishing aspects of a methodology developed by Westinghouse and depicted in drawing form which provides a "simplified" functional layout of equipment that interfaces with the Reactor Vessel Head.
Public disclosure of this proprietary information is likely to cause substantial harm to the competitive position of Westinghouse because it would enhance the ability of competitors to provide similar information and licensing defense services for commercial power reactors without commensurate expenses. Also, public disclosure of the information would enable others to use the information to meet NRC requirements for licensing documentation without purchasing the right to use the information.
The development of the technology described in part by the information is the result of applying the results of many years of experience in an intensive Westinghouse effort and the expenditure of a considerable sum of money.
The development of the technology described in part by the information is the result of applying the results of many years of experience in an intensive Westinghouse effort and the expenditure of a considerable sum of money.
6 CAW-13-3689 In order for competitors of Westinghouse to duplicate this information, similar technical programs would have to be performed and a significant manpower effort, having the requisite talent and experience, would have to be expended.Further the deponent sayeth not.
 
PROPRIETARY INFORMATION NOTICE Transmitted herewith is the proprietary version of drawings furnished to the NRC in connection with requests for generic and/or plant-specific review and approval.
6 CAW-13-3689 In order for competitors of Westinghouse to duplicate this information, similar technical programs would have to be performed and a significant manpower effort, having the requisite talent and experience, would have to be expended.
Each of the drawings is to be considered proprietary in its entirety.COPYRIGHT NOTICE The drawings transmitted herewith, each bear a Westinghouse copyright notice. The NRC is permitted to make the number of copies of the information contained in these drawings which is necessary for its internal use in connection with generic and plant-specific reviews and approvals as well as the issuance, denial, amendment, transfer, renewal, modification, suspension, revocation, or violation of a license, permit, order, or regulation subject to the requirements of 10 CFR 2.390 regarding restrictions on public disclosure to the extent such information has been identified as proprietary by Westinghouse, copyright protection notwithstanding.
Further the deponent sayeth not.
Copies made by the NRC must include the copyright notice in all instances and the proprietary notice if the original was identified as proprietary.
 
Attachment 4 Listing of Enclosure 2 SONGS Units 2 and 3 UFSAR and UFHA Files Non-Proprietary Directory of CD \UFSAR File Name Size (KB)001 NRC Amendment for Section 1.1.PDF 2,069 002 NRC Amendment for Section 1.2.PDF 7,489 003 NRC Amendment for Section 1.3.PDF 180 004 NRC Amendment for Section 1.4.PDF 509 005 NRC Amendment for Section 1.5.PDF 269 006 NRC Amendment for Section 1.6.PDF 270 007 NRC Amendment for Section 1.7.PDF 381 008 NRC Amendment for Section 1.8.PDF 396 009 NRC Amendment for Section 2.1 .PDF 1,205 010 NRC Amendment for Section 2.2.PDF 1,083 011 NRC Amendment for Section 2.3.PDF 15,212 012 NRC Amendment for Section 2.4.PDF 7,937 013a NRC Amendment for Section 2.5 Part 1 of 2.pdf 47,138 013b NRC Amendment for Section 2.5 Part 2 of 2.pdf 44,157 014 NRC Amendment for Section 3.1 .PDF 344 015 NRC Amendment for Section 3.2.PDF 502 016 NRC Amendment for Section 3.3.PDF 262 017 NRC Amendment for Section 3.4.PDF 6,298 018 NRC Amendment for Section 3.5.PDF 337 019 NRC Amendment for Section 3.6.PDF 2,817 020 NRC Amendment for Section 3.7.PDF 21,128 021 NRC Amendment for Section 3.8.PDF 30,805 022 NRC Amendment for Section 3.9.PDF 9,907 023 NRC Amendment for Section 3.10.PDF 428 024 NRC Amendment for Section 3.11.PDF 558 025 NRC Amendment for Appendix 3A.pdf 150 026 NRC Amendment for Appendix 3B.pdf 74 027 NRC Amendment for Appendix 3C.PDF 1,862 028 NRC Amendment for Section 4.1 .PDF 387 029 NRC Amendment for Section 4.2.PDF 681 Attachment 4 Pg 1 of 4 File Name Size (KB)030 NRC Amendment for Section 4.3.PDF 2,046 031 NRC Amendment for Section 4.4.PDF 849 032 NRC Amendment for Section 4.5.PDF 86 033 NRC Amendment for Section 4.6.PDF 474 034 NRC Amendment for Section 5.1 .PDF 1,851 035 NRC Amendment for Section 5.2.PDF 3,436 036 NRC Amendment for Section 5.3.PDF 509 037 NRC Amendment for Section 5.4.PDF 2,534 038 NRC Amendment for Section 6.1.PDF 287 039 NRC Amendment for Section 6.2.PDF 10,201 040 NRC Amendment for Section 6.3.PDF 5,281 041 NRC Amendment for Section 6.4.PDF 527 042 NRC Amendment for Section 6.5.PDF 965 043 NRC Amendment for Section 6.6.PDF 54 044 NRC Amendment for Section 7.1 .PDF 416 045 NRC Amendment for Section 7.2.PDF 12,069 046 NRC Amendment for Section 7.3.PDF 4,146 047 NRC Amendment for Section 7.4.PDF 1,151 048 NRC Amendment for Section 7.5.PDF 5,202 049 NRC Amendment for Section 7.6.PDF 334 050 NRC Amendment for Section 7.7.PDF 426 051 NRC Amendment for Section 8.1.PDF 144 052 NRC Amendment for Section 8.2.PDF 1,968 053 NRC Amendment for Section 8.3.PDF 1,941 054 NRC Amendment for Section 9.1 .PDF 2,903 055 NRC Amendment for Section 9.2.PDF 11,296 056 NRC Amendment for Section 9.3.PDF 17,597 057 NRC Amendment for Section 9.4.PDF 11,194 058 NRC Amendment for Section 9.5.PDF 6,471 059 NRC Amendment for Section 10.1 .PDF 18,782 060 NRC Amendment for Section 10.2.PDF 790 061 NRC Amendment for Section 10.3.PDF 121 062 NRC Amendment for Section 10.4.PDF 3,454 063 NRC Amendment for Section 11.1 .PDF 541 064 NRC Amendment for Section 11.2.PDF 5,232 065 NRC Amendment for Section 11.3.PDF 1,657 066 NRC Amendment for Section 11.4.PDF 1,579 067 NRC Amendment for Section 11.5.PDF 1,257 068 NRC Amendment for Section 12.1.PDF 83 069 NRC Amendment for Section 12.2.PDF 365 Attachment 4 Pg 2 of 4 File Name Size (KB)070 NRC Amendment for Section 12.3 Part 1 of 2.PDF 17,791 071 NRC Amendment for Section 12.3 Part 2 of 2.PDF 34,188 072 NRC Amendment for Section 12.4.PDF 318 073 NRC Amendment for Section 12.5.PDF 106 074 NRC Amendment for Section 13.1.PDF 525 075 NRC Amendment for Section 13.2.PDF 260 076 NRC Amendment for Section 13.3.PDF 491 077 NRC Amendment for Section 13.4.PDF 372 078 NRC Amendment for Section 13.5.PDF 302 079 NRC Amendment for Section 13.6.PDF 488 080 NRC Amendment for Section 14.1.PDF 483 081 NRC Amendment for Section 14.2.PDF 573 082 NRC Amendment for Section 15.0.PDF 196 083 NRC Amendment for Section 15.1.PDF 2,487 084 NRC Amendment for Section 15.2.PDF 1,017 085 NRC Amendment for Section 15.3.PDF 533 086 NRC Amendment for Section 15.4.PDF 1,320 087 NRC Amendment for Section 15.5.PDF 612 088 NRC Amendment for Section 15.6.PDF 2,487 089 NRC Amendment for Section 15.7.PDF 149 090 NRC Amendment for Section 15.8.PDF 261 091 NRC Amendment for Section 15.9.PDF 332 092 NRC Amendment for Section 15.1 0.PDF 1,079 093 NRC Amendment for Appendix 15A.PDF 300 094 NRC Amendment for Appendix 15B.PDF 235 095 NRC Amendment for Appendix 15C.PDF 348 096 NRC Amendment for Appendix 15D.PDF 322 097 NRC Amendment for Appendix 15E.PDF 665 098 NRC Amendment for Appendix 15F.PDF 286 099 NRC Amendment for Appendix 15G.PDF 172 100 NRC Amendment for Section 16.1.PDF 251 101 NRC Amendment for PDF Report 17.PDF 85 102 NRC Amendment for Section 17.0.PDF 76 103 NRC Amendment for Section 17.1.PDF 242 104 NRC Amendment for Section 17.2.PDF 228 105 NRC Amendment for Figure 17B-1.PDF 15 Attachment 4 Pg 3 of 4 Directory of CD \UFHA File Name Size (KB)001 NRC Amendment for Section 1.PDF 273 002 NRC Amendment for Section 2.PDF 366 003 NRC Amendment for Section 3.pdf 140 004 NRC Amendment for Section 4.pdf 234 005 NRC Amendment for Section 5.pdf 384 006 NRC Amendment for Section 6.pdf 138 007 NRC Amendment for Section 7.1 .pdf 401 008 NRC Amendment for Section 7.2.PDF 351 009 NRC Amendment for Section 7.3.PDF 464 010 NRC Amendment for Section 7.4.PDF 377 011 NRC Amendment for Section 7.5.pdf 668 012 NRC Amendment for Section 7.6.PDF 315 013 NRC Amendment for Section 7.7.PDF 344 014 NRC Amendment for Section 7.8.PDF 377 015 NRC Amendment for Section 7.9.pdf 3,532 016 NRC Amendment for Section 7.10.PDF 581 017 NRC Amendment for Section 7.11.PDF 331 018 NRC Amendment for Section 7.12.pdf 391 019 NRC Amendment for Section 7.13.PDF 350 020 NRC Amendment for Section 7.14.pdf 991 021 NRC Amendment for Section 7.15.PDF 375 022 NRC Amendment for Section 7.16.PDF 355 023 NRC Amendment for Section 7.17 .PDF 319 024 NRC Amendment for Section 7.18.PDF 341 025 NRC Amendment for Section 7.19.PDF 371 026 NRC Amendment for Section 8.1.PDF 47,135 027 NRC Amendment for Appendix A.PDF 250 028 NRC Amendment for Appendix B.PDF 1,846 029 NRC Amendment for Appendix C.PDF 251 030 NRC Amendment for Appendix D.pdf 1,198 Attachment 4 Pg 4 of 4}}
PROPRIETARY INFORMATION NOTICE Transmitted herewith is the proprietary version of drawings furnished to the NRC in connection with requests for generic and/or plant-specific review and approval. Each of the drawings is to be considered proprietary in its entirety.
COPYRIGHT NOTICE The drawings transmitted herewith, each bear a Westinghouse copyright notice. The NRC is permitted to make the number of copies of the information contained in these drawings which is necessary for its internal use in connection with generic and plant-specific reviews and approvals as well as the issuance, denial, amendment, transfer, renewal, modification, suspension, revocation, or violation of a license, permit, order, or regulation subject to the requirements of 10 CFR 2.390 regarding restrictions on public disclosure to the extent such information has been identified as proprietary by Westinghouse, copyright protection notwithstanding. Copies made by the NRC must include the copyright notice in all instances and the proprietary notice if the original was identified as proprietary.
Listing of Enclosure 2 SONGS Units 2 and 3 UFSAR and UFHA Files Non-Proprietary Directory of CD \\UFSAR File Name Size (KB) 001 NRC Amendment for Section 1.1.PDF 2,069 002 NRC Amendment for Section 1.2.PDF 7,489 003 NRC Amendment for Section 1.3.PDF 180 004 NRC Amendment for Section 1.4.PDF 509 005 NRC Amendment for Section 1.5.PDF 269 006 NRC Amendment for Section 1.6.PDF 270 007 NRC Amendment for Section 1.7.PDF 381 008 NRC Amendment for Section 1.8.PDF 396 009 NRC Amendment for Section 2.1.PDF 1,205 010 NRC Amendment for Section 2.2.PDF 1,083 011 NRC Amendment for Section 2.3.PDF 15,212 012 NRC Amendment for Section 2.4.PDF 7,937 013a NRC Amendment for Section 2.5 Part 1 of 2.pdf 47,138 013b NRC Amendment for Section 2.5 Part 2 of 2.pdf 44,157 014 NRC Amendment for Section 3.1.PDF 344 015 NRC Amendment for Section 3.2.PDF 502 016 NRC Amendment for Section 3.3.PDF 262 017 NRC Amendment for Section 3.4.PDF 6,298 018 NRC Amendment for Section 3.5.PDF 337 019 NRC Amendment for Section 3.6.PDF 2,817 020 NRC Amendment for Section 3.7.PDF 21,128 021 NRC Amendment for Section 3.8.PDF 30,805 022 NRC Amendment for Section 3.9.PDF 9,907 023 NRC Amendment for Section 3.10.PDF 428 024 NRC Amendment for Section 3.11.PDF 558 025 NRC Amendment for Appendix 3A.pdf 150 026 NRC Amendment for Appendix 3B.pdf 74 027 NRC Amendment for Appendix 3C.PDF 1,862 028 NRC Amendment for Section 4.1.PDF 387 029 NRC Amendment for Section 4.2.PDF 681 Pg 1 of 4
 
File Name Size (KB) 030 NRC Amendment for Section 4.3.PDF 2,046 031 NRC Amendment for Section 4.4.PDF 849 032 NRC Amendment for Section 4.5.PDF 86 033 NRC Amendment for Section 4.6.PDF 474 034 NRC Amendment for Section 5.1.PDF 1,851 035 NRC Amendment for Section 5.2.PDF 3,436 036 NRC Amendment for Section 5.3.PDF 509 037 NRC Amendment for Section 5.4.PDF 2,534 038 NRC Amendment for Section 6.1.PDF 287 039 NRC Amendment for Section 6.2.PDF 10,201 040 NRC Amendment for Section 6.3.PDF 5,281 041 NRC Amendment for Section 6.4.PDF 527 042 NRC Amendment for Section 6.5.PDF 965 043 NRC Amendment for Section 6.6.PDF 54 044 NRC Amendment for Section 7.1.PDF 416 045 NRC Amendment for Section 7.2.PDF 12,069 046 NRC Amendment for Section 7.3.PDF 4,146 047 NRC Amendment for Section 7.4.PDF 1,151 048 NRC Amendment for Section 7.5.PDF 5,202 049 NRC Amendment for Section 7.6.PDF 334 050 NRC Amendment for Section 7.7.PDF 426 051 NRC Amendment for Section 8.1.PDF 144 052 NRC Amendment for Section 8.2.PDF 1,968 053 NRC Amendment for Section 8.3.PDF 1,941 054 NRC Amendment for Section 9.1.PDF 2,903 055 NRC Amendment for Section 9.2.PDF 11,296 056 NRC Amendment for Section 9.3.PDF 17,597 057 NRC Amendment for Section 9.4.PDF 11,194 058 NRC Amendment for Section 9.5.PDF 6,471 059 NRC Amendment for Section 10.1.PDF 18,782 060 NRC Amendment for Section 10.2.PDF 790 061 NRC Amendment for Section 10.3.PDF 121 062 NRC Amendment for Section 10.4.PDF 3,454 063 NRC Amendment for Section 11.1.PDF 541 064 NRC Amendment for Section 11.2.PDF 5,232 065 NRC Amendment for Section 11.3.PDF 1,657 066 NRC Amendment for Section 11.4.PDF 1,579 067 NRC Amendment for Section 11.5.PDF 1,257 068 NRC Amendment for Section 12.1.PDF 83 069 NRC Amendment for Section 12.2.PDF 365 Pg 2 of 4
 
File Name Size (KB) 070 NRC Amendment for Section 12.3 Part 1 of 2.PDF 17,791 071 NRC Amendment for Section 12.3 Part 2 of 2.PDF 34,188 072 NRC Amendment for Section 12.4.PDF 318 073 NRC Amendment for Section 12.5.PDF 106 074 NRC Amendment for Section 13.1.PDF 525 075 NRC Amendment for Section 13.2.PDF 260 076 NRC Amendment for Section 13.3.PDF 491 077 NRC Amendment for Section 13.4.PDF 372 078 NRC Amendment for Section 13.5.PDF 302 079 NRC Amendment for Section 13.6.PDF 488 080 NRC Amendment for Section 14.1.PDF 483 081 NRC Amendment for Section 14.2.PDF 573 082 NRC Amendment for Section 15.0.PDF 196 083 NRC Amendment for Section 15.1.PDF 2,487 084 NRC Amendment for Section 15.2.PDF 1,017 085 NRC Amendment for Section 15.3.PDF 533 086 NRC Amendment for Section 15.4.PDF 1,320 087 NRC Amendment for Section 15.5.PDF 612 088 NRC Amendment for Section 15.6.PDF 2,487 089 NRC Amendment for Section 15.7.PDF 149 090 NRC Amendment for Section 15.8.PDF 261 091 NRC Amendment for Section 15.9.PDF 332 092 NRC Amendment for Section 15.1 0.PDF 1,079 093 NRC Amendment for Appendix 15A.PDF 300 094 NRC Amendment for Appendix 15B.PDF 235 095 NRC Amendment for Appendix 15C.PDF 348 096 NRC Amendment for Appendix 15D.PDF 322 097 NRC Amendment for Appendix 15E.PDF 665 098 NRC Amendment for Appendix 15F.PDF 286 099 NRC Amendment for Appendix 15G.PDF 172 100 NRC Amendment for Section 16.1.PDF 251 101 NRC Amendment for PDF Report 17.PDF 85 102 NRC Amendment for Section 17.0.PDF 76 103 NRC Amendment for Section 17.1.PDF 242 104 NRC Amendment for Section 17.2.PDF 228 105 NRC Amendment for Figure 17B-1.PDF 15 Pg 3 of 4
 
Directory of CD \\UFHA File Name Size (KB) 001 NRC Amendment for Section 1.PDF 273 002 NRC Amendment for Section 2.PDF 366 003 NRC Amendment for Section 3.pdf 140 004 NRC Amendment for Section 4.pdf 234 005 NRC Amendment for Section 5.pdf 384 006 NRC Amendment for Section 6.pdf 138 007 NRC Amendment for Section 7.1.pdf 401 008 NRC Amendment for Section 7.2.PDF 351 009 NRC Amendment for Section 7.3.PDF 464 010 NRC Amendment for Section 7.4.PDF 377 011 NRC Amendment for Section 7.5.pdf 668 012 NRC Amendment for Section 7.6.PDF 315 013 NRC Amendment for Section 7.7.PDF 344 014 NRC Amendment for Section 7.8.PDF 377 015 NRC Amendment for Section 7.9.pdf 3,532 016 NRC Amendment for Section 7.10.PDF 581 017 NRC Amendment for Section 7.11.PDF 331 018 NRC Amendment for Section 7.12.pdf 391 019 NRC Amendment for Section 7.13.PDF 350 020 NRC Amendment for Section 7.14.pdf 991 021 NRC Amendment for Section 7.15.PDF 375 022 NRC Amendment for Section 7.16.PDF 355 023 NRC Amendment for Section 7.17.PDF 319 024 NRC Amendment for Section 7.18.PDF 341 025 NRC Amendment for Section 7.19.PDF 371 026 NRC Amendment for Section 8.1.PDF 47,135 027 NRC Amendment for Appendix A.PDF 250 028 NRC Amendment for Appendix B.PDF 1,846 029 NRC Amendment for Appendix C.PDF 251 030 NRC Amendment for Appendix D.pdf 1,198 Pg 4 of 4}}

Latest revision as of 07:18, 11 January 2025

Updated Final Safety Analysis Report and Updated Fire Hazard Analysis, Revised May 2013
ML13182A288
Person / Time
Site: San Onofre  Southern California Edison icon.png
Issue date: 06/07/2013
From: Bauder D
Southern California Edison Co
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
CAW-13-3689
Download: ML13182A288 (19)


Text

I*

SOUTHERN CALIFORNIA EDISON' An EDISON INTERNATIONAL0* Company Proprietary Information Withhold from Public Disclosure Douglas R. Bauder Site Vice President & Station Manager San Onofre Nuclear Generating Station 1 0CFR50.71 (e)

June 7, 2013 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555

Subject:

Docket Nos. 50-361 and 50-362 Updated Final Safety Analysis Report and Updated Fire Hazard Analysis, Revised May 2013 San Onofre Nuclear Generating Station, Units 2 and 3 Letter from D. R. Bauder (SCE) to U. S. Nuclear Regulatory Commission (Document Control Desk) Letter dated June 10, 2011,

Subject:

Docket Nos. 50-361 and 50-362, Updated Final Safety Analysis Report and Updated Fire Hazard Analysis, Revised April 2009, San Onofre Nuclear Generating Station, Units 2 and 3

Reference:

Dear Sir or Madam:

In accordance with the requirements of 10 CFR 50.71(e), Southern California Edison hereby submits the biennial revisions to the Updated Final Safety Analysis Report (UFSAR) and the Updated Fire Hazard Analysis (UFHA), for San Ondfre Nuclear Generating Station (SONGS),

Units 2 and 3.

In addition, as required by 10 CFR 50.54(a), an update to the Quality Assurance Program Description for San Onofre Units 1, 2, and 3 is provided in accordance with 10 CFR 50.71(e).

Topical Report, Quality Assurance Program SCE-1 is incorporated as Chapter 17 of the UFSAR with changes identified by change bars. A summary of the changes to the Topical Report, Quality Assurance Program SCE-1 since the last submittal, is provided in Attachment 1.

Both updates are being provided within 24 months following the last update (Reference).

Enclosures 1 and 2 are compact disks (CD) containing the SONGS Units 2 and 3 UFSAR and UFHA. To denote the changes from the previous submittals, a vertical change bar is located in the page margin adjacent to the revised information.

The Enclosure 1 CD of this submittal contains information that is proprietary. SCE requests that this proprietary Enclosure be withheld from public disclosure in accordance with 10 CFR 2.390(a)(4). Attachment 2 provides the notarized affidavit which set forth the basis on which the information in Enclosure 1 may be withheld from public disclosure by the Commission and addresses with specificity the considerations listed by paragraph (b)(4) of 10 CFR 2.390. CD contains the files listed in Attachment 3.

P.O. Box 128 San Clemente, CA 92672 (949) 368-9275 PAX 89275 Fax: (949) 368-9881 Doug.Bauder@sce.com Proprietary Information Withhold from Public Disclosure Decontrolled Upon Removal of Enclosure 1 D5-ýý 0 Pf, F-'w-

Proprietary Information Withhold from Public Disclosure Document Control Desk June 7, 2013 provides the non-proprietary version of Enclosure 1. Enclosure 2 contains information that is deemed sensitive and the files on the CD are requested to be withheld from public disclosure in accordance with 10 CFR 2.390. Enclosure 2 CD contains the files listed in.

There are no commitments contained in this letter or its enclosures.

Should there be any questions regarding this submittal, please contact Mr. Mark Morgan, Licensing Lead, at (949) 368-6745.

I declare under penalty of perjury that the foregoing is true and correct.

(a//o3 Executed on By:

ouglas Bauder Site Vice President and Station Manager : : : : : :

Summary of changes in the Topical Report Quality Assurance Program SCE-1 since the last submittal Notarized Affidavit Listing of Enclosure 1 SONGS Units 2 and 3 UFSAR and UFHA files, Proprietary Listing of Enclosure 2 SONGS Units 2 and 3 UFSAR and UFHA files, Non-Proprietary Proprietary Enclosure (Compact Disk - San Onofre Nuclear Generating Station, SONGS 2 & 3, UFSAR and UFHA, Amended May 2013)

Non-Proprietary Enclosure (Compact Disk - San Onofre Nuclear Generating Station, SONGS 2 & 3, UFSAR and UFHA, Amended May 2013) cc: A. T. Howell III, Regional Administrator, NRC Region IV R. Hall, NRC Project Manager, SONGS Units 2 and 3 B. Benney, NRC Project Manager, SONGS Units 2 and 3 G. G. Warnick, NRC Senior Resident Inspector, SONGS Units 2 and 3 S. Y. Hsu, California Department of Public Health, Radiologic Health Branch Proprietary Information Withhold from Public Disclosure Decontrolled Upon Removal of Enclosure 1

Attachment I Summary of changes to the Topical Report Quality Assurance Program SCE-1, since the last submittal:

1. Changed TR Section 17.2.1.1, Scope, from stations to station.
2. Changed TR Section 17.2.1.2, Responsibilities, to delete 17.2-1, 17.2-1 B, 17.2-1 C, and contain within single figure 17.2.1A.
3. Changed TR Section 17.2.1.2, Responsibilities, to assign responsibly from Chief Executive Officer to SCE President.
4. Changed TR Section 17.2.1.2, Responsibilities, to reflect the new reporting structure of station management to include, projects, nuclear safety culture, nuclear regulatory affairs and emergency planning, leadership and organizational effectiveness, nuclear strategic projects.
5. Removed TR Section 17.2.1.2.1, Engineering and Technical Services and moved responsibilities for Engineering to section 17.2.1.2.2
6. Changed TR section 17.2.1.2.2, Site Management, to TR section 17.2.1.2.1, Station Management
7. Changed TR section 17.2.1.2.2, Site Management, to TR 17.2.1.2.1, Station Management include responsibility of Vice President & Station Manager.
8. Changed TR section 17.2.1.2.2, Site Management, to TR 17.2.1.2.1, Station Management to reflect the new reporting structure to the Vice President & Station Manager to remove, health physics, construction, testing, chemistry, and refueling, and to include radiation protection/health physics, chemistry and environmental, human performance and industrial safety, training, security and performance improvement.

Added Fire Protection services and removed Independent Technical Review program and Nuclear Training functions, and handling and storage of material and equipment.

9. Changed TR section 17.2.1.2.2, Site Management, to TR 17.2.1.2.1, Station Management to reassign responsibilities to the Station Manager from the Plant Manager.
10. Changed TR section 17.2.1.2.1, Engineering and Technical Services to TR section 17.2.1.2.2 to Engineering, Projects, and site Support Services, added engineering systems, programs, design, nuclear fuel management, projects and site support services (material support, documentation services, and facilities management.)
11. Changed TR section 17.2.1.2.3, Site Support (moved to 17.2.1.2.2), to Nuclear Regulatory Affairs & Emergency Planning and defined responsibilities.
12. Changed TR section 17.2.1.2.4, Nuclear Oversight to Nuclear Strategic Projects and defined responsibilities.

Pg 1 of 3

13. Changed TR section 17.2.1.2.5 Performance Improvement to Nuclear Oversight and changed manager and supervisors to managers only.
14. Moved TR section 17.2.1.2.5, Performance Improvement, to 17.2.1.2.1 to reflect new reporting structure to the Vice President and Station Manager.
15. Removed TR section 17.2.1.2.6 Nuclear Regulatory Affairs, and included responsibilities in section 17.2.1.2.3
16. Changed TR section 17.2.1.2.7, Other Organizations, to Other Corporate SCE Organizations to 17.2.1.2.6.
17. Changed TR section 17.2.1.2.6, Other Organizations, Shop Services and Instrumentation Department to include 'nuclear' before station and to change division managers to station management; removed the Manager OS SCM and Senior vice President, Safety, Operations support and chief Procurement Officer and added SCE Corporate Management; Removed Director, Site Support and added management responsible for site support services; Added responsibilities for Nuclear Procurement; Removed responsibilities for Business Resources to Corporate Records Center and added reporting structure to SCE Corporate Management, company records and an interfacing responsibility with site support services related to long term storage of nuclear records; Removed Business Integration from title of Information Technology and added responsibilities for managing, computing system and network.
18. Changed TR section 17.2.1.4, Reporting, to reflect regular reporting to the SCE President and Chief Nuclear Officer on the adequacy of the SCE Quality Assurance Program.
19. Changed TR section 17.2.4.2, Procurement Document Control, to add Nuclear before Procurement and to assign Procurement documents for Nuclear Fuel responsibilities to Engineering.
20. Changed TR section17.2.5.2, Instructions, Procedures, and Drawings, second paragraph, to define procedure reviews will be performed by Nuclear Oversight personnel during periodic audits and to add, prior to issuance, determination of the adequacy of the quality control requirements to verify implementation of these requirements. Removed from third paragraph responsibility for review by Nuclear Oversight personnel documents prepared by outside contractors.
21. Changed TR section 17.2.14.2, Inspection, Test and Operating Status, to assign responsibility to a Nuclear Oversight manager rather than a supervisor.
22. Changed TR section 17.2.15.2, Nonconforming Materials, parts or Components, to clarify how Management representatives review and assess Nuclear Notifications and or Condition Reports. Conditions adverse to quality also added for clarification.

Nonconformances processed through Nuclear Oversight through the use of Vendor Corrective Action Request process. Added the word pervasive to clarify specific Pg 2 of 3

programmatic weaknesses. Added nonconformances of unusual complexity or involvement may be submitted to the Onsite Review Committee for review.

23. Changed TR section 17.2.16.2, Corrective Action, to clarify conditions adverse to quality.
24. Changed TR section 17.2.16.2.1, Site Activities, to reference Condition Reports in addition to Nuclear Notifications. Added pervasive to further clarify specific trends.
25. Changed TR section 17.2.17.2, Quality Assurance Records, added Condition Reports, Cause Evaluations, Corrective Actions, and Effectiveness Reviews to be included as a quality record.
26. Changed TR section 17.2.18.2, Audits, added Nuclear Oversight to perform. Moved Safeguards Contingency Plan from at least once per 24 months to at least once per 12 months for the audit period and added Emergency Plan to at least once per 12 months.
27. Changed TR section 17.2.19.1, Organization, defined organizational responsibilities for fire protection, fire protection engineering and design and configuration, fire protection program materials, equipment and services.
28. Changed TR section 17.2.20.2.2, Composition, added Radiation Protection to Health Physics and clarified Engineering.
29. Changed TR section 17.2.20.2.6, Responsibilities, added responsibility for review of significant nonconformances of unusual complexity or involvement to the Onsite Review Committee.
30. Changed TR section 17.2.20.3.1, Activities, (f) assigned responsibility for review of the Physical Security Plan to Security and the Site Emergency Plan to Nuclear Regulatory Affairs. Deleted item j reference to 17.2.20.5.
31. Changed TR section 17.2.20.5.2, Lifetime Quality Assurance Records, clarified records of inservice inspections performed as required by the Inservice Inspection Program procedures.
32. Changed TR section 17.2.20.6, Working Hours, added 10CFR 26.205 and removed the requirement for any deviation from the working hour guidelines to be in accordance with the Technical Specifications as the requirements no longer reside in the Technical Specifications.
33. Changed TR Table 17.2.1, added 10CFR26.205 - Working Hours.

Pg 3 of 3 NOTARIZED AFFIDAVIT

W sig s

Westinghouse Electric Company Nuclear Services 1000 Westinghouse Drive Cranberry Township, Pennsylvania 16066 USA U.S. Nuclear Regulatory Commission Direct tel: (412) 374-4643 Document Control Desk Direct fax: (724) 720-0754 11555 Rockville Pike e-mail: greshaja@westinghouse.com Rockville, MD 20852 Proj letter: CONO-13-36 CAW-13-3689 April 18, 2013 APPLICATION FOR WITHHOLDING PROPRIETARY INFORMATION FROM PUBLIC DISCLOSURE

Subject:

Drawings:

1. 10050E91, Rev. 10, "SONGS Unit 2 Reactor Vessel Simplified Head Assembly Top Plate Grid Assembly" (Proprietary)
2.

10056E01, Rev. 2, "SONGS Unit 2 Reactor Vessel Simplified Head Assembly Head Assembly Package Field Assembly" (Proprietary)

3. E-1370-163-001, Rev. 09, "Magnetic Jack Assy" (Proprietary)
4.

E-1370-165-3 10, Rev. 09, Sheet I of 2, "In-Core Instrumentation Flange Assys" (Proprietary)

5. E-1370-165-3 10, Rev. 09, Sheet 2 of 2, "In-Core Instrumentation Flange Assys" (Proprietary)
6. J-1370-165-502, Rev. 05, "HJTC Probe Installation" (Proprietary)
7. E-1470-165-310, Rev. 05, "In-Core Instrumentation Flange Assy" (Proprietary)

The proprietary information for which withholding is being requested in the above-referenced drawings is further identified in Affidavit CAW-13-3689 signed by the owner of the proprietary information, Westinghouse Electric Company LLC. The affidavit, which accompanies this letter, sets forth the basis on which the information may be withheld from public disclosure by the Commission and addresses with specificity the considerations listed in paragraph (b)(4) of 10 CFR Section 2.390 of the Commission's regulations.

The subject drawings were prepared and classified as Westinghouse Proprietary Class 2. Westinghouse requests that the drawings be considered proprietary in their entirety. As such, non-proprietary versions will not be issued.

Accordingly, this letter authorizes the utilization of the accompanying affidavit by Southern California Edison.

CAW-13-3689 Page 2 of 2 Correspondence with respect to the proprietary aspects of the application for withholding or the Westinghouse affidavit should reference CAW-13-3689 and should be addressed to James A. Gresham, Manager, Regulatory Compliance, Westinghouse Electric Company, Suite 428, 1000 Westinghouse Drive, Cranberry Township, Pennsylvania 16066.

Very truly yours, si Manager Regulatory Compliance Enclosures

CAW-1 3-3689 AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA:

ss COUNTY OF BUTLER:

Before me, the undersigned authority, personally appeared James A. Gresham, who, being by me duly sworn according to law, deposes and says that he is authorized to execute this Affidavit on behalf of Westinghouse Electric Company LLC (Westinghouse), and that the averments of fact set forth in this Affidavit are true and correct to the best of his knowledge, information, and belief:

Jame-es A. Gresham, Manager Regulatory Compliance Sworn to and subscribed before me this I 'day of April 201 Notary Public COMMONWEALTH OF PENNSYLVANIA I

Notarial Seal I

Anne M. Stegman, Notary Public Unity Twp., Westmomland ounty SMy Commission Expires Aug, 7, 2016 MmBF.R PENNSYLVANIA ASSOCIATION OF NOTARIEs

2 CAW-13-3689 (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 connection with nuclear power plant licensing and rule making proceedings, and am authorized to apply for its withholding on behalf of Westinghouse.

(2)

I am making this Affidavit in conformance with the provisions of 10 CFR Section 2.390 of the Commission's regulations and in conjunction with the Westinghouse Application for Withholding Proprietary Information from Public Disclosure accompanying this Affidavit.

(3)

I have personal knowledge of the criteria and procedures utilized by Westinghouse in designating information 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 the information 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 held in confidence by Westinghouse.

(ii)

The information is of a type customarily held in confidence by Westinghouse and not customarily disclosed to the public. Westinghouse has a rational basis for determining the 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 in confidence. The application of that system and the substance of that system constitutes Westinghouse policy and provides the rational basis required.

Under that system, information is held in confidence if it falls in one or more of several types, the release of which might result in the loss of an existing or potential competitive advantage, 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

3 CAW-13-3689 Westinghouse's competitors without license from Westinghouse constitutes a competitive economic advantage over other companies.

(b)

It consists of supporting data, including test data, relative to a process (or component, structure, tool, method, etc.), the application of which data secures a competitive economic advantage, e.g., by optimization or improved marketability.

(c)

Its use by a competitor would reduce his expenditure of resources or improve his competitive position in the design, manufacture, shipment, installation, assurance of quality, or licensing a similar product.

(d)

It reveals cost or price information, production capacities, budget levels, or commercial strategies of Westinghouse, its customers or suppliers.

(e)

It reveals aspects of past, present, or future Westinghouse or customer funded development 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 the following:

(a)

The use of such information by Westinghouse gives Westinghouse a competitive advantage over its competitors. It is, therefore, withheld from disclosure to protect the Westinghouse competitive position.

(b)

It is information that is marketable in many ways. The extent to which such information is available to competitors diminishes the Westinghouse ability to sell products and services involving the use of the information.

(c)

Use by our competitor would put Westinghouse at a competitive disadvantage by reducing his expenditure of resources at our expense.

4 CAW-13-3689 (d)

Each component of proprietary information pertinent to a particular competitive advantage is potentially as valuable as the total competitive advantage. If competitors acquire components of proprietary information, any one component may be the key to the entire puzzle, thereby depriving Westinghouse of a competitive advantage.

(e)

Unrestricted disclosure would jeopardize the position of prominence of Westinghouse in the world market, and thereby give a market advantage to the competition of those countries.

(f)

The Westinghouse capacity to invest corporate assets in research and development depends upon the success in obtaining and maintaining a competitive advantage.

(iii)

The information is being transmitted to the Commission in confidence and, under the provisions of 10 CFR Section 2.390, it is to be received in confidence by the Commission.

(iv)

The information sought to be protected is not available in public sources or available information has not been previously employed in the same original manner or method to the best of our knowledge and belief.

(v)

The proprietary information sought to be withheld in this submittal is that which is appropriately marked in Westinghouse drawings: 10050E9 1, Rev. 10; 10056E01, Rev. 2, E-1370-163-001, Rev. 09; E-1370-165-310, Rev. 09; E-1370-165-310, Rev. 09; J-1370-165-502, Rev. 05; and E-1470-165-3 10, Rev. 05, for submittal to the Commission, being transmitted by Southern California Edison (SCE) Letter and Application for Withholding Proprietary Information from Public Disclosure, to the Document Control Desk. The proprietary information as submitted by Westinghouse is that which is associated with the designs of the San Onofre Nuclear Generating Station (SONGS) Units 2 and 3 Reactor Vessel Simplified Head Assembly (SHA), Magnetic Jack Assembly, In-Core Instrumentation (ICI) Flange Quickloc Assembly, and Heated Juncture Thermocouple (HJTC) Probe Assembly, and may be used only for that purpose.

5 CAW-13-3689 This information is part of that which will enable Westinghouse to:

(a)

Provide design, assembly, installation, and maintenance-related information for the aforementioned equipment. Release of this information would reveal to Westinghouse's competitors the distinguishing features of the assemblies depicted on these drawings.

Further this information has substantial commercial value as follows:

(a)

Westinghouse plans to sell the use of similar information and services to its customers for the purpose of supplying equipment design upgrades or replacements.

(b)

Westinghouse can sell support and defense of its equipment with respect to the means by which these designs are uniquely assembled and installed in the field, or dis-assembled for service or maintainance.

(b)

Some of the information requested to be withheld provides distinguishing aspects of a methodology developed by Westinghouse and depicted in drawing form which provides a "simplified" functional layout of equipment that interfaces with the Reactor Vessel Head.

Public disclosure of this proprietary information is likely to cause substantial harm to the competitive position of Westinghouse because it would enhance the ability of competitors to provide similar information and licensing defense services for commercial power reactors without commensurate expenses. Also, public disclosure of the information would enable others to use the information to meet NRC requirements for licensing documentation without purchasing the right to use the information.

The development of the technology described in part by the information is the result of applying the results of many years of experience in an intensive Westinghouse effort and the expenditure of a considerable sum of money.

6 CAW-13-3689 In order for competitors of Westinghouse to duplicate this information, similar technical programs would have to be performed and a significant manpower effort, having the requisite talent and experience, would have to be expended.

Further the deponent sayeth not.

PROPRIETARY INFORMATION NOTICE Transmitted herewith is the proprietary version of drawings furnished to the NRC in connection with requests for generic and/or plant-specific review and approval. Each of the drawings is to be considered proprietary in its entirety.

COPYRIGHT NOTICE The drawings transmitted herewith, each bear a Westinghouse copyright notice. The NRC is permitted to make the number of copies of the information contained in these drawings which is necessary for its internal use in connection with generic and plant-specific reviews and approvals as well as the issuance, denial, amendment, transfer, renewal, modification, suspension, revocation, or violation of a license, permit, order, or regulation subject to the requirements of 10 CFR 2.390 regarding restrictions on public disclosure to the extent such information has been identified as proprietary by Westinghouse, copyright protection notwithstanding. Copies made by the NRC must include the copyright notice in all instances and the proprietary notice if the original was identified as proprietary.

Listing of Enclosure 2 SONGS Units 2 and 3 UFSAR and UFHA Files Non-Proprietary Directory of CD \\UFSAR File Name Size (KB) 001 NRC Amendment for Section 1.1.PDF 2,069 002 NRC Amendment for Section 1.2.PDF 7,489 003 NRC Amendment for Section 1.3.PDF 180 004 NRC Amendment for Section 1.4.PDF 509 005 NRC Amendment for Section 1.5.PDF 269 006 NRC Amendment for Section 1.6.PDF 270 007 NRC Amendment for Section 1.7.PDF 381 008 NRC Amendment for Section 1.8.PDF 396 009 NRC Amendment for Section 2.1.PDF 1,205 010 NRC Amendment for Section 2.2.PDF 1,083 011 NRC Amendment for Section 2.3.PDF 15,212 012 NRC Amendment for Section 2.4.PDF 7,937 013a NRC Amendment for Section 2.5 Part 1 of 2.pdf 47,138 013b NRC Amendment for Section 2.5 Part 2 of 2.pdf 44,157 014 NRC Amendment for Section 3.1.PDF 344 015 NRC Amendment for Section 3.2.PDF 502 016 NRC Amendment for Section 3.3.PDF 262 017 NRC Amendment for Section 3.4.PDF 6,298 018 NRC Amendment for Section 3.5.PDF 337 019 NRC Amendment for Section 3.6.PDF 2,817 020 NRC Amendment for Section 3.7.PDF 21,128 021 NRC Amendment for Section 3.8.PDF 30,805 022 NRC Amendment for Section 3.9.PDF 9,907 023 NRC Amendment for Section 3.10.PDF 428 024 NRC Amendment for Section 3.11.PDF 558 025 NRC Amendment for Appendix 3A.pdf 150 026 NRC Amendment for Appendix 3B.pdf 74 027 NRC Amendment for Appendix 3C.PDF 1,862 028 NRC Amendment for Section 4.1.PDF 387 029 NRC Amendment for Section 4.2.PDF 681 Pg 1 of 4

File Name Size (KB) 030 NRC Amendment for Section 4.3.PDF 2,046 031 NRC Amendment for Section 4.4.PDF 849 032 NRC Amendment for Section 4.5.PDF 86 033 NRC Amendment for Section 4.6.PDF 474 034 NRC Amendment for Section 5.1.PDF 1,851 035 NRC Amendment for Section 5.2.PDF 3,436 036 NRC Amendment for Section 5.3.PDF 509 037 NRC Amendment for Section 5.4.PDF 2,534 038 NRC Amendment for Section 6.1.PDF 287 039 NRC Amendment for Section 6.2.PDF 10,201 040 NRC Amendment for Section 6.3.PDF 5,281 041 NRC Amendment for Section 6.4.PDF 527 042 NRC Amendment for Section 6.5.PDF 965 043 NRC Amendment for Section 6.6.PDF 54 044 NRC Amendment for Section 7.1.PDF 416 045 NRC Amendment for Section 7.2.PDF 12,069 046 NRC Amendment for Section 7.3.PDF 4,146 047 NRC Amendment for Section 7.4.PDF 1,151 048 NRC Amendment for Section 7.5.PDF 5,202 049 NRC Amendment for Section 7.6.PDF 334 050 NRC Amendment for Section 7.7.PDF 426 051 NRC Amendment for Section 8.1.PDF 144 052 NRC Amendment for Section 8.2.PDF 1,968 053 NRC Amendment for Section 8.3.PDF 1,941 054 NRC Amendment for Section 9.1.PDF 2,903 055 NRC Amendment for Section 9.2.PDF 11,296 056 NRC Amendment for Section 9.3.PDF 17,597 057 NRC Amendment for Section 9.4.PDF 11,194 058 NRC Amendment for Section 9.5.PDF 6,471 059 NRC Amendment for Section 10.1.PDF 18,782 060 NRC Amendment for Section 10.2.PDF 790 061 NRC Amendment for Section 10.3.PDF 121 062 NRC Amendment for Section 10.4.PDF 3,454 063 NRC Amendment for Section 11.1.PDF 541 064 NRC Amendment for Section 11.2.PDF 5,232 065 NRC Amendment for Section 11.3.PDF 1,657 066 NRC Amendment for Section 11.4.PDF 1,579 067 NRC Amendment for Section 11.5.PDF 1,257 068 NRC Amendment for Section 12.1.PDF 83 069 NRC Amendment for Section 12.2.PDF 365 Pg 2 of 4

File Name Size (KB) 070 NRC Amendment for Section 12.3 Part 1 of 2.PDF 17,791 071 NRC Amendment for Section 12.3 Part 2 of 2.PDF 34,188 072 NRC Amendment for Section 12.4.PDF 318 073 NRC Amendment for Section 12.5.PDF 106 074 NRC Amendment for Section 13.1.PDF 525 075 NRC Amendment for Section 13.2.PDF 260 076 NRC Amendment for Section 13.3.PDF 491 077 NRC Amendment for Section 13.4.PDF 372 078 NRC Amendment for Section 13.5.PDF 302 079 NRC Amendment for Section 13.6.PDF 488 080 NRC Amendment for Section 14.1.PDF 483 081 NRC Amendment for Section 14.2.PDF 573 082 NRC Amendment for Section 15.0.PDF 196 083 NRC Amendment for Section 15.1.PDF 2,487 084 NRC Amendment for Section 15.2.PDF 1,017 085 NRC Amendment for Section 15.3.PDF 533 086 NRC Amendment for Section 15.4.PDF 1,320 087 NRC Amendment for Section 15.5.PDF 612 088 NRC Amendment for Section 15.6.PDF 2,487 089 NRC Amendment for Section 15.7.PDF 149 090 NRC Amendment for Section 15.8.PDF 261 091 NRC Amendment for Section 15.9.PDF 332 092 NRC Amendment for Section 15.1 0.PDF 1,079 093 NRC Amendment for Appendix 15A.PDF 300 094 NRC Amendment for Appendix 15B.PDF 235 095 NRC Amendment for Appendix 15C.PDF 348 096 NRC Amendment for Appendix 15D.PDF 322 097 NRC Amendment for Appendix 15E.PDF 665 098 NRC Amendment for Appendix 15F.PDF 286 099 NRC Amendment for Appendix 15G.PDF 172 100 NRC Amendment for Section 16.1.PDF 251 101 NRC Amendment for PDF Report 17.PDF 85 102 NRC Amendment for Section 17.0.PDF 76 103 NRC Amendment for Section 17.1.PDF 242 104 NRC Amendment for Section 17.2.PDF 228 105 NRC Amendment for Figure 17B-1.PDF 15 Pg 3 of 4

Directory of CD \\UFHA File Name Size (KB) 001 NRC Amendment for Section 1.PDF 273 002 NRC Amendment for Section 2.PDF 366 003 NRC Amendment for Section 3.pdf 140 004 NRC Amendment for Section 4.pdf 234 005 NRC Amendment for Section 5.pdf 384 006 NRC Amendment for Section 6.pdf 138 007 NRC Amendment for Section 7.1.pdf 401 008 NRC Amendment for Section 7.2.PDF 351 009 NRC Amendment for Section 7.3.PDF 464 010 NRC Amendment for Section 7.4.PDF 377 011 NRC Amendment for Section 7.5.pdf 668 012 NRC Amendment for Section 7.6.PDF 315 013 NRC Amendment for Section 7.7.PDF 344 014 NRC Amendment for Section 7.8.PDF 377 015 NRC Amendment for Section 7.9.pdf 3,532 016 NRC Amendment for Section 7.10.PDF 581 017 NRC Amendment for Section 7.11.PDF 331 018 NRC Amendment for Section 7.12.pdf 391 019 NRC Amendment for Section 7.13.PDF 350 020 NRC Amendment for Section 7.14.pdf 991 021 NRC Amendment for Section 7.15.PDF 375 022 NRC Amendment for Section 7.16.PDF 355 023 NRC Amendment for Section 7.17.PDF 319 024 NRC Amendment for Section 7.18.PDF 341 025 NRC Amendment for Section 7.19.PDF 371 026 NRC Amendment for Section 8.1.PDF 47,135 027 NRC Amendment for Appendix A.PDF 250 028 NRC Amendment for Appendix B.PDF 1,846 029 NRC Amendment for Appendix C.PDF 251 030 NRC Amendment for Appendix D.pdf 1,198 Pg 4 of 4