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WCAP-16364-NP, Revision 2, Implementation Guidance for Risk Informed Modification to Selected Required Action End States at Combustion Engineering NSSS Plants (TSTF-422)
ML102500295
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Site: Technical Specifications Task Force
Issue date: 05/10/2010
From: Schneider R
Westinghouse
To:
Office of Nuclear Reactor Regulation
References
PA-LSC-0364, TSTF-422 WCAP-16364-NP, Rev 2
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Westinghouse Non-Proprietary Class 3 WCAP-16364-NP May 2010 Revision 2 Implementation Guidance for Risk Informed Modification to Selected Required Action End States at Combustion Engineering NSSS Plants (TSTF-422)

PA-LSC-0364 Westinghouse

Westinghouse Non-Proprietary Class 3 WCAP-16364-NP Revision 2 Implementation Guidance for Risk Informed Modification to Selected Required Action End States at Combustion Engineering NSSS Plants (TSTF-422)

PA-LSC-0364 May 2010 Raymond Schneider*

Author, Risk Applications & Methods I1 Robert Jaquith*

Reviewer, Risk Applications & Methods II Paul Hijeck*

Manager, Risk Applications & Methods I1

  • Electronically approved records are authenticated in the Electronic Document Management System Westinghouse Electric Company LLC P.O. Box 355 Pittsburgh, PA 15230-0355

© 2010 Westinghouse Electric Company LLC All Rights Reserved

LEGAL NOTICE This report has been prepared by Westinghouse Electric Company LLC and bears a Westinghouse Electric Company copyright notice. As am ember of the PWR Owners Group, you are permitted to copy and redistribute all or portions of the report within your organization; however all copies made by you must include the copyright notice in all instances.

COPYRIGHT NOTICE This report was prepared for the PWR Owners Group. T his Distribution Notice is intended to establish guidance for access to t his information. T his report ( including proprietary an d n on-proprietary versions) is not to be provided to any individual or organization outside of the PWR Owners Group program participants without prior written approval of the PWR Owners Group Program Management Office. Ho wever, pr ior wr itten appr oval i s n ot r equired for pr ogram participants t o pr ovide co pies o f Cl ass 3 No n P roprietary r eports t o t hird par ties t hat are supporting implementation at their plant, and for submittals to the NRC.

WCAP-16364-NP, Rev. 2 i I I

May 2010

PWR Owners Group Member Participation* for Project Task TSTF-422/ PA-LSC-0364 Utility Member Plant Site(s) Participant Yes I o AmerenUE Ca Ilaway (W) X American Electric Power D.C. Cook l&2 (W) X Arizona Public Service Palo Verde Unit 1, 2, & 3 (CE) X Constellation Energy Group Calvert Cliffs I & 2 (CE) X Constellation Energy Group Ginna (W) X Dominion Connecticut Millstone 2 (CE) X Dominion Connecticut Millstone 3 (W) X Dominion Kewaunee Kewaunee (W) X Dominion VA North Anna I.& 2, Surry I & 2 (W) X Duke Energy Catawba I & 2, McGuire I & 2 (W), X Oconee 1, 2, 3 (B&W)

Entergy P alisades (CE) X Entergy Nuclear Northeast Indian Point 2 & 3 (W) X Arkansas 2, Waterford 3 (CE), X Entergy Operations South Arkansas I (B&W)

Exelon Generation Co. LLC Braidwood I & 2, Byron I & 2 (W), X TMI I (B&W)

FirstEnergy Nuclear Operating Co Beaver Valley I & 2 (W), Davis-Besse X (B&W)

Florida Power & Light Group St. Lucie I & 2 (CE) X Florida Power & Light Group Turkey Point 3 & 4, Seabrook (W) X Florida Power & Light Group Pt. Beach l&2 (W) X Luminant Power Comanche Peak I & 2 (W) X Omaha Public Power District Fort Calhoun (CE) X Pacific Gas & Electric Diablo Canyon I & 2 (W) X Progress Energy Robinson 2, Shearon Harris (W), X Crystal River 3 (B&W)

PSEG - Nuclear Salem I & 2 (W) X Southern California Edison SONGS 2 & 3 (CE) X South Carolina Electric & Gas V.C. Summer (W) X So. Texas Project Nuclear Operating Co. South Texas Project I & 2 (W) X Southern Nuclear Operating Co. Farley I & 2, Vogtle I & 2 (W) X Tennessee Valley Authority Sequoyah I & 2, Watts Bar (W) X Wolf Creek Nuclear Operating Co. Wolf Creek (W) X Xcel Energy Prairie Island l&2 X Project participants as of the date the final deliverable was completed. On occasion, additional members will join a project.

Please contact the PWR Owners Group Program Management Office to verify participation before sending this document to participants not listed above.

WCAP-16364-NP, Rev. 2 May 2010

PWR Owners Group International Member Participation* for Project Task TSTF-422/ PA-LSC-0364 Plant Site(s) Participant Utility Member

  • Yes 4o British Energy Sizewell B X Electrabel (Belgian Utilities) Doel 1, 2 & 4, Tihange 1 & 3 X Hokkaido Tomari I & 2 (MMI) X Japan Atomic Power Company Tsuruga 2 (MHI) X Mihama 1, 2 & 3, Ohi 1, 2, 3 & 4, X Kansai Electric Co., LTD Takahama 1, 2, 3 &4 (W & Mi-Il)

Kori 1, 2, 3 & 4 X Korea Hydro & Nuclear Power Corp. Yonggwang I & 2 (W)

Korea Hydro & Nuclear Power Corp. Yonggwang 3, 4, 5 & 6 X Ulchin 3, 4,5 & 6(CE).

Kyushu Genkai 1, 2, 3 & 4, Sendai 1 & 2 X (MHI)

Nuklearna Electrarna KRSKO Krsko (W) X Axpo AG Beznau I & 2 (W) X Ringhals AB Ringhals 2, 3 & 4 (W) X Shikoku Ikata 1, 2 & 3 (MHW) X Spanish Utilities Asco I & 2, Vandellos 2, X Almaraz I & 2 (W)

Taiwan Power Co. Maanshan I & 2 (W) X Electricite de France 54 Units X This is a list of participants in this project as of the date the final deliverable was completed. On occasion, additional members will join a project. Please contact the PWR Owners Group Program Management Office to verify participation before sending documents to participants not listed above.

I WCAP-16364-NP, Rev. 2 iii I May 2010

Record of Revisions Rev Dat e Revision Description 00 See Original Issue EDMS 01 April 2010 The NRC requested that the RITSTF Initiative 1 Travelers be revised and that the text be clarified with respect to interaction between TSTF-422 and LCO 3.0.4. This was modified in Section 2.5. A revised TSTF-422 (CE) Traveler for the NRC has been submitted.

2 May 2010 Editorial Changes, Added PA number WCAP-16364-NP, Rev. 2 Page 1 of ll May 2010

TABLE OF CONTENTS 1.0 Impact on Maintenance Rule (a)(4) Program for Assessment and M anagem ent of Risk ................................................................................................ 4 2.0 Risk Assessment and management Considerations ................................................... 6 2.1 M ethods of assessm ent ...................................................................................... 6 2.2 Considerations From CEOG Topical Report ................................................... 6 2.3 G eneral Guidance ................................................ 7 2.4 Guidance for Specific Technical Specifications ............................................... 8 2.5 Interaction Between TSTF-422 and LCO 3.0.4 .............................................. 10 3.0 R eferences ...................................................................................................................... 11 WCAP-16364-NP, Rev. 2 Page 2 of ll May 2010

List of Acronyms AC Al ternating Current AFW Auxiliary Feedwater CCW Component Cooling Water CDP Core Damage Probability CEOG Combustion Engineering Owners Group CIAS Containment Isolation Actuation Signal CIV Containment Isolation Valve CPIS Containment Purge Isolation System CR C ontrol Room CREACUS Control Room Emergency Air Cleanup System CREATCS Control Room Emergency Air Temperature Control System CRIS Control Room Isolation Signal CVCS Chemical and Volume Control System DC Dire ct Current ECCS Emergency Core Cooling System ECW Emergency Cooling Water ESFAS Engineered Safety Features Actuation System LERP Large Early Release Probability NEI Nuclear Energy Institute NRC Nu clear Regulatory Commission NSSS Nuclear Steam Supply System NUMARC Nuclear Management and Resource Council RCP Reactor Coolant Pump RCS Reactor Coolant System RG R egulatory Guide RITS Risk Informed Technical Specification RWT Refueling Water Tank SDC Shutdow n Cooling SE Saf ety Evaluation SG Steam Generator SIAS Safety Injection Actuation Signal STS Standard Technical Specification SWS Service Water System TDAFW Turbine-Driven Auxiliary Feedwater TS T echnical Specification TSTF Technical Specification Task Force UHS Ultimate Heat Sink WCAP-16364-NP, Rev. 2 Page 3 of 11 May 2010

1.0 Impact on Maintenance Rule (a)(4) Program for Assessment and Management of Risk The purpose of this report is to provide guidance to the utility in implementing TSTF-422 (Reference 1) for the risk informed modifications to selected required action endstates for CE PWRs. This change is one of several risk informed Technical Specification (TS) changes intended to better manage the risk of plant operation by improving the integration between the Technical Specifications and Maintenance Rule. This guidance is applicable to all Technical Specification changes approved in the Topical Report (Reference 2). The preferred mode end states initiative applicable to those Standard Technical Specifications (STS) NUREG-1432, Revision 3, "Standard Technical Specifications for Combustion Engineering Plants," (Reference 6) Required Actions are explicitly identified in Table 1. Adoption of the associated TS changes will allow the operator increased flexibility in managing risk when in those TS shutdown actions. Specifically, these changes will allow the plant to remain in Mode 4, pending the results of a risk evaluation.

As Reference 2 indicates, while Mode 5 is an acceptable low risk end state, the risk of operation in Mode 4 is often lower. Generic risk assessments demonstrated that this lower risk is largely due to the availability of increased RCS heat removal resources in Mode 4. While Reference 2 identifies the benefits of remaining in Mode 4 following a shutdown, it recognizes that configurations may arise in Mode 4 that require special attention and may impact the decision to perform maintenance in that mode. Such activities may involve remaining in Mode 4 with the unavailability of turbine driven or diesel driven Auxiliary Feedwater (AFW) capability. Therefore, prior to implementing a risk-informed decision to remain in Mode 4, a risk evaluation must be performed that considers the guidance contained in Section 2 of this document. The risk assessment will be performed in accordance with NUMARC-93-01 (Reference 3). The risk assessment may be qualitative or quantitative, can credit generic insights identified in References I and 2 and should consider those TS specific "good practices" that are identified in References I and 2 and are summarized in Table 2.

Revision 01 to this document reflects a change to Reference I regarding the use of LCO 3.0.4.

The specific change is included in Reference 5 and is documented in Section 2.5 of this report.

WCAP-1 6364-NP, Rev. 2 Page 4 of 11 May 2010

Table 1 Summary of NUREG-1432 Technical Specification Required Actions with Revised Mode End States Required Action Technical Specification Title 3.3.5.D.2 (Analog)* ESFAS Logic and Manual Trip 3.3.8.B.2 (Analog)* CPIS (Containment Purge Isolation System) 3.3.8.B.2 (Analog)* CRIS (Control Room Isolation Signal) 3.3.9.D.2 (Analog)* CVCS (Chemical and Volume Control System) Isolation Signal 3.3.1O.B.2 (Analog)* Shield Building Filtration Actuation Signal 3.3.6.E.2 (Digital)* ESFAS Logic and Manual Trip 3.3.8.B.2 (Digital)* CPIS (Containment Purge Isolation System) 3.3.9.B.2 (Digital)* CRIS (Control Room Isolation Signal) 3.4.6.A.2 RCS Loops-Mode 4 3.5.4.B. 1 RWT (Refueling Water Tank) 3.6.2.D.2 Containment Air Locks 3.6.3.F.2 CIVs (Containment Isolation valves) 3.6.4.B.2 C ontainment Pressure 3.6.5.B.2 Containment Air Temperature 3.6.6A.B.2& E.2 Containment Spray and Cooling System (Credit taken for Iodine removal) 3.6.6B.F.2 Containment Spray and Cooling System (Credit not taken for Iodine removal) 3.6.1 I.B.2 S hield Building 3.7.7.B.2 CCW (Component Cooling Water) System 3.7.8.B.2 SWS (Service Water System) 3.7.9.B.2 UHS (Ultimate Heat Sink) 3.7.10.B.2 ECW (Emergency Cooling Water) 3.7.1 1.C.2 CREACUS (Control Room Emergency Air Cleanup System) 3.7.12.B.2 CREATCS (Control Room Emergency Air Temperature Control System) 3.7.13.C.2 ECCS Pump Room EACS (Exhaust Air Cleanup System) 3.7.15.C.2 Penetration Room EACS (Exhaust Air Cleanup System) 3.8.1.G.2 A C Sources-Operating 3.8.4.D.2 DC Sources- Operating 3.8.7.B.2 Inverters - Operating

WCAP-16364-NP, Rev. 2 Page 5 of 11 May 2010

2.0 Risk Assessment and management Considerations This section describes considerations for risk assessment and management relative to use of the Reference 2 preferred mode end states initiative.

2.1 Methods of assessment NUMARC-93-01 provides separate guidance for assessing risk during power operation (Section 11.3.4), and during shutdown conditions (Section 11.3.6). Thus, Section 11 .3.6 of NUMARC-93-01 contains the appropriate guidance for use of the preferred mode end states initiative. The guidance is based on maintaining defense-in-depth for key safety functions necessary for safe shutdown. The Topical Report (Reference 2) uses a quantitative assessment and qualitative-based resource evaluation to demonstrate core decay heat removal capabilities in Mode 4 are normally greater than in Mode 5, and hence remaining in Mode 4 is acceptable.

It is expected that consideration of the risk impacts of the preferred mode end state change will generally be performed qualitatively, or through a combination of quantitative and qualitative methods. In performing the Mode 4 risk assessments, the use of a key safety function defense-in-depth approach, as discussed in NUMARC-91-06 (Reference 4) (and Section I I of NUMARC-93-01) is considered an acceptable approach to satisfy the requirements regarding risk assessment and management. In performing this assessment, it should be ensured that adequate defense-in-depth for keysafety functions will be preserved in the use of the preferred end state Mode.

Application of the key safety function approach to the Mode 4 (i.e., "hot shutdown") may require additional considerations relative to the reactor coolant system being at a higher temperature, and pressure above atmospheric. Quantitative lower Mode risk assessments may also be used provided applicable tools and models are available. For those plants capable of quantifying the risk impact, the risk impact of the use of the preferred mode end states initiative may be quantified and compared to risk management thresholds provided in Section 11.3.7.2 of NUMARC-93-01 so that appropriate risk management actions can be implemented.

2.2 Considerations From CEOG Topical Report Some restrictions and enhanced guidance were determined by the TS-specific risk assessments, included in the Topical Report (Reference 2) and the staff's SE (included in Reference 2), in order to meet the guidance provided in RGs 1. 174 and 1.177 regarding defense-in-depth and potential high risk configurations. These restrictions and guidance are intended (1) to preclude preventive maintenance and operational activities on equipment combinations leading to reduced defense-in-depth and potentially high risk configurations and (2) to identify actions to exit expeditiously a risk-significant configuration should it occur. These restrictions and guidance should be included in appropriate plant procedures and / or administrative controls to preclude high risk plant configurations when the plant is in the preferred end states.

WCAP-16364-NP, Rev. 2 Page 6 of I I May 2010

The following sections describe this guidance. Both general guidance and specific guidance for particular Technical Specifications are provided.

2.3 Gen eral Guidance The following general guidance is provided for use when implementing TSTF-422:

I) Plants implementing the RITS initiative must commit to using the guidance of NUMARC 01, Section 11 for risk assessments performed to assess the risk ofutilizing the preferred end state, which may be the same process used for Maintenance Rule (a)(4) risk assessments.

Currently, NRC Regulatory Guide 1.182 provides that the NEI guidance is one acceptable approach to implement 10 CFR 50.65(a)(4). The guidance provides flexibility with respect to risk assessment and risk management approaches and allows for a combination of qualitative and quantitative evaluations as well as use of bounding assessments.

2) For all instances in which the preferred mode end.states initiative is used, the plant must perform a risk assessment consistent with NUMARC-93-01, Revision 3, Section 11. This assessment must be performed regardless of whether the entry into the preferred end state is for the performance of maintenance, or for any other reason. Assessments that recognize the contemporaneous configuration and refer to insights identified in the Topical Report (Reference 2) are acceptable as are bounding quantitative assessments.
3) Should contemporaneous risk assessments result in the identification of a high risk configuration, risk management actions should be taken. Risk management actions include consideration of expeditiously exiting Mode 4 (i.e., "hot shutdown") to a mode with lesser risk.
4) In performing Mode 4 risk assessments, the risk assessment should consider that reduced risks are associated with increased diversity and redundancy ofRCS heat removal capability in Mode 4. In particular, when considering remaining in Mode 4, the impact of equipment outages which reduce the redundancy of heat removal in the shutdown mode (i.e., Mode 5) should be assessed. Once on shutdown cooling (SDC) risks of Mode 4 and Mode 5 operation are similar. Note that the risk of SDC operation is reduced when backup steam generator (SG) heat removal is available.
5) Entry into the preferred end state, as modified by TSTF-422, should be for the primary purpose of accomplishing repairs or completing any other action which necessitated exiting the original operating mode.
6) NUMARC-93-01 discusses risk metrics for maintenance configurations. Configurations that should not be entered voluntarily have been defined as those configurations- whose overall incremental Core Damage Probability (CDP) or incremental Large Early Release Probability (LERP) is > 1.OE-5 and 1.OE-6 respectively, or have an instantaneous Core Damage WCAP-16364-NP, Rev. 2 Page 7 of I1 May 2010

Frequency >1.OE-3 per year. Emergent conditions should be treated in accordance with NEI -

93-01, Revision 3 (Reference 3).

7) Mode 5 remains an acceptable end state. Guidance contained herein should not be interpreted as discouraging a Mode 5 end state should that be the desired end state for operational or other considerations. While Mode 4 end states are often lower risk, the risk of Mode 5 operation, where permitted by Technical Specifications, remains acceptable.
8) Documentation of the basis for the decision to remain in Mode 4 should be available for internal reference. Acceptable documentation includes reference to pre-analyzed conditions, qualitative assessments of the plant configuration identifying the key features of the contemporaneous state, or on-line current risk assessments.
9) The risk of remaining in Mode 4 is reduced when SG inventory is available. The decision to remain in Mode 4 should consider the availability of SG inventory.
10) As Mode 4 includes high pressure capability, remaining in Mode 4 requires the RCS pressure boundary to be functional and appropriate pressure relief is available. Specifically, when the RCS is isolated from the SDC system, the RCS pressure boundary should be capable of pressure relief via pressurizer safety valves.

2.4 Guidance for Specific Technical Specifications The following table provides guidance for use of the preferred mode end states for specific Technical Specification conditions.

Table 2 Good Practice/Considerations for Remaining in Mode 4+

NUREG-1432 Tech Mode 4 End State Guidance Spec

  • 3.3.8 (Digital) The Containment Purge Isolation Signal (CPIS) supports automatic or manual Containment Purge isolation of any open containment purge valves upon indication of high Isolation Signal containment airborne radiation. When the CPIS is disabled in Mode 4, (CPIS) operation of the containment mini-purge should be restricted.

Consideration should be givento maintaining the availability of Containment Isolation Actuation Signal (CIAS) during the CPIS Mode 4 repair.

3.3.9 (Digital) The Control Room isolation signal (CRIS) initiates actuation of the emergency Control Room radiation protection system and terminates the normal supply of outside air to Isolation Signal the control room.

(CRIS)

With CRIS unavailable, consideration should be given to maintaining the availability of SIAS and alternate shutdown panel or other remote shutdown capabilities.

WCAP-16364-NP, Rev. 2 Page 8 of l1 May 2010

Table 2 (Continued)

Good Practice/Considerations for Remaining in Mode 4+

NUREG-1432 Tech Mode 4 End State Guidance Spec

  • 3.6.4 Containment Containment pressure control is necessary to assure plant operations within Pressure design basis limits in the event of severe plant challenges. As high pressure containment challenges are unlikely and the containment is particularly robust when considering such challenges in Mode 4, additional actions are unnecessary.

Steel shell containments are susceptible to vacuum conditions during inadvertent spray action. Such an event could potentially challenge the containment.

For plants with steel shell containments and the lower limit pressure specification is not met, confirm the operability of the vacuum breakers.

For all plants, entering this action statement for not meeting the low containment pressure limit for a period projected to exceed one day, one containment spray pump should be secured.

3.7.7 Component CCW provides cooling to RCP seals. Degradation of the CCW system can Cooling Water increase the risk of loss of seal cooling. C CW cooling to the RCP seals is (CCW) expected.

In the event that CCW inoperability results in a loss of RCP seal cooling, note that remaining in Mode 4 at the upper temperature limits may degrade Reactor Coolant Pump (RCP) seal elastomers. Going to Mode 5 ensures adequately low RCS temperatures so that any RCP seal challenges would be avoided.

Prior to entry into Mode 5 due to a loss of CCW to the RCP seals, the redundant CCW train should be confirmed to be available and backup cooling water systems should be considered for contingency use.

SG inventory should be maintained to ensure a diverse and redundant heat removal source if CCW is lost and renders the SDC system unavailable.

3.7.8 Service Water For conditions where the TS entry also results in the entry into the CCW TS System/Salt Water (TS 3.7.7) the conditions and guidance of 3.7.7 apply.

Cooling System/

Essential Spray Pond System/Auxiliary Component Cooling Water System (nomenclature Plant Specific)

WCAP-16364-NP, Rev. 2 Page 9 of II May 2010

Table 2 (Continued)

Good Practice/Considerations for Remaining in Mode 4+

NUREG-1432 Tech Mode 4 End State Guidance Spec

  • 3.7.11 Control Room The function of the CREACUS is to recirculate and filter control room air.

Emergency Air Cleanup System The Control Room (CR) plant staff should be made aware of the system (CREACUS) inoperability. Ensure availability of respiratory units and CR pressurization systems. Leakage pathways should be properly controlled.

Availability of alternate shutdown panels and local shutdown stations should be maintained.

3.7.12 Control Room CREATCS is required to ensure continued control room habitability and ensure Emergency Air that control room temperature will not exceed equipment operability Temperature Control requirements following isolation of the control room.

System (CREATCS)

Availability of alternate shutdown panels and local shutdown stations should be maintained.

3.8.1 AC Sources Switchyard activities, other than those necessary to restore offsite power, Operating should be prohibited.

Note that to properly use a Turbine-Driven AFW (TDAFW) pump(s) the SG pressure must be maintained above the minimum recommended pressure required to operate the TDAFW.

+ Based on Reference I

  • Applicability plant dependent 2.5 Interaction Between TSTF-422 and LCO 3.0.4 The general guidance states that for all instances in which the preferred mode end states initiative is used, the plant must perform a risk assessment and the assessment must be performed regardless of whether the entry into the preferred end state (i.e., Mode 4) is for the performance of maintenance, or for any other reason. Performance of the risk assessment is required regardless of whether the plant is transitioning down in Mode (i.e., from Mode 3 to Mode 4) or up in Mode (i.e.,from Mode 5 to Mode 4.)

TSTF-422 changes the final end-state for various Required Actions and allows the plant to stay in the Mode of Applicability. The revised Required Actions are also modified bya Note that prohibits the use of LCO 3.0.4.a to enter the end-state Mode during startup with the LCO not met. However, entry into the end-state Mode during startup using LCO 3.0.4.b is allowed. This provides assurance that the required risk assessments are performed and the appropriate risk management actions are implemented prior to entering the end-state Mode during startup. The Bases of LCO 3.0.4.b contain relevant considerations for performing this risk assessment.

WCAP-16364-NP, Rev. 2 Page 10 of I1 May 2010

3.0 R eferences

1. TSTF-422, Revision 2,. "Change in Technical Specifications End States (CE NPSD- 1186),"

December 22, 2009.

2. CE NPSD-1 186-A, "Technical Justification for the Risk Informed Modification to Selected Required Action End States for CEOG Member PWRs," Westinghouse Electric Company, October 2001.
3. NUMARC-93-01, Revision 3, "Industry Guideline for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants," Nuclear Management and Resource Council, July 2000.
4. NUMARC-91-06, "Guidelines for Industry Actions to Assess Shutdown Management,"

Nuclear Management and Resource Council, December 1991.

5. TSTF-09-25, "Transmittal of Revised Risk Informed End State Travelers," Letter TSTF, (K.

Shrader, et al) to USNRC, December 22, 2009.

6. NUREG-1432, Revision 3, "Standard Technical Specifications for Combustion Engineering Plant," June 2004; WCAP-16364-NP, Rev. 2 Page 11oflI May 2010

WCAP-16364-NP, Rev. 2 Westinghouse Non-Proprietary Class 3 Westinghouse Electric Company, LLC 20 International Drive Windsor, Connecticut 06095-0500

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