Text

License Amendment Request (LAR) for Measurement Uncertainty Recapture (Mur) Power Uprate - Response to NRC Requests for Additional Information (Rals)
	ML15029A417
Person / Time
Site:	Catawba
Issue date:	01/22/2015
From:	Henderson K; Duke Energy Carolinas
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
Shared Package
ML15029A611	List: CNS-15-007, License Amendment Request (LAR) for Measurement Uncertainty Recapture (Mur) Power Uprate - Response to NRC Requests for Additional Information (Rals);
References
	CNS-15-007, TAC MF4526, TAC MF4527
	Download: ML15029A417 (81)
	v • d • e

Kelvin Henderson

DUKE Vice President Catawba Nuclear Station

'IpENERGY, Duke Energy CNO1VP 1 4800 Concord Road York, SC 29745 o: 803.701.4251 f: 803.701.3221 CNS-15-007 January 22, 2015 10 CFR 50.90 U. S. Nuclear Regulatory Commission (NRC)

Attention: Document Control Desk Washington, D. C. 20555-0001

Subject:

Duke Energy Carolinas, LLC (Duke Energy)

Catawba Nuclear Station, Units 1 and 2 Docket Numbers 50-413 and 50-414 License Amendment Request (LAR) for Measurement Uncertainty Recapture (MUR) Power Uprate Response to NRC Requests for Additional Information (RAls)

(TAC Nos. MF4526 and MF4527)

References:

1. Letters from Duke Energy to NRC, dated June 23, 2014 (ADAMS Accession Number ML14176A109), August 26, 2014 (ADAMS Accession Number ML14245A059), and December 15, 2014 (ADAMS Accession Number not yet assigned)

2. Letters from NRC to Duke Energy, dated November 4, 2014 (ADAMS Accession Number ML14303A279) and November 26, 2014 (ADAMS Accession Number ML14325A667)

The Reference 1 letters submitted and supplemented a LAR for the Renewed Facility Operating Licenses (FOLs) for Catawba Nuclear Station (CNS) Units 1 and 2 NPF-35 and NPF-52 and the subject Technical Specifications (TS) to support a MUR power uprate for Catawba Unit 1. The Reference 2 letters transmitted two sets of RAI questions from the NRC associated with the LAR.

The purpose of this letter is to formally respond to the second set of RAls. The attachment to this letter constitutes Duke Energy's response to these RAls. The format of the attachment is to re-state each RAI question, followed by its associated response. Note that with respect to question EEEB RAI 6, Duke Energy is still evaluating the issues associated with Radiation Zones 30 and 45 (LAR Commitments 11 and 12, respectively, in the June 23, 2014 Reference 1 letter). Duke Energy will inform the NRC Project Manager regarding the expected response date for this issue once the work scope necessary to complete this portion of the response has been determined.

The conclusions of the original Regulatory.Evaluation and Environmental Consideration are unaffected as a result of this RAI response.

There are no regulatory commitments contained in this letter or its attachment. AOCD (

ý--44 www.duke-energy.com

I. . Pe .. ,ator Commission

-jNuclear January 22, 2015 Page 2 Pursuant to 10 CFR 50.91, a copy of this amendment request supplement is being sent to the designated official of the State of South Carolina.

Inquiries on this matter should be directed to L. J. Rudy of Catawba Regulatory Affairs at (803) 701-3084.

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

Executed on January 22, 2015.

Very truly yours, Kelvin Henderson Vice President, Catawba Nuclear Station LJR/s Attachment

11 SQNucleanr Reguflatory Commis.sion January 22, 2015 Page 3 xc (with attachment/with CD):

V. M. McCree Regional Administrator U.S. Nuclear Regulatory Commission - Region II Marquis One Tower 245 Peachtree Center Ave. NE, Suite 1200 Atlanta, Georgia 30303-1257 G. A. Hutto, III, NRC Senior Resident Inspector Catawba Nuclear Station G. E. Miller Project Manager Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Mail Stop 8 G9A 11555 Rockville Pike Rockville, Maryland 20852-2738 xc (with attachment/without CD):

S. E. Jenkins, Manager Radioactive & Infectious Waste Management Division of Waste Management South Carolina Department of Health and Environmental Control 2600 Bull Street Columbia, SC 29201

Attachment Response to NRC Requests for Additional Information (RAIs)

Attachment Page REQUEST FOR ADDITIONAL INFORMATION LICENSE AMENDMENT REQUEST TO SUPPORT THE MEASUREMENT UNCERTAINTY RECAPTURE POWER UPRATE DUKE ENERGY CAROLINAS, LLC CATAWBA NUCLEAR STATION, UNITS 1 AND 2 DOCKET NOS. 50-413 AND 50-414 TAC NOS. MF4526 AND MF4527 By letter dated June 23, 2014, Duke Energy Carolinas, LLC, the licensee for Catawba Nuclear Station, Units 1 and 2 (Catawba), requested a measurement uncertainty recapture (MUR) power uprate (Agencywide Documents Access and Management System (ADAMS) Accession No. ML14176A109). The proposed revision would increase the Catawba, Unit 1, authorized core power level from 3411 megawatts thermal (MWt) to 3469 MWt, an increase of 1.7 percent rated thermal power (RTP).

Based on the review of the amendment request, the NRC staff has determined that additional information is required regarding the MUR power uprate.

Vessels and Internals Integrity Branch (EVIB) - RAI 1 Paragraph (b)(1) of 10 CFR 50.61, "Fracture Toughness Requirements for Protection Against Pressurized Thermal Shock Events," requires that for each pressurized water nuclear power reactor, the licensee shall project values of RTPTS, accepted by the U. S. Nuclear Regulatory Commission (NRC), for each reactor vessel (RV) beltline material. Paragraph (a)(3) of Title 10 of the Code of FederalRegulations(10 CFR) 50.61 defines the RV beltline to include the region that directly surrounds the effective height of the active core and adjacent regions of the RV that are predicted to experience sufficient neutron radiation damage to be-considered in the selection of the most limiting material. RIS 2014-11 further clarifies that the beltline is defined to include those portions of the RV ferritic materials with neutron fluence greater than 1 x 1017 n/cm 2 (E > 1 MeV) at the end of the licensed operating period.

A. Verify that RTpTs was calculated for all ferritic RV materials expected to receive neutron fluence greater than 1 x 1017 n/cm 2 at the end of the licensed operating period. If not, revise the RTPTS calculations in the LAR, Enclosure 2, Paragraph IV.1.C.i and Table IV.1.C-1 to include all ferritic RV materials that will receive a neutron fluence greater than 1 x 1017 n/cm 2 at the end of the licensed operating period and submit the revised calculations to the NRC for review as a part of the management update and retrieval (MUR) LAR.

Attachment Page Duke Energy Response:

This RAI is being addressed via Westinghouse letter MCOE-LTR-15-2, which is included at the end of this attachment.

B. Clarify how the "bounding nozzle shell material" referred to in Table 5-42 of the Catawba 1 Updated Final Safety Report (UFSAR) correlates to the materials in the LAR, Enclosure 2, Table IV.1.C-1.

Duke Energy Response:

This RAI is being addressed via Westinghouse letter MCOE-LTR-15-2, which is included at the end of this attachment.

EVIB - RAI 2 10 CFR Part 50, Appendix G requires that P-T limits be developed to bound all ferritic materials in the RV. Further, Sections I and IV.A of 10 CFR Part 50, Appendix G specify that all ferritic reactor coolant pressure boundary (RCPB) components outside of the RV must meet the applicable requirements of American Society of Mechanical Engineers (ASME Code),Section III, "Rules for Construction of Nuclear Facility Components".

As clarified in RIS 2014-11, Pressure and Temperature (P-T) limit calculations for ferritic RV materials other than those materials with the highest reference temperature may define P-T curves that are more limiting because the consideration of stress levels from structural discontinuities (such as nozzles) may produce a lower allowable pressure.

Describe how the current P-T limit curves for Catawba 1 consider all ferritic components within the entire RV and the effects of neutron radiation for any locations that are predicted to experience a neutron fluence exposure greater than lx1017 n/cm 2 (E > 1 MeV) at the end of the licensed operating period.

If the current P-T limit curves do not consider all ferritic components within the entire RV and the effects of neutron radiation for any locations that are predicted to experience a neutron fluence exposure greater than lx1017 n/cm 2 (E > 1 MeV) at the end of the licensed operating period, provide appropriately revised P-T limit curves to the NRC for review as a part of the MUR LAR.

Duke Energy Response:

This RAI is being addressed via Westinghouse letter MCOE-LTR-13-103, which is included at the end of this attachment.

EVIB - RAI 3 10 CFR Part 50, Appendix G, Paragraph IV.A.1 .a requires that RV beltline materials must maintain Charpy upper shelf energy (USE) throughout the operating life of the RV of no less than 50 ft-lbs, unless an equivalent margins analysis (EMA) is performed in the manner specified in 10 CFR Part 50, Appendix G, Paragraph IV.A.1 .a that is approved by the NRC.

Attachment Page RIS 2014-11 clarifies that the beltline is defined to include all ferritic materials of the RV with a neutron fluence greater than 1 x 1017 n/cm2 (E > 1 MeV) at the end of the licensed operating period.

A. Verify that the USE calculations for Catawba 1 include all ferritic RV materials expected to receive a neutron fluence greater than 1 x 1017 n/cm2, (E > 1 MeV). If not, update the USE calculations in the LAR, Enclosure 2, Paragraph IV.1.C.v and Table IV.1.C-6 to include all ferritic RV materials that will receive a neutron fluence greater than 1 x 1017 n/cm2 at the end of the licensed operating period and submit the revised calculations to the NRC for review as a part of the MUR LAR.

Duke Energy Response:

This RAI is being addressed via Westinghouse letter MCOE-LTR-15-2, which is included at the end of this attachment.

B. Clarify how the "bounding nozzle shell material" referred to in Table 5-44 of the Catawba 1 UFSAR correlates to the materials in the LAR, Enclosure 2, Table IV.1.C-6.

Duke Energy Response:

This RAI is being addressed via Westinghouse letter MCOE-LTR-15-2, which is included at the end of this attachment.

Electrical Engineering Branch (EEEB) - RAI I Provide a list and brief discussion of the electrical analysis and calculations which the licensee reviewed or updated to determine that the alternate current (AC) distribution system(s) remain bounded by the existing analysis and calculations of record.

Duke Energy Response:

The electrical calculations of record that were reviewed to determine the impact of MUR on AC distribution system(s) are listed in the following table. This review determined that the AC distribution system(s) remain bounded by the existing analysis and calculations of record.

Number Title Description CNC-1381.05-00-0065 U112, 4.16kV Essential This calculation determines the Auxiliary Power System (EPC) capability of the Emergency Diesel-Generator (DIG) DIG to carry assigned loads Dynamic Loading Analysis following a LOCA or a Blackout and investigates the effects of tripping and restarting the largest motor while the rest of the loads are running.

Attachment Page Number Title Description CNC-1381.05-00-0118 Station Blackout Coping This calculation documents the Study ability of installed equipment to cope with Station Blackout (SBO) within the guidelines of NUMARC 87-00, Revision 1.

CNC-1381.05-00-0159 U1/2, 4.16kV Essential This calculation determines the Auxiliary Power System (EPC) capability of the Emergency Diesel-Generator (D/G) LOCA D/G to carry assigned loads Loading Simulation CYME following a LOCA/LOOP and Program reject the largest load.

CNC-1 381.05-00-0194 Ul/2, AC Power System ETAP This calculation establishes Model Base File the ETAP PowerStation base file that is subsequently used for any auxiliary power system analytical calculation using ETAP PowerStation.

CNC-1381.05-00-0198 U1 6.9kV, 4.16kV & 600V This calculation documents Auxiliary Power Systems ETAP load flow / voltage drop Safety-Related Voltage analyses of the Unit I AC Analysis Auxiliary Power Systems.

CNC-1381.05-00-0209 Catawba Unit I ETAP This calculation:

PowerStation Auxiliary Power Determines the 3 phase short System Fault Study circuit current (momentary and interrupting) at all buses and breakers in the 13.8kV, 6.9kV, 4.16kV, and 600V safety and non-safety systems.

Compares the calculated results to the equipment ratings to ensure that the equipment's short circuit rating is not exceeded.

CNC-1381.06-00-0030 6.9KV Normal Auxiliary Power This calculation determines the System Switchgear Relay settings for the relays on the Settings 6.9 kV Normal Auxiliary Power System.

CNC-1381.06-00-0032 Unit Main Power System This calculation determines the Protective Relay Setting settings for devices protecting Calculation unit main power system equipment and coordinate with protective relaying on systems EBD, EPB, and EPM to ensure selective tripping.

Attachment Page Number Title Description CNC-1381.06-00-0060 U1/2, 600V SSF Diesel- This calculation determines:

Generator (DIG) and Auxiliary The maximum operating load Power System Loading and required of the Standby Voltage Analysis Shutdown Facility (SSF) D/G.

The minimum terminal voltages for buses and loads of the SSF auxiliary power system when aligned to the SSF D/G.

CNC-1381.06-00-0061 Catawba ETAP PowerStation This calculation determines the Symmetrical Short Circuit 3 phase short circuit current Calculation for Unit I & Unit 2 through the generator circuit Main Generator Circuit breakers, compares the results Breakers to the ratings of the generator circuit breakers, and determines the minimum generator circuit breaker contact parting time.

CNC-1381.06-00-0069 Main Generator Voltage This calculation evaluates and Regulator Limiters and provides the basis for the Unit Protection Setting Evaluation 1 and 2 limiter and protection settings used in the Automatic Voltage Regulator (AVR).

CNC-1381.06-00-0073 Main Generator (Zone G) This calculation performs the Protective Relay Setting setting calculations and Calculation documents how each individual protective and alarm function setting was ascertained for the microprocessor based relays for Main Generator protection in Zone G.

EEEB - RAI 2 Provide a list and brief discussion of the electrical analysis and calculations which the licensee reviewed or updated to determine that the DC distribution system(s) [including 240/120 V AC Auxiliary Control and 120 V Vital Instrument and Control Power Systems] remain bounded by the existing analysis and calculations of records.

Duke Energy Response:

The electrical calculations of record that were reviewed to determine the impact of the MUR on DC distribution system(s) [including 240/120 V AC Auxiliary Control and 120 V Vital Instrument and Control Power Systems] are listed in the following table. This Attachment Page review determined that these systems remain bounded by the existing analysis and calculations of record.

Number Title Description CNC-1381.05-00-0007 120VAC Vital Instrumentation This calculation verifies that the and Control Power System 120 VAC Vital Instrumentation Voltage Regulator and and Control voltage regulator Transformer Sizing and transformer are adequately sized.

CNC-1381.05-00-011 125VDC Vital Instrumentation This calculation determines the and Control Power System adequacy of the 125VDC vital Battery and Battery Charger instrumentation and control Sizing Calculation batteries to power their assigned and back-up loads following a LOCA/LOOP event for a 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months coping duration, verifies the charger size is adequate, and computes battery discharge profiles.

CNC-1381.05-00-0050 U1/2, 125VDC Essential This calculation documents Diesel Auxiliary Power Emergency DIG 125 VDC System (EPQ) Battery and batteries and chargers are Charger Sizing adequately sized for the expected load profile.

CNC-1381.05-00-0135 U1/2, 125VDC Vital I&C Power This calculation documents the System (EPL) Short Circuit EPL system short circuit Analysis analysis.

CNC-1381.05-00-0136 120 VAC Essential Power This calculation documents the System (EPY) Voltage Drop EPY system voltage drop Calculation analysis.

CNC-1381.05-00-0149 UI/2, 125 VDC Vital I&C This calculation documents the Power System (EPL) Voltage EPL system voltage drop Drop Analysis analysis.

CNC-1381.05-00-0150 Station Blackout Battery This calculation documents Sizing Calculation for the Emergency D/G 125 VDC 125VDC Diesel Auxiliary batteries are adequately sized Power (EPQ) Batteries for the expected SBO load profile.

CNC-1381.05-00-0151 Voltage Analysis for the This calculation provides the 125VDC Essential Diesel analysis to ensure the 125VDC Auxiliary Power (EPQ) Essential Diesel Auxiliary Power System batteries will supply adequate voltage to critical DC components during a SBO.

Attachment Page Number Title Description CNC-1381.05-00-0235 Unit 1, 125VDC Essential This calculation determines the Diesel Auxiliary Power voltage adequacy of the 125 System (EPQ) Voltage Drop VDC Diesel Auxiliary Power (EPQ) System batteries during a LOCAISBO for the required 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months duration.

CNC-1381.06-00-0016 230kV Switchyard 125VDC This calculation verifies that the Battery and Charger Sizing switchyard 125 VDC batteries and chargers are adequately sized.

CNC-1381.06-00-0019 250VDC Power System This calculation verifies that the Battery and Battery Charger 250 VDC batteries and chargers Sizing are adequately sized.

CNC-1381.06-00-0021 240/120 Vac Auxiliary Power This calculation determines the System Inverter Sizing rating of the static inverters of the 240/120 Vac Auxiliary Power System (EPF).

CNC-1381.06-00-0022 240/120VAC Auxiliary Control This calculation verifies that the Power System Voltage 240/120 VAC Auxiliary Control Regulator and Transformer Power System voltage regulator Sizing and transformer are adequately sized.

CNC-1381.06-00-0023 U1/2, 125 VDC Auxiliary This calculation:

Control Power System (EPK) Determines the load duty cycle Battery & Charger Sizing of the EPK system batteries during a LOOP.

Verifies that the battery is capable of supplying the assigned load for 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months (one battery in service).

Verify that the battery is capable of supplying the assigned load for 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months with both batteries in service.

Verifies that the EPK battery chargers are sized to carry their normal continuous loads and recharge their battery within an 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months recharge time.

CNC-1381.06-00-0035 250/125 VDC Safe Shutdown This calculation verifies that the Facility Auxiliary Power SSF Power System batteries and System Battery and Battery battery chargers are adequately Charger Sizing Calculation sized.

Attachment Page Number Title Description CNC-1381.06-00-056 SSF Diesel Generator Battery This calculation verifies that the Sizing Calculation SSF D/G 24 VDC Power System batteries and chargers are adequately sized.

CNC-1 381.06-00-0071 ECS System UPS 120 V Load This calculation documents the Calculation loads on the ECS distribution panels, tracks additional added load impact on the ECS UPS system margin, and verifies component sizing.

EEEB - RAI 3 Provide a large-format copy of the current one line diagrams of the 250 V Direct Current (DC)

Auxiliary Power System, 125 V DC and 240/120 V AC Auxiliary Control Power System, and the safety-related 125 V DC and 120 V Vital Instrument and Control Power System. In addition, please provide a large-format copy of the current one line diagram of the 230 kV switchyard to which CNS Unit 1 and Unit 2 are connected.

Duke Energy Response:

Readable PDF versions of Updated Final Safety Analysis Report (UFSAR) Figures in Chapter 8 are provided via the attached CD for the above request:

UFSAR Figure 8-10, "230KV Switchyard General Arrangement" UFSAR Figure 8-11, "230KV Switchyard 125VDC Auxiliary Power System" UFSAR Figure 8-12, "230KV Switchyard and Station Interconnections" UFSAR Figure 8-22, "125 VDC and 240/120 VAC Auxiliary Control Power Systems" UFSAR Figure 8-23, "250 VDC Auxiliary Power System" UFSAR Figure 8-24, "125 VDC and 120 VAC Vital Instrumentation and Control Power System" The NRC indicated during a conference call discussing this RAI set that a CD would be acceptable.

EEEB - RAI 4 Section V.1.A states that all DC systems will continue to have adequate capacity and capability for plant operation with an MUR power uprate and are bounded by the existing analyses and calculations of record for the plant. It also states that additional load will be placed on the Electrical Computer Support System (ECS) in powering the leading edge flow meter (LEFM). Further, it states that this added load is within the rating of the ECS System.

Provide a discussion of the effects of the ECS additional load on the associated safety-related or non-safety-related buses with an MUR power uprate.

Attachment Page Duke Energy Response:

Catawba DC calculations CNC-1381.06-00-0023, "Ul/2, 125 VDC Auxiliary Control Power System (EPK) Battery and Battery Charger Sizing" and CNC-1381.06-00-0071, "ECS System UPS 120V Load Calculation" have been revised for MUR and reflect that Catawba continues to have adequate capacity and capability for plant operations with an MUR power uprate. Therefore, Catawba's MUR is bounded by existing analyses as described below. Note that the MUR hardware does not affect any safety related power loads.

The purpose of the ECS System UPS Systems is to provide 120 VAC battery backed power in the event that offsite power is lost or in the event of loss of the shared bus. The ECS UPS shall provide 120 VAC to the Operator Aid Computer (OAC) and Control Infrastructure Components installed in the OAC Room and Control Room behind 1(2)

MC2. All of the equipment being affected is non-safety related. A loss of power to the components in the OAC Room and behind 1(2) MC2 in the Control Room does not affect control functions in the Digital Control System (DCS) nor has the ability to initiate a plant transient or accident.

The design purpose for MUR changes to the redundant UPS Systems evaluated in calculation CNC-1381.06-00-0071 address changes for the designated loads listed on distribution panels OECS PL 01 and OECS PL 02 (total 120 VAC load requirements). In the event of the loss of the 600 VAC input power to one of the UPS Systems or the loss of a UPS System the other UPS System shall be capable of carrying the total load of the two distribution panels. Calculation CNC-1381.06-00-0071 identifies post-MUR margins as >

50% at a power factor of 1.0. Also, note that the two Auto Power Transfer Switches (APTS) in cabinet IAXI use ECS as the primary power source and use KUI as the backup power source.

The design purpose of calculation CNC-1381.06-00-0023 is to determine the loading on the batteries. This calculation looks at the actual loading on each inverter to determine the loading on the batteries from the AC loads. Loading on bus 2KXPA is still the worst case loading after MUR uprate on Unit 1. The current AC load is estimated to be 222.35 amps. Using the current load estimate of 222.35, the total load on the inverter is 120 Volts times 222.35 amps, or 26.7 KVA. So the inverters are still adequately sized (L30 KVA).

EEEB - RAI 5 Section V.1.D "Grid Stability" states that the power flow cases used in the generation impact study were developed from the Duke Energy internal year 2012 summer peak case. The results of Duke Energy's annual screening were used as a baseline to identify the impact of the new generation. All cases were modified to include 20 MWe of additional generation at Catawba, Unit 1. To determine the thermal impact on Duke Energy's transmission system, the existing Catawba, Unit 1, generation was increased by 20 MWe.

Provide a summary of the power flow analysis. Confirm whether the power flow analysis also included winter loading in addition to the summer loading. If not, explain why winter loading was not considered. In addition, please provide a discussion of how the economic generation Attachment Page dispatch and the generator interconnection queue was addressed during the thermal impact analysis mentioned above.

Duke Energy Response:

No network upgrades were identified as being attributable to the studied generating facility. This determination is based on a comparison of a model of the transmission system as is and a model of the transmission system that includes the additional generating capacity at Catawba.

Consistent with Duke Energy's generator interconnection studies and transmission planning practices, the power flow analysis was only performed on a summer model.

Duke Energy is summer peaking, so the summer models contain higher loads. Summer models also contain lower facility ratings than winter models because they are based on higher ambient temperatures. The pairing of higher loads and lower ratings creates the most stressed condition on the transmission system.

At the time the request was studied, higher queued generators were modeled. In all scenarios studied, the requested additional output at Catawba is modeled and the remaining Duke Energy generators are economically dispatched to account for the 20 Mw increase at Catawba.

EEEB - RAI 6 Section II.1.D.iii item 44 "Equipment Qualification (EQ) parameters" states that Unit 2 and Unit 1 of CNS share the auxiliary building and that there may be Unit 2 components in the auxiliary building that see environmental changes due to the Unit 1 power uprate. As a result, all components designated for Unit 1 and all components designated and applicable to both units were evaluated in the auxiliary building.

Please verify that the items in the bulleted list on page E2-27 of the LAR have been qualified or are within the CNS's dose limits and have been resolved in the corrective action program.

Duke Energy Response:

The EQ review for the Catawba MUR uprate included a review of equipment in the equipment data base for Unit 1 as well as Unit 2 components in the shared Auxiliary Building. As discussed in the LAR, the EQ evaluation identified the following for further evaluation:

Six pressure transmitters in the Reactor Vessel Level Indication System that had not been confirmed to be qualified at the MUR power uprate total integrated dose (TID) at the time that the LAR was submitted. Further analysis determined that the upper bound TID adjusted for MUR at the installed location of these six transmitters was below the tested qualification dose. Therefore, these six transmitters are qualified for MUR conditions and LAR Commitment 9 is considered complete.

One Struthers Dunn Type 219 relay could not be confirmed to be qualified at the MUR power uprate TID. A detailed materials evaluation concluded that this relay was qualified Attachment Page for the TID adjusted for MUR. The Struthers Dunn Type 219 relay is qualified for MUR conditions and LAR Commitment 10 is considered complete.

Duke Energy is still evaluating the issues associated with Radiation Zones 30 and 45 (LAR Commitments 11 and 12, respectively). Duke Energy will inform the NRC Project Manager regarding the expected response date for this issue once the work scope necessary to complete this portion of the response has been determined.

EEEB - RAI 7 In the August 26t 2014, supplement, Duke submitted additional information related to the EQ evaluation performed on 50 components consisting of in-core thermocouples (40), potential transformers (4), fuses (4), and damper operators (2) that were to be considered prior to implementation of the MUR power uprate. In addition, Section 11.1.D.iii item 44 states that CNS identified 40 enclosures containing 21 individual component types encompassing 330 total components in the auxiliary building that needed to be evaluated for post-MUR conditions. The submittal stated that these commitments were completed and that the results of the evaluation were acceptable for post-MUR EQ conditions.

Provide a summary of the results of the EQ evaluation performed on the in-core thermocouples (40), potential transformers (4), fuses (4), damper operators (2) and the 40 enclosures mentioned above and describe the impacts the results have on the CNS MUR power uprate.

Duke Energy Response:

As discussed in LAR Section I1.1.D.iii item 44 "Equipment Qualification (EQ) parameters",

during the review of EQ documents it was discovered that 50 component IDs were left out of the original evaluation. These were 40 incore thermocouples, four potential transformers, four fuses, and two damper operators. Further review of the incore thermocouples determined that they contained no age-sensitive materials and were therefore not susceptible to radiation effects. Evaluation of the four potential transformers, four fuses, and two damper operators determined that the post-MUR TIDs experienced by these components were within their tested TID. As shown in Table 1, all 50 components are qualified for post-MUR conditions.

While incorporating lessons learned from the McGuire MUR, Catawba identified a number of electrical enclosures that had not been evaluated on an individual component basis.

Individual components in the electrical enclosures were identified and these components were reviewed using the same methodology as the other EQ components - by comparing the component's qualified radiation exposure to the TID adjusted for MUR. As shown in Table 2, all of these additional components were found to be qualified for post-MUR conditions.

LAR Commitment 14 is considered complete.

Attachment Page Table 1: Evaluation of Additional Components from Active Harsh Equipment Data Base Search

Unit Sys Eq Equip Name Manufacturer Tested Total TID Qualification Status Comments Type Rads 1 through 40 1 ENA TE INCORE WESTINGHOUSE N/A N/A Associated cables Per review of CNM-1399.06-00068.001 THERMOCOUPLES qualified for Post MUR. Rev. D4 the incore thermocouples have been determined to be made of chronel-alumel, stainless steel sheathed, and aluminum oxide insulated. Based on this material review there are no age-sensitive materials within the thermocouple component. Therefore, the thermocouple components are not susceptible to radiation effects and remain acceptable at MUR conditions.

The associated incore thermocouple cables have individual EDB tag numbers (For example CN1 NC CX CA-I, etc.).

These individually tagged incore thermocouple cables are EQ harsh and have been evaluated and are qualified for Post MUR conditions.

41 1 EPC SW POTENTIAL General Electric 1.OE+05 9.30E+04 Qualified for Post MUR. Pin Point Dose Calculation CNC-TRANSFORMER 1229.00-00-0046 Rev. 2 provides an LOCATED IN upper bound TID for the switchgear room 1ETB19 BUS taking into account MUR of 9.3 E4 RADs.

42 1 EPC SW POTENTIAL General Electric 1.OE+05 9.30E+04 Qualified for Post MUR.

TRANSFORMER LOCATED IN 1ETB19 DG Attachment Page

Unit Sys Eq Equip Name Manufacturer Tested Total TID Qualification Status Comments Type Rads 43 1 EPC SW BUS SIDE General Electric / 1.00E+05 9.30E+04 Qualified for Post MUR.

POTENTIAL Shawmut TRANSFORMER Pin Point Dose Calculation CNC-FUSES 1229.00-00-0046 Rev. 2 provides an upper bound TID for the switchgear room taking into account MUR of 9.3 E4 RADs.

This upper bound TID is conservatively used in pace of lower component specific TIDs.

44 1 EPC SW D/G SIDE General Electric I 1.OOE+05 9.30E+04 Qualified for Post MUR.

POTENTIAL Shawmut TRANSFORMER FUSES 45 2 EPC SW POTENTIAL General Electric 1.OE+05 9.30E+04 Qualified for Post MUR. Pin Point Dose Calculation CNC-TRANSFORMER 1229.00-00-0046 Rev. 2 provides an LOCATED IN upper bound TID for the switchgear room 2ETB19 BUS taking into account MUR of 9.3 E4 RADs.

46 2 EPC SW POTENTIAL General Electric 1.OE+05 9.30E+04 Qualified for Post MUR.

TRANSFORMER LOCATED IN ETB19 DG Attachment Page

Unit Sys Eq Equip Name Manufacturer Tested Total TID Qualification Status Comments Type Rads 47 2 EPC SW BUS SIDE General Electric? 1.00E+05 9.30E+04 Qualified for Post MUR.

POTENTIAL Shawmut TRANSFORMER Pin Point Dose Calculation CNC-FUSES 1229.00-00-0046 Rev. 2 provides an upper bound TID for the switchgear room taking into account MUR of 9.3 E4 RADs.

This upper bound TID is conservatively used in pace of lower component specific TIDs.

48 2 EPC SW D/G SIDE General Electric/ 1.OOE+05 9.30E+04 Qualified for Post MUR.

POTENTIAL Shawmut TRANSFORMER FUSES 49 2 VA DA AUXILIARY ITT GENERAL 2.OOE+06 1.OOE+03 Qualified for Post MUR. PIP C-1 3-05241 CA 04 is determining BUILDING new radiation zones and dose values for VENTILATION areas of Zone 30.

DAMPER 2ABF-D-16 OPERATOR 50 2 VA DA AUX BLDG ITT GENERAL 2.OOE+06 1.OOE+03 Qualified for Post MUR.

VENTILATION DAMPER 2ABF-D-18 OPERATOR Attachment Page Table 2: Evaluation of Components within Enclosures in Harsh Radiation Environments Post Components within Enclosure Line Item Enclosure MUR TID (RADs) Component Qualified TID (RADs) Comments Type Manufacturer Terminal Block Stanwick 3.OOE+07 Qualified for Post MUR conditions.

Terminal Block Stanwick 3.OOE+07 Qualified for Post MUR conditions.

Optical Isolator E-Max 5.OOE'-04 Qualified for Post MUR conditions.

Optical Isolator E-Max 5.OOE+04 Qualified for Post MUR conditions.

1EATC9 4.19E+04 Optical Isolator E-Max 5.OOE+04 Qualified based on similarity to Digital Optical Isolators DOI-175C145 and DOI-175C156.

Optical Isolator E-Max 5.OOE+04 Qualified based on similarity to Digital Optical Isolators DOI-175C145 and DOI-175C156.

Relay Cutler-Hammer 1.OOE+06 Qualified for Post MUR conditions.

Relay Cutler-Hammer 1.OOE+06 Qualified based on similarity to C-H D23MR40A.

Attachment Page Post Components within Enclosure Line Item Enclosure MUR TID Component Qualified DComments (RADs) (RADs)

Type Manufacturer Qualified for Post MUR conditions. Per DPC-1381.05-0015, the following materials make up the Struthers-Dunn 219 Type Relays. Material qualifications obtained from EPRI Report NP-2129.

Material Analysis Polyphenylene Oxide: 1.0E5 RADs PVC: 5.0E5 RADs Polyester: 1.0E5 RADs Polymide: 1.0E7 RADs Epoxy: 2.0E8 RADs Relay Struthers-Dunn 1.50E+04 (See Comments) Teflon (Polytetrafluoroethylene): 1.5E4 RADs Phenolic: 3.0E5 RADs Polycarbonate: 7.0E5 RADs Melamine-Formaldehyde: 6.7E6 RADs Per CNC-1 381.05-00-0054, a pin point analysis was performed for enclosure 1EATC9 that determined a TID of 1.0E4 RADs for the enclosure. Increasing this TID by 2%

1 (cont.) 1EATC9 4.19E+04 (1.02E4 RADs) for the MUR remains below the qualification of the most sensitive material within the relay (Teflon -

Qualified to 1.5E4 RADs).

Qualified for Post MUR conditions. Qualification based on a material analysis of component performed within CNC-Relay Potter-Brumfield 5.00E+05 1381.05-00-0054.

Material Analysis Silicone Varnish: 1.4E9 RADs PVC: 5.OE5 RADs Qualified for Post MUR conditions. Qualification based on a material analysis of component performed within CNC-Socket Potter-Brumfield 7.OOE+05 1381.05-00-0054.

Material Analysis Polycarbonate: 7.0E5 RADs

& _______________ J L Attachment Page Post Components within Enclosure Line Item Enclosure MUR TID _ _ __ __ Comments (RADs) (RADs)

Type Manufacturer Qualified for Post MUR conditions. Per DPC-1381.05-0015, Socket Struthers-Dunn 3.OOE+05 the relay socket is made of phenolic material. Per EPRI Report NP-2129, phenolic is qualified to 3.OE5 RADs.

1 (cont.) 1EATC9 4.19E+04 Fuse Littelfuse 2.20E+07 Qualified for Post MUR conditions based on Revision 10 of CGD-3006-01-14-0001.

Fuse Block Bussman 5.OOE+06 Qualified for Post MUR conditions.

Gasket Hoffman 1.OOE+08 Qualified for Post MUR conditions.

Terminal Block Stanwick 3.OOE+07 Qualified for Post MUR conditions.

Optical Isolator E-Max 5.00E+04 Qualified for Post MUR conditions.

Optical Isolator E-Max 5.OOE+04 Qualified for Post MUR conditions.

2 1EATC9A 4.19E+04 Optical Isolator E-Max 5.OOE+04 Qualified based on similarity to Digital Optical Isolators DOI-175C155 and DOI-1 75C156.

Optical Isolator E-Max 5.OOE+04 Qualified for Post MUR conditions.

Relay Cutler-Hammer 1.OOE+06 Qualified for Post MUR conditions.

Attachment Page Post Components within Enclosure Line Item Enclosure MUR TID ____ _ Comments (RADs)

Type

[ Manufacturer (RADs)

Relay Cutler-Hammer 1.00E+06 Qualified based on similarity to C-H D23MR40A.

Relay Cutler-Hammer 1.50E+06 Qualified for Post MUR conditions.

Per CNWT-1 717-01.09-01 Rev. 43, the four Agastat lN/A 7022AET relays installed in IEATC9A are electrically Relay Agastat Nisolated. Therefore, these relays do not function and do not require an EQ evaluation.

2 (cont.) 1EATC9A 4.19E+04 Relay Agastat 2.OOE+05 Qualified for Post MUR conditions.

Qualified for Post MUR conditions. Qualification based on a material analysis of component performed within CNC-1381.05-00-0054.

P otter-B rum field 5.00 E +05 Material0A nalysi Relay Material Analysis Silicone Varnish: 1.4E9 RADs PVC: 5.0E5 RADs Qualified for Post MUR conditions. Qualification based on a material analysis of component performed within CNC-Socket Potter-Brumfield 7.OOE+05 1381.05-00-0054.

Material Analysis Polycarbonate: 7.0E5 RADs L L J L ____________ _______________ ______________________________

Attachment Page Components within Enclosure PostCopnnQulfeTD Line Item Enclosure MUR (RADs)TID Component (As Qualified T1D Comments Type Manufacturer Fuse Littelfuse 2.20E+07 Qualified for Post MUR conditions based on Revision 10 of CGD-3006-01-14-0001.

Fuse Block Buchanan 1.30E+07 Qualified for Post MUR conditions.

Alarm Rochester 2.00E+05 Qualified for Post MUR conditions.

2 (cont.) 1EATC9A 4.19E+04 Power Supply Acopian 1.OOE+05 Qualified for Post MUR conditions.

Qualified for Post MUR conditions. CGD-3006.05-00-0007 sets a generic radiation qualification of 1.0E3 RADs.

Capacitor Sprague 3.OOE+05 However, per CGD-3006.05-00-0007 the 731 P Capacitors are made of metalized polypropylene. Per EPRI Report NP-2129, polypropylene is qualified up to 3.0E5 RADs.

Gasket Hoffman 1.OOE+08 Qualified for Post MUR conditions.

Terminal Block Stanwick 3.OOE+07 Qualified for Post MUR conditions.

Terminal Block Buchanan 1.30E+07 Qualified for Post MUR conditions.

3 1EATC12 1.01E+03 Optical Isolator E-Max 5.OOE+04 Qualified for Post MUR conditions.

Optical Isolator E-Max 5.OOE+04 Qualified for Post MUR conditions.

Attachment Page Post Components within Enclosure Line Item Enclosure MUR TID _ _____ Comments (RADs) Type Manufacturer Qualified based on similarity to Digital Optical Isolators DOI-Optical Isolator E-Max 5.OOE+04 175C155 and DOI-175C156.

Optial EMax5.00+04Qualified Iolaor based on similarity to Digital Optical Isolators DOI-Optical I175C155 and DOI-175C156.

Optical Isolator E-Max 5.OOE+04 Qualified for Post MUR conditions.

Relay Cutler-Hammer 1.50E+06 Qualified for Post MUR conditions.

3 (cont.) 1EATC12 1.01E+03 Qualified for Post MUR conditions.

Relay Cutler-Hammer 1.50E+06 Relay Cutler-Hammer 1.50E+06 Qualified for Post MUR conditions.

Relay Cutler-Hammer 1 .50E+06 Qualified for Post MUR conditions.

Qualified for Post MUR conditions. Note the radiation qualification was arbitrarily assigned to correspond to a mild radiation zone. It is generally accepted in industry that Relay Agastat 1.OE+04 (See Comments) radiation environments up to 1.0E4 RADs remain below the damage threshold of most electrical components (EPRI Report NP-2129).

6 6 6 6 6 Attachment Page Post Components within Enclosure Line Item Enclosure MUR TID (RADs) _ __ _ _

(RADs) Comments Type Manufacturer Qualified for Post MUR conditions. Note the radiation qualification was arbitrarily assigned to correspond to a mild Socket Agastat 1.0E+04 (See Comments) radiation zone. It is generally accepted in industry that radiation environments up to 1.0E4 RADs remain below the damage threshold of most electrical components (EPRI Report NP-2129).

Fuse Littelfuse 2.20E+07 Qualified for Post MUR conditions based on Revision 10 of CGD-3006-01-14-0001.

3 (cont.) 1EATC12 1.01E+03 Fuse Block Buchanan 1.30E+07 Qualified for Post MUR conditions.

Fuse Block Bussman 5.OOE+06 Qualified for Post MUR conditions.

Qualified for Post MUR conditions. Note the radiation qualification was arbitrarily assigned to correspond to a mild radiation zone. It is generally accepted in industry that Transmitter Rochester 1.0E+04 (See Comments) radiation environments up to 1.0E4 RADs remain below the damage threshold of most electrical components (EPRI Report NP-2129). CGD-3011.01-01-0002 Attachment 5 show that similar Rochester components have been radiation tested and qualified to 1.0E4 RADs.

Attachment Page Post Components within Enclosure Line Item Enclosure MUR TID (RA~~s) (RADs)

Component Qualified TIDComments Cmet (RADs) Type Manufacturer Qualified for Post MUR conditions. Note the radiation qualification was arbitrarily assigned to correspond to a mild radiation zone. It is generally accepted in industry that Transmitter Rochester 1.0E+04 (See Comments) radiation environments up to 1.0E4 RADs remain below the damage threshold of most electrical components (EPRI Report NP-2129). CGD-3011.01-01-0002 Attachment 5 show that similar Rochester components have been radiation tested and qualified to 1.0E4 RADs.

Qualified for Post MUR conditions. Note this component Square Root Rochester 3.00E+05 corresponds to equipment tag number CN1 KCSR5531 Extractor which is EQ-N in EDB.

3Power Supply Acopian 1.0EE+05 Qualified for Post MUR conditions.

Power Supply Lambda 1.OOE+05 Qualified for Post MUR conditions.

Qualified for Post MUR conditions. CGD-3006.05-00-0007 sets a generic radiation qualification of 1.0E3 RADs.

Capacitor Sprague 3.OOE+05 However, per CGD-3006.05-00-0007 the 731 P Capacitors are made of metalized polypropylene. Per EPRI Report NP-2129, polypropylene is qualified up to 3.0E5 RADs.

Gasket Hoffman 1.OOE+08 Qualified for Post MUR conditions.

Attachment Page Post Components within Enclosure Line Item Enclosure MUR TID (RADs) Component Qualified TIDs (RADs) Cmet Type Manufacturer Terminal Block Stanwick 3.OOE+07 Qualified for Post MUR conditions.

Fuse Littelfuse 2.20E+07 Qualified for Post MUR conditions based on Revision 10 of CGD-3006-01-14-0001.

Qualified for Post MUR conditions. Per CGD-3007.02 0001 Attachment 3, the Phenolic Buchanan fuse blocks are 4 lTBOX0001 1.33E+07 conservatively considered to be qualified to 1.3E7 RADs based on engineering judgment. CGD-3007.02-08-0001 references EPRI Report NP-2129, stating phenolic materials have been subjected to much higher radiation values. Per EPRI Report NP-2129 Phenolic resins have radiation Fuse Block Buchanan 1.30E+07 (See Comments) thresholds of up to 3.9E8 RADs. Also other vender documentation within CGD-3007.02-08-0001 show that phenolic blocks have a radiation threshold of 4.0E8 RADs.

Therefore, based on the conservative radiation qualification determined from engineering judgment presented in CGD-3007.02-08-0001 and the material having a much higher radiation threshold these fuse blocks remain qualified for Post MUR conditions.

Terminal Block Stanwick 3.OOE+07 Qualified for Post MUR conditions.

5 1TBOX0002 1.33E+07 Fuse Littelfuse 2.20E+07 Qualified for Post MUR conditions based on Revision 10 of CGD-3006-01-14-0001.

Attachment Page Post Components within Enclosure Line Item Enclosure MUR riD dCaleT Comments (RADs) (RADs)

Type Manufacturer Qualified for Post MUR conditions. Per CGD-3007.02 0001 Attachment 3, the Phenolic Buchanan fuse blocks are conservatively considered to be qualified to 1.3E7 RADs based on engineering judgment. CGD-3007.02-08-0001 references EPRI Report NP-2129, stating phenolic materials have been subjected to much higher radiation values. Per EPRI Report NP-2129 Phenolic resins have radiation 5 (cont.) 1TBOX0002 1.33E+07 Fuse Block Buchanan 1.30E+07 (See Comments) thresholds of up to 3.9E8 RADs. Also other vender documentation within CGD-3007.02-08-0001 show that phenolic blocks have a radiation threshold of 4.0E8 RADs.

Therefore, based on the conservative radiation qualification determined from engineering judgment presented in CGD-3007.02-08-0001 and the material having a much higher radiation threshold these fuse blocks remain qualified for Post MUR conditions.

Terminal Block States 3.OOE+07 Qualified for Post MUR conditions.

6 1TBOX0655 6.50E+06 Gasket Hoffman 1.OOE+08 Qualified for Post MUR conditions.

Terminal Block States 3.OOE+07 Qualified for Post MUR conditions.

7 1TBOX0656 6.50E+06 Gasket Hoffman 1.OOE+08 Qualified for Post MUR conditions.

Terminal Block States 3.OOE+07 Qualified for Post MUR conditions.

8 1TBOX0657 6.50E+06 Gasket Hoffman 1.OOE+08 Qualified for Post MUR conditions.

Terminal Block States 3.OOE+07 Qualified for Post MUR conditions.

9 1TBOX0658 6.50E+06 Gasket Hoffman 1.OOE+08 Qualified for Post MUR conditions.

Attachment Page Post Components within Enclosure Line Item Enclosure MUR TID (RADs) Component Qualified TID (RADs) Comments Type Manufacturer Terminal Block Stanwick 3.00E+07 Qualified for Post MUR conditions.

10 1TBOX0298 9.49E+05 Relay Cutler-Hammer 1.00E+06 Qualified for Post MUR conditions.

Gasket Hoffman 1.00E+08 Qualified for Post MUR conditions.

Terminal Block Stanwick 3.00E+07 Qualified for Post MUR conditions.

Fuse Littelfuse 2.20E+07 Qualified for Post MUR conditions based on Revision 10 of CGD-3006-01-14-0001.

11 1ELCP0269 8.29E+05 Fuse Block Buchanan 1.30E+07 Qualified for Post MUR conditions.

Qualified for Post MUR conditions. Per CNC-1381.05 0054, a pin point analysis was performed for enclosure Switch Cutler-Hammer 5.OOE+05 (See Comments) 1ELCP0269 that determined a TID of 2.65E5 RADs for the enclosure. Increasing this TID by 2% (2.70E5 RADs) for the MUR remains below the qualification of this component.

Attachment Page Post Components within Enclosure Line Item Enclosure MUR TID (RADs) Component Qualified TID (RADs) Comments Type Manufacturer Qualified for Post MUR conditions. Per CGD-3008.01 0001 and MCM-1 393.02-0006.001, the E30 Series Pushbuttons and accessories are qualified to 1.9E5 RADs.

However, CNC-1381.05-00-0054 performed a material analysis of the E30 Series Pushbuttons and accessories, determining that the only radiation sensitive materials within these components are Polycarbonate, Phenolic, and Cork.

Per CNC-1 381.05-00-0054 these materials have radiation Push Button Cutler-Hammer 3.00E+05 (See Comments) qualifications of 7.0E5 RADs, 3.0E5 RADs, and 5.0E6 RADs respectively. Per CNC-1 381.05-00-0054, a pin point 11 (cont.) 1ELCP0269 8.29E+05 analysis was performed for enclosure 1ELCP0269 that determined a TID of 2.65E5 RADs for the enclosure.

Increasing this TID by 2% (2.70E5 RADs) for the MUR remains below the qualification of the most sensitive material within the E30 Series Pushbuttons (Phenolic -

Qualified conservatively to 3.0E5 RADs).

Qualified for Post MUR conditions. Per CNC-1381.05 0054, a pin point analysis was performed for enclosure Contactor Block Cutler-Hammer 5.OOE+05 (See Comments) 1ELCP0269 that determined a TID of 2.65E5 RADs for the enclosure. Increasing this TID by 2% (2.70E5 RADs) for the MUR remains below the qualification of this component.

Qualified for Post MUR conditions. Per CGD-3008.01 0001 and MCM-1 393.02-0006.001, the E30 Series Pushbuttons and accessories are qualified to 1.9E5 RADs.

However, CNC-1381.05-00-0054 performed a material analysis of the E30 Series Pushbuttons and accessories, determining that the only radiation sensitive materials within these components are Polycarbonate, Phenolic, and Cork.

Per CNC-1 381.05-00-0054 these materials have radiation 11 (cont.) 1 ELCP0269 8.29E+05 Contactor Block Cutler-Hammer 3.O0E+05 (See Comments) qualifications of 7.OE5 RADs, 3.0E5 RADs, and 5.0E6 RADs respectively. Per CNC-1381.05-00-0054, a pin point analysis was performed for enclosure 1ELCP0269 that determined a TID of 2.65E5 RADs for the enclosure.

Increasing this TID by 2% (2.70E5 RADs) for the MUR remains below the qualification of the most sensitive material within the E30 Series Pushbuttons (Phenolic -

Qualified conservatively to 3.OE5 RADs).

Attachment Page Post Components within Enclosure Line Item Enclosure MUR TID (RADs) Component Qualified TID (RADs) Comments Type Manufacturer The Moore Products Model 51V Indicators within 1ELCP0269 correspond to EDB tag numbers 1NIP5200 and Indicator Moore Products N/A 1NIP5220 per IP/1/B/3140/002 Rev. 34. Both 1NIP5200 and 1NIP5220 are designated EQ-N in EDB, therefore not requiring an EQ evaluation.

Gasket Hoffman 1.00E+08 Qualified for Post MUR conditions.

Terminal Block Stanwick 3.OOE+07 Qualified for Post MUR conditions.

12 1TBOX0015 2.84E+06 Gasket Hoffman 1.00E+08 Qualified for Post MUR conditions.

13 1TBOX0019 2.84E+06 Terminal Block Stanwick 3.OOE+07 Qualified for Post MUR conditions.

14 1TBOX0020 3.05E+06 Terminal Block Stanwick 3.OOE+07 Qualified for Post MUR conditions.

Terminal Block Stanwick 3.OOE+07 Qualified for Post MUR conditions.

15 1TBOX0021 3.05E+06 Gasket Hoffman 1.OOE+08 Qualified for Post MUR conditions.

Terminal Block Stanwick 3.OOE+07 Qualified for Post MUR conditions.

Optical Isolator E-Max 5.OOE+04 Qualified for Post MUR conditions.

Optical Isolator E-Max 5.00E+04 Qualified based on similarity to Digital Optical Isolator DOI-Optial EMax5.OO+041750156.

Iolaor 16 1SMTC1 1.01E+03 Relay Cutler-Hammer 1.50E+06 Qualified for Post MUR conditions.

Relay Cutler-Hammer 1.50E+06 Qualified for Post MUR conditions.

Attachment Page Components within Enclosure Post Component Qualified TID Line Item Enclosure MUR TID Comments (RADs)

(RADs)

Type Manufacturer Fuse Littelfuse 2.20E+07 Qualified for Post MUR conditions based on Revision 10 of CGD-3006-01-14-0001.

Fuse Block Bussman 5.00E+06 Qualified for Post MUR conditions.

Fuse Block Buchanan 1.30E+07 Qualified for Post MUR conditions.

Gasket Hoffman 1.OOE+08 Qualified for Post MUR conditions.

4 + +/- t Terminal Block Stanwick 3.OOE+07 Qualified for Post MUR conditions.

Qualified for Post MUR conditions. Per CNC-1381.05 0054, a pin point analysis was performed for enclosure 1ELCP01 12 that determined a TID of 5.0E3 RADs for the Optical Isolator E-Max 5.OOE+04 (See Comments) enclosure. Increasing this TID by 2% (5.1E3 RADs) for the MUR remains below the qualification of this component.

Qualification based on similarity to Digital Optical Isolators DOI-1 75C145 and DO-1 75C1 56.

17 1ELCP0112 3.22E+05 Qualified for Post MUR conditions. Per CNC-1381.05 0054, a pin point analysis was performed for enclosure Optical Isolator E-Max 5.OOE+04 (See Comments) 1ELCP01 12 that determined a TID of 5.0E3 RADs for the enclosure. Increasing this TID by 2% (5.1E3 RADs) for the MUR remains below the qualification of this component.

Qualified for Post MUR conditions. Per CNC-1381.05 0054, a pin point analysis was performed for enclosure Optical Isolator E-Max 5.OOE+04 (See Comments) 1ELCP01 12 that determined a TID of 5.0E3 RADs for the enclosure. Increasing this TID by 2% (5.1E3 RADs) for the MUR remains below the qualification of this component.

J h ______________ __________________

Attachment Page Components within Enclosure Post Component Qualified TID Line Item Enclosure MUR TID Comments (RADs)

(RADs)

Type Manufacturer Relay Cutler-Hammer 1.OOE+06 Qualified for Post MUR conditions.

Relay Cutler-Hammer 1.00E+06 Qualified based on similarity to C-H D23MR40A.

p q 4 4 p Relay Cutler-Hammer 1.OOE+06 Qualified based on similarity to C-H D23MR40A.

Indicating Light Cutler-Hammer 5.OOE+05 Qualified for Post MUR conditions.

Qualified for Post MUR conditions. Per CNC-1381.05 17(cont.) I 1ELCP0112 I 3.22E+05 0054, a pin point analysis was performed for enclosure Indicating Light Cutler-Hammer 1.90E+05 (See Comments) 1ELCP0112 that determined a TID of 5.0E3 RADs forthe enclosure. Increasing this TID by 2% (5.1E3 RADs) for the MUR remains below the qualification of this component.

Qualified for Post MUR conditions. Per CNC-1 381.05 0054, a pin point analysis was performed for enclosure Push Button Cutler-Hammer 1.90E+05 (See Comments) 1ELCP01 12 that determined a TID of 5.0E3 RADs for the enclosure. Increasing this TID by 2% (5.1E3 RADs) for the MUR remains below the qualification of this component.

Push Button Cutler-Hammer 5.00E+05 Qualified for Post MUR conditions.

h _________ n Attachment Page Post Components within Enclosure Line Item Enclosure MUR TID ______ Comments (RADs) (RADs)

Type Manufacturer Qualified for Post MUR conditions. Per CNC-1 381.05 0054, a pin point analysis was performed for enclosure Contactor Block Cutler-Hammer 1.90E+05 (See Comments) 1ELCP0112 that determined a TID of 5.0E3 RADs for the enclosure. Increasing this TID by 2% (5.1E3 RADs) for the MUR remains below the qualification of this component.

Contactor Block Cutler-Hammer 5.OOE+05 Qualified for Post MUR conditions.

17 (cont.) 1ELCP0112 3.22E+05 Fuse Littelfuse 2.20E+07 Qualified for Post MUR conditions based on Revision 10 of CD30-11-01 CGD-3006-01-14-0001.

Fuse Block Bussman 5.00E+06 Qualified for Post MUR conditions.

Separator Glastic 5.OOE+07 Qualified for Post MUR conditions.

Terminal Block Stanwick 3.00E+07 Qualified for Post MUR conditions.

Qualified for Post MUR conditions. Per CNC-1381.05 0054, a pin point analysis was performed for enclosure 18 1ELCP0113 8.29E+05 1ELCP01 13 that determined a TID of 1.25E4 RADs for the Optical Isolator E-Max 5.OOE+04 (See Comments) enclosure. Increasing this TID by 2% (1.28E4 RADs) for the MUR remains below the qualification of this component.

Qualification based on similarity to Digital Optical Isolators DO1-175C145 and DOI-175C156.

Attachment Page Post Components within Enclosure .

Line Item Enclosure MUR TID (RADs) Component Qualified TID (RADs) Comments Type Manufacturer Qualified for Post MUR conditions. Per CNC-1381.05 0054, a pin point analysis was performed for enclosure Optical Isolator E-Max 5.O0E+04 (See Comments) 1ELCP01 13 that determined a TID of 1.25E4 RADs for the enclosure. Increasing this TID by 2% (1.28E4 RADs) for the MUR remains below the qualification of this component.

Qualified for Post MUR conditions. Per CNC-1381.05 0054, a pin point analysis was performed for enclosure Optical Isolator E-Max 5.OOE+04 (See Comments) 1ELCP0113 that determined a TID of 1.25E4 RADs for the enclosure. Increasing this TID by 2% (1.28E4 RADs) for the MUR remains below the qualification of this component.

Relay Cutler-Hammer 1.OOE+06 Qualified for Post MUR conditions.

Relay Cutler-Hammer 1.00E+06 Qualified based on similarity to C-H D23MR40A.

18 (cont.) 1ELCP01 13 8.29E+05 Relay Cutler-Hammer 1.00E+06 Qualified based on similarity to C-H D23MR40A.

Relay Cutler-Hammer 1.50E+06 Qualified for Post MUR conditions.

Qualified for Post MUR conditions. Per CNC-1381.05 0054, a pin point analysis was performed for enclosure Indicating Light Cutler-Hammer 5.OOE+05 (See Comments) 1ELCP01 13 that determined a TID of 1.25E4 RADs for the enclosure. Increasing this TID by 2% (1.28E4 RADs) for the MUR remains below the qualification of this component.

Attachment Page PostCopnnQulfeTIComponents within Enclosure Line Item Enclosure MUR TID (RA~s)(RADs) _ _ __ _ Comments (RADs) Type Manufacturer Qualified for Post MUR conditions. Per CNC-1381.05 0054, a pin point analysis was performed for enclosure Indicating Light Cutler-Hammer 5.OOE+05 (See Comments) 1ELCP01 13 that determined a TID of 1.25E4 RADs for the enclosure. Increasing this TID by 2% (1.28E4 RADs) for the MUR remains below the qualification of this component.

Qualified for Post MUR conditions. Per CNC-1381.05 0054, a pin point analysis was performed for enclosure Indicating Light Cutler-Hammer 1.90E+05 (See Comments) 1ELCP01 13 that determined a TID of 1.25E4 RADs for the enclosure. Increasing this TID by 2% (1.28E4 RADs) for the MUR remains below the qualification of this component.

Qualified for Post MUR conditions. Per CNC-1381.05 0054, a pin point analysis was performed for enclosure Push Button Cutler-Hammer 1.90E+05 (See Comments) 1ELCP01 13 that determined a TID of 1.25E4 RADs for the enclosure. Increasing this TID by 2% (1.28E4 RADs) for the MUR remains below the qualification of this component.

Qualified for Post MUR conditions. Per CNC-1381.05 0054, a pin point analysis was performed for enclosure 18 (cont.) 1ELCP0113 8.29E+05 Push Button Cutler-Hammer 5.OOE+05 (See Comments) 1ELCP0113 that determined a TID of 1.25E4 RADs for the enclosure. Increasing this TID by 2% (1.28E4 RADs) for the MUR remains below the qualification of this component.

Qualified for Post MUR conditions. Per CNC-1381.05 0054, a pin point analysis was performed for enclosure Contactor Block Cutler-Hammer 1.90E+05 (See Comments) 1ELCP01 13 that determined a TID of 1.25E4 RADs for the enclosure. Increasing this TID by 2% (1.28E4 RADs) for the MUR remains below the qualification of this component.

Qualified for Post MUR conditions. Per CNC-1381.05 0054, a pin point analysis was performed for enclosure Contactor Block Cutler-Hammer 5.OOE+05 (See Comments) 1ELCP01 13 that determined a TID of 1.25E4 RADs for the enclosure. Increasing this TID by 2% (1.28E4 RADs) for the MUR remains below the qualification of this component.

Attachment Page Post Components within Enclosure Line Item Enclosure MUR TID (RADs) Component Qualified TID (RADs) Comments Type Manufacturer Fuse Littelfuse 2.20E+07 Qualified for Post MUR conditions based on Revision 10 of CGD-3006-01-14-0001.

18 (cont.) 1ELCP0113 8.29E+05 Fuse Block Bussman 5.OOE+06 Qualified for Post MUR conditions.

Separator Glastic 5.00E+07 Qualified for Post MUR conditions.

Gasket Hoffman 1.00E+08 Qualified for Post MUR conditions.

Terminal Block Stanwick 3.00E+07 Qualified for Post MUR conditions.

Qualified based on similarity to Digital Optical Isolator DOI-Optical Isolator E-Max 5.OOE+04 175C155.

19 1ELCC0046 1.01E+03 Optical Isolator E-Max 5.OOE+04 Qualified for Post MUR conditions.

Terminal Block Stanwick 3.00E+07 Qualified for Post MUR conditions.

Qualified for Post MUR conditions. Per CNC-1381.05 20 1 ELMC0020 3.22E+05 0054, a pin point analysis was performed for enclosure Optical Isolator E-Max 5.OOE+04 (See Comments) 1ELMC0020 that determined a TID of 9.0E3 RADs for the enclosure. Increasing this TID by 2% (9.2E3 RADs) for the MUR remains below the qualification of this component.

Attachment Page Post Components within Enclosure T Comments 1

Line Item Enclosure MUR TID _ _____

(RADs)

Qualified for Post MUR conditions. Per CNC-1381.05 0054, a pin point analysis was performed for enclosure Optical Isolator E-Max 5.00E+04 (See Comments) 1ELMC0020 that determined a TID of 9.0E3 RADs for the enclosure. Increasing this TID by 2% (9.2E3 RADs) for the MUR remains below the qualification of this component.

Relay Cutler-Hammer 1.00E+06 Qualified for Post MUR conditions.

Relay Cutler-Hammer 1.50E+06 Qualified for Post MUR conditions.

Switch Electro Switch 1.00E+07 Qualified for Post MUR conditions.

20 (cont.) 1ELMC0020 3.22E+05 Indicating Light Cutler-Hammer 5.00E+05 Qualified for Post MUR conditions.

Qualified for Post MUR conditions. Per CNC-1381.05 0054, a pin point analysis was performed for enclosure Indicating Light Cutler-Hammer 1.90E+05 (See Comments) 1ELMC0020 that determined a TID of 9.0E3 RADs for the enclosure. Increasing this TID by 2% (9.2E3 RADs) for the MUR remains below the qualification of this component.

Push Button Cutler-Hammer 5.OOE+05 Qualified for Post MUR conditions.

Contactor Block Cutler-Hammer 1.50E+06 Qualified for Post MUR conditions.

20 (cont.) 1ELMC0020 3.22E+05 Contactor Block Cutler-Hammer 1.50E+06 Qualified for Post MUR conditions.

Attachment Page Components within Enclosure Post Component Qualified TID Line Item Enclosure MUR TID Comments (RADs)

(RADs)

Type Manufacturer Contactor Block Cutler-Hammer 5.OOE+05 Qualified for Post MUR conditions.

Fuse Littelfuse 2.20E+07 Qualified for Post MUR conditions based on Revision 10 of CGD-3006-01-14-0001.

Fuse Block Buchanan 1.30E+07 Qualified for Post MUR conditions.

Tranzorb Gen Semi-Conductor 2.OOE+07 Qualified for Post MUR conditions.

Terminal Block Stanwick 3.OOE+07 Qualified for Post MUR conditions.

Qualified for Post MUR conditions. Per CNC-1381.05 0054, a pin point analysis was performed for enclosure 1ELMC0021 that determined a TID of 1.25E4 RADs for the Optical Isolator E-Max 5.00E+04 (See Comments) enclosure. Increasing this TID by 2% (1.28E4 RADs) for the MUR remains below the qualification of this component.

Qualification based on similarity to Digital Optical Isolators 21 1ELMC0021 I 8.29E+05 DOI-175C145 and DOI-1 75C1 56.

Qualified for Post MUR conditions. Per CNC-1381.05 0054, a pin point analysis was performed for enclosure Optical Isolator E-Max 5.00E+04 (See Comments) 1ELMC0021 that determined a TID of 1.25E4 RADs for the enclosure. Increasing this TID by 2% (1.28E4 RADs) for the MUR remains below the qualification of this component.

_________ A h A A A Attachment Page Post Components within Enclosure Line Item Enclosure MUR TID Component Qualified TIDComments (RADs) Mouments (RADs)

Type Manufacturer Qualified for Post MUR conditions. Per CNC-1381.05 0054, a pin point analysis was performed for enclosure Optical Isolator E-Max 5.OOE+04 (See Comments) 1ELMC0021 that determined a TID of 1.25E4 RADs for the enclosure. Increasing this TID by 2% (1.28E4 RADs) for the MUR remains below the qualification of this component.

Relay Cutler-Hammer 1.OOE+06 Qualified for Post MUR conditions.

Relay Cutler-Hammer 1.50E+06 Qualified for Post MUR conditions.

21 (cont.) 1ELMC0021 8.29E+05 Switch Electro Switch 1.OOE+07 Qualified for Post MUR conditions.

Qualified for Post MUR conditions. Per CNC-1381.05 0054, a pin point analysis was performed for enclosure Indicating Light Cutler-Hammer 5.OOE+05 (See Comments) 1ELMC0021 that determined a TID of 1.25E4 RADs for the enclosure. Increasing this TID by 2% (1.28E4 RADs) for the MUR remains below the qualification of this component.

Qualified for Post MUR conditions. Per CNC-1381.05 0054, a pin point analysis was performed for enclosure Indicating Light Cutler-Hammer 1.90E+05 (See Comments) 1ELMC0021 that determined a TID of 1.25E4 RADs for the enclosure. Increasing this TID by 2% (1.28E4 RADs) for the MUR remains below the qualification of this component.

Qualified for Post MUR conditions. Per CNC-1381.05 0054, a pin point analysis was performed for enclosure 21 (cont.) 1ELMC0021 8.29E+05 Push Button Cutler-Hammer 5.OOE+05 (See Comments) 1ELMC0021 that determined a TID of 1.25E4 RADs for the enclosure. Increasing this TID by 2% (1.28E4 RADs) for the MUR remains below the qualification of this component.

Attachment Page Components within Enclosure Post Component Qualified TID Line Item I Enclosure MUR TID (RADs)

Comments (RADs)

Type Manufacturer Contactor Block Cutler-Hammer 1.50E+06 Qualified for Post MUR conditions.

Contactor Block Cutler-Hammer 1.50E+06 Qualified for Post MUR conditions.

Qualified for Post MUR conditions. Per CNC-1381.05 0054, a pin point analysis was performed for enclosure Contactor Block Cutler-Hammer 5.00E+05 (See Comments) 1ELMC0021 that determined a TID of 1.25E4 RADs for the enclosure. Increasing this TID by 2% (1.28E4 RADs) for the MUR remains below the qualification of this component.

Fuse Littelfuse 2.20E+07 Qualified for Post MUR conditions based on Revision 10 of CGD-3006-01-14-0001.

Fuse Block Buchanan 1.30E+07 Qualified for Post MUR conditions.

Tranzorb Gen Semi-Conductor 2.OOE+07 Qualified for Post MUR conditions.

Terminal Block Buchanan 2.70E+06 Qualified for Post MUR conditions.

Cable Terminator PLM 6.OOE+06 Qualified for Post MUR conditions.

22 1TBOX0345 5.01 E+05 Bushing Amerace 1.OOE+08 Qualified for Post MUR conditions.

Bushing Amerace 1.OOE+08 Qualified for Post MUR conditions.

Attachment Page Components within Enclosure Post Line Item Enclosure MUR TID Comments (RADs)

Qualified for Post MUR conditions.

i Qualified for Post MUR conditions.

Qualified for Post MUR conditions. Pin point analysis CNC-1229.00.00-0058 Rev. 1 determined a TID of 4155 RADs for the chiller control electrical components. CNC-1229.00 5.00E+3 (See Comments) 0058 increases the TID to 5000 RADs, which bounds MUR.

Transformer Trane Note it is generally accepted in industry that radiation environments up to 1.0E4 RADs remain below the damage threshold of most electrical components (EPRI Report NP-2129).

2.70E+06 Qualified for Post MUR conditions.

6.OOE+06 Qualified for Post MUR conditions.

1.00E+08 Qualified for Post MUR conditions.

23 1TBOX0346 5.72E+05 1.OOE+08 Qualified for Post MUR conditions.

1.OOE+08 Qualified for Post MUR conditions.

m Attachment Page Components within Enclosure Post Component Qualified TID Line Item Enclosure MUR TID Comments (RADs)

(RADs)

Type Manufacturer Connector Elastimold 1.OOE+08 Qualified for Post MUR conditions.

Connector Elastimold 1.OOE+08 Qualified for Post MUR conditions.

Qualified for Post MUR conditions. Pin point analysis CNC-1229.00.00-0058 Rev. 1 determined a TID of 4155 RADs for the chiller control electrical components. CNC-1229.00 0058 increases the TID to 5000 RADs, which bounds MUR.

Transformer Trane 5.OOE+3 (See Comments) Note it is generally accepted in industry that radiation environments up to 1.0E4 RADs remain below the damage threshold of most electrical components (EPRI Report NP-2129).

I- I i t ~1-Terminal Block Stanwick 3.OOE+07 Qualified for Post MUR conditions.

Optical Isolator E-Max 5.OOE+04 Qualified for Post MUR conditions.

Optical Isolator E-Max 5.00E+04 Qualified based on similarity to Digital Optical Isolators DOI-175C155 and DOI-1 75C1 56.

24 2EATC9 2.65E+04 Optical Isolator E-Max 5.OOE+04 Qualified based on similarity to Digital Optical Isolators DOI-175C155 and DOI-1 75C1 56.

Relay Cutler-Hammer 1.OOE+06 Qualified for Post MUR conditions.

Qualified for Post MUR conditions.

Relay Cutler-Hammer 1.50E+06 Attachment Page Components within Enclosure Post Component Qualified TID Line Item Enclosure MUR TID Comments (RADs)

(RADs)

Type Manufacturer Qualified for Post MUR conditions. Pin point analysis CNC-1381.05-00-0069 Rev. 1 determined a TID of less than 1.0E3 RADs for this enclosure. Note CNC-1 381.05-00-0054 performed a material analysis of this component with the following results.

Relay Potter-Brumfield 5.OOE+05 Material Analysis Silicone Varnish: 1.4E9 RADs PVC: 5.0E5 RADs Component materials are qualified far in excess of the pin point analysis even after a 2% increase is applied.

.1. 1. 4 .4. 4 4 Qualified for Post MUR conditions. Pin point analysis CNC-1381.05-00-0069 Rev. 1 determined a TID of less than 1.0E3 RADs for this enclosure. Note CNC-1 381.05-00-0054 performed a material analysis of this component with the Socket Potter-Brumfield 7.OOE+05 following results.

Material Analysis Polycarbonate: 7.0E5 RADs Component materials are qualified far in excess of the pin point analysis even after a 2% increase is applied.

24 (cont.) 2EATC9 2.65E+04 Fuse Littelfuse 2.20E+07 Qualified for Post MUR conditions based on Revision 10 of CGD-3006-01-14-0001.

Fuse Block Bussman 5.OOE+06 Qualified for Post MUR conditions.

Gasket Hoffman 1.OOE+08 Qualified for Post MUR conditions.

Terminal Block Stanwick 3.OOE+07 Qualified for Post MUR conditions.

25 2EATC9A 2.65E+04 Optical Isolator E-Max 5.00E+04 Qualified for Post MUR conditions.

Attachment Page Components within Enclosure Post Component Qualified TID Line Item I Enclosure MUR TID (RADs)

Comments (RADs)

Type Manufacturer Optical Isolator E-Max 5.OOE+04 Qualified for Post MUR conditions.

Optical Isolator E-Max 5.OOE+04 Qualified based on similarity to Digital Optical Isolators DOI-175C155 and DO1-175C156.

Optical Isolator E-Max 5.OOE+04 Qualified for Post MUR conditions.

Relay Cutler-Hammer 1.00E+06 Qualified for Post MUR conditions.

4 4 4 Relay Cutler-Hammer 1.OOE+06 Qualified based on similarity to C-H D23MR40A.

Relay Cutler-Hammer 1.50E+06 Qualified for Post MUR conditions.

Per CNWT-2717-01.09-01 Rev. 41, the four Agastat 25 (cont.) 2EATC9A 2.65E+04 7022AET relays installed in 2EATC9A are electrically isolated. Therefore, these relays do not function and do not require an EQ evaluation.

Relay Agastat 2.00E+05 Qualified for Post MUR conditions.

Qualified for Post MUR conditions based on Revision 10 of Fuse Littelfuse 2.20E+07 CGD-3006-01-14-0001.

Attachment Page Components within Enclosure Post Component Qualified TID Line Item Enclosure MUR TID Comments (RADs)

(RADs)

Type Manufacturer Fuse Block Buchanan 1.30E+07 Qualified for Post MUR conditions.

Qualified for Post MUR conditions. Pin point analysis CNC-Alarm Rochester 2.00E+05 1381.05-00-0069 Rev. 1 determined a TID of less than 1.0E3 RADs for this enclosure.

Qualified for Post MUR conditions. Note component Power Supply Acopian 1.OOE+05 corresponds to tag number CN2 VC PY5160, which is not designated EQ Harsh in EDB.

Qualified for Post MUR conditions. CGD-3006.05-00-0007 sets a generic radiation qualification of 1.0E3 RADs.

Capacitor Sprague 3.OOE+05 However, per CGD-3006.05-00-0007 the 731 P Capacitors 25 (cont.) 2EATC9A 2.65E+04 are made of metalized polypropylene. Per EPRI Report NP-2129, polypropylene is qualified up to 3.0E5 RADs.

Gasket Hoffman 1.00E+08 Qualified for Post MUR conditions.

Terminal Block Stanwick 3.OOE+07 Qualified for Post MUR conditions.

Terminal Block Buchanan 1.30E+07 Qualified for Post MUR conditions.

Optical Isolator E-Max 5.OOE+04 Qualified for Post MUR conditions.

26 2EATC12 1.01E+03 Optical Isolator E-Max 5.OOE+04 Qualified for Post MUR conditions.

Qualified based on similarity to Digital Optical Isolators DOI-Optical Isolator E-Max 5.00E+04 175C155 and DOI-175C1 56..

Attachment Page Components within Enclosure Post Component Qualified TID Line Item Enclosure MUR TID Comments (RADs)

(RADs)

Type Manufacturer Optical Isolator E-Max 5.OOE+04 175C155 based Qualified on similarity to Digital Optical Isolators DOI-and DOI-175C156.

Optical Isolator E-Max 5.OOE+04 Qualified for Post MUR conditions.

Relay Cutler-Hammer 1.50E+06 Qualified for Post MUR conditions.

t ¶

Relay Cutler-Hammer 1.50E+06 Qualified for Post MUR conditions.

Qualified for Post MUR conditions. Note the radiation qualification was arbitrarily assigned to correspond to a mild Relay Agastat 1.0E+04 (See Comments) radiation zone. It is generally accepted in industry that radiation environments up to 1.0E4 RADs remain below the damage threshold of most electrical components (EPRI Report NP-2129).

Qualified for Post MUR conditions. Note the radiation qualification was arbitrarily assigned to correspond to a mild 26 (cont.) 2EATC12 1.01E+03 Socket Agastat 1.0E+04 (See Comments) radiation zone. It is generally accepted in industry that radiation environments up to 1.0E4 RADs remain below the damage threshold of most electrical components (EPRI Report NP-2129).

Fuse Littelfuse 2.20E+07 Qualified for Post MUR conditions based on Revision 10 of CGD-3006-01-14-0001.

Attachment Page Post Components within Enclosure Line Item Enclosure MUR TID (RAls) ______

(RADs) Comments Type Manufacturer Fuse Block Buchanan 1.30E+07 Qualified for Post MUR conditions.

Fuse Block Bussman 5.OOE+06 Qualified for Post MUR conditions.

Qualified for Post MUR conditions. Note the radiation qualification was arbitrarily assigned to correspond to a mild radiation zone. It is generally accepted in industry that Transmitter Rochester 1.0E+04 (See Comments) radiation environments up to 1.0E4 RADs remain below the damage threshold of most electrical components (EPRI Report NP-2129). CGD-3011.01-01-0002 Attachment 5 show that similar Rochester components have been radiation tested and qualified to 1.0E4 RADs.

Qualified for Post MUR conditions. Note the radiation qualification was arbitrarily assigned to correspond to a mild radiation zone. It is generally accepted in industry that Transmitter Rochester 1.0E+04 (See Comments) radiation environments up to 1.0E4 RADs remain below the damage threshold of most electrical components (EPRI Report NP-2129). CGD-3011.01-01-0002 Attachment 5 26 (cont.) 2EATC12 1.01 E+03 show that similar Rochester components have been radiation tested and qualified to 1.0E4 RADs.

Square Root Rochester 3.OOE+05 Qualified for Post MUR conditions.

Extractor Power Supply Acopian 1.OOE+05 Qualified for Post MUR conditions.

Power Supply Lambda 1.OOE+05 Qualified for Post MUR conditions.

Attachment Page Post Components within Enclosure Line Item Enclosure MUR TID (RADs) Component Qualified TID (RADs) Comments Type Manufacturer Qualified for Post MUR conditions. CGD-3006.05-00-0007 sets a generic radiation qualification of 1.0E3 RADs.

Capacitor Sprague 3.OOE+05 However, per CGD-3006.05-00-0007 the 731P Capacitors 26 (cont.) 2EATC12 1.01E+03 are made of metalized polypropylene. Per EPRI Report NP-2129, polypropylene is qualified up to 3.0E5 RADs.

Gasket Hoffman 1.OOE+08 Qualified for Post MUR conditions.

Terminal Block Stanwick 3.OOE+07 Qualified for Post MUR conditions.

27 2TBOX0298 9.49E+05 Relay Cutler-Hammer 1.50E+06 Qualified for Post MUR conditions.

Gasket Hoffman 1.OOE+08 Qualified for Post MUR conditions.

Terminal Block Stanwick 3.OOE+07 Qualified for Post MUR conditions.

Optical Isolator E-Max 5.OOE+04 Qualified for Post MUR conditions.

28 2TB0X0481 1.01E+03 Optical Isolator E-Max 5.OOE+04 Qualified for Post MUR conditions.

Optical Isolator E-Max 5.OOE+04 Qualified based on similarity to Digital Optical Isolators DOI-175C155 and DOI-175C156.

Terminal Block Stanwick 3.OOE+07 Qualified for Post MUR conditions.

Fuse Littelfuse 2.20E+07 Qualified for Post MUR conditions based on Revision 10 of 2ELCP0269 8.29E+05 CGD-3006-01-14-0001.

29 Fuse Block Buchanan 1.30E+07 Qualified for Post MUR conditions.

Attachment Page PostCopnnQulfeTIComponents within Enclosure Line Item Enclosure MUR TID ____ (RA~s)(RADs)

_ Comments (RADs) Type Manufacturer Qualified for Post MUR conditions. Per CNC-1381.05 0069, a pin point analysis was performed for enclosure Switch Cutler-Hammer 5.00E+05 (See Comments) 2ELCP0269 that determined a TID of 4.5E5 RADs for the enclosure. Increasing this TID by 2% (4.6E5 RADs) for the MUR remains below the qualification of this component.

Qualified for Post MUR conditions. Per CGD-3008.01 0001 and MCM-1393.02-0006.001, the E30 Series Pushbuttons and accessories are qualified to 1.9E5 RADs.

However, CNC-1381.05-00-0054 performed a material analysis of the E30 Series Pushbuttons and accessories, determining that the only radiation sensitive materials within these components are Polycarbonate, Phenolic, and Cork.

5 Push Button Cutler-Hammer 3.00E+05 (See Comments) Per CNC-1 381.05-00-0054 these materials have radiation Ps Button) CutlerHamme 8.29 5 (qualifications of 7.0E5 RADs, 3.0E5 RADs, and 5.0E6 RADs respectively. Per CNC-1381.05-00-0054, a pin point analysis was performed for enclosure 1ELCP0269 that determined a TID of 2.65E5 RADs for the enclosure.

Increasing this TID by 2% (2.70E5 RADs) for the MUR remains below the qualification of the most sensitive material within the E30 Series Pushbuttons (Phenolic -

Qualified conservatively to 3.0E5 RADs).

Qualified for Post MUR conditions. Per CNC-1381.05 0069, a pin point analysis was performed for enclosure Contactor Block Cutler-Hammer 5.OOE+05 (See Comments) 2ELCP0269 that determined a TID of 4.5E5 RADs for the enclosure. Increasing this TID by 2% (4.6E5 RADs) for the MUR remains below the qualification of this component.

Attachment Page Post Components within Enclosure Line Item Enclosure MUR TID (PADs) Component Qualified TID (PADs) Comments Type Manufacturer Qualified for Post MUR conditions. Per CGD-3008.01 0001 and MCM-1393.02-0006.001, the E30 Series Pushbuttons and accessories are qualified to 1.9E5 RADs.

However, CNC-1381.05-00-0054 performed a material analysis of the E30 Series Pushbuttons and accessories, determining that the only radiation sensitive materials within these components are Polycarbonate, Phenolic, and Cork.

Per CNC-1381.05-00-0054 these materials have radiation Contactor Block Cutler-Hammer 3.00E+05 (See Comments) qualifications of 7.0E5 RADs, 3.0E5 RADs, and 5.0E6 RADs respectively. Per CNC-1381.05-00-0054, a pin point analysis was performed for enclosure 1ELCP0269 that determined a TID of 2.65E5 RADs for the enclosure.

29 (cont.) 2ELCP0269 8.29E+05 Increasing this TID by 2% (2.70E5 RADs) for the MUR remains below the qualification of the most sensitive material within the E30 Series Pushbuttons (Phenolic -

Qualified conservatively to 3.0E5 RADs).

The Moore Products Model 51V Indicators within 2ELCP0269 correspond to EDB tag numbers 2NIP5200 and Indicator Moore Products N/A 2NIP5220 per IP/2/B/3140/002 Rev. 21. Both 2NIP5200 and 2NIP5220 are designated EQ-N in EDB, therefore not requiring an EQ evaluation.

Gasket Hoffman 1.OOE+08 Qualified for Post MUR conditions.

30 2TBOX0015 2.84E+06 Terminal Block Stanwick 3.OOE+07 Qualified for Post MUR conditions.

Terminal Block Stanwick 3.OOE+07 Qualified for Post MUR conditions.

31 2TBOX0018 2.03E+06 Gasket Hoffman 1.OOE+08 Qualified for Post MUR conditions.

32 2TBOX0019 2.84E+06 Terminal Block Stanwick 3.OOE+07 Qualified for Post MUR conditions.

33 2TBOX0020 3.05E+06 Terminal Block Stanwick 3.OOE+07 Qualified for Post MUR conditions.

Attachment Page Post Components within Enclosure Line Item Enclosure MUR TID _ _ __ __ Comments (RADs) (ROs)

Type Manufacturer Terminal Block Stanwick 3.00E+07 Qualified for Post MUR conditions.

34 2TBOX0021 3.05E+06 Gasket Hoffman 1.00E+08 Qualified for Post MUR conditions.

Terminal Block Stanwick 3.00E+07 Qualified for Post MUR conditions.

Optical Isolator E-Max 5.00E+04 Qualified for Post MUR conditions.

Optical Isolator E-Max 5.00E+04 Qualified based on similarity to Digital Optical Isolator DOI-175C156.

Relay Cutler-Hammer 1.50E+06 Qualified for Post MUR conditions.

35 2SMTC1 1.01E+03 Qualified for Post MUR conditions based on Revision 10 of Fuse Littelfuse 2 .20E+07 CGD-3006-01-14-0001.

Fuse Block Bussman 5.OOE+06 Qualified for Post MUR conditions.

Fuse Block - Buchanan 1.30E+07 Qualified for Post MUR conditions.

Gasket Hoffman 1.OOE+08 Qualified for Post MUR conditions.

Attachment Page Post Components within Enclosure Line Item Enclosure MUR TID Component Qualified TID Comments (RADs) Type Manufacturer Terminal Block Stanwick 3.OOE+07 Qualified for Post MUR conditions.

Qualified for Post MUR conditions. Per CNC-1381.05 0069, a pin point analysis was performed for enclosure Optical Isolator E-Max 5.OOE+04 (See Comments) 2ELCP01 12 that determined a TID of 5.0E3 RADs for the enclosure. Increasing this TID by 2% (5.1E3 RADs) for the MUR remains below the qualification of this component.

Qualified for Post MUR conditions. Per CNC-1381.05 0069, a pin point analysis was performed for enclosure Optical Isolator E-Max 5.00E+04 (See Comments) 2ELCP01 12 that determined a TID of 5.0E3 RADs for the enclosure. Increasing this TID by 2% (5.1E3 RADs) for the MUR remains below the qualification of this component.

36 2ELCP01 12 3.20E+05 Qualified for Post MUR conditions. Per CNC-1381.05 0069, a pin point analysis was performed for enclosure 2ELCP01 12 that determined a TID of 5.0E3 RADs for the Optical Isolator E-Max 5.OOE+04 (See Comments) enclosure. Increasing this TID by 2% (5.1E3 RADs) for the MUR remains below the qualification of this component.

Qualification based on similarity to Digital Optical Isolators DOI-1 75C155 and DO1-1 75C1 56.

Relay Cutler-Hammer 1.50E+06 Qualified for Post MUR conditions.

Indicating Light Cutler-Hammer 5.OOE+05 Qualified for Post MUR conditions.

Attachment Page Post Components within Enclosure Line Item Enclosure MUR TID I Component Qualified TID Comments (RADs) T (RADs)

Type Manufacturer Indicating Light Cutler-Hammer 5.00E+05 Qualified for Post MUR conditions.

Qualified for Post MUR conditions. Per CNC-1381.05 0069, a pin point analysis was performed for enclosure Indicating Light Cutler-Hammer 1.90E+05 (See Comments) 2ELCP01 12 that determined a TID of 5.0E3 RADs for the enclosure. Increasing this TID by 2% (5.1E3 RADs) for the MUR remains below the qualification of this component.

Qualified for Post MUR conditions. Per CNC-1381.05 0069, a pin point analysis was performed for enclosure Push Button Cutler-Hammer 1.90E+05 (See Comments) 2ELCP01 12 that determined a TID of 5.0E3 RADs for the enclosure. Increasing this TID by 2% (5.1E3 RADs) for the MUR remains below the qualification of this component.

36 (cont.) 2ELCP01 12 3.20E+05 Qualified for Post MUR conditions. Per CNC-1381.05 0069, a pin point analysis was performed for enclosure Contactor Block Cutler-Hammer 1.90E+05 (See Comments) 2ELCP0112 that determined a TID of 5.0E3 RADs for the enclosure. Increasing this TID by 2% (5.1E3 RADs) for the MUR remains below the qualification of this component.

Fuse Littelfuse 2.20E+07 Qualified for Post MUR conditions based on Revision 10 of CGD-3006-01-14-0001.

Fuse Block Bussman 5.00E+06 Qualified for Post MUR conditions.

Separator Glastic 5.00E+07 Qualified for Post MUR conditions.

37 1 2ELCP0113 8.29E+05 Terminal Block Stanwick 3.OOE+07 Qualified for Post MUR conditions.

Attachment Page Components within Enclosure Post Component Qualified TID Line Item I Enclosure MUR TID Comments (RADs)

(RADs)

Type Manufacturer Qualified for Post MUR conditions. Per CNC-1381.05 0069, a pin point analysis was performed for enclosure Optical Isolator E-Max 5.00E+04 (See Comments) 2ELCP01 13 that determined a TID of 1.25E4 RADs for the enclosure. Increasing this TID by 2% (1.28E4 RADs) for the MUR remains below the qualification of this component.

Qualified for Post MUR conditions. Per CNC-1381.05 0069, a pin point analysis was performed for enclosure Optical Isolator E-Max 5.00E+04 (See Comments) 2ELCP0113 that determined a TID of 1.25E4 RADs for the enclosure. Increasing this TID by 2% (1.28E4 RADs) for the MUR remains below the qualification of this component.

Qualified for Post MUR conditions. Per CNC-1381.05 0069, a pin point analysis was performed for enclosure 2ELCP01 13 that determined a TID of 1.25E4 RADs for the Optical Isolator E-Max 5.OOE+04 (See Comments) enclosure. Increasing this TID by 2% (1.28E4 RADs) for the MUR remains below the qualification of this component.

Qualification based on similarity to Digital Optical Isolators DO1-1 75C1 55 and DO1-1 75C1 56.

Relay Cutler-Hammer 1.50E+06 Qualified for Post MUR conditions.

Relay Cutler-Hammer 1.00E+06 Qualified based on similarity to C-H D23MR40A.

Qualified for Post MUR conditions. Per CNC-1381.05 0069, a pin point analysis was performed for enclosure 37 (cont.) 2ELCP0113 8.29E+05 Indicating Light Cutler-Hammer 5.OOE+05 (See Comments) 2ELCP01 13 that determined a TID of 1.25E4 RADs for the enclosure. Increasing this TID by 2% (1.28E4 RADs) for the MUR remains below the qualification of this component.

Attachment Page Components within Enclosure Post Component Qualified TID Line Item Enclosure MUR TID Comments (RADs)

(RADs)

Type Manufacturer Qualified for Post MUR conditions. Per CNC-1381.05 0069, a pin point analysis was performed for enclosure Indicating Light Cutler-Hammer 5.OOE+05 (See Comments) 2ELCP0113 that determined a TID of 1.25E4 RADs for the enclosure. Increasing this TID by 2% (1.28E4 RADs) for the MUR remains below the qualification of this component.

Qualified for Post MUR conditions. Per CNC-1381.05 0069, a pin point analysis was performed for enclosure Indicating Light Cutler-Hammer 1,90E+05 (See Comments) 2ELCP01 13 that determined a TID of 1.25E4 RADs for the enclosure. Increasing this TID by 2% (1.28E4 RADs) for the MUR remains below the qualification of this component.

Fuse Littelfuse 2.20E+07 Qualified for Post MUR conditions based on Revision 10 of CGD-3006-01-14-0001.

Fuse Block Bussman 5.00E+06 Qualified for Post MUR conditions.

Separator Glastic 5.OOE+07 Qualified for Post MUR conditions.

Gasket Hoffman 1.OOE+08 Qualified for Post MUR conditions.

Terminal Block Stanwick 3.OOE+07 Qualified for Post MUR conditions.

38 2ELCC0046 1.01E+03 Qualified based on similarity to Digital Optical Isolators DOI-Optical Isolator E-Max 5.OOE+04 175C145, DO1-175C155, and DOI-175C156.

39 2ELMC0020 3.20E+05 Terminal Block Stanwick 3.OOE+07 Qualified for Post MUR conditions.

Attachment Page Components within Enclosure Post Component Qualified TID Line Item I Enclosure MUR TID Comments (RADs)

(RADs)

Type Manufacturer Qualified for Post MUR conditions. Per CNC-1381.05 0069, a pin point analysis was performed for enclosure Optical Isolator E-Max 5.00E+04 (See Comments) 2ELMC0020 that determined a TID of 4.0E3 RADs for the enclosure. Increasing this TID by 2% (4.1E3 RADs) for the MUR remains below the qualification of this component.

Qualified for Post MUR conditions. Per CNC-1381.05 0069, a pin point analysis was performed for enclosure 2ELMC0020 that determined a TID of 4.0E3 RADs for the Optical Isolator E-Max 5.OOE+04 (See Comments) enclosure. Increasing this TID by 2% (4.1 E3 RADs) for the MUR remains below the qualification of this component.

Qualification based on similarity to Digital Optical Isolator DOI-175C156.

Relay Cutler-Hammer 1.50E+06 Qualified for Post MUR conditions.

Switch Electro Switch 1.OOE+07 Qualified for Post MUR conditions.

39 (cont.) 2ELMC0020 3.20E+05 Indicating Light Cutler-Hammer 5.OOE+05 Qualified for Post MUR conditions.

Attachment Page Components within Enclosure Post Component Qualified TID Line Item I Enclosure MUR TID Comments (RADs)

(RADs)

Type Manufacturer Qualified for Post MUR conditions. Per CNC-1381.05 0069, a pin point analysis was performed for enclosure Indicating Light Cutler-Hammer 1.90E+05 (See Comments) 2ELMC0020 that determined a TID of 4.0E3 RADs for the enclosure. Increasing this TID by 2% (4.1E3 RADs) for the MUR remains below the qualification of this component.

Push Button Cutler-Hammer 5.OOE+05 Qualified for Post MUR conditions.

Contactor Block Cutler-Hammer 1.50E+06 Qualified for Post MUR conditions.

Contactor Block Cutler-Hammer 5.OOE+05 Qualified for Post MUR conditions.

Fuse Littelfuse 2.20E+07 Qualified for Post MUR conditions based on Revision 10 of CGD-3006-01-14-0001.

Fuse Block Buchanan 1.30E+07 Qualified for Post MUR conditions.

Tranzorb Gen Semi-Conductor 2.OOE+07 Qualified for Post MUR conditions.

40 2ELMC0021 8.29E+05 Terminal Block Stanwick 3.OOE+07 Qualified for Post MUR conditions.

Attachment Page Components within Enclosure Post Component Qualified TID Line Item Enclosure MUR TID Comments (RADs)

(RADs)

Type Manufacturer Qualified for Post MUR conditions. Per CNC-1381.05 0069, a pin point analysis was performed for enclosure Optical Isolator E-Max 5.OOE+04 (See Comments) 2ELMC0021 that determined a TID of 1.25E4 RADs for the enclosure. Increasing this TID by 2% (1.28E4 RADs) for the MUR remains below the qualification of this component.

Qualified for Post MUR conditions. Per CNC-1 381.05 0069, a pin point analysis was performed for enclosure 2ELMC0021 that determined a TID of 1.25E4 RADs for the Optical Isolator E-Max 5.OOE+04 (See Comments) enclosure. Increasing this TID by 2% (1.28E4 RADs) for the MUR remains below the qualification of this component.

Qualification based on similarity to Digital Optical Isolator DOI-175C156.

Relay Cutler-Hammer 1 .50E+06 Qualified for Post MUR conditions.

Switch Electro Switch 1.OOE+07 Qualified for Post MUR conditions.

Qualified for Post MUR conditions. Per CNC-1381.05 0069, a pin point analysis was performed for enclosure Indicating Light Cutler-Hammer 5.OOE+05 (See Comments) 2ELMC0021 that determined a TID of 1.25E4 RADs for the enclosure. Increasing this TID by 2% (1.28E4 RADs) for the MUR remains below the qualification of this component.

Qualified for Post MUR conditions. Per CNC-1381.05 0069, a pin point analysis was performed for enclosure 40 (cont.) 2ELMC0021 8.29E+05 Indicating Light Cutler-Hammer 1.90E+05 (See Comments) 2ELMC0021 that determined a TID of 1.25E4 RADs for the enclosure. Increasing this TID by 2% (1.28E4 RADs) for the MUR remains below the qualification of this component.

Attachment Page Components within Enclosure Post Component Qualified TID Line Item Enclosure MUR TID Comments (RADs)

(RADs)

Type Manufacturer Qualified for Post MUR conditions. Per CNC-1381.05 0069, a pin point analysis was performed for enclosure Push Button Cutler-Hammer 5.00E+05 (See Comments) 2ELMC0021 that determined a TID of 1.25E4 RADs for the enclosure. Increasing this TID by 2% (1.28E4 RADs) for the MUR remains below the qualification of this component.

Contactor Block Cutler-Hammer 1.50E+06 Qualified for Post MUR conditions.

Qualified for Post MUR conditions. Per CNC-1381.05 0069, a pin point analysis was performed for enclosure Contactor Block Cutler-Hammer 5.OOE+05 (See Comments) 2ELMC0021 that determined a TID of 1.25E4 RADs for the enclosure. Increasing this TID by 2% (1.28E4 RADs) for the MUR remains below the qualification of this component.

Qualified for Post MUR conditions based on Revision 10 of Fuse Littelfuse 2.20E+07 CGD-3006-01-14-0001.

Fuse Block Buchanan 1.30E+07 Qualified for Post MUR conditions.

40 (cont.) 2ELMC0021 8.29E+05 Tranzorb Gen Semi-Conductor 2.00E+07 Qualified for Post MUR conditions.

Attachment Page Westinghouse Letters MCOE-LTR-15-2 and MCOE-LTR-13-103 Attachment Page Westinghouse Non-Proprietary Class 3

Westinghouse To: John F. Victor Date: January 8, 2015 From: Amy E. Freed Tel: 412-374-2734 Our ref. MCOE-LTR- 15-2, Rev. 0

Subject:

Catawba Unit I MUR Power Uprate - Reactor Vessel Integrity RAI Responses

References:

1. NRC Letter, "Catawba Nuclear Station, Units I and 2: Request for Additional Information Regarding License Amendment Request to Support a Measurement Uncertainty Recapture Power Uprate for Catawba, Unit 1 (TAC Nos. MF4526 and MF4527)," November 26, 2014. [NRC ADAMS Accession Number ML14325A667]

2. Duke Energy Letter, "Duke Energy Carolinas, LLC (Duke Energy) Catawba Nuclear Station, Units 1 and 2 Docket Numbers 50-413 and 50-414 License Amendment Request (LAR) for Measurement Uncertainty Recapture (MUR) Power Uprate," June 23, 2014. [NRC ADAMS Accession Number ML14176A109]

3. Westinghouse Report WCAP-17669-NP, Revision 0, "Catawba Unit 1 Measurement Uncertainty Recapture (MUR) Power Uprate: Reactor Vessel Integrity and Neutron Fluence Evaluations,"

June 2013.

Attachment A contains responses to NRC Requests for Additional Information (RAIs, Reference 1) received on the Catawba Unit 1 Measurement Uncertainty Recapture (MUR) power uprate license amendment request (LAR, Reference 2). These RAIs pertain to the reactor vessel integrity analyses performed for the MUR power uprate. The RAI responses are supported by the information contained in WCAP- 17669-NP (Reference 3).

Do not hesitate to contact the undersigned if you have any questions regarding the contents of this letter.

Authored by: ELECTRONICALLY APPROVED* Verified by: ELECTRONICALLY APPROVED*

Amy E. Freed Elliot J. Long Materials Center of Excellence Materials Center of Excellence Approved by: ELECTRONICALLY APPROVED*

Frank C. Gift, Manager Materials Center of Excellence

Electronicallvapprovedrecords are authenticatedin the electronicdocument management systen.

.411 Rights Reserved

Westinghouse Non-Proprietary Class 3 Page 2 of 6 MCOE-LTR- 15-2, Rev. 0 January 8, 2015 Attachment A Catawba Unit 1 MUR Power Uprate -

Reactor Vessel Integrity RAI Responses

Page 3 of 6 MCOE-LTR- 15-2, Rev. 0 January 8, 2015 Catawba Unit 1 MUR Power Uprate - Reactor Vessel Inte~ritv RAI Responses Vessels and Internals Integrity Branch (EVIB) - RAI 1 Paragraph (b)(l) of 10 CFR 50.61, "Fracture Toughness Requirements for Protection Against Pressurized Thermal Shock Events," requires that for each pressurized water nuclear power reactor, the licensee shall project values of RTPTS, accepted by the U. S. Nuclear Regulatory Commission (NRC), for each reactor vessel (RV) beltline material. Paragraph (a)(3) of Title 10 of the Code of Federal Regulations (10 CFR) 50.61 defines the RV beltline to include the region that directly surrounds the effective height of the active core and adjacent regions of the RV that are predicted to experience sufficient neutron radiation damage to be considered in the selection of the most limiting material. RIS 2014-11 further clarifies that the beltline is defined to include those portions of the RV ferritic materials with neutron fluence greater than 1 x 1017 n/cm 2 (E > I MeV) at the end of the licensed operating period.

A. Verify that RTPTS was calculated for all ferritic RV materials expected to receive neutron fluence greater than I x 1017 n/cm 2 at the end of the licensed operating period. If not, revise the RTPTS calculations in the LAR, Enclosure 2, Paragraph IV.I.C.i and Table IV.1.C-I to2 include all ferritic RV materials that will receive a neutron fluence greater than I x 10 17 n/cm at the end of the licensed operating period and submit the revised calculations to the NRC for review as a part of the management update and retrieval (MUR) LAR.

B. Clarify how the "bounding nozzle shell material" referred to in Table 5-42 of the Catawba I Updated Final Safety Report (UFSAR) correlates to the materials in the LAR, Enclosure 2, Table IV. I .C- 1.

Response to EVIB - RAI 1, Part A WCAP-17669-NP (Reference 1) contains the basis for the Catawba Unit I Measurement Uncertainty Recapture (MUR) power uprate RTPTS calculations documented in the license amendment request (LAR), , Paragraph IV.1.C.i and Table IV.1.C-I. Specifically, the Catawba Unit I reactor vessel RTPTS calculations summarized in the LAR, Enclosure 2, Table IV. I.C-1 are supported by the information contained in Section 6 and Table 6-1 of WCAP- 17669-NP.

These MUR power uprate RTPTS calculations were performed using 60-year projected end-of-life extension (EOLE) neutron fluence values calculated at 54 effective full power years (EFPY) for the Catawba Unit I reactor vessel materials. The neutron fluence values at EOLE (54 EFPY) documented in Table 2-2 of WCAP- 17669-NP were used as input to the RTPTS calculations and are summarized in Table I of this letter. Based on the results of Section 2 and Table 2-2 of WCAP-17669-NP, the materials that exceeded the 1 x 1017 n/cm 2 (E> 1.0 MeV) neutron fluence threshold at 54 EFPY (EOLE) were considered to be the Catawba Unit I beltline materials.

As shown in Table 1, the Catawba Unit I beltline materials consist of the Upper Shell Forging, Intermediate Shell Forging, Lower Shell Forging, Bottom Head Ring, Upper Shell to Intermediate Shell Circumferential Weld, Intermediate Shell to Lower Shell Circumferential Weld, and Lower Shell to Bottom Head Ring Circumferential Weld. These materials were included in the Catawba MUR power uprate RTPTS calculations.

Page 4 of 6 MCOE-LTR-15-2, Rev. 0 January 8, 2015 Therefore, all of the reactor vessel materials that were projected to receive a neutron fluence greater than I x 1011 n/cm 2 at EOLE (54 EFPY) were included in the RTPTS calculations contained in Section IV.I.C.i of Enclosure 2 of the LAR.

Table 1 Catawba Unit 1 Calculated Neutron Fluence Projections at the Reactor Vessel Clad/Base Metal Interface at 54 EFPY Fluence Reactor Vessel Material (n/cm 2 , E > 1.0 MeV)

Outlet Nozzle to Upper Shell Welds (Lowest Extent) 1, 2, 3, and 4 2.74E+16 Inlet Nozzle to Upper Shell Welds (Lowest Extent) 1, 2, 3, and 4 5.67E+16 Upper Shell Forging 1.16E+ 18 Intermediate Shell Forging 2.60E+19 Lower Shell Forging 2.60E+19 Bottom Head Ring 1.95E+18 Upper Shell to Intermediate Shell Circumferential Weld 1.16E+18 Intermediate Shell to Lower Shell Circumferential Weld 2.60E+19 Lower Shell to Bottom Head Ring Circumferential Weld 1.95E+18 Bottom Head Ring to Lower Vessel Head Circumferential Weld 3.OOE+ 14 Response to EVIB - RAI 1, Part B A detailed plant-specific fluence analysis was performed for the Catawba Unit I MUR power uprate evaluation and summarized in Section 2 of WCAP-17669-NP. As discussed in the response to Part A of this RAI, the reactor vessel materials that were projected to receive a neutron fluence greater than I x 1017 n/cm 2 at EOLE (54 EFPY) were included in the RTpTS calculations for the MUR power uprate. As shown in Table 1, the reactor vessel inlet and outlet nozzle materials are not projected to receive a neutron fluence greater than 1 x 1017 n/cm 2 at 54 EFPY; therefore, these materials were not included in the pressurized thermal shock evaluation for reactor vessel beltline materials.

Table 5-42 of the Catawba Unit I UFSAR will be updated to reflect the Catawba Unit 1 MUR power uprate results. The updated Table 5-42 containing the reactor vessel RTPTS calculations will remove the "bounding nozzle shell material" since the nozzle forging materials are not considered beltline materials for the MUR power uprate evaluation.

Page 5 of 6 MCOE-LTR-15-2, Rev. 0 January 8, 2015 EVIB - RAI3 10 CFR Part 50, Appendix G, Paragraph IV.A.I.a requires that RV beltline materials must maintain Charpy upper shelf energy (USE) throughout the operating life of the RV of no less than 50 ft-lbs, unless an equivalent margins analysis (EMA) is performed in the manner specified in 10 CFR Part 50, Appendix G, Paragraph IV.A.I.a that is approved by the NRC. RIS 2014-11 clarifies that the beltline is defined to include all ferritic materials of the RV with a neutron fluence greater than I x 1017 n/cm 2 (E > I MeV) at the end of the licensed operating period.

A. Verify that the USE calculations for Catawba I include all ferritic RV materials expected to receive a neutron fluence greater than I x 1017 n/cm 2, (E > I MeV). If not, update the USE calculations in the LAR, Enclosure 2, Paragraph IV.I.C.v and Table IV.1.C-6 to include all ferritic RV materials that will receive a neutron fluence greater than I x i 07 n/cm 2 at the end of the licensed operating period and submit the revised calculations to the NRC for review as a part of the MUR LAR.

B. Clarify how the "bounding nozzle shell material" referred to in Table 5-44 of the Catawba 1 UFSAR correlates to the materials in the LAR, Enclosure 2, Table IV. I .C-6.

Response to EVIB - RAI 3, Part A WCAP-17669-NP (Reference 1) contains the basis for the Catawba Unit 1 MUR power uprate USE calculations documented in the LAR, Enclosure 2, Paragraph IV.I.C.v and Table IV.1.C-6. Specifically, the Catawba Unit 1 reactor vessel USE calculations summarized in the LAR, Enclosure 2, Table IV. I.C-6 are supported by the information contained in Section 7 and Table 7-1 of WCAP-17669-NP.

These MUR power uprate USE calculations were performed using 60-year projected EOLE neutron fluence values calculated at 54 EFPY for the Catawba Unit I reactor vessel materials. The neutron fluence values at EOLE (54 EFPY) documented in Table 2-2 of WCAP-17669-NP were used as input to the USE calculations and are summarized in Table I of this letter (See Response to RAI 1). Based on the2 results of Section 2 and Table 2-2 of WCAP-17669-NP, the materials that exceeded the I x 10"7 n/cm (E> 1.0 MeV) neutron fluence threshold at 54 EFPY (EOLE) were considered to be the Catawba Unit I beltline materials.

As discussed in the response to Part A of RAI 1, the Catawba Unit I beltline materials consist of the Upper Shell Forging, Intermediate Shell Forging, Lower Shell Forging, Bottom Head Ring, Upper Shell to Intermediate Shell Circumferential Weld, Intermediate Shell to Lower Shell Circumferential Weld, and Lower Shell to Bottom Head Ring Circumferential Weld. These materials were included in the Catawba MUR power uprate USE calculations.

Therefore, all of the reactor vessel materials that were projected to receive a neutron fluence greater than I x 1017 n/cm 2 at EOLE (54 EFPY) were included in the USE calculations contained in Section IV.I.C.v of Enclosure 2 of the LAR.

Page 6 of 6 MCOE-LTR- 15-2, Rev. 0 January 8,2015 3 *, 11 "

Response to EVIB - RAI/ Part B A detailed plant-specific fluence analysis was performed for the Catawba Unit' I MUR power uprate evaluation and summarized in Section 2 of WCAP-17669-NP. As discussed in the response to Part A of this RAI, the reactor vessel materials that were projected to receive a neutron fluence greater than 1 x 1017 n/cm 2 at EOLE (54 EFPY) were included in the USE calculations for the MUR power uprate. As shown in Table 1, the reactor vessel inlet and outlet nozzle materials are not projected to receive a neutron fluence greater than I x 1017 nlcm 2 at 54 EFPY; therefore, these materials were not included in the USE evaluation for reactor vessel beltline materials.

Table 5-44 of the Catawba Unit I UFSAR will be updated to reflect the Catawba Unit I MUR power uprate results. The updated Table 5-44 containing the reactor vessel USE calculations will remove the "bounding nozzle shell material" since the nozzle forging materials are not considered beltline materials for the MUR power uprate evaluation.

Reference

1. Westinghouse Report WCAP- 17669-NP, Revision 0, "Catawba Unit I Measurement Uncertainty Recapture (MUR) Power Uprate: Reactor Vessel Integrity and Neutron Fluence Evaluations,"

June 2013.

Westinghouse Non-Proprietary Class 3 SWestinghouse To: John F. Victor Date: January 9, 2014 cc: Frank C. Gift From: Amy E. Freed Your ref: N/A Tel: 412-374-2734 Our ref: MCOE-LTR-13-103, Rev. 0 Fax: 724-940-8565

Subject:

Catawba Unit I Pressure-Temperature Limits: Reactor Vessel Nozzles and Other Ferritic Reactor Coolant Pressure Boundary Components

Reference:

1. NRC Letter, "McGuire Nuclear Station, Units I and 2, Issuance of Amendments Regarding Measurement Uncertainty Recapture Power Uprate (TAC Nos. ME8213 and ME8214)," May 16, 2013. [NRC ADAMS Accession Number ML13073A041]

Attachment A provides a summary of the reactor vessel (RV) inlet and outlet nozzle pressure-temperature (P-T) limits assessment for Catawba Unit I based on the NRC Request for Additional Information (RAI)

(Reference 1) received on the McGuire Measurement Uncertainty Recapture (MUR) power uprate license amendment request (LAR). Additionally, discussion of the other ferritic components in the reactor coolant pressure boundary (RCPB) with regards to P-T limit curves is also provided in Attachment A.

Do not hesitate to contact the undersigned if you have any questions regarding the contents of this letter.

Authored by: ELECTRONICALLY APPROVED*

Amy E. Freed Materials Center of Excellence Verified by: ELECTRONICALLY APPROVED* ELECTRONICALLY APPROVED*

Elliot J. Long Anees Udyawar Materials Center of Excellence Piping Analysis and Fracture Mechanics Approved by: ELECTRONICALLY APPROVED* ELECTRONICALLY APPROVED*

Frank C. Gift, Manager Seth A. Swamy, Manager Materials Center of Excellence Piping Analysis and Fracture Mechanics

Electronicallyapproved recordsare authenticatedin the electronicdocument management system.

Westinghouse Non-Proprietary Class 3 Page 1 of 13 MCOE-LTR- 13-103 Rev. 0 Attachment A January 9, 2014 Attachment A Catawba Unit 1 Pressure-Temperature Limits: RV Nozzles and Other Ferritic RCPB Components

Westinghouse Non-Proprietary Class 3 Page 2 of 13 MCOE-LTR- 13-103 Rev. 0 Attachment A January 9, 2014 Catawba Unit 1 Pressure-Temperature Limits: RV Nozzles and Other Ferritic RCPB Components Assessment Summary

Background

As part of the reactor vessel integrity (RVI) portion of the Measurement Uncertainty Recapture (MUR) power uprate project, Westinghouse provided a Pressure-Temperature (P-T) limit curves applicability evaluation to Duke Energy for Catawba Unit 1, which will be submitted to the Nuclear Regulatory Commission (NRC) for review. The applicability evaluation was performed in WCAP-17669-NP (Reference 1) for the Catawba Unit 1 34 Effective Full-Power Years (EFPY) P-T limit curves. The original 34 EFPY P-T limit curves were documented in WCAP-15203, Revision I (Reference 2). With consideration of all reactor vessel materials that were projected to achieve a neutron fluence level of I x 1017 n/cm 2 ( E > I MeV) or higher, it was previously concluded in WCAP-17669-NP that the MUR uprate evaluation did require a reduction of the existing Catawba Unit I P-T limit curve applicability date. The revised applicability date of the 34 EFPY P-T limit curves decreased to 30.7 EFPY. The Catawba Unit 1 P-T limit curves are documented in Technical Specification Figures 3.4.3-1 and 3.4.3-2.

As part of the MUR power uprate project, a similar applicability evaluation was performed for the existing 34 EFPY P-T limit curves for McGuire Units I and 2. McGuire received a Request for Additional Information (RAI) on the P-T Limit applicability MUR submittal. As documented in Reference 3, the following NRC RAI was issued to Duke:

Submit a site-specific analysis or a topical report addressingthe below McGuire RAI Question 41 within approximately one year after NRC approval of the MNS MUR license amendment request:

RA141 Pressure-Temperature(P-T)linit curves The regulation at 10 CFR Part 50, Appendix G, ParagraphIVA states that, "the pressure-retaining components of the reactor coolant pressure boundary [RCPB] that are made offerritic materials must meet the requirements of the American Society ofMechanical Engineers Boiler and Pressure Vessel Code

[ASME Code, Section III], supplemented by the additionalrequirements set forth in /paragraphIVA.2, "Pressure-Tenperature(P-T)Limits and Minimum Temperature Requirements']... " Therefore, 10 CFR Part 50, Appendix G requires that P-T limits be developed for the ferritic materials in the reactorvessel (RV) beltline (neutronfluence > 1 x 1017 n/cm2 , E > I MeV), as well asferriticmaterials not in the RV beltline (neutronfluence I MeV). Further,10 CFR Part 50, Appendix G, requires that all RCPB components must meet the ASME Code, Section 111, requirements. The relevant ASME Code, Section 111, requirement that will affect the P-T limits is the lowest service temperaturerequirement for all RCPB components specified in Section 111, NB-2332(b).

The P-T limit calculationsfor ferritic RCPB components that are not R V beltline shell materials may define P-T curves that are more limiting than those calculatedfor the RV beltline shell materials due to the following factors:

Westinghouse Non-Proprietary Class 3 Page 3 of 13 MCOE-LTR-13-103 Rev. 0 Attachment A January 9, 2014

1. RV nozzles, penetrations, and other discontinuities have complex geometries that may exhibit significantly higher stresses than those for the RV beitline shell region. These higher stresses can potentially result in more restrictive P-T limits, even if the reference temperature (RTNDT) for these components is not as high as that of RV beitline shell materials that have simpler geometries.

2. FerriticRCPB components that are not part of the RV may have initialRTNDT values, which may define a more restrictive lowest operating temperaturein the P -T limits than those for the R V beltline shell materials.

Consequently, please describe how the current P-T limit curves at 34 EFPY for McGuire Units 1 and 2 and the methodology used to develop these curves consideredall R V materials (beltline and non-beltline) and the lowest service temperature of allferritic RCPB materials, consistent with the requirements of 10 CFR Part 50, Appendix G, in the MUR power uprate LAR.

Catawba Unit 1 is anticipated to receive a similar RAI on the future P-T limit applicability evaluation submittal. The standard Westinghouse P-T limit methodology was approved by the NRC in WCAP-14040-A, "Methodology Used to Develop Cold Overpressure Mitigating System Setpoints and RCS Heatup and Cooldown Limit Curves" (References 4 and 5). Note that the current Catawba Unit 1 P-T limit curves were developed using WCAP-14040-NP-A, Revision 2 (Reference 5) along with Code Case N-640 (Reference 6), which allows the use of the K1c methodology, and was later incorporated into WCAP-14040-A, Revision 4 (Reference 4).

For Westinghouse nuclear steam supply systems, Topical Report WCAP-14040 describes the methodology that is used to comply with the requirements of 10 CFR 50 Appendix G, "Fracture Toughness Requirements" (Reference 7). Since only the reactor vessel (RV) undergoes neutron embrittlement, the RV beltline region is considered to be the most limiting reactor coolant system (RCS) component. Therefore, the methodology in WCAP-14040 only addresses the RV beltline region of the RCS as the most limiting for the P-T limits. The original NRC Safety Evaluation (SE) for this topical report states, "We find the report to be acceptable for referencing in the administrative controls section of technical specifications for license amendment applications to the extent specified and under the limitations delineated in the report and the associated NRC safety evaluation, which is enclosed. The safety evaluation defines the basis for acceptance of the report." The SE further states, "The staff finds the WCAP-14040 methodology consistent with Appendix G to Section III of the ASME Code and SRP Section 5.3.2" and "T is the metal temperature and RTNDT is the ART value of the limiting vessel material" confirming that the reactor vessel is the limiting component evaluated in the development of the P-T limits. Table I of the NRC SE provides requirements regarding the fluence methodology, surveillance capsule program requirements, LTOPS requirements, adjusted reference temperature (ART) calculation, and 10 CFR 50 Appendix G temperature requirements, which have all been addressed in the current Catawba Unit 1 Technical Specification P-T limit curves, consistent with the NRC SE.

The discussion in this letter report addresses the NRC RAI for the non-beltline reactor vessel components and other ferritic reactor coolant pressure boundary (RCPB) components with regards to P-T limits for Catawba Unit 1.

Westinghouse Non-Proprietary Class 3 Page 4 of 13 MCOE-LTR- 13-103 Rev. 0 Attachment A January 9, 2014 Reactor Vessel Beitline Components The reactor vessel beltline and extended beltline materials were previously analyzed in WCAP- 17669-NP (Reference 1) for P-T limits considering the MUR power uprate at Catawba Unit 1. The maximum 34 EFPY fast neutron (E > 1 MeV) exposure of the Catawba Unit I reactor pressure vessel, including the projected effect of a core power uprate to 3469 MWt, was previously calculated in order to determine the reactor vessel materials with a neutron fluence > I x 1017 n/cm 2, E > I MeV.

As documented in Table 2-2 of Reference 1, the upper shell forging, bottom head ring, upper shell to intermediate shell circumferential weld, and the lower shell to bottom head ring circumferential weld are projected to receive fluence values greater than I x 1017 n/cm 2 at 34 EFPY. Note that these materials are collectively considered to be the extended beltline region materials; whereas, the traditional beltline region materials include the intermediate shell, lower shell and the intermediate shell to lower shell circumferential weld. It is noted that although the upper shell forging and associated upper shell to 2

intermediate shell circumferential weld are projected to exceed the I x 1017 n/cnM threshold, the reactor vessel inlet and outlet nozzle forgings as well as the nozzle to upper shell welds remain below I x 1017 2

n/cml through 34 EFPY.

The ART values for the Catawba Unit I beltline and extended beltline materials were calculated at 34 EFPY and were determined using the methodology contained in Regulatory Guide 1.99, Revision 2 (Reference 8). These ART values were calculated using the MUR power uprate fluence values and are documented in Section 8.1 of Reference 1. The 34 EFPY ART values for the Catawba Unit I beltline and extended beltline materials were used to perform an applicability evaluation of the 34 EFPY P-T limit curves, originally documented in WCAP-15203, Revision 1 (Reference 2). The P-T limit applicability evaluation of the 34 EFPY P-T limit curves is documented in Section 8.2 of Reference 1. It was concluded that the applicability date of the current Catawba Unit 1 heatup and cooldown P-T limit curves decreased from 34 EFPY to 30.7 EFPY, with consideration of all reactor vessel materials projected to achieve surface neutron fluence levels of 1 x 1017 n/cm 2 or higher at 34 EFPY including the MUR power uprate.

Westinghouse Non-Proprietary Class 3 Page 5 of 13 MCOE-LTR- 13-103 Rev. 0 Attachment A January 9, 2014 Reactor Vessel Non-Beltline Components WCAP-14040 does not consider the embrittlement of ferritic materials in the area adjacent to the beltline, specifically the stressed inlet and outlet nozzles. The inside corner regions of these nozzles are the most highly stressed ferritic component outside the beitline region of the reactor vessel; therefore, these components are analyzed in this section.

The ART values for the Catawba Unit I nozzle comer regions were calculated at 34 EFPY for each reactor vessel inlet and outlet nozzle forging. These ART values were determined using the methodology contained in Regulatory Guide 1.99, Revision 2 (Reference 8) along with the inputs described below.

Nozzle M'aterial Properties Best-estimate copper (Cu) and nickel (Ni) weight percent (wt%) values were obtained directly from the material-specific analyses documented in the respective Certified Material Test Report (CMTR) for each of the Catawba Unit 1 reactor vessel inlet and outlet nozzle forgings. The initial RTNDT (RTNDT(U)) values were determined for each of the Catawba Unit I reactor vessel inlet and outlet nozzle forging materials using the measured Charpy V-Notch impact energy and drop-weight test data reported in each respective material CMTR. The reactor vessel inlet and outlet nozzle forging best-estimate copper and nickel weight percents and initial RTNDT material property values are consistent with the values reported in Table 5-12 of the Catawba Unit 1 Updated Final Safety Analysis Report (UFSAR, Reference 9).

The Chemistry Factor (CF) values for the nozzle forging materials were calculated using the Regulatory Guide 1.99, Revision 2 (Reference 8) methodology. Specifically, the Position 1.1 CF values were determined using the material-specific wt% copper and nickel values along with Table 2 of Regulatory Guide 1.99, Revision 2.

Nozzle Neutron Fluence Values The Catawba Unit I maximum calculated neutron fluence projections at 34 EFPY for the inlet and outlet nozzle forging materials were documented in Table 2-2 of WCAP-17669-NP (Reference 1). The maximum neutron fluence projections for the Catawba Unit 1 reactor pressure vessel were calculated using a methodology that follows the guidance and meets the requirements of Regulatory Guide 1.190 (Reference 10). As previously documented, the inlet nozzles are projected to achieve a maximum neutron fluence of 3.82 x 1016 n/cm 2 (E > 1 MeV) at the lowest extent of the nozzles at 34 EFPY. Similarly, the outlet nozzles are projected to achieve a maximum neutron fluence of 1.85 x 1016 n/cm 2 (E > 1 MeV) at the lowest extent of the nozzles at 34 EFPY. Table I summarizes the maximum projected neutron fluence values for the inlet and outlet nozzle forging materials at Catawba Unit 1. Note that the fluence values used in the ART calculations were calculated at the lowest extent of the nozzles (i.e., the nozzle to upper shell weld locations) and were chosen at an elevation lower than the actual elevation of the postulated flaw, which is at the inside comer of the nozzle, for conservatism.

Westinghouse Non-Proprietary Class 3 Page 6 of 13 MCOE-LTR- 13-103 Rev. 0 Attachment A January 9, 2014 Table 1 Catawba Unit 1 Calculated Neutron Fluence Projections on the Reactor Vessel Nozzle Materials at 34 EFPY Reactor Vessel.Material ' Fl.eiic (n/cmrn*,E > 1.0 MeV)I Inlet Nozzle Forgings 3.82E+16aw Outlet Nozzle Forgings 1.85E+16(a, Note for Table 1:

(a) Fluence values at the lowest extent of the nozzles.

Nozzle ART Values The ART values for the nozzle corner regions were calculated using the Regulatory Guide 1.99, Revision 2 methodology and are documented in Table 2. The ART values were conservatively calculated using the maximum through-wall fluence at the lowest extent of the nozzle, rather than at the standard 1/4T location. Note that the ART values for the inlet and outlet nozzle forgings were conservatively calculated at 34 EFPY. even though the applicability of the P-T limit curves documented in Technical Specification Figures 3.4.3-1 and 3.4.3-2 decreased to 30.7 EFPY with consideration of all reactor vessel materials that were projected to achieve surface fluence levels of 1 x 1017 n/cm 2 (E > 1 MeV) or higher at 34 EFPY for the MUR power uprate. The nozzle forging ART values were then used for the 1/4T flaw evaluation at the nozzle comer region.

Westinghouse Non-Proprietary Class 3 Page 7 of 13 MCOE-LTR- 13-103 Rev. 0 Attachment A January 9, 2014 Table 2 ART Calculations for the Catawba Unit 1 Reactor Vessel Nozzle Forging Materials at 34 EFPY 0

Re(C)ese Maeil(e) ) . FC TTu~d RNTri R Reacto:r Vessel.,,Matervial Wtua%/ N()*%

Wt (F)

CFb) ncm2, Maximum "*0~v Fluence(c) FF ..*(F FeRTNT(U)) A(Margin

.*ii*i:: (F !j. °) "

ART

......... (nc , MeV) (O F) (0 F)((OF)(.(F) (OF)

Inlet Nozzle 11 0.05 0.75 31 3.82E+16 0.0547 -13 1.7 0 0.8 1.7 -9.6 Inlet Nozzle 12 0.07 0.74 44 3.82E+16 0.0547 -4 2.4 0 1.2 2.4 0.8 Inlet Nozzle 13 0.04 0.77 26 3.82E+16 0.0547 -4 1.4 0 0.7 1.4 -1.2 Inlet Nozzle 14 0.05 0.75 31 3.82E+16 0.0547 -13 1.7 0 0.8 1.7 -9.6 Outlet Nozzle 15 0.05 0.75 31 1.85E+16 0.0308 -22 1.0 0 0.5 1.0 -20.1 Outlet Nozzle 16 0.07 0.75 44 1.85E+16 0.0308 -4 1.4 0 0.7 1.4 -1.3 Outlet Nozzle 17 0.04 0.77 26 1.85E+16 0.0308 -13 0.8 0 0.4 0.8 -11.4 Outlet Nozzle 18 0.05 0.80 31 1.85E+16 0.0308 -4 1.0 0 0.5 1.0 -2.1 Notes for Table 2:

(a) The Cu and Ni wt% values are material-specific values as documented in each respective material CMTR. These values are consistent with those reported in Table 5-12 of the Catawba Unit 1 UFSAR.

(b) CF values were calculated using the Cu and Ni wt% values and Table 2 of Regulatory Guide 1.99, Revision 2.

(c) Maximum neutron fluence values at the lowest extent of the nozzles at 34 EFPY. Fluence factor (FF) values were calculated using Regulatory Guide 1.99, Revision 2.

(d) RTNDT(u) values are based on measured data documented in each respective material CMTR. These values are consistent with those reported in Table 5-12 of the Catawba Unit 1 UFSAR.

(e) Per Regulatory Guide 1.99, Revision 2, the base metal nozzle forging materials oA = 17'F for Position 1.1 without surveillance data. However., *A need not exceed 0.5*ARTNDT.

Westinghouse Non-Proprietary Class 3 Page 8 of 13 MCOE-LTR- 13-103 Rev. 0 Attachment A January 9, 2014 A summary of the limiting inlet and outlet nozzle ART values at Catawba Unit I is presented in Table 3.

Table 3 Summary of the Limiting ART Values for the Inlet and Outlet Nozzle Materials at Catawba Unit 1

.... Nozzle. Material and ID Limiting ART Value>.

Number .(OF)

Inlet Nozzle 12 0.8 34 Outlet Nozzle 16 -1.3 Nozzle P-T Limits Calculation -ofthe Catawba Unit I nozzle cooldown P-T limits was completed using the inlet and outlet nozzle ART values at 34 EFPY to account for nozzle embrittlement. The stress intensity factors for pressure loading were determined based on WRC-175 methodology (Reference II); whereas, the stress intensity factor due to thermal transient stresses were calculated based on the magnification factor method provided in ORNL/TM-2010/246 (Reference 12). The stress intensity factor correlations used for the nozzle corners are consistent with the ASME PVP2011-57015 (Reference 13). The methodology used included postulating an inside surface 1/4T nozzle comer flaw, along with calculating through-wall nozzle comer stresses for a cooldown rate of I00°F/hour.

The stress intensity factors from internal pressure loading for a nozzle corner crack were calculated based on the methodology provided in WRC- 175. The pressure stress intensity factor expression is:

K, = F(a/rn)gh-[Ra where, K, = stress intensity factor for pressure loading on the nozzle comer 3 4 F(a/r*) = 2.4582 - 5.4782(a/rn) + 9.6492(a/r,,)2 - 8.80(air,) + 3.1446(a/r )

a = crack depth at the nozzle corner, for use with 1/4T (25% of the wall thickness) rn = apparent radius of nozzle = ri + 0.29r, r = actual inner radius of nozzle r = nozzle comer radius

= the shell hoop stress

Westinghouse Non-Proprietary Class 3 Page 9 of 13 MCOE-LTR-13-103 Rev. 0 Attachment A January 9, 2014 The through-wall thermal stresses at the nozzle corner location were fitted based on a third-order polynomial of the form:

2 3 a = Ao+ A Ix+A 2x +A 3 x where, G through-wall stress distribution x = through-wall distance from inside surface A0, A,, A2, A3 = coefficients of polynomial fit for the third-order polynomial, used in the stress intensity factor expression discussed below The stress intensity factors generated for a rounded nozzle corner for the thermal gradient were calculated based on the methodology provided in ORNL/TM-2010/246. The thermal stress intensity factor expression for a rounded corner is:

K = vr'c [0.706Ao+ 0.537 ()A,+ 0.448 (-)A+ 0.393 (3*)A 2 3j where, K, stress intensity factor for a circular corner crack on a nozzle with a rounded inner radius comer a crack depth at the nozzle corner, for use with 1/4T (25% of the wall thickness)

The Catawba Unit 1 inlet and outlet nozzle P-T limit curves are shown in Figures 1 and 2, respectively, based on the stress intensity factor expressions discussed above. The nozzle P-T limits are provided for a cooldown rate of -100°F/hr, along with a steady-state (SS) curve. Also shown in these figures is the traditional beltline P-T limit curve for cooldown and steady-state operation, which is valid through 30.7 EFPY (Reference 1). The P-T limit curves used for normal heatup and cooldown operation are documented in Technical Specification Figures 3.4.3-1 and 3.4.3-2. The Technical Specification heatup and cooldown limits for plant operation incorporates the 10 CFR 50, Appendix G closure head and vessel flange requirements (Reference 7).

It should be noted that an outside surface flaw in the nozzle was not considered because the pressure stress is significantly lower at the outside surface than the inside surface. A heatup nozzle P-T limit curve is not provided, since it would be less limiting than the cooldown nozzle P-T limit curve in Figures I and 2 for an inside surface flaw. Similarly, the traditional beltline P-T limit curve for heatup is also not shown in Figures 1 and 2, since it is less limiting than the traditional beltline cooldown P-T limit curve for comparison purposes to the developed nozzle curves.

Based on the results shown in Figures 1 and 2, it is concluded that the RV nozzle P-T limits are bounded by the traditional beltline curves. Therefore, the P-T limits provided in the updated Catawba Unit I Technical Specification Figures 3.4.3-1 and 3.4.3-2 for 30.7 EFPY, based on the MUR power uprate P-T limits applicability evaluation, are still applicable for the non-beltline reactor vessel components.

Westinghouse Non-Proprietary Class 3 Page 10 of 13 MCOE-LTR-13-103 Rev. 0 Attachment A January 9, 2014 30.7 EFPY Catawba Unit I Curves with Standard Flange Requirements - SS and Cooldown Curves 250011111 - - --. 1 --- -- A.I--II- - - -- - - -.-

1 1 f i ll 11 fill I 2000 III Inlet Nozzle IIII II I I I I IL- I Steady State M I 11 fill 11 Unacceptable ll II fil fi llI I I lil Operation I I I I/ i i I I I I I I I I I I I II II I Inlet Nozzle Cooldown: I

... ;;!!!-10O0 (*F/hr) I M

U) 1500

!!! Acceptable III Operation IIII H "U

1.0 J iJ*- Cooldown Rates (°F/Hr) I

-* 1000 III i 0, 20, 40, 60 & 100 '

I I e; t 500 II H M I I II I I i II

'~~f i lt l I-.I

:. J I I II I

: Clsue Ha 0

0 50 100 150 200 250 300 350 400 450 500 Indicated Temperature (Deg. F)

Figure 1: Comparison of Catawba Unit 1 Technical Specification P-T Limits to Inlet Nozzle Limits

Westinghouse Non-Proprietary Class 3 Page 11 of 13 MCOE-LTR-13-103 Rev. 0 Attachment A January 9, 2014 30.7 EFPY Catawba Unit I Curves with Standard Flange Requirements - SS and Cooldown Curves 2500

,1 11 1 II II iiTi Outlet Nozzle 2000pi I Unacceptable .LI iLL-1-i-L Qtfe-A Y

Qtfn+ý Operation_

I!!! I! IIHI III III IIII III 111 OutletNozzleCooldown

-100 (*F/hr)

MM 11 _FTT 1 1

- 1500 0 Acceptable 0 eration "0

C.

L _L1_1 I I

+

Cu

j1000 Cooldown Rates (*F/Hr) 0, 20, 40, 60 & 100 1 11111 Mill 500 Closure Head &

Vessel Flange Limit ILL_

0 0 50 100 150 200 250 300 350 400 450 500 Indicated Temperature (Deg. F)

Figure 2: Comparison of Catawba Unit 1 Technical Specification P-T Limits to Outlet Nozzle Limits

Westinghouse Non-Proprietary Class 3 Page 12 of 13 MCOE-LTR- 13-103 Rev. 0 Attachment A January 9, 2014 Other Ferritic Components in the Reactor Coolant Pressure Boundary The second portion the NRC RAI for P-T limits, described above, addresses other ferritic components of the reactor coolant system, and states the following:

10 CFR Part 50, Appendix G, requires that all RCPB components must meet the ASME Code, Section H1I, requirements. The relevant ASME Code,Section III, requirement that will affect the P-T limits is the lowest service temperaturerequirementfor all RCPB components specified in Section III, NB-2332(b).

The ferritic RCPB components that are not part of the RV consist of the Babcock and Wilcox (B&W)-designed Replacement Steam Generators (RSGs) and the original Westinghouse-designed Model D Series 84 Pressurizer. The Catawba Unit I RSGs have been analyzed for the non-ductile facture mechanics analysis as per the 1986 Code Edition of ASME Section III, Appendix G (Reference 14).

Similarly, the Model D Series 84 Pressurizer has been analyzed for the non-ductile facture mechanics analysis as per the 1971 Code Edition through Summer 1972 Addendum of ASME Section III, Appendix G. Since all of the Catawba Unit I ferritic RCPB components meet the ASME Code,Section III requirements, no further consideration is necessary for these components with regards to P-T limits.

The lowest service temperature (LST) requirement of NB-2332(b) is applicable to material for ferritic piping, pumps and valves with a nominal wall thickness greater than 2 1/22 inches (Reference 15). Note that the Catawba Unit 1 reactor coolant system does not have ferritic materials in the Class I piping, pumps or valves. Therefore, the LST requirements of NB-2332(b) are not applicable to the Catawba Unit I P-T limits.

Westinghouse Non-Proprietary Class 3 Page 13 of 13 MCOE-LTR- 13-103 Rev. 0 Attachment A January 9, 2014 References

1. Westinghouse Report WCAP- 17669-NP, Revision 0, "Catawba Unit I Measurement Uncertainty Recapture (MUR) Power Uprate: Reactor Vessel Integrity and Neutron Fluence Evaluations,"

June 2013.

2. Westinghouse Report WCAP-15203, Revision 1, "Catawba Unit I Heatup and Cooldown Curves for Normal Operation Using Code Case N-640," April 2001.

3. NRC Letter, "McGuire Nuclear Station, Units 1 and 2, Issuance of Amendments Regarding Measurement Uncertainty Recapture Power Uprate (TAC Nos. ME8213 and ME8214)," May 16, 2013. [NRC ADAMS Accession Number ML13073A041]

4. Westinghouse Report WCAP-14040-A, Revision 4, "Methodology Used to Develop Cold Overpressure Mitigating System Setpoints and RCS Heatup and Cooldown Limit Curves," May 2004.

5. WCAP-14040-NP-A, Revision 2, "Methodology Used to Develop Cold Overpressure Mitigating System Setpoints and RCS Heatup and Cooldown Limit Curves," January 1996.

6. ASME Code Case N-640, "Alternative Reference Fracture Toughness for Development of P-T Limit Curves for Section XI, Division I," February 26, 1999.

7. Code of Federal Regulations, 10 CFR Part 50, Appendix G, "Fracture Toughness Requirements,"

U.S. Nuclear Regulatory Commission, Federal Register, Volume 60, No. 243, December 19, 1995.

8. Regulatory Guide 1.99, Revision 2, "Radiation Embrittlement of Reactor Vessel Materials," U.S.

Nuclear Regulatory Commission, Office of Nuclear Regulatory Research, May 1988.

9. Duke Energy Company Catawba Nuclear Station Updated Final Safety Analysis Report, Chapter 5, Revision 16, effective April 17, 2012.

10. Regulatory Guide 1.190, "Calculational and Dosimetry Methods for Determining Pressure Vessel Neutron Fluence," U.S. Nuclear Regulatory Commission, Office of Nuclear Regulatory Research, March 2001.

11. WRC-175 Bulletin, "PVRC Recommendations on Toughness Requirements for Ferritic Materials," August 1972.

12. Oak Ridge National Laboratory Report, ORNL/TM-2010/246, "Stress and Fracture Mechanics Analyses of Boiling Water Reactor and Pressurized Water Reactor Pressure Vessel Nozzles -

Revision 1," June 2012.

13. ASME PVP2011-57015, "Additional Improvements to Appendix G of ASME Section XI Code for Nozzles," G. Stevens, H. Mehta, T. Griesbach, D. Sommerville, July 2011.

14. ASME B&PV Code Section II, Appendix G, "Fracture Toughness Criteria for Protection Against Failure."

15. ASME B&PV Code Section III, Division I, NB-2332, "Material for Piping Pumps, and Valves, Excluding Bolting Material," 2004 Edition.

v t e Letter Sequence Response to RAI
TAC:MF4526, (Open) TAC:MF4527, (Open)
Initiation Request, Request, Request, Request Acceptance... Administration Questions 8 January 2015 26 November 2014 9 February 2015 13 August 2015 Answers 22 January 2015 30 November 2015 15 December 2014 23 April 2015 16 November 2015 Results Approval... Other: CNS-14-131, WCAP-17669-NP, Revision 0, Catawba Unit 1 Measurement Uncertainty Recapture (Mur) Power Uprate: Reactor Vessel Integrity and Neutron Fluence Evaluations, CNS-15-024, WCAP-17993-NP, Revision 0-B, Justification for the Use of RAPTOR-M3G for the Catawba, Unit 1, Measurement Uncertainty Recapture (Mur) Power Uprate Fluence Evaluations., ML14353A028
MONTHYEAR2014-08-26 [Table View]

CNS-15-007, License Amendment Request (LAR) for Measurement Uncertainty Recapture (Mur) Power Uprate - Response to NRC Requests for Additional Information (Rals)

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