View source for AEP-NRC-2018-02, Request for Approval of Application of Proprietary Leak-Before-Break Methodology for Reactor Coolant System Small Diameter Piping

{{Adams
| number = ML18072A012
| issue date = 03/07/2018
| title = Request for Approval of Application of Proprietary Leak-Before-Break Methodology for Reactor Coolant System Small Diameter Piping
| author name = Lies Q
| author affiliation = American Electric Power, Indiana Michigan Power Co
| addressee name = 
| addressee affiliation = NRC/Document Control Desk, NRC/NRR
| docket = 05000315
| license number = 
| contact person = 
| case reference number = AEP-NRC-2018-02
| document type = Letter type:AEP, License-Application for Facility Operating License (Amend/Renewal) DKT 50
| page count = 54
}}

=Text=
{{#Wiki_filter:m INOIANA                                                                                         Indiana Michigan Power MICHIGAN                                                                                        Cook Nuclear Plant POWER.                                                                                         One Cook Place Bridgman, Ml 49106 A unit ofAmerican Electric Power                                                                 lndianaMichiganPower.com March 7, 2018                                                                                AEP-NRC-2018-02 10 CFR 50.90 Docket Nos.: 50-315 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555-0001 Donald C. Cook Nuclear Plant Unit 1 Request for Approval of Application of Proprietary Leak-Before-Break Methodology for Reactor Coolant System Small Diameter Piping In accordance with the provisions of Section 50.90 of Title 10 of the Code of Federal Regulations (10 CFR),             Indiana Michigan         Power Company (l&M),            the     licensee for
-Donald C. Cook Nuclear Plant (CNP) Unit 1, is submitting a request for a License Amendment Request for an amendment to Technical Specifications (TS) for CNP, Unit 1.
Pursuant to the provision of General Design Criteria (GDC) 4 of 10 CFR Part 50, Appendix A, l&M requests Nuclear Regulatory Commission (NRC) approval to apply Leak Before Break (LBS) methodology to piping for the Accumulator, Residual Heat Removal (RHR), and Safety Injection (SI) systems at CNP, Unit 1. GDC 4 provides for the exclusion of the dynamic effects due to postulated pipe ruptures from the design basis, provided the NRC reviews and approves analysis demonstrating that the probability of fluid system piping rupture is extremely low under conditions consistent with the piping design basis.
The proposed amendment would modify TS Section 3.4.13, "RCS Operational LEAKAGE," to remove a Required Action to verify that the source of Reactor Coolant System unidentified leakage is not the pressurizer surge line and to change the limits for unidentified leakage from greater than 1 gallon per minute (gpm) to greater than .8 gpm.
l&M is requesting this approval because, without the requirement to design against a double guillotine break, there would be additional margin in future piping analysis. Specifically, the additional margin would be utilized as a risk mitigation technique for the Unit 1 reactor upflow modification currently scheduled to be performed in the Spring of 2019, if a piping reanalysis is required to evaluate the impact of revised loss-of-coolant accident loads. l&M desires the assurance that there is additional margin in the piping, pipe support, and component support analyses that has not yet been recognized. The margin associated with the approval of this request could eliminate future needs for additional pipe restraints or supports whose installation and maintenance could require personnel radiation exposure as well as resource expenditures to engineer, install, and maintain.
PROPRIETARY INFORMATION Enclosures 3, 4, and 5 to this letter contains proprietary information.
Withhold from public disclosure under 10 CFR 2.390.
Upon removal of Enclosures 3, 4, and 5, this Letter is decontrolled.
                                                   / ..
                                                   ~

U. S. Nuclear Regulatory Commission                                                   AEP-NRC-201.8-02 Page 2 Additionally, in the event the planned baffle bolt installation process is interrupted, the reduced Loss of Coolant Accident loads, a benefit of the LBB analysis, could also correspond to a reduced required number of baffle bolts, minimizing the potential need of a future baffle bolt replacement effort. to this letter provides an affirmation statement. Enclosure 2 provides an evaluation of the proposed change. contains WCAP-18295-P * "Technical Justification for Eliminating Accumulator Line Rupture as the Structural Design Basis for D.C. Cook Units 1 and 2, Using Leak-Before-Break Methodology." This report is an LBB analysis performed in accordance with 10 CFR 50, Appendix A, GDC-4 and NUREG-0800, Standard Review Plan 3.6.3. The analysis performs an evaluation of CNP Unit 1 and Unit 2 Accumulator piping, but this request is only asking for approval for Unit 1 Accumulator piping. contains WCAP-18302-P 'Technical Justification for Eliminating Residual Heat Removal Line Rupture as the Structural Design Basis for D.C. Cook Units 1 and 2, Using Leak-Before-Break Methodology." This report is an LBB analysis performed in accordance with 10 CFR 50, Appendix A, GDC-4 and NUREG-0800, Standard Review Plan 3.6.3. The analysis performs an evaluation of CNP Unit 1 and Unit 2 RHR piping, but this request is only asking for approval for Unit 1 RHR piping. contains WCAP-18309-P "Technical Justification for Eliminating Safety Injection Line Rupture as the Structural Design Basis for D.C. Cook Units 1 and 2, Using Leak-Before-Break Methodology." This report is an LBB analysis performed in accordance with 10 CFR 50, Appendix A, GDC-4 and NUREG-0800, Standard Review Plan 3.6.3. The analysis performs an evaluation of CNP Unit 1 and Unit 2 SI piping, but this request is only asking for approval for Unit 1 SI piping. contains affidavits from the Westinghouse Electric Company for withholding the proprietary information contained in Enclosures 3, 4, and 5. Each affidavit sets forth the basis for which the information may be withheld from public disclosure by the Commission and addresses with specificity the considerations listed in 10 CFR 2.390(b)(4). Accordingly, it is respectfully requested that the information which is proprietary to Westinghouse be withheld from public disclosure in accordance with 10 CFR 2.390.
Enclosures 7, 8, and 9 contain non-proprietary versions of Enclosures 3, 4, and 5 respectively. The non-proprietary reports are being provided based on the NRC's expectation that the submitter of the proprietary information should provide, if possible, a non-proprietary version of the document with brackets showing where the proprietary information has been deleted. 0 provides existing Unit 1 TS pages, marked up to show the proposed changes. New clean Unit1 TS pages with proposed changes incorporated will be provided to the NRC Licensing Project Manager when requested: * *
* PROPRIETARY INFORMATION Enclosures 3, 4, and 5 to this letter contains proprietary information.
Withhold from public disclosure under 10 CFR 2.390.
Upon removal of Enclosures 3, 4, and 5, this Letter is decontrolled.

U:*S. Nuclear Regulatory Commission                                                  AEP-NRC-2018-02 Page 3. 1 provides existing Unit 1 TS Bases pages, marked up to show the proposed changes.
TS Bases markups are included for information only. Changes to the existing TS Bases, consistent with the technical and regulatory analyses, will be implemented under the Technical Specifications Bases Control Program.
Approval of the proposed amendment is requested by December 2018. Once approved, the amendment will be implemented within 90 days. Copies of this letter are being transmitted to the Michigan Public Service Commission and Michigan Department of Environmental Quality, in accordance with the requirements of 10 CFR 50.91.
There are no new regulatory commitments made in this letter. Should you have any questions, please contact Mr. Michael K. Scarpello, Regulatory Affairs Manager, at (269) 466-2649.
* Sincerely,
   ?~if-~
a.Cane Lies Site Vice President JMT/mll

==Enclosures:==
: 1. Affirmation
: 2. Evaluation of the Proposed Changes
: 3. WCAP-18295-P, Revision O ''Technical Justification for Eliminating Accumulator Line Rupture as the Structural Design Basis for D.C.
* Cook Units 1 and 2, Using Leak-Before-Break Methodology" (Proprietary)
: 4. WCAP-18302-P, Revision O "Technical Justification for Eliminating Residual Heat Removal Line Rupture as the Structural Design Basis for D.C. Cook Units 1 and 2, Using Leak-Before-Break Methodology" (Proprietary)
: 5. WCAP-18309-P, Revision O "Technical Justification for Eliminating Safety Injection Line Rupture as the Structural Design Basis for D.C. Cook Units 1 and 2, Using Leak-Before-Break Methodology" (Proprietary)
: 6. Affidavits of Withholding Pursuant to 10 CFR 2.390, Westinghouse Electric Company
: 7. WCAP-18295-NP, Revision O "Technical Justification for Eliminating Accumulator Line Rupture as the Structural Design Basis for D.C. Cook Units 1 and 2, Using Leak-Before-Break Methodology" (Non-Proprietary)
: 8. WCAP-18302-NP, Revision O "Technical Justification for Eliminating Residual Heat Removal Line Rupture as the Structural Design Basis for D.C. Cook Units 1 and 2, Using Leak-Before-Break Methodology" (Non-Proprietary)
PROPRIETARY INFORMATION Enclosures 3, 4, and 5 to this letter contains proprietary information.
Withhold from public disclosure under 10 CFR 2.390.
Upon removal of Enclosures 3, 4, and 5, this Letter is decontrolled.

U. S. Nuclear Regulatory Commission                                                    AEP-NRC-2018-02 Page 4         - *
: 9. WCAP-18309-NP, Revision O ''Technical Justification for Eliminating Safety Injection Line
* Rupture as the Structural Design Basis for D.C. Cook Units 1 and 2, Using Leak-Before-Break Methodology" (Non-Proprietary)                                      *
: 10. .Donald C. Cook Nuclear Plant Unit 1 Technical Specification Pages Marked To Show Proposed Changes
: 11. Donald C. Cook Nuclear Plant Unit 1 Technical Specification Bases Pages Marked To Show Proposed Changes (For Information Only) c:       R. J. Ancona - MPSC MDEQ - RMD/RPS NRC Resident Inspector J. K. Rankin, NRC Washington, D.C.
K. S. West, NRC Region Ill A. J. Williamson - AEP Ft. Wayne, w/o enclosures PROPRIETARY INFORMATION Enclosures 3, 4, and 5 to this letter contains proprietary information.
Withhold from public disclosure under 10 CFR 2.390. * .
Upon removal of Enclosures 3, 4, and 5, this Letter is decontrolled.

Broadnax, Tawanna From:                              Helen L Levendosky <hllevendosky@aep.com>
Sent:                              Monday, March 12, 2018 3:08 PM To:                                Rankin, Jennivine

==Subject:==
[External_Sender] FW: AEP-NRC-2018-02 Leak-before-Break Hi Jennie, See Westinghouse reply to your request below. If you need something more, please let me know.
Thanks, Helen Helen Levendosky Licensing Supervisor Regulatory Affairs D. C. Cook Nuclear Plant
{269) 466-2811 From: Brusamonti, Peter [mailto:brusamp@westinghouse.com]
Sent: Monday, March 12, 2018 2:49 PM To: Helen L Levendosky; Dave Dolby Cc: Joe Tanko

==Subject:==
[EXTERNAL] RE: AEP-NRC-.2018-02 Leak-before-Break
: Helen, The approval information pages with the header "Proprietary Class 3" can be made publically available.
The "Proprietary Class 3" classification is considered "Non-Proprietary Class 3".
Please let me know if you need any additional information.
: Thanks, Pete From: Helen L Levendosky [mailto:hllevendosky@aep.com]
Sent: Monday, March 12, 2018 1:20 PM To: Dave Dolby; Brusamonti, Peter Cc: Joe Tanko

==Subject:==
FW: AEP-NRC-2018-02 Leak-before-Break Importance: High Dave/Pete, 1

The last page of each of the redacted WCAPs (see attached pdf files) has a header that says "Proprietary Class 3" vice "Non-Proprietary Class 3" which is causing the a problem for the NRC to docket the correspondence.
Could you please reply to this e-ma_il stating that those 3 pages can be made publicly available. I will then forward to Cook Plant's NRR Project Manager so this can be resolved.
Thanks, Helen Helen Levendosky Licensing Supervisor Regulatory Affairs D. C. Cook Nuclear Plant (269) 466-2811 From: Rankin, Jennivine [mailto:Jennivine.Rankin@nrc.gov]
Sent: Monday, March 12, 2018 12:52 PM To: Kristen M Harper; Helen L Levendosky

==Subject:==
[EXTERNAL] RE: AEP-NRC-2018-02 Leak-before-Break Importance: High Good afternoon, I am having trouble docketing the below request in ADAMS. The document has been rejected for docketing because on the last page of each non-proprietary enclosure there is heading in the top right hand corner that states "Proprietary Class 3." Everywhere else it says "Non-proprietary Class 3."
Please confirm with your counterpart at Westinghouse that those pages can be made publicly available. If I can get an email with Westinghouse's agreement, then I can try to handle it from my end.
: Thanks, Jennie From: Kristen M Harper [mailto:kmharper@aep.com]
Sent: Thursday, March 08, 2018 2:43 PM To: Rankin, Jennivine <Jennivine.Rankin@nrc.gov>

==Subject:==
[External_Sender] AEP-NRC-2018-02 Leak~before-Break Hi Jennie, Attached is Part I of AEP-NRC-2018-02, Request for Approval of Application of Proprietary Leak-Before-Break Methodology for Reactor Coolant System Small Diameter Piping, dated March 7, 2018. Hard copy will follow in the mail.
Thank you Kristen Harper Cook Nuclear Plant Regulatory Affairs - Compliance Kmharper@aep.com 2

269-465-5901 x1785 3

                               *Enclosure 1 to AEP-NRC-2018-02 AFFIRMATION I, Q. Shane Lies, being duly sworn, state that I am the Site Vice President of Indiana Michigan Power Company (l&M), that I am authorized to sign and file this request with the U. S. Nuclear Regulatory Commission on behalf of l&M, and that the statements made and the matters set forth herein pertaining to l&M are true and correct to the best of my knowledg_e, information, and*
belief.
Indiana Michigan Power Company z~JC,,
Q. Shane Lies Site Vice President SWORN TO AND SUBSCRIBED BEFORE ME DANIELLE BURGOYNE
                                                                . Notary Public, State of Michigan THIS-----'-*{_ DAY OF ~O--::( ( \ : \             , 2018 County of Berrien
~ ,.. :&#xa3;i(;h              ~
My Commission Expires 04-04-2024 lb.~~>,,~                 A~ting in the County ot?.iecc',~
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Enclosure 2 to AEP-NRC-2018-02 Evaluation of Proposed Changes

==Subject:==
Request for Approval of Leak Before Break (LBB) Methodology for Reactor Coolant System (RCS) Small Diameter Piping.
1.0 

==SUMMARY==
DESCRIPTION 2.0 DETAILED DESCRIPTION 2.1 System Design and Operation 2.2 Current Technical Specification Requirements 2.3 Reason for the Proposed Change 2.4 Description of the Proposed Change

==3.0 TECHNICAL EVALUATION==

3.1 Basis for the approval of request 3.2 Evaluation Approach

===3.3 Evaluation Findings===
3.4 Evaluation of Change to TS 3.4.13 "RCS Operational LEAKAGE"

==4.0 REGULATORY EVALUATION==

4.1 Applicable Regulatory Requirements/Criteria 4.2 Precedent 4.3 No Significant Hazards Consideration 4.4 Conclusions

==5.0 ENVIRONMENTAL CONSIDERATION==

==6.0 REFERENCES==

Enclosure 2 to AEP-NRC-2018-02                                                            Page2 1.0 

==SUMMARY==
DESCRIPTION Pursuant to Title 10 of the Code of Federal Regulations (10 CFR) 90, Indiana Michigan Power Company (l&M), the licensee for Donald C. Cook Nuclear Plant (CNP) Unit 1, proposes an amendment to Renewed Facility Operating License No. DPR-58 for CNP, Unit 1. This license amendment request (LAR) requests approval for application of a leak-before-break (LBB) methodology to piping for the Accumulator, Residual Heat Removal (RHR), and Safety Injection (SI) systems at CNP, Unit 1.
The proposed amendment would modify Technical Specifications (TS) Section 3.4.13, "RCS Operational LEAKAGE," to remove a Required Action to verify that the source of RCS unidentified leakage is not the pressurizer surge line and to change the limits for unidentified leakage from greater than 1 gallon per minute (gpm) to greater than .8 gpm.
In this application, l&M is requesting approval of LBB methodology to evaluate Accumulator, RHR, and SI piping in Unit 1. The analysis provided in Enclosures 3, 4, and 5 include evaluation of portions of the Accumulator piping, RHR piping, and the SI piping, respectively.
2.0 DETAILED DESCRIPTION 2.1 System Design and Operation The Accumulator lines are attached to each of the four primary reactor coolant loop (RCL) cold leg piping segments. The Accumulator lines allow for injection from the Accumulator tanks into
* the reactor vessel, via the cold leg piping, to provide emergency core cooling. Each of the Accumulator lines are 10-inch, Schedule 140 and the portion of piping evaluated for LBB extends from the*cold leg pipe through two check valves and ends at an isolation valve near the Accumulator tanks.
The RHR lines evaluated for LBB are separated into the RHR suction line and RHR return lines.
The RHR lines draw coolant from the RCL, pass it through a heat exchanger to remove residual heat, and return the coolant back to the RCL. The RHR suction line is attached to one of the four RCL hot leg piping segments. The RHR suction line evaluated for LBB is 14-inch, Schedule 160 extending from the hot leg pipe through an isolation valve and ending at a second isolation valve.
The RHR return lines are attached to the Accumulator line piping for two of the four reactor coolant loops. The RHR return line evaluated for LBB is 8-inch, Schedule 140 at the connection to the Accumulator line and ending at the first check valve.
* The SI lines evaluated*tor LBB are associated with both the RCL hot leg piping and cold leg piping. Hot leg SI lines are directly attached to each of the four RCL hot leg piping segments.
The hot leg SI lines evaluated for LBB are 6-inch, Schedule 160 extending from the hot leg pipe
* through a check valve before transitioning to 8-inch, Schedule 140 piping and ending at an isolation valve.
Cold leg SI lines are attached to the Accumulator line piping and provide injection to the RCL cold leg through the Accumulator line. The cold leg SI lines evaluated for LBB are 10-inch, to AEP-NRC-2018-02                                                            Page 3 Schedule 140 at the connection to the Accumulator line transitioning to 6-inch, Schedule 160 piping and ending at a check valve.
Operating pressure and temperature considered for the LBB evaluation of each of these piping systems are provided in Table 1, below.
Table 1 LBB Evaluation Input Parameters for Operating Conditions Accumulator Lines:
Operating Temperature, Fahrenheit (&deg;F)
From cold leg to shortly beyond first check valve             549 From shortly beyond first check valve to isolation valve      120 Operating Pressure, Pounds Per Square Inch Gauge (psig)
From cold leg to first check valve                           2345 From first check valve to second check valve                 2235 From second check valve to isolation valve                    644 RHR Lines:
Operating Temperature, &deg;F Suction line, from hot leg to first isolation valve           617 Suction line, from first isolation valve to second isolation valve                                                         120 Return line, from Accumulator line to first check valve       120 Operating Pressure, psig Suction line, from hot leg to first isolation valve          2235 Suction line, from first isolation valve to second isolation valve                                                         450 Return line, from Accumulator line to first check valve      2235 SI Lines:
Operating Temperature, &deg;F Hot leg SI, from hot leg to first check valve                 618 Hot leg SI, from first check valve to isolation valve         120 Cold leg SI, from Accumulator line to first check valve       120 Operating Pressure, psig Hot leg SI, from hot leg to isolation valve                  2235 Cold leg SI, from Accumulator line to first check valve      2235 Thermal stratification occurs when operating conditions permit hot and cold layers of water to exist simultaneously in a horizontal pipe. This can result in significant thermal loadings due to the high fluid .temperature differentials. Changes in the stratification state result in thermal cycling, which can cause fatigue damage. In response to Nuclear Regulatory Commission (NRC) Bulletin 88-08, Supplement 3 (Reference 1), the potential for thermal stratification was examined for CNP in 1989. WCAP-12143, including Supplement 1 (Reference 2), identifies auxiliary piping systems at CNP which may be susceptible to thermal stratification. The piping

Enclosure 2 to AEP-NRC-2018-02                                                                Page4
. of _the Accumulator lines, RHR lines, and SI lines are not identified as piping systems which are susceptible to thermal stratification.
2.2 Current Technical Specifications Requirements A reliable leak detection system is required for application of the LBB methodology. This reliability is necessary to monitor initiation of a leak in the reactor coolant pressure boundary so that appropriate actions can be taken to place the plant in a safe condition.
At CNP, the TS for Unit 1 requires that the reactor coolant leakage detection system be operable in operating Modes 1 through 4. The CNP reactor coolant leakage detection systems meet the TS requirement to detect a .8 gpm leak within one hour. This exceeds the criterion of 1.0 gpm detection within 4 hours, stated in Generic Letter 84-04 (Reference 3) and NUREG-1061, Volume 3, Section 5.7(b) (Reference 4) as being acceptable for applying the LBB methodology. In addition, the CNP reactor coolant leakage detection systems are consistent with the intent of the regulatory position in Regulatory Guide 1.45, "Reactor Coolant Pressure Boundary Leakage Detection. Systems," (Reference 5) in that they provide the means for detecting, and to the extent practical, identifying the location of the source of reactor coolant leakage, and at least one method is capable of detecting 1 gpm leak in 1 hour.
Furthermore, the application of LBB has been previously evaluated for the pressurizer surge line at CNP Unit 1. The basis for the surge line LBB evaluation considered a leak detection rate of 0.8 gpm, below the 1.0 gpm leak detection capability criterion (References 3, 4, and 5). The NRC approval for implementation of the surge line LBB was predicated on demonstration that the CNP leakage detection systems are capable of reliably detecting 0.8 gpm of primary coolant leakage. The Safety Evaluation Report for the surge line LBB (Reference 6) documents that the 0.8 gpm leakage detection capability was adequately justified. A CNP leakage detection
. capability calculation demonstrates the 0.8 gpm leak detection capability is valid for leaks in the Accumulator, RHR, and SI piping. As such, the 0.8 gpm leak detection capability is the basis for the LBB evaluation of the Accumulator, RHR, and SI lines with no response time assumed.
2.3 Reason for the Proposed Change l&M is requesting this approval because, without the requirement to design against a double guillotine break, there would be additional margin in future piping analysis. Specifically, the additional margin would be utilized as a risk mitigation technique for the Unit 1 reactor upflow modification currently scheduled to be performed in the Spring of 2019, in that piping reanalysis is required to evaluate the impact of revised loss-of-coolant accident loads. l&M desires the assurance that there is additional margin in the piping, pipe support, and component support analyses that has not yet been recognized. The margin associated with the approval of this request could eliminate future needs for additional pipe restraints or supports whose installation and maintenance could require personnel radiation exposure as well as resource expenditures to engineer, install, and maintain.
Additionally, in the event the planned baffle bolt installation process is interrupted, the reduced Loss of Coolant Accident (LOCA) loads, a benefit of the LBB analysis, could also correspond to a* reduced required number of baffle bolts, minimizing the potential need of a future baffle bolt
.replacement effort.

Enclosure 2 to AEP-NRC-2018-02                                                               Page 5 2.4 Description of the Proposed Change l&M requests NRC approval to apply LBB methodology to piping for the Accumulator, RHR, and SI systems at CNP, Unit 1.
The proposed amendment would modify TS Section 3.4.13, "RCS Operational LEAKAGE," to remove Actions A and B and revise Action C to restore consistency with the Unit 2 TS 3.4.13, *
  "RCS Operational LEAKAGE," and is consistent with TSTF-449-A, Revision 4, "Steam Generator Tube Integrity." Application of TSTF-449-A, Revision 4 to CNP Unit 1 was approved by the NRC in Reference 12. Additionally, Actions C and D will be renumbered to Actions A and B. Enclosure
* 10 to this letter provides existing Unit 1 TS pages, marked up to show the proposed changes.
Enclosure 11 to this letter provides Unit 1 TS Bases pages, marked up to reflect the TS change.
The TS Bases pages are provided for information purposes only. Changes to the existing TS Bases, consistent with the technical and regulatory analyses, will be implemented under the Technical Specifications Bases Control Program. New clean Unit 1 TS pages with proposed changes incorporated will be provided to the NRC Licensing Project Manager when requested.

===Background===
In a nuclear power plant, structures, systems, and components important to safety require protection from accidents, including pipe breaks. A pipe break creates dynamic forces due to fluid discharge and pipe whip as a reaction to the jet created at the break location. The magnitude of the dynamic forces generated by a pipe break depends on the size of the break.
One method to determine the size of the break is to assume an instantaneous formation of an arbitrary break and separation across the pipe diameter. This deterministic postulation is non-mechanistic and provides the severest condition requiring a complex protection system to counteract the dynamic forces created by the pipe break.
In reality, a pipe break occurs through the formation of a tiny crack in the line that, if unstable, develops into a full size crack over time. A second method for estimating a break makes use of this fact by examining the potential for, and the duration of the crack formation. Through this analysis, it is possible to predict whether a crack will form and, in the event of its formation, whether sufficient warning will be available to safely shut down the plant. This complex analysis requires reliable engineering data of the pipe material, its configuration and plant operating experience. However, a successful implementation of this methodology reduces the complexity of systems required to protect the plant against pipe breaks. The application of this methodology, referred to as LBB methodology, reduces radiation exposure and maintenance costs while maintaining plant safety.
10 CFR 50, Appendix A, General Design Criteria (GDC) 4 allows the use of LBB analyses, when reviewed and approved by the NRC, to eliminate from the design basis the dynamic effects of the pipe ruptures postulated in NUREG-0800, Section 3.6.3 (Reference 7). An NRC staff-approved LBB analysis permits licensees to remove protective hardware such as pipe whip
* restraints and jet impingement barriers, redesign pipe connected components, their supports and their internals, and perform other related changes in operating plants.
On February 1, 1984, the NRC issued Reference 3 to all operating PWR licenses on the subject of "Safety Evaluation of Westinghouse Topical Reports Dealing With Elimination of Postulated.

Enclosure 2 to AEP-NRC-2018-02                                                              Page 6 Pipe Breaks in PWR Primary Main Loops." The NRC completed their review of l&Ms response
*-* to Reference 3 and issued a Safety Evaluation and License Amendment No. 76 to CNP
* Unit 2 (Reference 8) to delete license condition 2.C.(3)(a) on "Analysis of Reactor Vessel Supports and Internals." A corresponding amendment for Unit 1 is not required since no similar license condition was imposed for CNP Unit 1.
The NRC also approved application of LBB methodology for the CNP Unit 1 and Unit 2, pressurizer surge line rupture. An LBB analysis was performed by Westinghouse consistent with the criteria in NUREG-1061, Volume 3, and GDC-4 of Appendix A to 10 CFR 50. The analysis concluded that the probability of large pipe breaks occurring in the pressurizer surge line is sufficiently low such that dynamic effects associated with the postulated pipe breaks need not be included in the design basis. The LBB analysis was submitted for NRC review, and was approved as documented in a NRC Safety Evaluation Report (Reference 6).

==3.0 TECHNICAL EVALUATION==

3.1 Technical Assessment:
The proposed update of the l&M Unit 1 LBB evaluation is provided in three separate enclosures as described below:
Enclosure 3, to this letter, contains WCAP-18295-P ''Technical Justification fo~ Eliminating Accumulator Line Rupture as the Structural Design Basis for D.C. Cook Units 1 and 2, Using Leak-Before-Break Methodology." This report is an LBB analysis performed in accordance with 10 CFR 50, Appendix A, GDC-4 and NUREG-0800, Standard Review Plan 3.6.3. The analysis performs an evaluation of CNP Unit 1 and Unit 2 Accumulator piping, but this request is only
* asking for approval for Unit 1 Accumulator piping. Enclosure 7 contains a non-proprietary version of WCAP-18295-P.
   *Enclosure 4, to this letter, contains WCAP-18302-P ''Technical Justification for Eliminating Residual Heat Removal Line Rupture as the Structural Design Basis for D.C. Cook Units 1 and 2, Using Leak-Before-Break Methodology." This report is an LBB analysis performed in accordance with 10 CFR 50, Appendix A, GDC-4 and NUREG-0800, Standard Review Plan 3.6.3. The analysis performs an evaluation of CNP Unit 1 and Unit 2 RHR piping, but this request is only asking for approval for Unit 1 RHR piping. Enclosure 8 contains a non-proprietary version of WCAP-18302-P.
* *Enclosure 5, to this letter, contains WCAP-18309-P ''Technical Justification for Eliminating Safety Injection Line Rupture as the Structural Design Basis for D.C. Cook Units 1 and 2, Using Leak-Before-Break Methodology." This report is an LBB analysis performed in accordance with 10 CFR 50, Appendix A, GDC-4 and NUREG-0800, Standard Review Plan 3.6.3. The analysis performs an evaluation of CNP Unit 1 arid Unit 2 SI piping, but this request is only asking for approval for Unit 1 SI piping. Enclosure 9 contains a non-proprietary version of WCAP-18309-P.
Enclosure 6, to this letter, contains affidavits from the Westinghouse Electric Company for
  . withholding the proprietary information contained in Enclosures 3, 4, and 5. Each affidavit sets forth the basis for which the information may . be withheld from public disclosure by the to AEP-NRC-2018-02                                                                Page 7 Commission and addresses with specificity the considerations listed in 10 CFR 2.390(b)(4).
Accordingly, it is respectfully requested that
* the information which is proprietary to Westinghouse be withheld from public disclosure in accordance with 10 CFR 2.390.
3.2 Evaluation Approach:
For application of the LBB methodology, Westinghouse performed a review of PWR operating history to validate that the probability of crack development due to primary water stress corrosion cracking, water hammer, cyclic fatigue, thermal stratification, creep, erosion, erosion-corrosion, and brittle fracture is remote. This review has been provided through review of the operating history of the plant, including, but not limited to vendor operating history, piping design bases, water quality control, and the Updated Final Safety Analysis Report.
A review of the materials and their properties was also performed. The material type of the seamless pipes (A376 TP316) and fittings (A403 WP316) were found to be resistant to stress corrosion cracking and other potential degradation mechanisms.
The final step in the evaluation is the determination of the margins against leakage and unstable flaw propagation. This evaluation is initiated through the calculation of applied loads. For the leak rate evaluations, loading contributions from dead-weight, thermal expansion, and pressure are considered. For flaw stability evaluations, loading contributions from dead-weight, thermal expansion, pressure, and faulted seismic events are considered. The piping systems are analyzed using these load combinations to determine the limiting locations. The leakage and the critical flaw sizes at the limiting locations were calculated to determine the margin.
The highlights of this evaluation are summarized as follows:
: 1.       The forces and moments asso.ciated with normal operation (e.g., pressure, dead-weight, and thermal expansion) and faulted seismic events (Design Basis Earthquake) have been considered in the piping analyses.
: 2.       Analysis locations are categorized by piping geometry, operating conditions (pressure and temperature), material properties, and welding process. The critical analysis location is determined by the maximum faulted stress of any location in each .
distinct category.
: 3.       Through-wall flaws, under normal operation loading, have been postulated at the critical analysis locations. The predicted flaw size at each critical analysis location is large enough to ensure detection with a margin of at least ten over the plant leak detections capability under normal operating conditions.
: 4.       Using the fracture mechanics analytical model, flaw stability evaluations. were*
performed to determine the critical flaw sizes, at each critical analysis location, under faulted operation loading. Th*e ratio of critical flaw sizes to the respective leakage flaw sizes at each critical analysis location is shown to meet the required margin of two or greater.
to AEP-NRC-2018-02                                                                 Page 8
: 5.      A review of CNP operating experience has been performed to evaluate whether the pipe will experience stress corrosion cracking, fatigue, or water hammer. The review included system operational procedures, system modification history, water chemistry parameters, limits and controls, resistance of piping material to various forms of stress corrosion, and performance of the pipe under cyclic loading.
: 6.      The piping materials have been examined for susceptibility to thermal aging and
        *potential for creep or brittle cleavage-type failure over the range of operating tern peratures.

===3.3 Evaluation Findings===
The results of this evaluation indicate that a factor of ten or more exists for leak detection and a factor of two or more exists between the leakage flaw size and the critical flaw size for CNP Unit 1. The faulted loads have been combined by the absolute summation method and therefore, the recommended margin on loads is satisfied. All other conditions relative to the operating history are also satisfied. The results of the evaluation are summarized below:
: 1.      The result of analyses using the normal (pressure, dead-weight, and thermal expansion) and faulted loads identified seven critical analysis locations for the Accumulator lines, six critical analysis location for the RHR lines, and nine critical analysis locations for the SI lines. Each critical location represents the highest stress for each categorization based on piping geometry, operating conditions (pressure and temperature), material properties, and welding process.
: 2.      The leakage flaw sizes are calculated for 8 gpm and therefore, the margin of ten on leak rate is satisfied with respect to the 0.8 gpm leak detection capability at CNP.
The faulted loads have been summed absolutely; a margin exceeding one exists for the load conditions. The minimum margin between the leakage flaw size and the critical flaw size is two.
: 3.      The CNP operating history indicated that there is reasonable assurance that the pipe will not be affected by water hammer, stress corrosion cracking, and fatigue.
Additionally, CNP Unit 1 lnservice Inspection (ISi) examination records for the associated piping were reviewed and none of the examinations reported recordable indications.
The LBB analysis does not include any time dependencies and is not being used to discontinue any activities credited for age managing components in CNPs Unit 1 License Renewal. Also, there are no impacts to existing calculations associated with CNP Unit 1. Therefore, application of this LBB methodology to CNP Unit 1 would not impact CNP Unit 1 License Renewal.
It is, therefore, concluded that the LBB methodology is applicable to the CNP Unit 1 Accumulator lines, RHR lines, and SI lines.

Enclosure 2 to AEP-NRC-2018-02                                                            Page 9 3.4 Evaluation of Change to TS 3.4.13 "RCS Operational LEAKAGE":
By removing Actions A and B of Unit 1 TS 3.4.13 "RCS Operational LEAKAGE" and revising Action C to be consistent with the application TSTF-449-A, Rev. 4 (Reference 12), the TS will be more restrictive by removing the allowance to meet the Limiting Condition of Operation Action statement if it can be verified that the unidentified LEAKAGE is not originating from the pressurizer surge line. This TS change will bound the application of LBB to RHR, SI,
* Accumulator, and Pressurizer Surge Line piping by reducing the allowed RCS Operational LEAKAGE for unidentified LEAKAGE to 0.8 gpm for all Conditions of unidentified LEAKAGE.
This change restores the TS to be consistent with Reference 12 and the Unit 2 TS 3.4.14. This change maintains the validity of the NRG Safety Evaluation Report (Reference 9) which approves LBB application to the Pressurizer Surge Line piping.

==4.0 REGULATORY EVALUATION==

4.1 Applicable Regulatory Requirements/Criteria Regulatory Requirements The applicable regulatory requirement for submitting the LBB evaluation to exclude the dynamic effects associated with postulated pipe ruptures from the design basis is specified in
* 10 CFR 50, Appendix A, GDC 4. This LAR is submitted in accordance with 10 CFR 50.90.
10 CFR 50, Appendix     A  GDC CRITERION 4 Environmental and dynamic effects design bases, states:
Structures, systems, and components important to safety shall be designed to accommodate the effects of and to be compatible with the environmental conditions associated with normal operation, maintenance, testing, and postulated accidents, including loss-of-coolant accidents. These structures, systems, and components shall be appropriately protected against dynamic effects, including the effects of missiles, pipe whipping, and discharging fluids, that may result from equipment failures and from events and conditions outside .the nuclear power unit. However, dynamic effects .
* associated with postulated pipe ruptures in nuclear power units may be excluded from the design basis when analyses reviewed and approved by the Commission demonstrate that the probability of fluid system piping rupture is extremely low under conditions consistent with the design basis for the piping.
As described in Updated Final Safety Analysis Report, Section 1.4, the Plant Specific Design Criteria (PSDC) define the principal criteria and safety objectives for the CNP design. The following PSDC are relevant to the proposed amendment:
PSDC CRITERION 33 Reactor Coolant Pressure Boundary Capability.
The reactor coolant* pressure boundary shall be capable of accommodating without rupture the static and dynamic loads imposed on any boundary component as a result of an inadvertent and sudden release of energy to the coolant. As a design refemnce, this sudden release shall be taken as that which would result from a sudden reactivity to AEP-NRC-2018-02                                                             Page 10 insertion such as rod ejection (unless prevented by positive mechanical means), rod dropout, or cold water addition.
PSDC CRITERION 34 Reactor Coolant Pressure Boundary Rapid Propagation Failure Prevention The reactor coolant pressure boundary shall be designed and operated to reduce to an acceptable /eve/ the probability of rapidly propagating type failure. Consideration is given (a) to the provisions for control over service temperature and irradiation effects which may require operational restrictions, (b) to the design and construction of the reactor pressure vessel in accordance with applicable codes, including those which establish requirements for absorption of energy within the elastic strain energy range and for absorption of energy by plastic deformation and (c) to the design and construction of reactor coolant pressure boundary piping and equipment in accordance with applicable codes.
NUREG-1061, Volume 3 (Reference 4) provides a methodology that the NRC accepts for LBB submittals. The LBB approach described applies the fracture mechanics technology to demonstrate that high energy fluid piping is very unlikely to experience double-ended ruptures or their equivalent in longitudinal or diagonal splits. The NUREG also provides a step by step approach to performing LBB analysis. l&M has followed the guidance of NUREG-1061, Volume 3, in performing the enclosed analyses.
NUREG-0800, Section 3.6.3 (Reference 7) provides guidance to NRC reviewers on the specific areas to review and acceptance criteria for LBB applications.
* The LBB methodology is reviewed for key parameters to ensure that acceptance criteria are satisfied.
The proposed changes are consistent with the above regulatory requirements and criteria.
Therefore, the proposed changes will assure safe operation by continuing to meet applicable regulations and requirements.
4.2 Precedents The NRC has approved similar LARs to allow for the acceptance of LBB methodology analysis as listed in Precedents 1 and 2.
Previously, l&M has received approval from the NRC for the use of LBB methodology on CNP .
Unit 1 and Unit 2 Pressurizer Surge Line piping and RCS piping. These approvals were received outside of the LAR process, as listed in Precedents 3 and 4.
: 1. Letter from Thomas J. Wengert (NRC) to Mark A. Schimmel (Northern States Power Company - Minnesota), "Prairie Island Nuclear Generating Plant, Units 1 and 2 -
Issuance of Amendments Re: Request to Exclude the Dynamic Effects Associated with Certain Postulated Pipe Ruptures from the Licensing Basis Based Upon Application of Leak-Before-Break . Methodology. (TAC Nos. ME2976* and ME2977),"
* dated October 27, 2011, (ADAMS Accession Number ML112200856).
to AEP-NRC-2018-02                                                           Page 11
: 2. Letter from Patrick D. Milano (NRC) to Mary [sic] G. Korsnick (R. E. Ginna Nuclear Power Plant, LLC), "R. E. Ginna Nuclear Power Plant -Amendment Re: "Application of Leak-Before-Break Methodology For Pressurizer Surge Line and Accumulator Lines" (TAC No. MC4929)," dated September 22, 2005, (ADAMS Accession Number ML052430343).
: 3. Letter from John F. Stang (NRC) to Robert P. Powers (Indiana Michigan Power Company), "Donald C. Cook Nuclear Plant, Units 1 and 2 - Review of Leak-Before-Break for the Pressurizer Surge Line Piping as Provided by 10 CFR Part 50, Appendix A, GDC 4" (TAC Nos. MA7834 and MA7835)," dated November 8, 2000, (ADAMS Accession Number ML003767675).
: 4. Letter from Steven A. Varga (NRC) to John Dolan (Indiana and Michigan Electric Company), Issuance of Amendment No. 76 to Donald C. Cook Unit 2 to delete license condition on analysis of reactor vessel supports and internals, dated November 22, 1985, (ADAMS Accession Number ML021010521 ).
4.3 No Significant Hazards Consideration In accordance with 10 CFR 50.90, Indiana Michigan Power Company (l&M), the licensee for Donald C. Cook Nuclear Plant (CNP) Unit 1, Facility Operating License No. DPR-58, proposes to be allowed to exclude the dynamic effects (Leak Before Break (LBB)) associated with postulated pipe ruptures from the licensing basis for piping attached to the Reactor Coolant System (RCS). Specifically, this includes portions of the Safety Injection, Residual Heat Removal, and accumulator systems attached to the RCS. Additionally, a change will be made to the Technical Specification (TS) for the RCS leakage detection making the TS more restrictive. This TS change is to reflect the required leakage detection capabilities in order to apply leak before break.
l&M has evaluated whether or not a significant hazards consideration is involved with the proposed amendment by focusing on the three standards set forth in 10 CFR 50.92(c),
"Issuance of amendment," as discussed below:
: 1. Does the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?
Response: No.
Overall protection system performance will remain within the bounds of the previously performed accident analyses. The design of the protection systems will be unaffected. The reactor protection system and engineered safety feature actuation system will continue to function in a manner consistent with the plant design basis. All design, material and construction standards that were applicable prior to the request are maintained.
For CNP, Unit 1, the bounding accident for pipe breaks is a Large Break Loss of Coolant Accident (LBLOCA). Since the application of the LBB analysis verifies the integrity of the piping attached to the reactor coolant system, the probability of a . previously evaluated accident is not increased_. The consequences of a LBLOCA have been previously evaluated to AEP-NRC-2018-02                                                                Page 12 and found to be acceptable. The application of the LBB analysis will cause no change in the dose analysis associated with a LBLOCA, and therefore, does not affect the consequences of an accident.
The proposed amendment will not alter any assumptions or change any mitigation actions in the radiological consequence evaluations in the Updated Final Safety Analysis Report (UFSAR).
Therefore, the proposed changes do not involve a significant increase in the probability or consequences of an accident previously evaluated.
: 2. Does the proposed amendment create the possibility of a new or different kind of accident from any previously evaluated?
Response: No.
No new accident scenarios, failure mechanisms, or single failures are introduced as a result of the proposed change. All systems, structures, and components previously required for the mitigation of an event remain capable of fulfilling their intended design function. The proposed change has no adverse effects on any safety related systems or components and does not challenge the performance or integrity of any safety related system. Further, there are no changes in the method by which any safety-related plant system performs its safety function. This amendment will not affect the normal method of power operation or change any operating parameters .
   .Therefore, the proposed changes do not create the possibility of a new or different kind of accident from any accident previously evaluated.
: 3. Does the proposed amendment involve a significant reduction in a margin of safety?
Response: No.
Margin of safety is related to the ability of the fission product barriers to perform their design functions during and following accident conditions. These barriers include the fuel cladding, the reactor coolant system, and the containment. The proposed amendment request does not involve a change to any of these barriers.
The proposed change does not involve a significant reduction in a margin of safety because the proposed changes do not reduce the margin of safety that exists in the present CNP Unit 1 TS or UFSAR. The operability requirements of the TS are consistent with the initial condition assumptions of the safety analyses.
This proposed amendment uses LBB technology combined with leakage monitoring to show that it is acceptable to exclude the dynamic effects associated with postulated pipe ruptures
  . from the licensing basis for the systems evaluated that are attached to the RCS .. The
  . enclosed analysis demonstrates that the LBB margins discussed in NUREG-1061, Volume 3 are satisfied.

Enclosure 2 to AEP-NRC-2018-02                                                               Page 13 Therefore, the proposed changes do not involve a significant reduction in a margin of safety.
Based on the above, l&M concludes that the proposed amendments do not involve a significant hazards consideration under the standards s.et forth in 10 CFR 50.92(c), and, accordingly, a finding of no significant hazards consideration is justified.
4.4 Conclusions In conclusion, based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed
. manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

==5.0 ENVIRONMENTAL CONSIDERATION==

l&M has evaluated the proposed amendments for environmental considerations. The review has resulted in the determination that the proposed amendment would change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR 20. However, the proposed amendments do not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluent that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed amendments meet the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR .51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendments.

==6.0 REFERENCES==
: 1. NRC Bulletin 88-08, Supplement 3, "Thermal Stresses in Piping Connected to Reactor Coolant Systems," April 11, 1989.
: 2. WCAP-12143, Revision O and Supplement 1, "Report on Evaluation of Auxiliary Piping attached to the* Reactor Coolant System per NRC Bulletin 88-08 for American Electric Power Service Corporation D. C. Cook Units 1 and 2," April 1989.
: 3. Nuclear Regulatory Commission, Generic Letter 84-04, "Safety Evaluation of Westinghouse Topical Reports Dealing with Elimination of Postulated Pipe Breaks in PWR Primary Main Loops," February 1, 1984.
: 4. NUREG-1061, Volume 3, "Report of the U.S. Nuclear Regulatory Commission Piping Review Committee, Evaluation of Potential for Pipe Breaks," November 1984.
: 5. Regulatory Guide 1.45, "Reactor Coolant Pressure Boundary Leakage Detection Systems," Revision 1, May 2008.

.Enclosure 2 to AEP-NRC-2018-02                                                      Page 14
: 6. Letter from John F. Stang (NRC) to Robert P. Powers (Indiana Michigan Power Company), "Donald C. Cook Nuclear Plant, Units 1 and 2 - Review of Leak-Before-Break for the Pressurizer Surge Line Piping as Provided by 10 CFR Part 50, Appendix A, GDC 4" (TAC Nos. MA7834 and . MA7835)," dated November 8, 2000, (ADAMS Accession Number ML003767675).
: 7. NUREG-0800, Revision 1, Standard Review Plan: 3.6.3 Leak-Before-Break Evaluation Procedures, March 2007.
: 8. Letter from Steven A. Varga (NRC) to John Dolan (Indiana and Michigan Electric Company), Issuance of Amendment No. 76 to Donald C. Cook Unit 2 to delete license condition on analysis of reactor vessel supports and internals, dated November 22, 1985, (ADAMS Accession Number ML021010521).
   *9_ Letter from John F. Stang (NRC) to Robert P. Powers (Indiana Michigan Power Company), "Donald C. Cook Nuclear Plant, Units 1 and 2 - Review of Leak-Before-Break for the Pressurizer Surge Line Piping as Provided by 10 CFR Part 50, Appendix A, GDC 4" (TAC Nos. MA7834 and MA7835)," dated November 8, 2000, (ADAMS Accession Number ML003767675).
: 10. Nuclear Regulatory Commission, 10 CFR 50, Modification of General Design Criteria 4 Requirements for Protection Against Dynamic Effects of Postulated Pipe Ruptures, Final Rule, Federal RegisterNol. 52, No. 207/Tuesday, October 27, 1987/Rules and Regulations, pp. 41288-41295.
: 11. Standard Review Plan: Public Comments Solicited; 3.6.3 Leak-Before-Break Evaluation Procedures; Federal RegisterNol. 52, No. 167/Friday August 28, 1987/Notices, pp. 32626-32633.
: 12. Letter form Peter S. Tam (NRC) to Mano K. Nazar (Indiana Michigan Power Company),
        "Donald C. Cook Nuclear Plant, Units 1 and 2 (DCCNP-1 and -2) Issuance od Amendment - Re: Steam Generator Tube Integrity (TAC Nos. MD0075, MD0076, MD2306 and MD2307)," dated March 14, 2007 (ADAMS Accession Number ML070570559)

ENCLOSURE 6 TO AEP-NRC-2018-02 Affidavits of Withholding Pursuant to 10 CFR 2.390, Westinghouse Electric Company Westinghouse Application for Withholding Proprietary Information from Public Disclosure, CAW-18-4697, WCAP-18295-P, Revision O "Technical Justification for Eliminating Accumulator Line Rupture as the Structural Design Basis for D.C. Cook Units 1 and 2, Using Leak-Before-Break Methodology" (Proprietary).
Westinghouse Application for Withholding Proprietary Information from Public Disclosure, CAW~18-4698, WCAP-18302-P, Revision O ''Technical Justification for Eliminating Residual Heat Removal Line Rupture as the Structural Design Basis for D.C. Cook Units 1 and 2, Using Leak-Before-Break Methodology" (Proprietary)
Westinghouse Application for Withholding Proprietary Information from Public Disclosure, CAW-18-4699, WCAP-18309-P, Revision O ''Technical Justification for Eliminating Safety Injection Line Rupture as the Structural Design Basis for D.C. Cook Units 1 and 2, Using Leak-Before-Break Methodology" (Proprietary)

Westinghouse Non-Proprietary Class 3
          @Westinghouse                                                                 Westinghouse Electric Company 1000 Westinghouse Drive Cranberry Township, Pennsylvania 16066 USA U.S. Nuclear Regulatory Commission                                Direct tel: (412) 374-4643 Document Control Desk                                            Direct fax: (724) 940-8542 11555 Rockville Pike                                                e-mail: greshaja@westinghouse.com Rockville, MD 20852 CAW-18-4697 January 16, 2018 APPLICATION FOR WITHHOLDING PROPRIETARY INFORMATION FROM PUBLIC DISCLOSURE

==Subject:==
WCAP-18295-P, Revision 0, "Technical Justification for Eliminating Accumulator Line Rupture as the Structural Design Basis for D.C. Cook Units I and 2, Using Leak-Before-Break Methodology" (Proprietary)
The Application for Withholding Proprietary Information from Public Disclosure is submitted by Westinghouse Electric Company LLC ("Westinghouse"), pursuant to.the provisions of paragraph (b)(l) of Section 2.390 of the Nuclear Regulatory Commission's ("Commission's") regulations. It contains commercial strategic information proprietary to Westinghouse and customarily held in confidence.
The proprietary information for which withholding is being requested in the above-referenced report is further identified in Affidavit CA W-18-4697 signed by the owner of the proprietary information, Westinghouse. The Affidavit, which accompanies this letter, sets forth the basis on which the information may be withheld from public disclosure by the Commission and addresses with specificity the considerations listed in paragraph (b)(4) of IO CFR Section 2.390 of the Commission's regulations.
Accordingly, this letter authorizes the utilization of the accompanying Affidavit by Indiana Michigan Power Company.
Correspondence with respect to the proprietary aspects of the Application for Withholding or the Westinghouse Affidavit should reference CAW-18-4697 and should be addressed to James A. Gresham, Manager, Regulatory Compliance, Westinghouse Electric Company, 1000 Westinghouse Drive, Building 2, Suite 259, Cranberry Township, Pennsylvania 16066.
i~rurager Regulatory Compliance
                                 &#xa9; 2018 Westinghouse Electric Company LLC. All Rights Reserved.

CAW-18-4697 AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA:
ss COUNTY OF BUTLER:
I, James A. Gresham, am authorized to execute this Affidavit on behalf of Westinghouse Electric Company LLC ("Westinghouse") and declare that the averments of fact set forth in this Affidavit are true and correct to the best of my knowledge, information, and belief.
Executed on:  __,f~(~~,_fig__
James A. Gresham, Manager Regulatory Compliance

3                                     CA W-18-4697 (1) I am Manager, Regulatory Compliance, Westinghouse Electric Company LLC ("Westinghouse"),
and as such, I have been specifically delegated the function of reviewing the proprietary information sought to be withheld from public disclosure in connection with nuclear power plant licensing and rule making proceedings, and am authorized to apply for its withholding on behalf of Westinghouse.
(2) I am making this Affidavit in conformance with the provisions of 10 CFR Section 2.390 of the Nuclear Regulatory Commission's ("Commission's';) regulations and in conjunction with the Westinghouse Application for Withholding Proprietary Information from Public Disclosure accompanying this Affidavit. *
(3) I have personal knowledge of the criteria and procedures utilized by Westinghouse in designating information as a trade secret, privileged or as confidential commercial or financial information.
(4) Pursuant to the provisions of paragraph (b)(4) of Section 2.390 of the Commission's regulations, the following is furnished for consideration by the Commission in determining whether the information sought to be withheld from public disclosure should be withheld.
(i)      The information sought to be withheld from public disclosure is owned and has been held in confidence by Westinghouse.
(ii)     The information is of a type customarily held in confidence by Westinghouse and not customarily disclosed to the public. Westinghouse has a rational basis for determining the types of information customarily held in confidence by it and, in that connection, utilizes a system to determine when and whether to hold certain types of information in confidence. The application of that system and the substance of that system constitute Westinghouse policy and provide the rational basis required.
Under that system, information is held in confidence if it falls in one or more of several types, the release of which might result in the loss of an existing or potential competitive advantage, as follows:
(a)      The information reveals the distinguishing aspects of a process (or component, structure, tool, method, etc.) where prevention of its use by any of

4                                      CAW-18-4697 Westinghouse's competitors without license from Westinghouse 6onstitutes a competitive economic advantage over other companies.
(b)    It consists of supporting data, including test data, relative to a process (or component, structure, tool, method, etc.), the application of which data secures a competitive economic advantage (e.g., by optimization or improved marketability).
(c)     Its use by a competitor would reduce his expenditure of resources or improve his competitive position in the design, manufacture, shipment, installation, assurance of quality, or licensing a similar product.
( d)    It reveals cost or price information, production capacities, budget levels, or commercial strategies of Westinghouse, its customers or suppliers.
(e)     It reveals aspects of past, present, or future Westinghouse or customer funded development plans and programs of potential commercial value to Westinghouse.
(t)     It contains patentable ideas, for which patent protection may be desirable.
(iii) There are sound policy reasons behind the Westinghouse system which include the following:
(a)     The use of such information by Westinghouse gives Westinghouse a competitive advantage over its competitors. It is, therefore, withheld from disclosure to protect the Westinghouse competitive position.
(b)     It is information that is marketable in many ways. The extent to which such information is available to competitors diminishes the Westinghouse ability to sell products and services involving the use of the information.
(c)     Use by our competitor would put Westinghouse at a competitive disadvantage by reducing his expenditure of resources at our expense.

5                                    CAW-18-4697 (d)     Each component of proprietary information pertinent to a particular competitive advantage is potentially as valuable as the total competitive advantage. If competitors acquire components of proprietary information, any one component may be the key to the entire puzzle, thereby depriving Westinghouse of a competitive advantage.
(e)      Unrestricted disclosure would jeopardize the position of prominence of Westinghouse in the world market, and thereby give a market advantage to the competition of those countries.
(f)      The Westinghouse capacity to invest corporate assets in research and development depends upon the success in obtaining and maintaining a competitive advantage.
(iv) The information is being transmitted to the Commission in confidence and, under the provisions of 10 CFR Section 2.390, is to be received in confidence by the Commission.
(v)  The information sought to be protected is not available in public sources or available information has not been previously employed in the same original manner or method to the best of our knowledge and belief.
(vi) The proprietary information sought to be withheld in this submittal is that which is appropriately marked in WCAP-18295-P, Revision 0, "Technical Justification for Eliminating Accumulator Line Rupture as the Structural Design Basis for D.C. Cook Units 1 and 2, Using Leak-Before-Break Methodology" (Proprietary), dated January 2018, for submittal to the Commission, being transmitted by Indiana Michigan Power Company letter. The proprietary information as submitted by Westinghouse is that associated with Westinghouse's request forNRC approval ofWCAP-18295-P, and may be used only for that purpose.
(a)      This information is part of that which will enable Westinghouse to provide a technical justification for eliminating accumulator line rupture as the design basis for D.C. Cook Units 1 and 2.

6                                    CAW-18-4697 (b)     Further, this information has substantial commercial value as follows:
(i)      Westinghouse plans to sell the use of similar information to its customers for the purpose of performing Leak-Before-Break evaluations of the technical justification for eliminating accumulator line rupture as the design basis.
(ii)     Westinghouse can sell support and defense of industry guidelines and acceptance criteria for plant-specific applications.
(iii)    The information requested to be withheld reveals the distinguishing aspects of a methodology which was developed by Westinghouse.
Public disclosure of this proprietary information is likely to cause substantial harm to the competitive position of Westinghouse because it would enhance the ability of competitors to provide similar technical evaluation justifications and licensing defense services for commercial power reactors without commensurate expenses. Also, public disclosure of the information would enable others to use the information to meet NRC requirements for licensing documentation without purchasing the right to use the information.
The development of the technology described in part by the information is the result of applying the results of many years of experience in an intensive Westinghouse effort and the expenditure of a considerable sum of money.
In order for competitors of Westinghouse to duplicate this information, similar technical programs would have to be performed and a significant manpower effort, having the requisite talent and experience, would have to be expended.
Further the deponent sayeth not.

PROPRIETARY INFORMATION NOTICE Transmitted herewith are proprietary and non-proprietary versions of a document, furnished to the NRC in connection with requests for generic and/or plant-specific review and approval.
In order to conform to the requirements of 10 CFR 2.390 of the Commission's regulations concerning the protection of proprietary information so submitted to the NRC, the information which is proprietary in the proprietary versions is contained within brackets, and where the proprietary information has been deleted in the non-proprietary versions, only the brackets remain (the information that was contained within the brackets in the proprietary versions having been deleted). The justification for claiming the information so designated as proprietary is indicated in both versions by means oflower case letters (a) through (f) located as a superscript immediately following the brackets enclosing each item of information being identified as proprietary or in the margin opposite such information. These lower case letters refer to the types of information Westinghouse customarily holds in confidence identified in Sections (4)(ii)(a) through (4)(ii)(f) of the Affidavit accompanying this transmittal pursuantto 10 CPR 2.390(b)(l).
COPYRIGHT NOTICE The reports transmitted herewith each bear a Westinghouse copyright notice. The NRC is permitted to make the number of copies of the information contained in these reports which are necessary for its internal use in connection with generic and plant-specific reviews and approvals as well as the issuance, denial, amendment, transfer, renewal, modification, suspension, revocation, or violation of a license, permit, order, or regulation subject to the requirements of 10 CPR 2.390 regarding restrictions on public disclosure to the extent such information has been identified as proprietary by Westinghouse, copyright protection notwithstanding. With respect to the non-proprietary versions of these reports, the NRC is permitted to make the number of copies beyond those necessary for its internal use which are necessary in order to have one copy available for public viewing in the appropriate docket files in the public document room in Washington, DC and in local public document rooms as may be required by NRC regulations if the number of copies submitted is insufficient for this purpose. Copies made by the NRC must include the copyright notice in all instances and the proprietary notice if the original was identified as proprietary.

Letter for Transmittal to the NRC The following paragraphs should be included in your letter to the NRC Document Control Desk:
Enclosed are:
I. WCAP-18295-P, "Technical Justification for Eliminating Accumulator Line Rupture as the Structural Design Basis for D.C. Cook Units 1 and 2, Using Leak-Before-Break Methodology" (Proprietary)
: 2. WCAP-18295-NP, "Technical Justification for Eliminating Accumulator Line Rupture as the
    . Structural Design Basis for D.C. Cook Units .1 and 2, Using Leak-Before-Break Methodology'' (Non-Proprietary)
Also enclosed are the Westinghouse Application for Withholding Proprietary Information from Public Disclosure CAW-18-4697, accompanying Affidavit, Proprietary Information N9tice, and Copyright Notice.
As Item 1 contains information proprietary to Westinghouse Electric Company LLC ("Westinghouse"), it is supported by an Affidavit signed by Westinghouse, the owner of the information. The Affidavit sets forth the basis on which the information may be withheld from public disclosure by the Nuclear Regulatory Commission ("Commission") and addresses with specificity the .considerations listed in paragraph (b)(4) of Section 2.390 of the Commission's regulations.       *    *     *         *
* Accordingly, it is respectfully requested that the information which is proprietary to Westinghouse be withheld from public disclosure in accordance with 10 CFR Section 2.390 of the Commission's regulations.
Correspondence with respect to the copyright or proprietary aspects of the items listed above or the supporting Westinghouse Affidavit should reference CAW-18-4697 and should be addressed to James A. Gresham, Manager, Regulatory Compliance, Westinghouse Electric Company, 1000 Westinghouse Drive, Building 2, Suite 259, Cranberry Township, Pennsylvania 16066.

Westinghouse Non-Proprietary Class 3
@Westinghouse                                                                 Westinghouse Electric Company 1000 Westinghouse Drive Cranberry Township, Pennsylvania 16066 USA U.S. Nuclear Regulatory Commission                                Direct tel: (412) 374-4643 Document Control Desk                                            Direct fax: (724) 940-8542 11555 Rockville Pike                                                e-mail: greshaja@westinghouse.com Rockville, MD 20852 CAW-18-4698 January 16, 2018 APPLICATION FOR WITHHOLDING PROPRIETARY INFORMATION FROM PUBLIC DISCLOSURE

==Subject:==
WCAP-18302-P, Revision 0, "Technical Justification for Eliminating Residual Heat Removal Line Rupture as the Structural Design Basis for D.C. Cook Units 1 and 2, Using Leak-Before-Break Methodology" (Proprietary)
The Application for Withholding Proprietary Information from Public Disclosure is submitted by Westinghouse Electric Company LLC ("Westinghouse"), pursuant to the provisions of paragraph (b)(l) of Section 2.390 of the Nuclear Regulatory Commission's ("Commission's") regulations. It contains commercial strategic information proprietary to Westinghouse and customarily held in confidence.
The proprietary information for which withholding is being requested in the above-referenced report is further identified in Affidavit CAW-18-4698 signed by the owner of the proprietary information, Westinghouse. The Affidavit, which accompanies this letter, sets forth the basis on which the information may be withheld from public disclosure by the Commission and addresses with specificity the considerations listed in paragraph (b)(4) of 10 CFR Section 2.390 of the Commission's regulations.
Accordingly, this letter authorizes the utilization of the accompanying Affidavit by Indiana Michigan Power Company.
Correspondence with respect to the proprietary aspects of the Application for Withholding or the Westinghouse Affidavit should reference CAW-18-4698 and should be addressed to James A. Gresham, Manager, Regulatory Compliance, Westinghouse Electric Company, 1000 Westinghouse Drive, Building 2, Suite 259, Cranberry Township, Pennsylvania 16066.
                                                     ~
                                                  ,~es A. GreID=, Manager Regulatory Compliance
                       &#xa9; 2018 Westinghouse Electric Company LLC. All Rights Reserved.

CA W-18-4698 AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA:
ss COUNTY OF BUTLER:
I, James A. Gresham, am authorized to execute this Affidavit on behalf of Westinghouse Electric Company LLC ("Westinghouse") and declare that the averments of fact set forth in this Affidavit are true and correct to the best of my knowledge, information, and belief.
Executed on:  ~'~/t_6~r,i__                                aJ~-
iames A. Gresham, Manager Regulatory Compliance L_*

3                                     CAW-18-4698 (1)  I am Manager, Regulatory Compliance, Westinghouse Electric Company LLC ("Westinghouse"),
and as such, I have been specifically delegated the function of reviewing the proprietary information sought to be withheld from public disclosure in connection with nuclear power plant licensing and rule making proceedings, and am authorized to apply for its withholding on behalf of Westinghouse.
(2) I am making this Affidavit in conformance with the provisions of 10 CFR Section 2.390 of the Nuclear Regulatory Commission's ("Commission's") regulations and in conjunction with the Westinghouse Application for Withholding Proprietary Information from Public Disclosure accompanying this Affidavit.
(3) I have personal knowledge of the criteria and procedures utilized by Westinghouse in designating information as a trade secret, privileged or as confidential commercial or financial information.
(4) Pursuant to the provisions of paragraph (b)(4) of Section 2.390 of the Commission's regulations, the following is furnished for consideration by the Commission in determining whether the information sought to be withheld from public disclosure should be withheld.
(i)      The information sought to be withheld from public disclosure is owned and has been held in confidence by Westinghouse.
(ii)     The information is of a type customarily held in confidence by Westinghouse and not customarily disclosed to the public. Westinghouse has a rational basis for determining the types of information customarily held in confidence by it and, in that connection, utilizes a system to determine when and whether to hold certain types of information in confidence. The application of that system and the substance of that system constitute Westinghouse policy and provide the rational basis required.
Under that system, information is held in confidence if it falls in one or more of several types, the release of which might result in the loss of an existing or potential competitive advantage, as follows:
(a)       The information reveals the distinguishing aspects of a process (or component,
                     . structure, tool, method, etc.) where prevention* of its use by any of .

4                                       CAW-18-4698 Westinghouse's competitors without license from Westinghouse constitutes a competitive economic advantage over other companies.
(b)     It consists of supporting data, including test data, relative to a process (or component, structure, tool, method, etc.), the application of which data secures a competitive economic advantage (e.g., by optimization or improved marketability).
(c)     Its use by a competitor would reduce his expenditure of resources or improve his competitive position in the design, manufacture, shipment, installation, assurance of quality, or licensing a similar product.
(d)     It reveals cost or price information, production capacities, budget levels, or commercial strategies of Westinghouse, its customers or suppliers.
(e)     It reveals aspects of past, present, or future Westinghouse or customer funded development plans and programs of potential commercial value to Westinghouse.
(f)     It contains patentable ideas, for which patent protection may be desirable.
(iii) There are sound policy reasons behind the Westinghouse system which include the following:
(a)     The use of such information by Westinghouse gives Westinghouse a competitive advantage over its competitors. It is, therefore, withheld from disclosure to protect the Westinghouse competitive position.
(b)     It is information that is marketable in many ways. The extent to which such information is available to competitors diminishes the Westinghouse ability to sell products and services involving the use of the information.
(c)     Use by our competitor would put Westinghouse at a competitive disadvantage by reducing his expenditure of resources at our expense.

5                                     CAW-18-4698 (d)     Each component of proprietary information pertinent to a particular competitive advantage is potentially as valuable as the total competitive advantage. If competitors acquire components of proprietary information, any one component may be the key to the entire puzzle, thereby depriving Westinghouse of a competitive advantage.
( e)     Unrestricted disclosure would jeopardize the position of prominence of Westinghouse in the world market, and thereby give a market advantage to the competition of those countries.
(f)      The Westinghouse capacity to invest corporate assets in research and development depends upon the success in obtaining and maintaining a competitive advantage.
(iv) The information is being transmitted to the Commission in confidence and, under the provisions of 10 CFR Section 2.390, is to be received in confidence by the Commission.
(v)  The information sought to be protected is not available in public sources or available information has not been previously employed in the same original manner or method to the best of our knowledge and beiief.
(vi) The proprietary information sought to be withheld in this submittal is that which is appropriately marked in WCAP-18302-P, Revision 0, "Technical Justification for Eliminating Residual Heat Removal Line Rupture as the Structural Design Basis for D.C.
Cook Units 1 and 2, Using Leak-Before-Break Methodology" (Proprietary), dated January 2018, for submittal to the Commission, being transmitted by Indiana Michigan Power Company letter. The proprietary information as submitted by Westinghouse is that associated with Westinghouse's request forNRC approval ofWCAP-18302-P, and may be used only for that purpose.
(a)      This information is part of that which will enable Westinghouse to provide a technical justification for eliminating residual heat removal line rupture as the design basis for D.C. Cook Units 1 and 2.

6                                     CAW-18-4698 (b)     Further, this information has substantial commercial value as follows:
(i)      Westinghouse plans to sell the use of similar information to its customers for the purpose of performing Leak-Before-Break evaluations of the technical justification for eliminating residual heat removal line rupture as the design basis.
(ii)     Westinghouse can sell support and defense of industry guidelines and acceptance criteria for plant-specific applications.
(iii)    The information requested to be withheld reveals the distinguishing aspects of a methodology which was developed by Westinghouse.
Public disclosure of this proprietary information is likely to cause substantial harm to the competitive position of Westinghouse because it would enhance the ability of competitors to provide similar technical evaluation justifications and licensing defense services for commercial power reactors without commensurate expenses. Also, public disclosure of the information would enable others to use the information to meet NRC requirements for licensing documentation without purchasing the right to use the information.
The development of the technology described in part by the information is the result of applying the results of many years of experience *in an intensive Westinghouse effort and the expenditure of a considerable sum of money.
In order for competitors of Westinghouse to duplicate this information, similar technical programs would have to be performed and a significant manpower effort, having the requisite talent and experience, would have to be expended.
Further the deponent sayeth not.

PROPRIETARY INFORMATION NOTICE Transmitted herewith are proprietary and non-proprietary versions of a document, furnished to the NRC in connection with requests for generic and/or plant-specific review and approval.
In order to conform to the requirements of 10 CFR 2.390 of the Commission's regulations concerning the protection of proprietary information so submitted to the NRC, the information which is proprietary in the proprietary versions is contained within brackets, and where the proprietary information has been deleted in the non-proprietary versions, only the brackets remain (the information that was contained within the brackets in the proprietary versions having been deleted). The justification for claiming the information so d~signated as proprietary is indicated in both versions by means oflower case letters (a) through (f) located as a superscript immediately following the brackets enclosing each item of information being identified as proprietary or in the margin opposite such information. These lower case letters refer to the types of information Westinghouse customarily holds in confidence identified in Sections (4)(ii)(a) through (4)(ii)(f) of the Affidavit accompanying this transmittal pursuantto 10 CFR 2.390(b)(l).
COPYRIGHT NOTICE The reports transmitted herewith each bear a Westinghouse copyright notice. The NRC is permitted to make the number of copies of the information contained in these reports which are necessary for its internal use in connection with generic and plant-specific reviews and approvals as well as the issuance, denial, amendment, transfer, renewal, modification, suspension, revocation, or violation of a license, permit, order, or regulation subject to the requirements of 10 CFR 2.390 regarding restrictions on public disclosure to the extent such information has been identified as proprietary by Westinghouse, copyright protection notwithstanding. With respect to the non-proprietary versions of these reports, the NRC is permitted to make the number of copies beyond those necessary for its internal use which are necessary in
* order to have one copy available for public viewing in the appropriate docket files in the public document room in Washington, DC and in local public document rooms as may be required by NRC regulations if the number of copies submitted is insufficient for this purpose. Copies made, by the NRC must include the copyright notice in all instances and the proprietary notice if the original was identified as proprietary.

Letter for Transmittal to the NRC The following paragraphs should be included in your letter to the NRC Document Control Desk:
Enclosed are:
: 1. WCAP-18302-P, "Technical Justification for Eliminating Residual Heat Removal Line Rupture as the Structural Design Basis for D.C. Cook Units 1 and 2, Using Leak-Before-Break Methodology" (Proprietary)
: 2. WCAP-18302-NP, "Technical Justification for Eliminating Residual Heat Removal Line Rupture as the Structural Design Basis for D.C. Cook Units 1 and 2, Using Leak-Before-Break Methodology" (Non-Proprietary)
Also enclosed are the Westinghouse Application for Withholding Proprietary Information from Public Disclosure CA W-18-4698, accompanying Affidavit, Proprietary Information Notice, and Copyright Notice.
As Item 1 contains information proprietary to Westinghouse Electric Company LLC ("Westinghouse"), it is supported by an Affidavit signed by Westinghouse, the owner of the information. The Affidavit sets forth the basis on which the information may be withheld from public disclosure by the Nuclear Regulatory Commission ("Commission") and addresses with specificity the considerations listed in
* paragraph (b)(4) of Section 2.390 of the Commission's regulations.
Accordingly, it is respectfully requested that the information which is proprietary to Westinghouse be withheld from public disclosure in accordance with 10 CFR Section 2.390 of the Commission's regulations.
Correspondence with respect to the copyright or proprietary aspects of the items listed above or the supporting Westinghouse Affidavit should reference CA W-18-4698 and should be addressed to James A. Gresham, Manager, Regulatory Compliance, Westinghouse Electric Company, 1000 Westinghouse Drive, Building 2, Suite 259, Cranberry Township, Pennsylvania 16066.

Westinghouse Non-Proprietary Class 3
    @Westinghouse                                                                Westinghouse Electric Company 1000 Westinghouse Drive Cranberry Township, Pennsylvania 16066 USA.
U.S. Nuclear Regulatory Commission                                Directtel: (412)374-4643 Document Control Desk                                            Direct fax: (724) 940-8542 11555 Rockville Pike                                               e-mail: greshaja@westinghouse.com Rockville, MD 20852 CAW-18-4699 January 17, 2018 APPLICATION FOR WITHHOLDING PROPRIETARY INFORMATION FROM PUBLIC DISCLOSURE

==Subject:==
WCAP-18309-P, Revision 0, "Technical Justification for Eliminating Safety Injection Line Rupture as the Structural Design Basis for D.C. Cook Units 1 and 2; Using Leak-Before-Break Methodology'' (Proprietary)
The Application for Withholding Proprietary Information from Public Disclosure is submitted by Westinghouse Electric Company LLC ("Westinghouse"), pursuant to the provisions of paragraph (b)(1)
  . of Section 2.390 of the Nuclear Regulatory *commission's (''Commission's")&deg; regulations. It contains commercial strategic information proprietary to Westinghouse and customarily held in. confidence.
The proprietary information for which withholding is being requested in the above-referenced report is further identified in Affidavit CAW-18-4699 signed by the owner of the proprietary information, Westinghouse. The Affidavit, which accompanies this letter, sets forth the basis on which the information may be withheld from public disclosure by the Commission and addresses with specificity the considerations listed in paragraph (b)(4) of 10 CFR Section 2.390 of the Commission's regulations.
Accordingly, this letter authorizes the utilization of the accompanying Affidavit by Indiana Michigan Power Company.
Correspondence with respect to the proprietary aspects of the Application for Withholding or the Westinghouse Affidavit should reference CAW-18-4699 and should be addressed to James A. Gresham, Manager, Regulatory Compliance, Westinghouse Electric Company, 1000 Westinghouse Drive, Building 2, Suite 259, Cranberry Township, Pennsylvania 16066.
James A. Gresham, Manager Regulatory Compliance
                           &#xa9; 2018 Westinghouse Electric Company LLC. All Rights Reserved I

CAW-18-4699 AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA:
ss COUNTY OF BUTLER:
I, James A. Gresham, am authorized to execute this Affidavit on behalf of Westinghouse Electric Company LLC ("Westinghouse") and declare that the averments of fact set forth in this Affidavit are true and correct to the best of my knowledge, information, and belief.
Executed on:     1f,1(r~
* ames A. Gresham, Manager Regulatory Compliance

3                                     CAW-18-4699 (1)    I am Manager, Regulatory Compliance, Westinghouse Electric Company LLC ("Westinghouse"),
and as such, I have been specifically delegated the function of reviewing the proprietary information sought to be withheld from public disclosure in connection with nuclear power plant licensing and rule making proceedings, and am authorized to apply for its withholding on behalf of Westinghouse.
(2)   I am making this Affidavit in conformance with the provisions of 10 CFR Section 2.390 of the Nuclear Regulatory Commission's ("Commission's") regulations and in conjunction with the Westinghouse Application for Withholding Proprietary Information from Public Disclosure accompanying this Affidavit (3)   I have personal knowledge of the criteria and procedures utilized by Westinghouse in designating information as a trade secret, privileged or as confidential commercial or financial infonnation.
(4)   Pursuantto the provisions of paragraph (b)(4) of Section 2.390 of the Commission's regulations, the following is furnished for consideration by the Commission in determining whether the
* information sought to be withheld from public disclosure should be withheld.
(i)      The information sought to be withheld from public disclosure is owned and has been held in confidence by Westinghouse ..
(ii)     The information is of a type customarily held in confidence by Westinghouse and not customarily disclosed to the public. Westinghouse has a rational basis for determining the types of information customarily held in confidence by it and, in that connection, utilizes a system to determine when and whether to hold certain types of infonnation in confidence. The application of that system and the substance of that system constitute Westinghouse policy and provide the rational basis required.
Under that system, information is held in confidence if it falls in one or more of several types, the release of which might result in the loss of an existing or potential competitive advantage, as follows:
(a)      The information reveals the distinguishing aspects of a process (or component, structure, tool, method, etc.) where prevention of its use by any of

4                                        CAW-18-4699 Westinghouse's competitors without license from Westinghouse constitutes a competitive economic advantage over other companies.
(b)     It consists of supporting data, including test data, relative to a process (or component, structure, tool, method, etc.), the application of which data secures a competitive economic advantage (e.g., by optimization or improved marketability).
(c)    Its use by a competitor would reduce his expenditure of resources or improve his competitive position in the design, manufacture, shipment, installation, assurance of quality, or licensing a similar product.
(d)     It reveals cost or price infonnation, production capacities, budget levels, or commercial strategies of Westinghouse, its customers or suppliers.
(e)     It reveals aspects of past, present, or future Westinghouse or customer funded development plans and programs of potential commercial value to Westinghouse.
(t)     It contains patentable ideas, for which patent protection may be desirable.
(iii) There are sound policy reasons behind the Westinghouse system which include the following:
(a)     The use of such infonnation by Westinghouse gives Westinghouse a competitive advantage over its competitors. It is, therefore, withheld from disclosure to protect the Westinghouse competitive position.
(b)     It is infonnation that is marketable in many ways. The extent to which such infonnation is available to competitors diminishes the Westinghouse ability to sell products and services involving the use of the information.
(c)     Use by our competitor would put Westinghouse at a competitive disadvantage by reducing his expenditure of resources at our expense.

5                                     CAW-18-4699 (d)     Each component of proprietary infonnation pertinent to a particular competitive advantage is potentially as valuable as the total competitive advantage. If competitors acquire components of proprietary information, any one component may be the key to the entire puzzle, thereby depriving Westinghouse of a competitive advantage.
(e)     Unrestricted disclosure would jeopardize the position of prominence of Westinghouse in the world market, and thereby give a market advantage to the competition of those countries.
(f)      The Westinghouse capacity to invest corporate assets in research and development depends upon the success in obtaining and maintaining a competitive advantage.
(iv)   The information is being transmitted to the Commission in confidence and, under the provisions of 10 CFR Section 2.390, is to be received in confidence by the Commission.
(v)  . The information sorightto be protected is not available in public sources or available information has not been previously employed in the same original manner or method to the best of our knowledge and belief.
(vi)   The proprietary information sought to be withheld in this submittal is that which is appropriately marked in WCAP-18309-P, Revision 0, "Technical Justification for Eliminating Safety Injection Line Rupture as the Structural Design Basis for D.C. Cook Units 1 and 2, Using Leak-Before-Break Methodology" (Proprietary), dated January 2018, for submittal to the Commission, being transmitted by Indiana Michigan Power Company letter. The proprietary information as submitted by Westinghouse is that associated with Westinghouse's request for NRC approval of WCAP-18309-P, and may be used only for that purpose.
(a)      This information is part of that which will enable Westinghouse to provide a technical justification for eliminating safety injection line rupture as the design basis for D.C. Cook Units 1 and 2.

6                                      CAW-18-4699 (b)     Further, this information has substantial commercial value as follows:
(i)      Westinghouse plans to sell the use ofsimilar information to its customers for the purpose of performing Leak-Before-Break evaluations of the technical justification for eliminating safety injection line rupture as the design basis.
( ii)    Westinghouse can sell support an_d deferise of industry ~idel~es and acceptance criteria for plant-specific applications.
(iii)    The information requested to be withheld reveals the distinguishing aspects of a methodology which was developed by Westinghouse.
Public disclosure of this proprietary information is likely to cause substantial harm to the competitive position of Westinghouse because it would enhance the ability of competitors to provide similar technical evaiuationjustifications and licensing defense services for comm~rcial power reactors without commensurate expenses. Also, public disclosure of the information would enable others to use the information to meet NRC requirements for licensing documentation without purchasing the right to use the information.
The development of the technology described in part by the information is the result of applying the results of many years of experience in an intensive Westinghouse effort and the expenditure of a considerable sum of money.
In order for competitors of Westinghouse to duplicate this information, similar technical programs would have to be performed and a significant manpower effort, having the requisite talent and experience, would have to be expended.
Further the deponent sayeth not.

PROPRIETARY INFORMATION NOTICE Transmitted herewith are proprietary and non-proprietary versions of a document, furnished to the NRC in connection with requests for generic and/or plant-specific review and approval.
In order to conform to the requirements of 10 CFR 2.390 of the Commission's regulations concerning the protection of proprietary information so submitted to the NRC, the information which is proprietary in the proprietary versions is contained within brackets, and where the proprietary information has been deleted in the non-proprietary versions, only the brackets remain (the information that was contained within the brackets in the proprietary versions having been deleted). The justification for claiming the information so designated as proprietary is indicated in both versions by means oflower case letters (a) through (f) located as a superscript immediately following the brackets enclosing each item of information being identified as proprietary or in the margin opposite such information. These lower case letters refer to the
* types of information Westinghouse customarily holds in confidence identified in Sections (4)(ii)(a) through (4)(ii)(f) of the Affidavit accompanying this transmittal pursuantto 10 CFR 2.390(b)(l).
COPYRIGHT NOTICE The reports transmitted herewith each bear a Westinghouse copyright notice. The NRC is permitted to make the number of copies of the information contained in these reports which are necessary for its internal use in connection with generic and plant-specific reviews and approvals as well as the issuance, denial, amendment, transfer, renewal, modification, suspension, revocation, or violation of a license, permit, order, or regulation subject to the requirements of IO CFR 2.390 regarding restrictions on public disclosure to the extent such information has been identified as proprietary by Westinghouse, copyright protection notwithstanding. With respect to the non-proprietary versions of these reports, the NRC is permitted to make the number of copies beyond those necessary for its internal use which are necessary in order to have one copy available for public viewing in the appropriate docket files in the public document room in Washington, DC and in local public document rooms as may be required by NRC regulations if the number of copies submitted is insufficient for this purpose. Copies made by the NRC must include the copyright notice in all instances and the proprietary notice if the original was identified as proprietary.

Letter for Transmittal to the NRC The following paragraphs should be included in your letter to the NRC Document Control Desk:
Enclosed are:
: 1. WCAP-18309-P, "Technical Justification for Eliminating Safety Injection Line Rupture as the Structural Design Basis for D.C. Cook Units 1 and 2, Using Leak-Before-Break Methodology" (Proprietary)            *
: 2. WCAP-18309-NP, ."Technical. Justification for _Eliminating Saftity Injection Line Rupw.re as the Structural Design Basis for D.C. Cook Units 1 and 2, Using Leak-Before-Break Methodology" (Non-Proprietary)
* Also enclosed are the Westinghouse Application for Withholding Proprietary Information from Public Disclosure CAW-18-4699, accompanying Affidavit, Proprietary Information Notice, and Copyright Notice.
As Item 1 contains information proprietary to Westinghouse Electric Company LLC ("Westinghouse"), it is supported by an Affidavit signed by Westinghouse, the owner of the information. The Affidavit sets forth the basis on which the information may be withheld from public disclosure by the Nuclear Regulatory .Commission ("Commission") and addresses .with specificity the considerations listed in paragraph (b)(4) of Section 2.390 of the Commission's regulations.
Accordingly, it is respectfully requested that the information which is proprietary to Westinghouse be withheld from public disclosure in accordance with 10 CFR Section 2.390 of the Commission's regulations.
Correspondence with respect to the copyright or proprietary aspects of the items listed above or the supporting Westinghouse Affidavit should reference CAW-18-4699 and should be addressed to James A. Gresham, Manager, Regulatory Compliance, Westinghouse Electric Company, 1000 Westinghouse Drive, Building 2, Suite 259, Cranberry Township, Pennsylvania 16066.

ENCLOSURE 10 TO AEP-NRC-2018-02 Donald C. Cook Nuclear Plant Unit 1 Technical Specification Pages Marked To Show Proposed Changes

RCS Operational LEAKAGE 3.4.13 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.13       RCS Operational LEAKAGE LCO 3.4.13              RCS operational LEAKAGE shall be limited to:
: a. No pressure boundary LEAKAGE;
: b.
* 0.8 gpm unidentified LEAKAGE;
: c. 10 gpm identified LEAKAGE; and
                      . d. . 150 gallons per day primary to secondary LEAKAGE through .any _
one steam generator (SG).
APPLICABILITY:          MODES 1, 2, 3, and 4.
ACTIONS CONDITION                      REQUIRED ACTION                      COMPLETION TIME I\
Unidentified LEAKAGE          A.1     VeFif,1 se1;1Fse ef 1;1nidentified  4 hel:IFS
     > 0.8_gpm..                            LEAKAGE is net the pressurizer surge line.
GR
                                   ,ti,.2   Red1;1se 1;1nidentified            4 hel:IFS LEAK/.GE te *i.&.iithin limit.
8,. Unidentified LEAKAGE          B.1      Red1;1se 1;1nidentified            4 h9l:IFS
     ,::..1.0 gpm.                          LEAKAGE te .::: 1.0 gpm.
Cook Nuclear Plant Unit 1                     3.4.13-1                        Amendment No. ~ . 298

RCS Operational LEAKAGE 3.4.13 ACTIONS (continued)
CONDITION                             REQUIRED ACTION                       COMPLETION TIME
 ~-IRCS o~erationall                    ~.1        Reduce LEAKAGE to within            4 hours identified LEAKAGE not                      limits.
within limits for reasons other than lpressurei
      !boundary LEAKAGE o~
primary to secondary LEAKAGE.
l&sect;IQ. Required Action and              l&sect;IQ.1     Be in MODE 3.                       6 hours associated Completion Time of Condition A,--B,           AND eF--G not met.
l&sect;IQ.2     Be in MODE 5.                       36 hours OR Pressure boundary LEAKAGE exists.
OR Primary to secondary LEAKAGE not within limit.
SURVEILLANCE REQUIREMENTS SURVEILLANCE                                              FREQUENCY SR 3.4.13.1           -------------------------------NOTES----------------------------
: 1. Not required to be performed until 12 hours after establishment of steady state operation.
: 2. Not applicable to primary to secondary LEAKAGE.
Verify RCS operational LEAKAGE is within limits by                 In accordance performance of RCS water inventory balance.                        with the Surveillance Frequency Control Pro ram Cook Nuclear Plant Unit 1                              3.4.13-2               Amendment No. ~ . 2-00, 334

ENCLOSURE 11 TO AEP-NRC-2018-02 Donald C. Cook Nuclear Plant Unit 1 Technical Specification Bases Pages Marked To Show Proposed Changes

RCS Operational LEAKAGE 83.4.13 BASES APPLICABLE SAFETY ANALYSES (continued) to limit primary to secondary LEAKAGE through any one SG to less than or equal to 150 gallons per day is significantly less than the conditions assumed in the safety analysis.
Primary to secondary LEAKAGE is a factor in the dose releases outside containment resulting from a steam line break (SLB) accident. To a lesser extent, primary to secondary LEAKAGE is a factor in the dose releases.
outside containment in other accidents or transients involving secondary steam release to the atmosphere, such as a steam generator tube rupture (SGTR). The leakage contaminates the secondary .fluid. .
* The UFSAR (Ref. 3) analysis for SGTR assumes the contaminated secondary fluid is released via the steam generator power operated relief valves (and safety valves if their setpoint is reached) if offsite power is not available or if the condenser steam dump system fails to operate. The safety analysis for the SLB accident assumes 0.25 gpm per steam generator (1.0 gpm for all SGs) primary to secondary LEAKAGE as an initial condition. The dose consequences resulting from events resulting in a steam discharge to the atmosphere are within the limits defined in 10 CFR 50.67.
The RCS Operational LEAKAGE satisfies Criterion 2 of 10 CFR 50.36(c)(2)(ii).
LCO                  RCS operational LEAKAGE shall be limited to:
: a. Pressure Boundary LEAKAGE No pressure boundary LEAKAGE is allowed, being indicative of material deterioration. LEAKAGE of this type is unacceptable as the leak itself could cause further deterioration, resulting in higher LEAKAGE. Violation of this LCO could result in continued degradation of the RCPB. LEAKAGE past seals and gaskets is not pressure boundary LEAKAGE.
: b. Unidentified LEAKAGE The 0.8 gallon per minute (gpm) of unidentified LEAKAGE is allowed as a reasonable minimum detectable amount that the containment air particulate monitoring equipment can detect within a reasonable time period.                     *                     *           *
* leak before break methodology.
satis the requirements for the a plication of Leak-Before-Brea methodolo as documented in References 4 and 8, and a roved b the NRC as documented in References 5 and 9. Violation of this Cook Nuclear Plant Unit 1                    B 3.4.13-2                             Revision No. e4,

RCS Operational LEAKAGE B 3.4.13 BASES ACTIONS              A.1 and A.2 VVith unidentified LEAKAGE > 0.8 gpm, the pressurizer surge line must be verified not to be the source of unidentified LEAKAGE or the unidentified LEAKAGE must be reduced to within limit 1.vithin 4 hours. These Required Aotions are necessary to satisfy the* requfrements for the application of Leak Before Break methodology to the pressurizer surge line as documented in Reference 4 and approved by the NRG as documented in Reference 5, and are necessary to prevent further deterioration of the RCPB associated 1.vith the pressurizer surge line. The Completion Time allov,s time to verify leakage rates and either identify the       I unidentified LEAKAGE or reduce LEAKAGE to within limit before the                . I I
reactor must be shut dovm.
Unidentified LEAKAGE > 1.0 gpm must be reduced to < 1.0 gpm within 4 hours. This Completion Time allows time to verify leakage rates and either identify unidentified LEAKAGE or reduce LEAKAGE to within limits before the reactor must be shut down. This action is necessary to prevent further deterioration of the RCPB.
                     ~-
                     !Unidentified LEAKAGE od identified LEAKAGE, 1.vith the exception of
* primary to s9condary_LEA~<AGE, in excess of the LCO _limit~ must be*
I
* reduced to within-limits within 4 hours. This Com letion Time allows time to verify leakage rates and either identi unidentified LEAKAGE o reduce LEAKAGE to within limits before the reactor must be shut down.
This action is necessary to prevent further deterioration of the RCPB.
[&sect;IQ.1 and[&sect;lp.2 If any Required Action and associated Completion Time of Condition A Bf
                     , B, or C is not met, if any pressure boundary LEAKAGE exists, or if primary to secondary LEAKAGE is not within limit, the reactor must be brought to lower pressure conditions to reduce the severity of the LEAKAGE and its potential consequences. It should be noted that LEAKAGE past seals and gaskets is not pressure boundary LEAKAGE.
The reactor must be brought to MODE 3 within 6 hours and MODE 5 within 36 hours. This action reduces the LEAKAGE and also reduces the factors that tend to degrade the pressure boundary.
The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems. In
* MODE 5; the pressure stresses acting on the RCPB are much lower, and further deterioration is much less likely.
Cook Nuclear Plant Unit 1                   B 3.4.13-5                            Revision No. 12

RCS Operational LEAKAGE B 3.4.13 BASES SURVEILLANCE REQUIREMENTS (continued) measured at room temperature as described in Reference 7. Prior to comparison with the 150 gallons per day TS limit, the measured primary to secondary LEAKAGE is multiplied by a_ volume correction facto_r of 1.52. The correction factor ensures the offsite dose analyses, which assume primary to secondary leakage is at normal operating temperature and pressure, remain bounding. The operational LEAKAGE rate limit .
applies to LEAKAGE through any one SG. If it is not practical to assign the LEAKAGE to an individual SG, all of the primary to secondary LEAKAGE should be conservatively assumed to be from one SG.
The Surveillance is modified by a Note which states that the Surveillance
* is not required to be pe"rformed until 12 hours after establishment of
* steady state operation. For RCS primary to secondary LEAKAGE determination, steady state is defined as stable RCS pressure, temperature, power level, pressurizer and makeup tank levels, makeup and letdown, and RCP seal injection and return flows.
The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. The primary to secondary LEAKAGE is determined using continuous process radiation monitors or radiochemical
* grab sampling in accordance with the EPRI guidelines (Ref. 7).
REFERENCES            1. UFSAR, Section 1.4.3..
: 2. Regulatory Guide 1.45, May 1973.
: 3. UFSAR, Section 14.2.4.
: 4. Letter from Indiana Michigan Power Company (M. W. Renchecl<) to the NRC dated October 26, 2000 (Letter C1000-20).
: 5. Letter from NRC (John F. Stang) to Indiana Michigan Power Company (Robert P. Powers), dated November 8, 2000.
: 6. NEI 97-06, "Steam Generator Program Guidelines."
: 7. EPRI, "Pressurized Water Reactor Primary-to-Secondary Leak Guidelines."
: 8. Letter from Indiana Michigan Power Company (Q. S. Lies) to the NRC dated XXXXX X, 2018.
: 9. Letter from NRC (XXXXX X. XXXX) to Indianan Michigan Power Company (Joel. P. Gebbie), dated XXXXXXXX XX, 2018.
Cook Nuclear Plant Unit 1                   83.4.13-7                              Revision No. 63}}