ML093430506

McGuire, Units 1 and 2 and Catawba, Units 1 and 2, License Amendment Request for Technical Specification 3.16.13, Ice Condenser Doors, Response to Request for Additional Information

ML093430506
Person / Time
Site:	Mcguire, Catawba, McGuire
Issue date:	08/25/2009
From:	Hamilton B H Duke Energy Carolinas, Duke Energy Corp
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
Download: ML093430506 (24)

Text

{{#Wiki_filter:BRUCE H HAMILTON ATTACHMENT B OF ENCLOSURE I CONTAINS PROPRIETAY Vice President U-OvEnergy. INFORMATION REQUESTED TO BE WITHHELD FROM PUBLIC McGuire -Nuclear Station DISCLOSURE PER 10 CFR 2.390. WHEN SEPARATED FROM ATTACHMENT B OF ENCLOSURE 1, THE BALANCE OF THIS Duke Energy Corporation LETTER MAY BE CONSIDERED NON-PROPRIETARY. MGOI VP / 12700 Ferry Road Huntersville, NC 28078 704-875-5333 704-875-4809 fax bhhamilton@duke-eneraycorn August 25, 2009U.S. Nuclear Regulatory Commission Document Control Desk Washington, DC 20555-001 ATTENTION: Document Control Desk

Subject:

Duke Energy Carolinas (DEC), LLC McGuire Nuclear Station, Units I and 2 Docket Nos. 50-369 and 50-370 Catawba Nuclear Station, Units 1 and 2 Docket Nos. 50-413 and 50-414 License Amendment Request (LAR) for Technical Specification (TS)3.6.13, Ice Condenser Doors, Response to Request for Additional Information (RAI)This letter provides the response to a RAI for a LAR submitted on October 2, 2008 torevise TS 3.6.13 -Ice Condenser Doors for the McGuire and Catawba Nuclear Stations.The RAI was sent via electronic mail from Jon Thompson dated May 21, 2009. The draft response to the RAI was discussed during a conference call with the NRC staff on June 18, 2009. The NRC staffs questions and DEC's responses are provided in Enclosure 1.The additional information provided in this RAI does not impact the conclusions of the No Significant Hazards Considerations and the basis for the categorical exclusion from performing an Environmental/Impact Statement presented in the October 2, 2008 LAR submittal. Specifically, the proposed revisions to TS 3.6.13 do not affect the current post-accident Containment Response analysis of record.Attachment B of Enclosure I contains information that the owner, Westinghouse Electric Corporation (WEC), considers proprietary. In accordance with the provisions of 10 CFR 2.390, Enclosure 2 contains a request and affidavit CAW 2643 from WEC thatthe proprietary information identified in Attachment B of Enclosure I be withheld from public disclosure. Enclosure 3 provides the non-proprietary version of Enclosure 1, Attachment B.www duke-energ.com _Duke r",EnergYe ATIACHMENT B OF ENCLOSURE 1 CONTAINS PROPRIETAY INFORMATION REQUESTED TO BE WITHHELD FROM PUBLIC DISCLOSURE PER 10 CFR 2.390. WHEN SEPARATED FROM A TIACHMENT B OF ENCLOSURE 1, THE BALANCE OF THIS BRUCE H HAMILTON Vice President McGuire Nuclear Station Dulce Energy Corporation LETTER MAY BE CONSIDERED NON-PROPRIETARY. MGOl VP /12700 H<JBMS Ferry Road Huntersville. NC 28078' 704*875*5333 704-875-4809 f<Jx bhhamilton@duke-energy.com August 25, 2009 U.S. Nuclear Regulatory Commission Document Control Desk Washington, DC 20555-001 ATTENTION: Document Control Desk "

Subject:

Duke Energy Carolinas (DEC), LLC McGuire Nuclear Station, Units 1 and 2 Docket Nos. 50-369 and 50-370 Catawba Nuclear Station, Units 1 and 2 Docket Nos. 50-413 and 50-414 License Amendment Request (LAR) for Technical Specification (TS) 3.6.13, Ice Condenser Doors, Response to Request for Additional Information (RAJ) This letter provides the response to a RAI for a LAR submitted on October 2, 2008 to revise TS 3.6.13 -Ice Condenser Doors for the McGuire and Catawba Nuclear Stations. The RAI was sent via electronic mail from Jon Thompson dated May 21, 2009. The draft response to the RAI was discussed during a conference call with the NRC staff on June 18, 2009. The NRC staffs questions and DEC's responses are provided in Enclosure

1. The additional information provided in this RAI does not impact the conclusions of the No Significant Hazards Considerations and the basis for the categorical exclusion from performing an Environmental/Impact Statement presented in the October 2. 2008 LAR submittal.

Specifically, the propOsed revisions to T8 3.6.13 do not affect the current post-accident Containment Response analysis of record. . Attachment B of Enclosure 1 contains information that the owner, Westinghouse Electric Corporation (WEC), considers proprietary. In accordance with the provisions of 10 CFR 2.390, Enclosure 2 contains a request and affidavit CAW 2643 from WEC thaUhe proprietary information*identified in Attachment B of Enclosure 1 be from public disclosure. Enclosure 3 provides the non-proprietary version of Enclosure

1. Attachment B. www.duke-energy.com Aoo( \ I I I I t I \ L I I I' i _Duke r",EnergYe ATIACHMENT B OF ENCLOSURE 1 CONTAINS PROPRIETAY INFORMATION REQUESTED TO BE WITHHELD FROM PUBLIC DISCLOSURE PER 10 CFR 2.390. WHEN SEPARATED FROM A TIACHMENT B OF ENCLOSURE 1, THE BALANCE OF THIS BRUCE H HAMILTON Vice President McGuire Nuclear Station Dulce Energy Corporation LETTER MAY BE CONSIDERED NON-PROPRIETARY.

MGOl VP /12700 H<JBMS Ferry Road Huntersville. NC 28078' 704*875*5333 704-875-4809 f<Jx bhhamilton@duke-energy.com August 25, 2009 U.S. Nuclear Regulatory Commission Document Control Desk Washington, DC 20555-001 ATTENTION: Document Control Desk "

Subject:

Duke Energy Carolinas (DEC), LLC McGuire Nuclear Station, Units 1 and 2 Docket Nos. 50-369 and 50-370 Catawba Nuclear Station, Units 1 and 2 Docket Nos. 50-413 and 50-414 License Amendment Request (LAR) for Technical Specification (TS) 3.6.13, Ice Condenser Doors, Response to Request for Additional Information (RAJ) This letter provides the response to a RAI for a LAR submitted on October 2, 2008 to revise TS 3.6.13 -Ice Condenser Doors for the McGuire and Catawba Nuclear Stations. The RAI was sent via electronic mail from Jon Thompson dated May 21, 2009. The draft response to the RAI was discussed during a conference call with the NRC staff on June 18, 2009. The NRC staffs questions and DEC's responses are provided in Enclosure

1. The additional information provided in this RAI does not impact the conclusions of the No Significant Hazards Considerations and the basis for the categorical exclusion from performing an Environmental/Impact Statement presented in the October 2. 2008 LAR submittal.

Specifically, the propOsed revisions to T8 3.6.13 do not affect the current post-accident Containment Response analysis of record. . Attachment B of Enclosure 1 contains information that the owner, Westinghouse Electric Corporation (WEC), considers proprietary. In accordance with the provisions of 10 CFR 2.390, Enclosure 2 contains a request and affidavit CAW 2643 from WEC thaUhe proprietary information*identified in Attachment B of Enclosure 1 be from public disclosure. Enclosure 3 provides the non-proprietary version of Enclosure

1. Attachment B. www.duke-energy.com Aoo( \ I I I I t I \ L I I I' i August 25, 2009 Nuclear Regulatory Commission Page 2 This RAI response contains no regulatory commitments for McGuire or Catawba.Please direct any questions with regard to this matter to Julius W. Bryant at (980) 875-4162.Very truly yours, B. H. Hamilton Enclosures August 25, 2009 Nuclear Regulatory Commission Page 2 This RAI response contains no regulatory commitments for McGuire or Catawba. Please direct any questions with regard to this matter to JUlius W. Bryant at (980) 875-4162. Very truly yours, B. H. Hamilton Enclosures I I ! -I I j I I i ., 'I ;1 ; : ; . ; ; August 25, 2009 Nuclear Regulatory Commission Page 2 This RAI response contains no regulatory commitments for McGuire or Catawba. Please direct any questions with regard to this matter to JUlius W. Bryant at (980) 875-4162. Very truly yours, B. H. Hamilton Enclosures I I ! -I I j I I i ., 'I ;1 ; : ; . ; ;

August 25, 2009 Nuclear Regulatory Commission Page 3 xc w/ Enclosures L. A. Reyes Regional Administrator, Region II U.S. Nuclear Regulatory Commission Sam Nunn Atlanta Federal Center 61 Forsyth St., SW, Suite 23T85 Atlanta, GA 30303 J. B. Brady NRC Senior Resident Inspector McGuire Nuclear Station G. A. Hutto III NRC Senior Resident Inspector Catawba Nuclear Station J. H. Thompson (addressee only)Project Manager (MNS and CNS)U.S. Nuclear Regulatory Commission Mail Stop 0-8 G9A Washington, DC 20555-0001 B. 0. Hall Section Chief Division of Radiation Protection Section 1645 Mail Service Center Raleigh, NC 27699 S.E. Jenkins Section Manager Division of Waste Management South Carolina Department of Health and Environmental Control 2600 Bull St.Columbia, SC 29201 August 25, 2009 Nuclear Regulatory Commission Page 3 xc wi Enclosures L. A. Reyes Regional Administrator, Region II U.S. Nuclear Regulatory Commission Sam Nunn Atlanta Federal Center 61 Forsyth St., SW, Suite 23T85 Atlanta, GA 30303 J. B. Brady NRC Senior Resident Inspector "McGuire Nuclear Station G. A. Hutto III NRC Senior Resident Inspector Catawba Nuclear Station J. H. Thompson (addressee only) Project Manager (MNS and CNS) U.S. Nuclear Regulatory Commission Mail Stop 0-8 G9A Washington, DC 20555-0001 B. O. Hall Section Chief Division of Radiation Protection Section 1645 Mail Service Center " Raleigh, NC 27699 S.E. Jenkins Section Manager Division of Waste Management South Carolina Department of Health and Environmental Control 2600 Bull St. Columbia, SC 29201 August 25, 2009 Nuclear Regulatory Commission Page 3 xc wi Enclosures L. A. Reyes Regional Administrator, Region II U.S. Nuclear Regulatory Commission Sam Nunn Atlanta Federal Center 61 Forsyth St., SW, Suite 23T85 Atlanta, GA 30303 J. B. Brady NRC Senior Resident Inspector "McGuire Nuclear Station G. A. Hutto III NRC Senior Resident Inspector Catawba Nuclear Station J. H. Thompson (addressee only) Project Manager (MNS and CNS) U.S. Nuclear Regulatory Commission Mail Stop 0-8 G9A Washington, DC 20555-0001 B. O. Hall Section Chief Division of Radiation Protection Section 1645 Mail Service Center " Raleigh, NC 27699 S.E. Jenkins Section Manager Division of Waste Management South Carolina Department of Health and Environmental Control 2600 Bull St. Columbia, SC 29201 August 25, 2009 Nuclear Regulatory Commission Page 4OATH AND AFFIRMATION Bruce H. Hamilton affirms that he is the person who subscribed his name to the foregoing statement, and that all the matters and facts set forth herein are true andcorrect to the best of his knowledge. Bruce H. Hamilton, Site Vice President Subscribed and sworn to me: Date N--otary Public My commission expires: (% / I I/lo I,?""1 Date August 25, 2009 Nuclear Regulatory Commission Page 4 OATH AND AFFIRMATION Bruce H. Hamilton affirms that he is the person who subscribed his name to the foregoing statement, and that all the matters and facts set forth herein are true and correct to the best of his knowledge. Bruce H. Hamilton, Site Vice President Subscribed and sworn to me: /iLgu d S; ;1.00"1 Date C. fh/Jnj otary Public U My commission expires: a;; I I, )0 {;r . Date I I ! ,l August 25, 2009 Nuclear Regulatory Commission Page 4 OATH AND AFFIRMATION Bruce H. Hamilton affirms that he is the person who subscribed his name to the foregoing statement, and that all the matters and facts set forth herein are true and correct to the best of his knowledge. Bruce H. Hamilton, Site Vice President Subscribed and sworn to me: /iLgu d S; ;1.00"1 Date C. fh/Jnj otary Public U My commission expires: a;; I I, )0 {;r . Date I I ! ,l Enclosure 1 Response to NRC Staff RAI Related to October 2, 2008 LAR for TS 3.6.13, Ice Condenser Doors, NRC Staff Question SCVB#I (Three Parts; la, lb, and 1c)Please provide the following clarifications on TS 3.6.13 as to how Condition A and Condition B are applied under the current TS versus how they are intended to be applied under the proposed TS.NRC Staff Question SCVB#1a: Technical Specification Surveillance Requirement (TSSR) 3.6-13.1 and TSSR 3.6.13.4 are applicable to the lower inlet doors. TSSR 3.6.13.1 is performed at a frequency of 12 hours during modes 1, 2, 3, & 4. TSSR 3.6.13.4 is conducted at a frequency of 18 months during outages. Please explain what condition statement the plant will be in upon failure to pass TSSR 3.6.13.1 -"Verify all inlet doors indicate closed by the InletDoor Position Monitoring System." Is it Condition A, Condition B, or both? If the answer is Condition B only, what is 1 hour completion time for Require Action A.1 mean under the proposed revision to the TS?DEC Response to NRC Staff Question SCVB#la: Revision 3.0 of the Standard Technical Specifications (STS) for Westinghouse Plants (NUREG-1431) is worded such that Condition A of STS TS 3.6.16 applies only to the Inlet Doors ("Inlet Doors" and "Lower Inlet Doors" represent synonymous terms) 1 However, the current McGuire/Catawba TS 3.6.13 wording does not incorporate the-"Inlet" or Lower Inlet" text into the Condition A description .As a result, Condition A of the current McGuire/Catawba TS 3.6.13 is applicable to all Ice Condenser Doors (Lower Inlet Doors, Intermediate Deck Doors, and the Top Deck Doors). The proposed revision to the McGuire/Catawba TS 3.6.13 wording adopts the Westinghouse STS clarification in Condition A (i.e., by adding the descriptor "Lower Inlet") so that only the Lower Inlet Doors are affected by Condition A.For both the current McGuire/Catawba TS 3.6.13 and the proposed McGuire/Catawba TS 3.6.13, TSSR 3.6.13.1 is applicable to the Lower Inlet Doors only ("Inlet Doors" and"Lower Inlet Doors" represent synonymous terms). If a Lower Inlet Door (or more than one Lower Inlet Door) opens while in a Mode of Applicability (i.e., Modes 1, 2, 3, or 4), TSSR 3.6.13.1 is not met, and only Condition B is entered since the Condition as described for such an occurrence would be "not closed".Under the proposed revision to McGuire/Catawba TS 3.6.13, the one-hour Required Action Completion Time for Condition A would be entered only if one or more Lower Inlet Door(s) is physically restrained from opening. Such a condition could arise if a Lower Inlet Door blocking device, which is temporarily installed during outages to prevent inadvertent opening of the doors, is unintentionally left in place and the Unit is brought into a Mode of Applicability while in that configuration. Page 1 of 6 Enclosure 1 Response to NRC Staff RAI Related to October 2, 2008 LAR for TS 3.6.13, Ice Condenser Doors, NRC Staff Question SCVB#1 IThree Parts; 1 a, 1 b, and 1 c) Please provide the following clarifications on TS 3.6.13 as to how Condition A and Condition B are applied under the current TS versus how they are intended to be applied under the proposed TS. NRC Staff Question SeVB#1a: Technical Specification Surveillance Requirement (TSSR) 3.6.13.1 and TSSR 3.6.13.4 are applicable to the lower inlet doors. TSSR 3.6.13.1 is performed at a frequency of 12 hours during modes 1, 2, 3,.& 4. TSSR 3.6.13.4 is conducted at a frequency of 18 months during outages. Please explain what condition statement the plant will be in upon failure to pass TSSR 3.6.13.1 -"Verify all inlet doors indicate closed by the Inlet Door Position Monitoring System." Is it Condition A, Condition B, or both? 1f the answer is Condition B only, what is 1 hour completion time for Require Action A.1 mean under the proposed revision to the TS? DEC Response to NRC Staff Question SCVB#1a: Revision 3.0 of the Standard Technical Specifications (STS) for Westinghouse Plants (NUREG-1431) is worded such that Condition A of STS TS 3.6.16 applies only to the Inlet Doors ("Inlet Doors" and "Lower Inlet Doors" represent synonymous terms) 1. However, the current McGuire/Catawba TS 3.6.13 wording does not incorporate "Inlet" or "Lower Inlet" text into the Condition A description

2. As a result, Condition A of the current McGuire/Catawba TS 3.6.13 is applicable to all Ice Condenser Doors (Lower Inlet Doors, Intermediate Deck Doors, and the Top Deck Doors). The proposed revision to the McGuire/Catawba TS 3.6.13 wording adopts the Westinghouse STS clarification in Condition A (i.e., by adding the descriptor "Lower Inlet") so that only the Lower Inlet Doors are affected by Condition A. For both the current McGuire/Catawba TS 3.6.13 and the proposed McGuire/Catawba TS 3.6.13, TSSR 3.6.13.1 is applicable to the Lower Inlet Doors only ("Inlet Doors" and "Lower Inlet Doors" represent synonymous terms). If a Lower Inlet Door (or more than one Lower Inlet Door) opens while in a Mode of Applicability (i.e., Modes 1, 2, 3, or 4), TSSR 3.6.13.1 is not met, and only Condition B is entered since the Condition as described for such an occurrence would be "not closed". Under the proposed revision to McGuire/Catawba TS 3.6.13, the one-hour Required Action Completion Time for Condition A would be entered only if one or more Lower Inlet Ooor(s) is physically restrained from opening. Such a condition could arise if a Lower Inlet Door blocking device, which is temporarily installed during outages to prevent inadvertent opening of the doors, is unintentionally left in place and the Unit is brought into a Mode of Applicability while in that configuration.

Page 1 of6 Enclosure 1 Response to NRC Staff RAI Related to October 2, 2008 LAR for TS 3.6.13, Ice Condenser Doors, NRC Staff Question SCVB#1 IThree Parts; 1 a, 1 b, and 1 c) Please provide the following clarifications on TS 3.6.13 as to how Condition A and Condition B are applied under the current TS versus how they are intended to be applied under the proposed TS. NRC Staff Question SeVB#1a: Technical Specification Surveillance Requirement (TSSR) 3.6.13.1 and TSSR 3.6.13.4 are applicable to the lower inlet doors. TSSR 3.6.13.1 is performed at a frequency of 12 hours during modes 1, 2, 3,.& 4. TSSR 3.6.13.4 is conducted at a frequency of 18 months during outages. Please explain what condition statement the plant will be in upon failure to pass TSSR 3.6.13.1 -"Verify all inlet doors indicate closed by the Inlet Door Position Monitoring System." Is it Condition A, Condition B, or both? 1f the answer is Condition B only, what is 1 hour completion time for Require Action A.1 mean under the proposed revision to the TS? DEC Response to NRC Staff Question SCVB#1a: Revision 3.0 of the Standard Technical Specifications (STS) for Westinghouse Plants (NUREG-1431) is worded such that Condition A of STS TS 3.6.16 applies only to the Inlet Doors ("Inlet Doors" and "Lower Inlet Doors" represent synonymous terms) 1. However, the current McGuire/Catawba TS 3.6.13 wording does not incorporate "Inlet" or "Lower Inlet" text into the Condition A description

2. As a result, Condition A of the current McGuire/Catawba TS 3.6.13 is applicable to all Ice Condenser Doors (Lower Inlet Doors, Intermediate Deck Doors, and the Top Deck Doors). The proposed revision to the McGuire/Catawba TS 3.6.13 wording adopts the Westinghouse STS clarification in Condition A (i.e., by adding the descriptor "Lower Inlet") so that only the Lower Inlet Doors are affected by Condition A. For both the current McGuire/Catawba TS 3.6.13 and the proposed McGuire/Catawba TS 3.6.13, TSSR 3.6.13.1 is applicable to the Lower Inlet Doors only ("Inlet Doors" and "Lower Inlet Doors" represent synonymous terms). If a Lower Inlet Door (or more than one Lower Inlet Door) opens while in a Mode of Applicability (i.e., Modes 1, 2, 3, or 4), TSSR 3.6.13.1 is not met, and only Condition B is entered since the Condition as described for such an occurrence would be "not closed". Under the proposed revision to McGuire/Catawba TS 3.6.13, the one-hour Required Action Completion Time for Condition A would be entered only if one or more Lower Inlet Ooor(s) is physically restrained from opening. Such a condition could arise if a Lower Inlet Door blocking device, which is temporarily installed during outages to prevent inadvertent opening of the doors, is unintentionally left in place and the Unit is brought into a Mode of Applicability while in that configuration.

Page 1 of6 Enclosure 1 Response to NRC Staff RAI Related to October 2, 2008 LAR for TS 3.6.13, Ice Condenser Doors, NRC Staff Question SCVB#1b: The LAR proposes to reword Condition A to apply to the Lower Inlet Doors only, eliminating the one-hour action statement for any condition discovered involving the Intermediate Deck Doors or the Top Deck Doors. The applicable surveillance requirements are TSSR 3.6.13.2 for the Intermediate Deck Doors and TSSR 3.6.13.3 for the Top Deck Doors. Please explain which part of the surveillance requirements could put the plant in Condition A under the current TS?DEC Response to NRC Staff Question SCVB#1b: Revision 3.0 of the STS for Westinghouse Plants (NUREG-1431) is worded such that Condition A of STS TS 3.6.16 applies only to the Inlet Doors (uInlet Doors" and "Lower Inlet Doors" represent synonymous terms) However, the current McGuire/Catawba TS 3.6.13 wording does not incorporate the "Inlet" or "Lower Inlet" text into the Condition A description 2 As a result, Condition A of the current McGuire/Catawba TS 3.6.13 is applicable to all Ice Condenser Doors (Lower Inlet Doors, Intermediate Deck Doors, and the Top Deck Doors). Therefore, if TSSR 3.6.13.2 is not satisfied due to ice, frost or debris physically restraining one or more intermediate deck door(s) from opening and/or TSSR 3.6.13.3 is not satisfied due to condensation, frost, or ice physically restraining one or more top deck door(s) from opening, the current McGuire/Catawba TS 3.6.13 wording would require entry into TS 3.6.13 Condition A.The proposed revision to the McGuire/Catawba TS 3.6.13wording adopts the Westinghouse STS clarification in Condition A (i.e., by adding the descriptor "Lower Inlet") so that only the Lower Inlet Doors are affected by Condition A 1. Therefore, if TSSR 3.6.13.2 and/or TSSR 3.6.13.3 are not satisfied for any reason, the proposed revised McGuire/Catawba TS 3.6.13 wording would only require entry into TS 3.6.13 Condition B. This is appropriate since the Intermediate Deck Doors and Top Deck Doors are primarily thermal/humidity barriers, and their time-dependent behavior during an accident scenario (i.e., allowing the passage of air/non-condensable gases from the lower compartment to the upper compartment during initial blowdown) is not quantified in the containment response analysis 3. As such, for the case where one or more Intermediate Deck Door(s) or one or more Top Deck Door(s) is/are inoperable, the 14 day Required Action Completion Time of McGuire/Catawba TS 3.6.13 Condition B is appropriate and consistent with the Westinghouse STS.Page 2 of 6 Enclosure 1 Response to NRC Staff RAJ Related to October 2,2008 LAR for TS 3.6.13, Ice Condenser Doors. NRC Staff Question SCVB#1 b: The LAR proposes to reword Condition A to apply to the Lower Inlet Doors only, eliminating the one-hour action statement for any condition discovered involving the Intermediate Deck Doors or the Top Deck Doors. The applicable surveillance requirements are TSSR 3.6.1"3.2 for the Intermediate Deck Doors and TSSR 3.6.13.3 for the Top Deck Doors. Please explain which part of the surveillance requirements could put the plant in Condition A under the current TS? DEC Response to NRC Staff Question SCVB#1 b: Revision 3.0 of the STS for Westinghouse Plants (NUREG-1431) is worded such that .condition A of STS TS 3.6.16 applies only to the Inlet Doors ("Inlet Doors" and "Lower Inlet Doors" represent synonymous terms) However, the current McGuire/Catawba TS 3.6.13 wording does not incorporate the "Inlet" or "Lower Inlet" text into the Condition A description

2. As a result, Condition A of the current McGuire/Catawba TS 3.6.13 is applicable to all Ice Condenser Doors (Lower Inlet Dbors, Intermediate Deck Doors, and the Top Deck Doors). Therefore, if TSSR 3.6.13.2 is not satisfied due to ice, frost or debris physically restraining one or more intermediate deck door(s) from opening and/or TSSR 3.6.13.3 is not satisfied due to condensation, frost, or ice physically restraining one or more top deck door(s) from opening, the current McGuire/Catawba TS 3.6.13 wording would require entry into TS 3.6.13 Condition A The proposed revision to the McGuire/Catawba TS 3.6.13 wording adopts the Westinghouse STS clarification in Condition A (i.e., by adding the descriptor "Lower Inlet") so that only the Lower Inlet Doors are affected by Condition A 1. Therefore, if TSSR 3.6.13.2 and/or TSSR 3.6.13.3 are not satisfied for any reason, the proposed revised McGuire/Catawba TS 3.6.13 wording would only require entry into TS 3.6.13 Condition B. This is appropriate since the Intermediate Deck Doors and Top Deck Doors are primarily thermal/humidity barriers, and their time-dependent behavior during an accident scenario (i.e., allowing the passage of air/non-condensable gases from the lower compartment to the upper compartment during initial blowdown) is not quantified in the containment response analysis 3. As such, for the case where one or more Intermediate Deck Door(s) or one or more Top Deck Door(s) is/are inoperable, the 14 day Required Action Completion Time of McGuire/Catawba TS 3.6.13 Condition B is appropriate and consistent with the Westinghouse STS. Page 2 of6 I i . ! I : : t i Enclosure 1 Response to NRC Staff RAJ Related to October 2,2008 LAR for TS 3.6.13, Ice Condenser Doors. NRC Staff Question SCVB#1 b: The LAR proposes to reword Condition A to apply to the Lower Inlet Doors only, eliminating the one-hour action statement for any condition discovered involving the Intermediate Deck Doors or the Top Deck Doors. The applicable surveillance requirements are TSSR 3.6.1"3.2 for the Intermediate Deck Doors and TSSR 3.6.13.3 for the Top Deck Doors. Please explain which part of the surveillance requirements could put the plant in Condition A under the current TS? DEC Response to NRC Staff Question SCVB#1 b: Revision 3.0 of the STS for Westinghouse Plants (NUREG-1431) is worded such that .condition A of STS TS 3.6.16 applies only to the Inlet Doors ("Inlet Doors" and "Lower Inlet Doors" represent synonymous terms) However, the current McGuire/Catawba TS 3.6.13 wording does not incorporate the "Inlet" or "Lower Inlet" text into the Condition A description

2. As a result, Condition A of the current McGuire/Catawba TS 3.6.13 is applicable to all Ice Condenser Doors (Lower Inlet Dbors, Intermediate Deck Doors, and the Top Deck Doors). Therefore, if TSSR 3.6.13.2 is not satisfied due to ice, frost or debris physically restraining one or more intermediate deck door(s) from opening and/or TSSR 3.6.13.3 is not satisfied due to condensation, frost, or ice physically restraining one or more top deck door(s) from opening, the current McGuire/Catawba TS 3.6.13 wording would require entry into TS 3.6.13 Condition A The proposed revision to the McGuire/Catawba TS 3.6.13 wording adopts the Westinghouse STS clarification in Condition A (i.e., by adding the descriptor "Lower Inlet") so that only the Lower Inlet Doors are affected by Condition A 1. Therefore, if TSSR 3.6.13.2 and/or TSSR 3.6.13.3 are not satisfied for any reason, the proposed revised McGuire/Catawba TS 3.6.13 wording would only require entry into TS 3.6.13 Condition B. This is appropriate since the Intermediate Deck Doors and Top Deck Doors are primarily thermal/humidity barriers, and their time-dependent behavior during an accident scenario (i.e., allowing the passage of air/non-condensable gases from the lower compartment to the upper compartment during initial blowdown) is not quantified in the containment response analysis 3. As such, for the case where one or more Intermediate Deck Door(s) or one or more Top Deck Door(s) is/are inoperable, the 14 day Required Action Completion Time of McGuire/Catawba TS 3.6.13 Condition B is appropriate and consistent with the Westinghouse STS. Page 2 of6 I i . ! I : : t i Enclosure 1 Response to NRC Staff RAI Related to October 2, 2008 LAR for TS 3.6.13, Ice Condenser Doors, NRC Staff Question SCVB#lc: The LAR proposes to add a new note to TS Actions indicating entry into Condition B for the Intermediate Deck and Top Deck Doors is not required due to personnel standing on or opening doors for short durations to perform required surveillances, minor maintenance, or routine tasks.What condition entries are made during the performance of the same activities under the current TS? What is the duration it normally takes to complete these activities?

Notes 1 and 2 under Actions in the proposed TS could allow multiple doors to be openat the same time. Please provide a brief description of the activities that will be covered by the proposed Note 2 and if they in fact require multiple doors to be opened simultaneously. The concern staff has with these activities is potential for ice bed sublimation, melting, and ice condenser flow.paths. Please address these concerns in your response.Proposed Note 2 did not indicate a duration for these activities. However, a duration of< 4 hours is mentioned in the Bases section. What is the reason for not including the time of < 4 hours in Note 2? Also, discuss the acceptability of < 4 hours time in your response to the question immediately above.DEC Response to NRC Staff Question SCVB#1c: Condition B of the current McGuire/Catawba TS 3.6.13 is entered when personnel open one or more Intermediate Deck Door(s) or Top Deck Door(s) for any duration to perform surveillances, minor maintenance, or routine tasks. All of these evolutions typically require approximately 2 hours or less to complete. Condition entry for these tasks is not required if doors are not opened or if personnel are standing on these doors.The proposed new Note 2 is intended to relate only to required surveillances, minor maintenance, and routine tasks as defined in the License Amendment package dated October 2, 2008. These activities would include tasks that are necessary to ensure ice condenser operability (e.g.. door visual inspection, light housekeeping), require only a minimum amount of time to perform (typically 2 hours or less), and involve a small number of personnel

3. These tasks would not be expected to require the opening of multiple doors simultaneously.

An extended maintenance activity (e.g. ice basket weighing) could require multiple doors to be opened simultaneously. For this situation, Condition B of both the current and proposed McGuire/Catawba TS 3.6.13 would be entered which requires monitoring of the ice bed temperature at least every four hours to ensure maximum ice bed temperatures do not approach the melting point 2.In addition, the 14 day Required Action Completion Time of Condition B ensures there would not be a significant loss of ice from sublimation

2. The flow channel clearance through the ice bed is not affected by the opening of doors since the applicable doors are in an area physically distinct from flow channels and these doors function mainly to Page 3 of 6 Enclosure 1 Response to NRC Staff RAI Related to October 2. 2008 LAR for TS 3.6.13. Ice Condenser Doors. NRC' Staff Question SCVB#1 c: The tAR proposes to add a new note to TS Actions indicating entry into Condition B for the Intermediate Deck and Top Deck Doors is not required due to personnel standing on or opening doors for short durations to perform required surveillances, minor maintenance, or routine tasks. What condition entries are made during the performance of the same activities under the current TS? What is the duration it normally takes to complete these activities?

Notes 1 and 2 under Actions in the proposed TS could allow multiple doors to be open at the same time. Please provide a brief description of the activities that will be covered by the proposed Note 2 and if they in fact require multiple doors to be opened simultaneously. The concern staff has with these activities is potential for ice bed sublimation, melting, and ice condenser flow.paths. Please address these concerns in your response. Proposed Note 2 did not indicate a' duration for these activities. However, a duration of < 4 hours is mentioned in the Bases section. What is the reason for not including the time of < 4 hours in Note 2? Also, discuss the acceptability of < 4 hours time in your response to the question immediately above. DEC Response to NRC Staff Question SCVB#1c: Condition B of the current McGuire/Catawba TS 3.6.13 is entered when personnel open one or more Intermediate Deck Door(s) or lop Deck Ooor(s) for any duration to perform surveillances, minor maintenance, or routine tasks. All of these evolutions typically require approximately 2 hours or less to complete. Condition entry for these tasks is not required if doors are not opened or if personnel are standing on these doors. The proposed new Note 2is intended to relate only to required surveillances, minor maintenance, and routine tasks as defined in the License Amendment package dated October 2, 2008. These activities' would include tasks that are necessary to ensure ice condenser operability (e.g . ., door visual inspeGtion, light housekeeping), require only a minimum amount of time to perform (typically 2 hours or less), and involve a small number of personnel

3. These tasks would not be expected to require the opening of multiple doors simultaneously.

An extended maintenance activity (e.g. ice basket weighing) could require multiple doors to be opened simultaneously. For this situation, Condition B of both the current and proposed McGuire/Catawba TS 3.6.13 would be entered which requires monitoring of the ice bed temperature at least every four hours to ensure maximum ice bed temperatures do not approach the melting point 2. In addition, the 14 day Required Action Completion Time of CondITion B ensures there would not be a significant loss of ice from sublimation

2. The flow channel clearance thro!Jgh the ice bed is not affected by the opening of doors since the applicable doors are in an area physically distinct from flow channels and these doors fUnction mainly to Page 3 of6 ! I I i I I I I I I .\ I 'I Enclosure 1 Response to NRC Staff RAI Related to October 2. 2008 LAR for TS 3.6.13. Ice Condenser Doors. NRC' Staff Question SCVB#1 c: The tAR proposes to add a new note to TS Actions indicating entry into Condition B for the Intermediate Deck and Top Deck Doors is not required due to personnel standing on or opening doors for short durations to perform required surveillances, minor maintenance, or routine tasks. What condition entries are made during the performance of the same activities under the current TS? What is the duration it normally takes to complete these activities?

Notes 1 and 2 under Actions in the proposed TS could allow multiple doors to be open at the same time. Please provide a brief description of the activities that will be covered by the proposed Note 2 and if they in fact require multiple doors to be opened simultaneously. The concern staff has with these activities is potential for ice bed sublimation, melting, and ice condenser flow.paths. Please address these concerns in your response. Proposed Note 2 did not indicate a' duration for these activities. However, a duration of < 4 hours is mentioned in the Bases section. What is the reason for not including the time of < 4 hours in Note 2? Also, discuss the acceptability of < 4 hours time in your response to the question immediately above. DEC Response to NRC Staff Question SCVB#1c: Condition B of the current McGuire/Catawba TS 3.6.13 is entered when personnel open one or more Intermediate Deck Door(s) or lop Deck Ooor(s) for any duration to perform surveillances, minor maintenance, or routine tasks. All of these evolutions typically require approximately 2 hours or less to complete. Condition entry for these tasks is not required if doors are not opened or if personnel are standing on these doors. The proposed new Note 2is intended to relate only to required surveillances, minor maintenance, and routine tasks as defined in the License Amendment package dated October 2, 2008. These activities' would include tasks that are necessary to ensure ice condenser operability (e.g . ., door visual inspeGtion, light housekeeping), require only a minimum amount of time to perform (typically 2 hours or less), and involve a small number of personnel

3. These tasks would not be expected to require the opening of multiple doors simultaneously.

An extended maintenance activity (e.g. ice basket weighing) could require multiple doors to be opened simultaneously. For this situation, Condition B of both the current and proposed McGuire/Catawba TS 3.6.13 would be entered which requires monitoring of the ice bed temperature at least every four hours to ensure maximum ice bed temperatures do not approach the melting point 2. In addition, the 14 day Required Action Completion Time of CondITion B ensures there would not be a significant loss of ice from sublimation

2. The flow channel clearance thro!Jgh the ice bed is not affected by the opening of doors since the applicable doors are in an area physically distinct from flow channels and these doors fUnction mainly to Page 3 of6 ! I I i I I I I I I .\ I 'I Enclosure 1 Response to NRC Staff RAI Related to October 2, 2008 LAR for TS 3.6.13, Ice Condenser Doors, open and relieve pressure from the lower compartment of containment during the blowdown phase of a large break Design Basis Accident (DBA). Therefore an open door is already fulfilling this DBA function.The general intent in adding the proposed Note 2 to the McGuire/Catawba TS 3.6.13 Actions is the adoption of the Westinghouse STS 3.6.16 Bases wording. During the internal review of the LAR submitted.

October 2, 2008 (prior to submittal to NRC), it was determined that wording included in the STS 3.6.16 Bases that identifies criteria for entering an action statement would be better positioned in the actual technical specification (for Operator expediency), rather than in the Bases document. The STS.3.6.16 Bases wording does not identify a timeframe for "short duration". Therefore, it was determined that the Condition B four hour completion time for ice bed temperature verification would be invoked since it represented a limit already prescribed by the technical specification and easily bounded the expected timeframe for performing routine surveillances and inspections: The four hour timeframe defining a "short duration" entry is considered a technical specification clarification, and as such was determined to be better left in the TS Bases document.NRC Staff Question SCVB#2 In reference to the attachments containing existing UFSAR pages marked-up to showthe proposed changes, please clarify if the changes are same as those referenced in the last paragraph of Section 2.2 of Attachment 1. If they are different, give us a time line of the 10CFR50.59 changes to the McGuire UFSAR, and when it was recognized. that the flow proportioning characteristics of the inlet doors is not a design requirement for McGuire and Catawba.DEC Response to NRC Staff Question SCVB#2: The marked-up McGuire UFSAR pages included with the LAR package dated October 2, 2008 are different from the revisions that were made to the McGuire UFSAR as a result of the I OCFR50.59 evaluation described in Section 2.2 of Attachment 1 of the same LAR package 3. Section 2.2 of Attachment 1 of the LAR describes the removal of the description of the "double break" scenario, in which a small break LOCA event occurs first, followed by a large break LOCA event in rapid succession. It was determined in early 2005 that the "double break" scenario was beyond the design basis of the McGuire station (reference detail in Section 3.3.1 of Attachment I of the LAR package), and the UFSAR was subsequently revised via a 10CFR50.59 evaluation in February of 2005 4. The Catawba UFSAR did not contain outdated references to the"double break" scenario, and therefore did not need revision in 2005 to reflect this determination. Page 4 of 6 Enclosure 1 Response to NRC Staff RAI Related to October 2, 2008 LAR for TS 3.6.13, Ice Condenser Doors, open and relieve pressure from the compartment of containment during the* blowdown phase of a large break Design Basis Accident (DBA). Therefore an open d.oor is already fulfilling this DBA function. The general intent in adding the proposed Note 2 to the McGuire/Catawba TS 3.6.13 Actions is the adoption of the Westinghouse STS 3.6.16 Bases wording. During the internal review of the LAR submitled.October' 2, 2008 (prior to submittal to NRC), it was determined that wording included in the STS 3.6.16 Bases that identifies criteria for entering an action statement would be better positioned in the actual technical specification (for Operator expediency), rather than in the Bases document. The STS *3.6.16 Bases wording does not identify a timeframe for "short duration". Therefore, it was determined that the Condition B four hour completion time for ice bed temperature verification would be invoked since it represented a limit already prescribed by the technical specification and easily bounded the expected timeframe for performing routine surveillances and inspections: The four hour timeframe defining a "short duration" entry is considered a technical specification clarification, and as such was determined to be better left in the TS Bases document. NRC Staff Question SCVB#2 In reference to the attachments containing existing UFSAR pages marked-up to show . the proposed changes, please clarify if the changes are same as those referenced in the last paragraph of Section 2.2 of Attachment

1. If they are different, give us a time tine of the 10CFR50.59 changes to the McGuire UFSAR, and when it was recognized, that the flow proportioning characteristics of the inlet doors is not a design requirement for McGuire and Catawba. DEC Response to NRC Staff Question SCVB#2: The marked-up McGuire UFSAR pages included with the LAR package dated October 2, 2008 are different from the revisions that were made to the McGuire UFSAR as a result of the 10CFR50.59 evaluation described in Section 2.2 of Attachment 1 of the same LAR package 3. Section 2.2 of Attachment 1 of the LAR describes the removal of the description of the "double break" scenario, in which a small break LOCA event occurs first, followed by a large break LOCA event in rapid succession.

' It was determined in early 2005 that the "double break" scenario was beyond the design basis . of the McGuire station (reference detail in Section 3.3.1 of Attachment 1 of the tAR package), and the UFSAR was subsequently revised via a 10CFR50.59 evaluation in February of 2005 4. The Catawba'UFSAR did not contain outdated references to the "double break" scenario, and therefore did not need revision in 2005 to reflect this determination. Page4of6 I i 1 I I I I I I I I I I I : , Enclosure 1 Response to NRC Staff RAI Related to October 2, 2008 LAR for TS 3.6.13, Ice Condenser Doors, open and relieve pressure from the compartment of containment during the* blowdown phase of a large break Design Basis Accident (DBA). Therefore an open d.oor is already fulfilling this DBA function. The general intent in adding the proposed Note 2 to the McGuire/Catawba TS 3.6.13 Actions is the adoption of the Westinghouse STS 3.6.16 Bases wording. During the internal review of the LAR submitled.October' 2, 2008 (prior to submittal to NRC), it was determined that wording included in the STS 3.6.16 Bases that identifies criteria for entering an action statement would be better positioned in the actual technical specification (for Operator expediency), rather than in the Bases document. The STS *3.6.16 Bases wording does not identify a timeframe for "short duration". Therefore, it was determined that the Condition B four hour completion time for ice bed temperature verification would be invoked since it represented a limit already prescribed by the technical specification and easily bounded the expected timeframe for performing routine surveillances and inspections: The four hour timeframe defining a "short duration" entry is considered a technical specification clarification, and as such was determined to be better left in the TS Bases document. NRC Staff Question SCVB#2 In reference to the attachments containing existing UFSAR pages marked-up to show . the proposed changes, please clarify if the changes are same as those referenced in the last paragraph of Section 2.2 of Attachment

1. If they are different, give us a time tine of the 10CFR50.59 changes to the McGuire UFSAR, and when it was recognized, that the flow proportioning characteristics of the inlet doors is not a design requirement for McGuire and Catawba. DEC Response to NRC Staff Question SCVB#2: The marked-up McGuire UFSAR pages included with the LAR package dated October 2, 2008 are different from the revisions that were made to the McGuire UFSAR as a result of the 10CFR50.59 evaluation described in Section 2.2 of Attachment 1 of the same LAR package 3. Section 2.2 of Attachment 1 of the LAR describes the removal of the description of the "double break" scenario, in which a small break LOCA event occurs first, followed by a large break LOCA event in rapid succession.

' It was determined in early 2005 that the "double break" scenario was beyond the design basis . of the McGuire station (reference detail in Section 3.3.1 of Attachment 1 of the tAR package), and the UFSAR was subsequently revised via a 10CFR50.59 evaluation in February of 2005 4. The Catawba'UFSAR did not contain outdated references to the "double break" scenario, and therefore did not need revision in 2005 to reflect this determination. Page4of6 I i 1 I I I I I I I I I I I : , Enclosure 1 Response to NRC Staff RAI Related to October 2. 2008 LAR for TS 3.6.13, Ice Condenser Doors, The conservative flow proportioning characteristics of the Lower Inlet Doors was recognized prior to 2005 by the Ice Condenser Utility Group (ICUG). At the ICUG Technical Conference held at the Donald C. Cook plant in 2002, the subject was discussed at length 5. The relevant pages of a meeting summary from that conference are included as Attachment A to this Enclosure in conjunction with the response to item SCVB#3 below. The proposed UFSAR changes shown in the LAR submitted on October 2, 2008 will be implemented after NRC approval of that LAR.NRC Staff Question SCVB#3 In reference to the statements in paragraph 3 of Section 2.4 of Attachment 1, please provide copies of relevant pages of ICUG interpretation in 2002 that was discussed in that year's ICUG Technical Conference. DEC Response to NRC Staff Question SCVB#3: The RAI question refers to the interpretation of the Lower Inlet Door 40 Degree Torque Test series (TSSR 3.6.13.6) results. Copies of relevant pages of the ICUG Technical Conference meeting summary held at the Donald C. Cook Nuclear Plant in Bridgman, Michigan in 2002 are included in Attachment A to this Enclosure 5 NRC Staff Question SCVB#4 It was stated in page 11 of Attachment 1 that inlet door movement characteristics (after initially breaking away) are not tied directly to the Containment response analysis and referenced a Westinghouse (OEM) letter. Please provide copies of relevant pages of the letter containing appropriate justification. Staff would also like to be informed if the proposed removal of TSSR 3.6.13.6 was discussed with the OEM, and if so, provide us with a brief description of the OEM's response.DEC Response to NRC Staff Question SCVB#4: The RAI question refers to a letter written by the OEM (WEC) in response to a contracted task to formally document the original design basis of the Lower Inlet Doors at McGuire and Catawba as it relates to the Technical Specifications. Copies of the relevant pages of the referenced OEM letter are included as Attachment B to this Enclosure 6 As discussed in the LAR package dated October 2, 2008, the accidents (LBLOCA and SBLOCA) are separate events and cannot occur concurrently or in rapid succession. A LBLOCA does not require the flow proportioning function of the Lower Inlet Doors to prevent maldistribution of break energy; as under these high energy conditions the ports Page 5 of 6 Enclosure 1 Response to NRC Staff RAI Related to October 2, 2008 LAR for TS 3.6.13, Ice Condenser Doors, The conservative flow proportioning characteristics of the Lower Inlet Doors was recognized prior to 2005 by the Ice Condenser Utility Group (ICUG). At the ICUG Technical Conference held at the Donald C. Cook plant in 2002, the subject was discussed at length 5. The relevant pages of a meeting summary from that conference are included as Attachment A to this Enclosure in conjunction with the response to item $CVB#3 below. The proposed UFSAR changes shown in the LAR submitted on October 2, 2008 will be implemented after NRC approval of that LAR. NRC Staff Question SCVB#3 In reference to the statements in paragraph 3 of Section 2.4 of Attachment 1, please provide copies of relevant pages of ICUG interpretation in 2002 that was discussed in that year's ICUG Technical Conference. DEC Response to NRC Staff Question SCVB#3: The RAI question refers to the interpretation of the Lower Inlet Door 40 Degree Torque Test series (TSSR 3.6.13.6) results. Copies of relevant pages of the ICUG Technical Conference meeting summary held at the Donald C. Cook Nuclear Plant in Bridgman, Michigan in 2002 are included in Attachment A to this Enclosure

5. NRC Staff Question SCVB#4 It was stated in page 11 of Attachment 1 that inlet door movement characteristics (after initially breaking away) are not tied directly to the Containment response analysis and referenced a Westinghouse (OEM) letter. Please provide copies of relevant pages of the letter containing appropriate justification.

Staff would also like to be informed if the proposed removal of TSSR 3.6.13.6 was discussed with the OEM, and if so, provide us with a brief description of the OEM's response. DEC Response to NRC Staff Question SCVB#4: The RAJ question refers to a letter written by the OEM (WEC) in response to a contracted task to formally document the original design basis of the lower Inlet Doors at McGuire and Catawba as it relates to the Technical Specifications. Copies of the relevant pages of the referenced OEM letter are included as Attachment B to this Enclosure

6. As discussed in the LAR package dated October 2, 2008, the accidents (lBlOCA and SBlOCA) are separate events and cannot occur concurrently or in rapid succession.

A lBLOCA does not require the flow proportioning function of the lower Inlet Doors to prevent maldistribution of break energy; as under these high energy conditions the ports . Page 5 of6 i Enclosure 1 Response to NRC Staff RAI Related to October 2, 2008 LAR for TS 3.6.13, Ice Condenser Doors, The conservative flow proportioning characteristics of the Lower Inlet Doors was recognized prior to 2005 by the Ice Condenser Utility Group (ICUG). At the ICUG Technical Conference held at the Donald C. Cook plant in 2002, the subject was discussed at length 5. The relevant pages of a meeting summary from that conference are included as Attachment A to this Enclosure in conjunction with the response to item $CVB#3 below. The proposed UFSAR changes shown in the LAR submitted on October 2, 2008 will be implemented after NRC approval of that LAR. NRC Staff Question SCVB#3 In reference to the statements in paragraph 3 of Section 2.4 of Attachment 1, please provide copies of relevant pages of ICUG interpretation in 2002 that was discussed in that year's ICUG Technical Conference. DEC Response to NRC Staff Question SCVB#3: The RAI question refers to the interpretation of the Lower Inlet Door 40 Degree Torque Test series (TSSR 3.6.13.6) results. Copies of relevant pages of the ICUG Technical Conference meeting summary held at the Donald C. Cook Nuclear Plant in Bridgman, Michigan in 2002 are included in Attachment A to this Enclosure

5. NRC Staff Question SCVB#4 It was stated in page 11 of Attachment 1 that inlet door movement characteristics (after initially breaking away) are not tied directly to the Containment response analysis and referenced a Westinghouse (OEM) letter. Please provide copies of relevant pages of the letter containing appropriate justification.

Staff would also like to be informed if the proposed removal of TSSR 3.6.13.6 was discussed with the OEM, and if so, provide us with a brief description of the OEM's response. DEC Response to NRC Staff Question SCVB#4: The RAJ question refers to a letter written by the OEM (WEC) in response to a contracted task to formally document the original design basis of the lower Inlet Doors at McGuire and Catawba as it relates to the Technical Specifications. Copies of the relevant pages of the referenced OEM letter are included as Attachment B to this Enclosure

6. As discussed in the LAR package dated October 2, 2008, the accidents (lBlOCA and SBlOCA) are separate events and cannot occur concurrently or in rapid succession.

A lBLOCA does not require the flow proportioning function of the lower Inlet Doors to prevent maldistribution of break energy; as under these high energy conditions the ports . Page 5 of6 i Enclosure I Response to NRC Staff RAI Related to October 2, 2008 LAR for TS 3.6.13, Ice Condenser Doors, in the Crane Wall are designed to distribute the inflow to the ice condenser. The SBLOCA, as an independent low energy event, does not propagate to a LBLOCA and therefore preventing steam bypass from getting to the upper compartment of containment (ostensibly prior to a subsequent LBLOCA high energy event) is not necessary. The proposed removal of the TSSR 3.6.13.6 Lower Inlet Door Torque test series (and incorporation of a freedom of movement test into SR 3.6.13.5) was not formally discussed with the OEM. As noted in the LAR package dated October 2, 2008, there is an industry precedent (TSTF 429-A) for revising an ice condenser-related technical specification using this approach. TSTF 429-A was approved by NRC in September 2003, and reflects a revision to the Ice Condenser Ice Bed Mass Determination statistical analysis and sampling methodology governed by McGuire/Catawba TSSR 3.6.12.4 and TSSR 3.6.12.57. Enclosure I References

1. Westinghouse STS 3.6.16 and BASES (NUREG-1431, Rev. 3, Volume 1)2. Current McGuire/Catawba TS 3.6.13 and TS BASES 3. October 2, 2008 LAR package, Attachment 1, page 9 of 27 4. PIP M-04-5115, CA#34 5. ICUG Meeting Summary -July 2002, Pgs 7-10 (see Attachment A of Enclosure 1 in this submittal)

6. Westinghouse Letter LTR-RIDA-06-106, Rev 2, Portion Titled "Scope and Clarifications Number 8" (see Attachment B of Enclosure 1 in this submittal)

7. TSTF-429, Revision 3, dated November 2003 Page 6 of 6 Enclosure 1 Response to NRC Staff HAl Related to October 2, 2008 LAR for TS 3.6.13, Ice Condenser Doors, in the Crane Wall are designed to distribute the inflow to the ice condenser.

The SBLOCA, as an independent low energy event, does not propagate to a LBLOCA and therefore preventing steam bypass from getting to the upper compartment of containment (ostensibly prior to a subsequent LBLOCA high energy event) is not nece..fosary. The proposed removal of the TSSR 3.6.13.6 Lower Inlet Door Torque test series (and incorporation of a freedom of movement test into SR 3.6.13.5) was not formally discussed with the OEM. As noted in the LAR package dated October 2, 2008, there is an industry precedent (TSTF 429-A) for reviSing an ice condenser-related technical specification using this approach. TSTF 429-A was approved by NRC in September 2003, and reflects a revision to the Ice Condenser Ice Bed Mass Determination statistical analysis and sampling methodology governed by McGuire/Catawba TSSR 3.6.12.4 and TSSR 3.6.12.5 7. Enclosure 1 References

1. Westinghouse STS 3.6.16 and BASES (NUREG-1431, Rev. 3, Volume 1) 2. Current McGuire/Catawba TS 3.6.13 and TS BASES 3. October 2, 2008 LAR package, Attachment 1, page 9 of 27 4. PIP M-Q4-5115, CA#34 5. ICUG Meeting Summary -July 2002, Pgs 7-10 (see Attachment A of Enclosure 1 in' this submittal)

6. Westinghouse Letter L TR-RIOA-06-106, Rev 2, Portion Titled "Scope and Clarifications Number 8" (see Attachment B of Enclosure 1 in this submittal)

7. TSTF-429, Revision 3, dated November 2003 Page 6 of6 Enclosure 1 Response to NRC Staff HAl Related to October 2, 2008 LAR for TS 3.6.13, Ice Condenser Doors, in the Crane Wall are designed to distribute the inflow to the ice condenser.

The SBLOCA, as an independent low energy event, does not propagate to a LBLOCA and therefore preventing steam bypass from getting to the upper compartment of containment (ostensibly prior to a subsequent LBLOCA high energy event) is not nece..fosary. The proposed removal of the TSSR 3.6.13.6 Lower Inlet Door Torque test series (and incorporation of a freedom of movement test into SR 3.6.13.5) was not formally discussed with the OEM. As noted in the LAR package dated October 2, 2008, there is an industry precedent (TSTF 429-A) for reviSing an ice condenser-related technical specification using this approach. TSTF 429-A was approved by NRC in September 2003, and reflects a revision to the Ice Condenser Ice Bed Mass Determination statistical analysis and sampling methodology governed by McGuire/Catawba TSSR 3.6.12.4 and TSSR 3.6.12.5 7. Enclosure 1 References

1. Westinghouse STS 3.6.16 and BASES (NUREG-1431, Rev. 3, Volume 1) 2. Current McGuire/Catawba TS 3.6.13 and TS BASES 3. October 2, 2008 LAR package, Attachment 1, page 9 of 27 4. PIP M-Q4-5115, CA#34 5. ICUG Meeting Summary -July 2002, Pgs 7-10 (see Attachment A of Enclosure 1 in' this submittal)

6. Westinghouse Letter L TR-RIOA-06-106, Rev 2, Portion Titled "Scope and Clarifications Number 8" (see Attachment B of Enclosure 1 in this submittal)

7. TSTF-429, Revision 3, dated November 2003 Page 6 of6 Attachment A To Enclosure I Selected Pages From Meeting Summary For July 16-18, 2002 Ice Condenser Utility Group Technical Conference Attachment A To Enclosure 1 Selected Pages From Meeting Summary For July 16-18,2002 Ice Condenser Utility Group Technical Conference I :1 '. d 1 d ., . ; I * : I *1 , I : : Attachment A To Enclosure 1 Selected Pages From Meeting Summary For July 16-18,2002 Ice Condenser Utility Group Technical Conference I :1 '. d 1 d ., . ; I * : I *1 , I : :

2002 ICUG Technical Conference- Page 7 1. Primary focus of the guide would be to educate/enlighten Work Control and plant management to the significance ofthe I/C surveillances in an era of ever-shortening outages.

2. The IG would need to be comprehensive; i.e., it would encompass all the I/C TSs and the design principles behind them.3. Guide would include a reference section that would lead to the public domain, so that the bases in the guide will tie to documents we all share.

4. Operating experience would be included (both plant OE and regulatory history).5. A description of the TS implementation procedures and-associated maintenance practices (such as AIMM methodology) from each plant would be included.6. This would need to be assembled pretty quickly. Sequoyah NP might be the first to adopt the Ice Mass DeterminationTS from NUREG-1431, and if so would do it in time for the spring 2003 RFO there. That schedule would mean at least a draft IG would need to be in place by early 2003 to support the implementation of the TS.From these comments, the following outline of the ICUG Implementation Guide was developed:

lo. Section 1: Operating Experience (Plant and Regulatory)

o. Section IH: Design Philosophy (link to TSs)b. Section III: Implementation of TS / Maintenance Support b. Section IV:

References (linked to public domain)Paul L. and Russ took action to begin assembling information for Section II1, with Paul taking the Ice Mass TS and Russ taking the I/C Door TS LID issues. As this develops, assistance will be needed from ICUG members.The next agenda item involved the recent issues regarding the I/C Door TS, in particular, the surveillance tests surrounding the Lower Inlet Doors. It had been determined that, due to continuing confusion about this subject by the staff and others, documentation of an industry position was needed for supporting not just our response to the issues individually, but for enhancing our credibility as an industry group capable of consistently addressing regulatory issues. Russ gave a synopsis of what brought this item to the ICUG agenda: the NRC Resident at Catawba had raised the issue of LID testing, in particular the fact thatthere was no process installed at CNS for tracking "failures" of the LID tests after an as-left surveillance. This was deemed a problem since, by 1 OCFR50.65 guidance (Maintenance Rule), failures of high-risk, safety-significant systems needed to be trended. He issued a non-cited violation (against Criterion XVI) to Catawba the week prior to the ICUG meeting, as a result. Hehad other issues as well, which turn out to be similar to those surfaced by the Residents at the other Region 11 plants: , As-left testing versus as-found testing, why not do both?o. Adequacy of the LID 401 Torque Test to determine operability

o. MR trending The ICUG discussion of this item at the meeting was extensive; what follows is a summary of it that also served as the industry position basis: In February of 2002, Cook Nuclear Plant Unit I entered a planned refueling outage, at which time the Ice Condenser Lower Inlet Doors (LIDs) were tested per the plant's surveillance requirements.

At Cook NP, the surveillances on the LIDs are performed in both the as-found and the as-left condition. The remaining ice condenser plants (TVA-Sequoyah, TVA-Watts Bar, Duke-Catawba and Duke-McGuire, all in Region IH) conduct the LID surveillances only in the as-left condition. The LID testing performed at Cook NP Unit I was witnessed by NRC personnel, and at the time of the tests several issues arose about the methodology being implemented to perform them. Ultimately, Cook NP determined that their test procedure for the LIDs was not adequate. Cook personnel then corrected the test procedure and re-tested the Unit I LIDs. Unit 2 LIDs were addressed through approval of an emergency Technical Specification amendment allowing Unit 2 to operate until its next outage without fuirther testing.2002 ICUG Technical Conference -Page 7 ). Primary focus of the guide would ,be to educate/enlighten Work Control and plant management to the significance of the IIC surveillances in an era of ever-shortening outages. 2. The IG would need to be comprehensive; i.e., it would encompass all the IIC TSs and the design principles behind them. 3. Guide would include a reference section that would lead to the public domain, so that the bases in the guide will tie to docwnents we all share. 4. Operating experience would be included (both plant OE and regulatory history).

5. A description of the TS implementation procedures and.associated maintenance practices (such as AIMM methodology) from each plant would be included.

6. This would need to be assembled pretty quickly. Sequoyah NP might be the first to adopt the Ice Mass Deterinination TS from NUREG-1431, and if so would do it in time for the spring 2003 RFO there. That schedule would mean at least a draft IG would need to be in place by early 2003 to support the implementation of the TS. From these comments, the following outline of the ICUG Implementation Guide was developed:

.. Section I: Operating Experience (plant and Regulatory) .. Section n: Design Philosophy (link to TSs) .. Section m: Implementation ofTS I Maintenance Support .. Section N: References (linked to public domain) Paul L. and Russ took action to begin assembling information for Section Ill, with Paul taking the Ice Mass TS and Russ taking the IIC Door TS LID issues. As this develops, assistance will be needed from ICUG members. The next agenda item involved the recent issues regarding the lIC Door TS, in particular, the surveillance tests surrounding the Lower Inlet Doors. It bad been detennined that, due to continuing confusion about this subject by the staff and others, -documentation of an industry position was needed for supporting not just our response to the issues individually, but for enhancing our credibility as an industry group capable of consistently addressing regulatory issues. Russ gave a synopsis of what brought this item to the ICUG agenda: the NRC Resident at Catawba had raised the issue of LID testing, in particular the fact that there was no process installed at CNS for tracking "failures" of the LID tests after an as-Ieft surveillance. This was deemed a .problem since, by J OCFR50.65 guidance (Maintenance Rule), failures ofhigh-risk, safety-significant systems needed to be trended. He issued a non-cited violation (against Criterion XVI) to Catawba the week prior to the ICUG meeting, as a result. He had other issues as well, which tum out to be similar to those surfaced by the Residents at the other Region 11 plants: As-left testing versus as-found testing. why not do both? Do Adequacy of the LID 40° Torque Test to determine operability .. MR trending The ICUG discussion of this item at the meeting was extensive; what follows is a summary of it that also served as the industry position basis: In February of2002, Cook Nuclear Plant Unit 1 entered a planned refueling outage, at which time the Ice Condenser Lower Inlet Doors (LIDs) were tested per the plant's surveillance requirements. At Cook NP, the surveillances on the LIDs are performed in both the as-found and the as-Ieft condition. The remaining ice condenser plants (IV A-Sequoyah, TV A-Watts Bar, Duke-Catawba and Duke-McGuire, all in Region n) conduct the LID surveillances only in the as-left condition. The LID testing performed at Cook NP Unit I was witnessed by NRC personnel, and at the time ofthe tests several issues arose about the methodology being implemented to perform them. Ultimately, Cook NP determined that their test procedure for the LIDs was not adequate. Cook persormel then corrected the test procedure and re-tested the Unit I LIDs.. Unit 2 LIDs were addressed through approval of an emergency Technical Specification amendment allowing Unit 2 to operate until its next outage without further testing. 2002 ICUG Technical Conference -Page 7 ). Primary focus of the guide would ,be to educate/enlighten Work Control and plant management to the significance of the IIC surveillances in an era of ever-shortening outages. 2. The IG would need to be comprehensive; i.e., it would encompass all the IIC TSs and the design principles behind them. 3. Guide would include a reference section that would lead to the public domain, so that the bases in the guide will tie to docwnents we all share. 4. Operating experience would be included (both plant OE and regulatory history).

5. A description of the TS implementation procedures and.associated maintenance practices (such as AIMM methodology) from each plant would be included.

6. This would need to be assembled pretty quickly. Sequoyah NP might be the first to adopt the Ice Mass Deterinination TS from NUREG-1431, and if so would do it in time for the spring 2003 RFO there. That schedule would mean at least a draft IG would need to be in place by early 2003 to support the implementation of the TS. From these comments, the following outline of the ICUG Implementation Guide was developed:

.. Section I: Operating Experience (plant and Regulatory) .. Section n: Design Philosophy (link to TSs) .. Section m: Implementation ofTS I Maintenance Support .. Section N: References (linked to public domain) Paul L. and Russ took action to begin assembling information for Section Ill, with Paul taking the Ice Mass TS and Russ taking the IIC Door TS LID issues. As this develops, assistance will be needed from ICUG members. The next agenda item involved the recent issues regarding the lIC Door TS, in particular, the surveillance tests surrounding the Lower Inlet Doors. It bad been detennined that, due to continuing confusion about this subject by the staff and others, -documentation of an industry position was needed for supporting not just our response to the issues individually, but for enhancing our credibility as an industry group capable of consistently addressing regulatory issues. Russ gave a synopsis of what brought this item to the ICUG agenda: the NRC Resident at Catawba had raised the issue of LID testing, in particular the fact that there was no process installed at CNS for tracking "failures" of the LID tests after an as-Ieft surveillance. This was deemed a .problem since, by J OCFR50.65 guidance (Maintenance Rule), failures ofhigh-risk, safety-significant systems needed to be trended. He issued a non-cited violation (against Criterion XVI) to Catawba the week prior to the ICUG meeting, as a result. He had other issues as well, which tum out to be similar to those surfaced by the Residents at the other Region 11 plants: As-left testing versus as-found testing. why not do both? Do Adequacy of the LID 40° Torque Test to determine operability .. MR trending The ICUG discussion of this item at the meeting was extensive; what follows is a summary of it that also served as the industry position basis: In February of2002, Cook Nuclear Plant Unit 1 entered a planned refueling outage, at which time the Ice Condenser Lower Inlet Doors (LIDs) were tested per the plant's surveillance requirements. At Cook NP, the surveillances on the LIDs are performed in both the as-found and the as-Ieft condition. The remaining ice condenser plants (IV A-Sequoyah, TV A-Watts Bar, Duke-Catawba and Duke-McGuire, all in Region n) conduct the LID surveillances only in the as-left condition. The LID testing performed at Cook NP Unit I was witnessed by NRC personnel, and at the time ofthe tests several issues arose about the methodology being implemented to perform them. Ultimately, Cook NP determined that their test procedure for the LIDs was not adequate. Cook persormel then corrected the test procedure and re-tested the Unit I LIDs.. Unit 2 LIDs were addressed through approval of an emergency Technical Specification amendment allowing Unit 2 to operate until its next outage without further testing. 2002 ICUG Technical Conference -Page 8 As a result of these events, resident NRC inspectors queried personnel at the Region II plants regarding the LID tests, and during the spring 2002 outage season LID testing and associated procedures were reviewed and in some cases witnessed by the staff at those stations. Subsequently, NRC personnel at Sequoyah and Catawba Nuclear Stations requested clarification on the following issues: i- Basis for performing as-left LID testing in lieu of as-found LID testing. This issue concerns a Licensee's ability to show that the LIDs are still operable at the end of a cycle (or at any other time after the current as-left tests).l Validity of the methodology for performing the LID 40' "Torque Test." This issue involves the evaluation of free LID movement and friction in the LID hinges (required by the current surveillance requirements). i Process for trending LID failures for Maintenance Rule. This issue surfaced after it was noted by NRC that the LIDs are included in MR as high-risk, safety significant components, but no process for trending failures exists since the LIDs cannot "fail" the as-left surveillance test (LIDs are not required operable in Mode 5 when the SR tests are performed). Pursuant to the generic position, the following topics were discussed at length: I. LID design basis 2. LID surveillance test acceptance criteria basis (e.g;, empirical data, analysis, or other)3. Current surveillance requirement link to IOCFR50.36

4. Current industry procedures for identifying unexpected changes from last as-left LID tests 5. Current industry procedures for performing the LID Opening Force Test6. Current industry procedures for performing the LID 400 Torque Test

7. Industry experience with the LID 40' Torque Test and associated results 8. LID contribution to functional capability of lee Condenser (Maintenance Rule)Representatives from each of the utilities provided plant-specific information and recent experience related to the surveillance-testing of LIDs. Salient points from past discussions with resident inspectors were also exchanged, as well as past LID testing issues and plant events.While each utility has a different approach for addressing the three outlined issues brought by the NRC residents, the bases behind the approaches is essentially the same and adequately represents that the industry is not divergent in its interpretation ofthe requirements set forth in the current Ice Condenser Door technical specification.

Issue: As-Left LID Surveillance Testina versus As-Found LID Surveillance Testing All representatives agreed that as-left (post-ice bed maintenance) surveillance testing is sufficient to show the LIDs will be capable of performing their safety function. Combined industry operating experience has verified the absence of any mechanism for LID degradation during normal operation ("innage"). Innage-related anomalies (e.g., a steam leak in containment or excessive AHU drain pan leakage) that could potentially challenge LID performance are addressed in each plant's Corrective Action Program including, as appropriate, operability evaluation per the guidance outlined in Generic Letter 91-18.Outage-related ice bed maintenance, however, does present conditions that commonly degrade LIDs. These conditions include exposure of the LIDs to ice and water outfall. As a result of these activities and the potential degradation that they impose, LID restoration is a normal activity at the conclusion of each maintenance outage. Final restoration activities include completion of the required surveillance testing. During the course of performing this LID testing, "failures" (when they occur) have typically been attributed to outage maintenance-induced ice build-up on the LIDs, the compressive effect of LID blocking hardware, or the known sensitivity of the test parameters when performed by inexperienced personnel. The satisfactory completion of this as-leftLID testing meets the applicable surveillance requirements by assuring the limited condition for operation of the LIDs will be met for the duration of the surveillance interval as required by I0CFR50.36 (c) (3).2002 I CUG Technical Conference -Page 8 As a result of these events, resident NRC inspectors queried personnel at the Region II plants regarding the LID tests, and during the spring 2002 outage season LID testing and associated procedUres were reviewed and in some cases witnessed by the staff at those stations. Subsequently, NRC personnel at Sequoyah and Catawba Nuclear Stations requested clarification on the following issues: Basis for performing as-left LID testing in lieu of as-found LID testing. This issue concerns a Licensee's ability to show that the LIDs are still operable at the end of a cycle (or at any otl!er time after the current as-left tests). Validity of the methodology for performing the LID 40° "Torque Test" This issue involves the evaluation of free LID movement and friction in the LID hinges (required by the current surveillance requirements) . . Process for trending LID failures for Maintenance Rule. This issue surfaced after it was noted by NRC that the LIDs are included in MR as high-risk, safety significant components. but no process for trending failures exists since the LIDs cannot "fail" the as-left surveillance test (LIDs are not required operable in Mode 5 when the SR tests are performed). Pursuant to the generic position, the following topics were discussed at length: ) . LID design basis 2. LID surveillance test acceptance criteria basis (e.g" empirical data, analysis, or other) 3. Current surveillance requirement link to IOCFR50.36

4. Current industry procedures for identifying unexpected changes from last as-left LID tests 5. Current industry procedures for performing the LID Opening Force Test 6. Current industry procedures for performing the LID 400 Torque Test 7. Industry experience with the LID 400 Torque Test and associated results 8. LID contribution to :functional cap8bility ofIce Condenser (Maintenance Rule) Representatives from each of the utilities provided plant-specific information and recent experience related to the surveillance -testing of LIDs. Salient points from past discussions with resident inspectors were also exchanged, as well as past LID testing issues and plant events. While each utility has a different approach for addressing the three outlined issues brought by the NRC residents, the bases behind the approacbes is essentially the same and adequately represents that the industry is not divergent in its interpretation of the requirements set forth in the current Ice Condenser Door technical specification.

Issue: As-Left LID Surveillance Testing versus As-Found LID Surveillance Testing All representatives agreed that as-left (post-ice bed maintenance) surveillance testing is sufficient to show the LIDs will be capable of performing their safety function. Combined industry operating experience has verified the absence of any mechanism for LID degradation during normal operation ("innage"). Innage-related anomalies (e.g., a steam leak in containment or excessive AHU drain pan leakage) that could potentially challenge LID performance are addressed in each plant's Corrective Action Program including, as appropriate, operability evaluation per the guidance outlined in Generic Letter 91-18. Outage-related i,ce bed maintenance, however, does present conditions that commonly degrade LIDs. These conditions include exposure of the LIDs to ice and water outfall. As a result of these activities and the potential degradation that they impose, LID restoration is a normal activity at the conclusion of each maintenance outage. Final restoration activities include completion of the required surveillance testing. During the course of performing this LID testing, "failures" (when they occur) have typically been attributed to outage maintenance-induced ice build-up on the LIDs, the compressive effect of LID blocking hardware, or the known sensitivity of the test parameters when performed by inexperienced personnel. The satisfactory completion of this as-Ieft LID testing meets the applicable surveillance requirements by assuring the limited condition for operation of the LIDs will be met for the duration of the surveillance interval as required by IOCFRS0.36 (e) (3). 1 I I I r I 2002 I CUG Technical Conference -Page 8 As a result of these events, resident NRC inspectors queried personnel at the Region II plants regarding the LID tests, and during the spring 2002 outage season LID testing and associated procedUres were reviewed and in some cases witnessed by the staff at those stations. Subsequently, NRC personnel at Sequoyah and Catawba Nuclear Stations requested clarification on the following issues: Basis for performing as-left LID testing in lieu of as-found LID testing. This issue concerns a Licensee's ability to show that the LIDs are still operable at the end of a cycle (or at any otl!er time after the current as-left tests). Validity of the methodology for performing the LID 40° "Torque Test" This issue involves the evaluation of free LID movement and friction in the LID hinges (required by the current surveillance requirements) . . Process for trending LID failures for Maintenance Rule. This issue surfaced after it was noted by NRC that the LIDs are included in MR as high-risk, safety significant components. but no process for trending failures exists since the LIDs cannot "fail" the as-left surveillance test (LIDs are not required operable in Mode 5 when the SR tests are performed). Pursuant to the generic position, the following topics were discussed at length: ) . LID design basis 2. LID surveillance test acceptance criteria basis (e.g" empirical data, analysis, or other) 3. Current surveillance requirement link to IOCFR50.36

4. Current industry procedures for identifying unexpected changes from last as-left LID tests 5. Current industry procedures for performing the LID Opening Force Test 6. Current industry procedures for performing the LID 400 Torque Test 7. Industry experience with the LID 400 Torque Test and associated results 8. LID contribution to :functional cap8bility ofIce Condenser (Maintenance Rule) Representatives from each of the utilities provided plant-specific information and recent experience related to the surveillance -testing of LIDs. Salient points from past discussions with resident inspectors were also exchanged, as well as past LID testing issues and plant events. While each utility has a different approach for addressing the three outlined issues brought by the NRC residents, the bases behind the approacbes is essentially the same and adequately represents that the industry is not divergent in its interpretation of the requirements set forth in the current Ice Condenser Door technical specification.

Issue: As-Left LID Surveillance Testing versus As-Found LID Surveillance Testing All representatives agreed that as-left (post-ice bed maintenance) surveillance testing is sufficient to show the LIDs will be capable of performing their safety function. Combined industry operating experience has verified the absence of any mechanism for LID degradation during normal operation ("innage"). Innage-related anomalies (e.g., a steam leak in containment or excessive AHU drain pan leakage) that could potentially challenge LID performance are addressed in each plant's Corrective Action Program including, as appropriate, operability evaluation per the guidance outlined in Generic Letter 91-18. Outage-related i,ce bed maintenance, however, does present conditions that commonly degrade LIDs. These conditions include exposure of the LIDs to ice and water outfall. As a result of these activities and the potential degradation that they impose, LID restoration is a normal activity at the conclusion of each maintenance outage. Final restoration activities include completion of the required surveillance testing. During the course of performing this LID testing, "failures" (when they occur) have typically been attributed to outage maintenance-induced ice build-up on the LIDs, the compressive effect of LID blocking hardware, or the known sensitivity of the test parameters when performed by inexperienced personnel. The satisfactory completion of this as-Ieft LID testing meets the applicable surveillance requirements by assuring the limited condition for operation of the LIDs will be met for the duration of the surveillance interval as required by IOCFRS0.36 (e) (3). 1 I I I r I 2002 ICUG Technical Conference -Page 9Noted as well were the existing as-found visual inspections of the LID area performed after Unit shut-down. Some utilitiesvisually inspect the LID seal and door surfaces, while others do a general visual inspection to ascertain anomalous conditions that might affect LID operability, such as ice build-up or other degradation- These as-found inspections are formal procedures at some plants. Each plant (as appropriate) should evaluate the need to proceduralize these inspections to verify that as-found LID condition is being evaluated to appropriately identify any Conditions Adverse to Quality (CAQ). If during the as-found inspection a CAQ is discovered, further evaluation, of the LID condition would be indicated, up to and including a surveillance test.It was determined during the discussion that LID "cycling" (i.e., opening and closing) prior to any as-found inspections or as-left surveillance tests was practically unavoidable-This cycling is a result of the very low differential pressure needed to open the LIDs, and is the reason the LID Blocking hardware, used to hold the doors closed during ice bed maintenance, was developed. All plants reported experiencing inadvertent LID cycling during containment ventilation transients, which occur as the Unit changes modes and as personnel air locks and containment equipment hatches are opened in preparation for outage work. In addition, at some plants the only ingress path to the ice condenser Lower Plenum after shutdown is through a LID, which requires at least one LID to be opened just to gain access to the area. There is no failure mechanism being masked by this LID cycling.The seal design is such that the seal does not freeze to the door surface; any freezing condition that restricts LID opening requires a significant build-up of ice or frost, which is identifiable during as-found visual inspections. As required by IOCFR50, Appendix B, any CAQ must be identified and corrected, whether it is discovered via a surveillance test or other means. The as-found visual inspections provide the primary basis for identifying CAQs. LID maintenance performed at the conclusion of the outage is generally defined as those routine activities needed to restore the doors from the effects of outagework. This maintenance, since it is occurring prior to the as-left surveillance tests, must be limited to maintenance that repairs a condition caused by other outage maintenance activities or a condition for which the as-found condition of the door has been evaluated. For example, allowed routine maintenance might include seal/hinge lubrication performed as a standard practice to remove moisture from the hinges introduced during ice bed replenishment. Conversely, hinge/spring adjustments are not routine maintenance activities, and wouldneed to be evaluated to determine the cause of the condition/adjustment. After routine maintenance is performed, a "soak time" is conservatively allotted before the surveillance tests are performed, to allow the LID to settle. Each plant (as appropriate) should evaluate the need to establish allowed maintenance practices and "soak times" prior to performing the as-left LID tests.Issue: Validity of LID 40' "Torque Test" Methodology The primary focus of this issue centers on the function of the LIDs during the postulated Design Basis Accident-For all ice condenser plants, the Large Break LOCA (LBLOCA) is the bounding analysis. The only other licensing basis analysis is applicable only to Cook NP, which has unique containment design issues that have resulted in a sump inventory analysis(MAAP) that occurs in the SBLOCA event.ICUG notes that the LIDs are intended (and analytically assumed) to open immediately and evenly upon initiation of the Large Break or Small Break LOCA, and then recover their position and modulate the longer-term flow of steam into the ice bed until the bed is depleted. This design function forms the basis for the current LID Opening Force Test and the LID Torque Test, and supports the LBLOCA analysis modeled by the TMD/LOTIC codes as well as the SBLOCA MAAP code for the Cook NP sump inventory analysis. The Duke plants are currently licensed to a TMD/GOTHIC code model which does allow cross-flow betweenelements and has a more detailed nodalization than the original LOTIC work. Analysis runs using the GOTHIC code show that the LIDs do not need to open evenly or recover and modulate steam flow into the ice bed after the DBA has initiated. While not all ice condenser plants are licensed to this model, it supports the ICUG view that the current Ice Condenser Door technical specification is conservative. In order to show the functional capability of the LIDs to modulate steam flow after the initiation of either the LBLOCA or SBLOCA, the surveillance test (the LID Torque Test) identifies limits for opening torque, closing torque, and frictional torque with the LID positioned at 400 open (this represents the free opening position of the doors before significant contact against theshock absorbers or foam bags). Generally, the 2002 ICUG Technical Conference -Page 9 Noted as well were the existing as-found visual inspections of the LID area performed after Unit shut-down. Some utilities visually inspect the LID seal and door surfaces, while others do a general visual inspection to ascertain anomalous conditions that might affect LID operability, such as ice build-up or other degradation. These as-found inspections are formal procedures at some plants. Each plant (as appropriate) should evaluate the need to proceduralize these inspections to verity that as-found LID condition is being evaluated to appropriately identifY any Conditions Adverse to Quality (CAQ). If during the as-found inspection a CAQ is discovered, further evaluation of the LID condition would be indicated, up to and including a surveillance test. It was determined during the discussion that LID "cycling" (i.e., opening and closing) prior to any as-found inspections or as-left surveillance tests was practically unavoidable. This cycling is a result of the very low differential pressure needed to open the LIDs, and is the reason the LID Blocking hardware, used to hold the doors closed during ice bed maintenance, was developed. All plants reported experiencing inadvertent LID cycling during containment ventilation transients, which occur as the Unit changes modes and as personnel air locks and containment equipment hatches are opened in preparation for outage work. In addition, at some plants the only ingress path to the ice condenser Lower Plenum after shutdown is through a LID, which requires at least one LID to be opened just to gain access to the area. There is no failure mechanism being masked by this LID cycling. The seal design is such that the seal does not freeze to the door surface; any freezing condition that restricts LID opening requires a significant build-up of ice or frost, which is identifiable during as-found visual inspections. As required by lOCFRSO, Appendix B, any CAQ must be identified and corrected, whether it is discovered via a surveillance test or other means. The as-found visual inspections provide the primary basis for identifYing CAQs.. LID maintenance performed at the cOIlclusion of the outage is generally defined as those routine activities needed to restore the doors from the effects of outage work. This maintenance, since it is occurring prior to the as-Ieft surveillance tests, must be limited to maintenance that repairs a condition caused by other outage maintenance activities or a condition for which the as-found condition ofthe door has been evaluated, For example, allowed routine maintenance might include seal/hinge lubrication performed as a standard practice to remove moisture from the hinges introduced during ice bed replenishment. Conversely, hinge/spring adjustments are not routine maintenance activities, and would'need to be evaluated to determine the cause of the condition/adjustment. After routine maintenance is performed, a "soak tim en is conservatively allotted before the surveillance tests are performed, to allow the LID to senle. Each plant (as appropriate) should evaluate the need to establish allowed maintenance practices and "soak times" prior to performing the as-left LID tests. Issue: Validity of LID 40° "Torgue Test" Methodology The primary focus of this issue centers on the function of the LIDs during the postulated Design Basis Accident. For all ice condenser plants, the Large Break LOCA (LBLOCA) is the bounding analysis. The only other licensing basis analysis is applicable only to Cook NP, which has unique containment design issues that have resulted in a sump inventory analysis (MAAP) that occurs in the SBLOCA event. ICUG notes that the LIDs are int!!Jlded (and analytically assumed) to open immediately and evenly upon initiation oft)1e Large , Break or Small Break LOCA, and then recover their position and modulate the longer-term flow of steam into the ice bed until the bed is depleted. This design function forms the basis for the current LID Opening Force Test and the LID Torque Test, and supports the LBLOCA analysis modeled by the TMDILOTIC codes as well as the SBLOCA MAAP code for the Cook NP sump inventory analysis. The Duke plants are currently licensed to a lMD/GOnnC code model which does allow cross-flow between elements and has a more detailed nodalization than the original Lonc work. Analysis runs using the GOTHIC code show that the LIDs do not need to open evenly or recover and modulate steam flow into the ice bed after the DBA has initiated. While not all ice condenser plants are licensed to this model, it supports the ICUG view that the current Ice CondeDser Door technical specification is conservative. In order to show the functional capability of the LIDs to modulate steam flow after the initiation of either the LBLOCA or SBLOCA, the surveillance test (the LID Torque Test) identifies limits for opening torque, closing torque, and frictional torque with the LID positioned at 40" open (this represents the free opening position of the doors before significant contact against the shock absorbers or foam bags). Generally, the 2002 ICUG Technical Conference -Page 9 Noted as well were the existing as-found visual inspections of the LID area performed after Unit shut-down. Some utilities visually inspect the LID seal and door surfaces, while others do a general visual inspection to ascertain anomalous conditions that might affect LID operability, such as ice build-up or other degradation. These as-found inspections are formal procedures at some plants. Each plant (as appropriate) should evaluate the need to proceduralize these inspections to verity that as-found LID condition is being evaluated to appropriately identifY any Conditions Adverse to Quality (CAQ). If during the as-found inspection a CAQ is discovered, further evaluation of the LID condition would be indicated, up to and including a surveillance test. It was determined during the discussion that LID "cycling" (i.e., opening and closing) prior to any as-found inspections or as-left surveillance tests was practically unavoidable. This cycling is a result of the very low differential pressure needed to open the LIDs, and is the reason the LID Blocking hardware, used to hold the doors closed during ice bed maintenance, was developed. All plants reported experiencing inadvertent LID cycling during containment ventilation transients, which occur as the Unit changes modes and as personnel air locks and containment equipment hatches are opened in preparation for outage work. In addition, at some plants the only ingress path to the ice condenser Lower Plenum after shutdown is through a LID, which requires at least one LID to be opened just to gain access to the area. There is no failure mechanism being masked by this LID cycling. The seal design is such that the seal does not freeze to the door surface; any freezing condition that restricts LID opening requires a significant build-up of ice or frost, which is identifiable during as-found visual inspections. As required by lOCFRSO, Appendix B, any CAQ must be identified and corrected, whether it is discovered via a surveillance test or other means. The as-found visual inspections provide the primary basis for identifYing CAQs.. LID maintenance performed at the cOIlclusion of the outage is generally defined as those routine activities needed to restore the doors from the effects of outage work. This maintenance, since it is occurring prior to the as-Ieft surveillance tests, must be limited to maintenance that repairs a condition caused by other outage maintenance activities or a condition for which the as-found condition ofthe door has been evaluated, For example, allowed routine maintenance might include seal/hinge lubrication performed as a standard practice to remove moisture from the hinges introduced during ice bed replenishment. Conversely, hinge/spring adjustments are not routine maintenance activities, and would'need to be evaluated to determine the cause of the condition/adjustment. After routine maintenance is performed, a "soak tim en is conservatively allotted before the surveillance tests are performed, to allow the LID to senle. Each plant (as appropriate) should evaluate the need to establish allowed maintenance practices and "soak times" prior to performing the as-left LID tests. Issue: Validity of LID 40° "Torgue Test" Methodology The primary focus of this issue centers on the function of the LIDs during the postulated Design Basis Accident. For all ice condenser plants, the Large Break LOCA (LBLOCA) is the bounding analysis. The only other licensing basis analysis is applicable only to Cook NP, which has unique containment design issues that have resulted in a sump inventory analysis (MAAP) that occurs in the SBLOCA event. ICUG notes that the LIDs are int!!Jlded (and analytically assumed) to open immediately and evenly upon initiation oft)1e Large , Break or Small Break LOCA, and then recover their position and modulate the longer-term flow of steam into the ice bed until the bed is depleted. This design function forms the basis for the current LID Opening Force Test and the LID Torque Test, and supports the LBLOCA analysis modeled by the TMDILOTIC codes as well as the SBLOCA MAAP code for the Cook NP sump inventory analysis. The Duke plants are currently licensed to a lMD/GOnnC code model which does allow cross-flow between elements and has a more detailed nodalization than the original Lonc work. Analysis runs using the GOTHIC code show that the LIDs do not need to open evenly or recover and modulate steam flow into the ice bed after the DBA has initiated. While not all ice condenser plants are licensed to this model, it supports the ICUG view that the current Ice CondeDser Door technical specification is conservative. In order to show the functional capability of the LIDs to modulate steam flow after the initiation of either the LBLOCA or SBLOCA, the surveillance test (the LID Torque Test) identifies limits for opening torque, closing torque, and frictional torque with the LID positioned at 40" open (this represents the free opening position of the doors before significant contact against the shock absorbers or foam bags). Generally, the 2002 ICUG Technical Conference -Page 10 opening and closing forces are determined by utilizing a hand-held or rig-mounted scale (spring or digital), and the forcesconverted (as appropriate) to torque at the hinges. Once the opening and closing values are determined by test, the frictional component is derived by taking the difference between them and dividing by 2. Since the LIDs were not originally design-tested empirically or analytically in this capacity, these numbers are representative of a new LID installed to applicable construction tolerances. By definition, deviation from these limits would constitute a degradation process warranting further evaluation. During the discussion of this, all plants reported limited situations (past and present) where the indicated opening force on the scale (that required to open the LID further from the 40' open position) actually measured less than the associated closing force (that required to hold the LID still at the 400 open position). While this situation did not cause any LID tests to exceed thespecified limits, it did raise the question of test methodology validity, a concern also raised by the resident inspectors. Several valid points were identified in response to this: I. The accuracy of the scale used in the LID 400 Torque Test can contribute to misleading indicated opening and closing forces. Both spring and digital scales are used by the industry for these tests.2. Measurement of the LID opening and closing forces for the surveillance are influenced by "dynamic effects," which are essentially a combination of factors such as "bouncing" (allowing the LID to hit the scale and rebound, even from a short distance) and air outrush during the tests (due to the existence of cold air static head in the ice condenser when the LID is opened).3. The derived frictional component of the LID 400 Torque Test, whether it is positive or negative, is a sufficient indicator of the LID's freedom to move (i.e., recover and modulate) after a postulated Large Break or Small Break LOCA scenario.Each plant should evaluate the need to address these factors in the LID Opening Torque Test and the LID 40' Torque Test surveillance procedures. Based on the technical information and operating experience shared by the utilities, ICUG feels that the current LID surveillance requirements continue to be adequate and conservative in determining the functional capability of the LIDs. ICUG consensus is that the generic Ice Condenser Door Technical Specification (STS version) is acceptable andconservative as currently written, and that revisions to it, as necessary, should be handled on a plant-specific basis.Issue: Trending LID Surveillance Test Failures for Maintenance Rule All plants indicated similar general scoping of ice condenser components into the Maintenance Rule (MR) program, but the industry differed on the definition of what actually constitutes a functional failure (FF) of the ice condenser. All agreed that individual component "failures" (such as a LID) did not necessarily indicate an I/C FF (particularly when MR scoping is based on safety function rather than an individual component basis), but that it needed linkage to analytical bases such as the TMD/LOTIC or TMD/GOTHIC models via a blockage limit (generally noted as 15% allowable blockage due to ice build-up). Some plants have clearly defined limits in this regard. Since this is a plant-specific determination, the industry agrees that different approaches to MR scoping will exist.Of more interest to the staff is the requirement to trend failures of high-risk, safety-significant components. As-found inspections of the LIDs provide the primary basis to identify and trend failures of the doors within the plant's Corrective Action Program. Itwas generally agreed that, even though during an outage the LIDs are not required to be operable, as-left LID surveillance test failures, if they occur, should be documented in a plant's Corrective Action Program, and that that would provide the required trending process to evaluate failures per Maintenance Rule. Each plant should evaluate the need to document LID surveillance test failures in their Corrective Action Programs.At this stage, Paul L. provided the group with video footage of actual LID 400 torque tests performed at Cook Plant The video depicted one test run the way Cook initially did it (prior to February 2002) using a test rig mounted to the portal frame, one test run the revised way (post-2/02) that provided for hand-held instrumentation, and then a demonstration of a newly-designed test rig ($I50K worth), developed with Framatome ANP, for testing the doors with a minimum of movement The Framatome rig, which Cook NP has not yet officially brought into action, attaches to a bolt head on the outside of the LID surface, and uses adigital scale for the hinge resistance. Motion in the LID during the torque test is kept at about 0.008", and experience with it shows that friction forces decreased significantly. Cook is still utilizing the air dams to prevent the dynamic effect of rushing air.2002 ICUG Technical Conference -Page 10 opening and closing forces are determined by utilizing a hand-held or rig-mounted scale (spring or digital), and the forces converted (as appropriate) to torque at the hinges. Once the opening and closing values are determined by test, the frictional component is derived by taking the difference between them and dividing by 2. Since the LIDs were not originally design-tested empirically or analytically in this capacity, these numbers are representative of a new LID installed to applicable construction tolerances. By definition; deviation from these limits would constitute a degradation process warranting further evaluation. During the discussion ofthis, all plants reported limited situations (past and present) where the indicated opening force on the scale (that required to open the LID further from the 40° open position) actually measured less than the associated closing force (that required to bold the LID still at the 40° open position). While this situation did not cause any LID tests to exceed the specified limits, it did raise the question of test 'methodology validity, a concern also raised by the resident inspectors. Several valid points were identified in response to this: I. The accuracy of the scale used in the LID 40° Torque Test can contribute to misleading indicated opening and closing forces. Both spring and digital scales are used by the industry for these tests. 2. Measurement of the LID opening and closing forces for the surveillance are influenced by "dynamic effects," which are essentially a combination of factors such as "bouncing" (allowing the LID to hit the scale and rebound, even from a short distance) and air outrush during the tests (due to the existence of cold air static head in the ice condenser when the LID is opened). 3. The derived frictional component of the LID 40° Torque Test, whether it is positive or negative, is a sufficient indicator of the LID's freedom to move (i.e., recover and modulate) after a postulated Large Break or Small Break LOCA scenario. Each plant should evaluate the need to address these factors 'in the LID Opening Torque Test and the LID 40° Torque Test surveillance procedures. Based on the technical information and operating experience shared by the utilities, ICUG feels that the current LID surveillance requirements continue to be adequate and conservative in determining the functional capability of the LIDs, ICUG consensus is that the generic Ice Condenser Door Technical Specification (STS version) is acceptable and conservative as currently written, and that revisions to it, as necessary, should be handled on a plant-specific basis. Issue: Trending LID Surveillance Test Failures for Maintenance Rule All plants indicated similar general scoping of ice condenser components into the Maintenance Rule (MR) program, but the industry differed on the definition of what actually constitutes a functional failure (FF) of the ice condenser. All agreed that individual component "failures" (such as a LID) did not necessarily indicate an IIC FF (particularly when MR scoping is based on safety function rather than an individual component basis), but that it needed linkage to analytical bases such as the TMDILOTIC or TMD/GOTHlC models via a blockage limit (generally noted as 15% allowable blockage due to ice build-up). Some plants have clearly defined limits in this regard. Since this is a plant-specific determination, the industry agrees that different approaches to MR scoping will exist. Of more interest to the staff is the requirement to trend failures of high-risk, safety-significant components. As-found inspections of the LIDs provide the primary basis to identifY and trend failures of the doors within the plant's Corrective Action Program. It was generally agreed that, even though during an outage the LIDs are not required to be operable, LID surveillance test failures, if they occur, should be documented in a plant's Corrective Action Program, and that that would provide the required trending process to evaluate failures per Maintenance Rule, Each plant should evaIuate the need to document LID surveillance test failures in their Corrective Action Programs. At this stage, Paul L, provided the group with video footage of LID 400 torque tests performed at Cook Plant. The video depicted one test IllJl the way Cook initially did it (prior to February 2002) using a test rig mounted to the portal frame, one test run the revised way (post-2102) that provided for hand-held instrumentation, and then a demonstration of a newly-designed test rig ($150K worth), developed with Framatorne ANP, for testing the doors with a minimum of movement. The Framatome rig. . which Cook NP has not yet officially brought into action, attaches to a bolt head on the outside of the LID surface, and uses a digital scale for the hinge resistance. Motion in the LID during the torque test is kept at about 0.008", and experience with it shows that friction forces decreased significantly. Cook is still utilizing the air dams to prevent the dynamic effect ofroshing air. I : I I I 'I 2002 ICUG Technical Conference -Page 10 opening and closing forces are determined by utilizing a hand-held or rig-mounted scale (spring or digital), and the forces converted (as appropriate) to torque at the hinges. Once the opening and closing values are determined by test, the frictional component is derived by taking the difference between them and dividing by 2. Since the LIDs were not originally design-tested empirically or analytically in this capacity, these numbers are representative of a new LID installed to applicable construction tolerances. By definition; deviation from these limits would constitute a degradation process warranting further evaluation. During the discussion ofthis, all plants reported limited situations (past and present) where the indicated opening force on the scale (that required to open the LID further from the 40° open position) actually measured less than the associated closing force (that required to bold the LID still at the 40° open position). While this situation did not cause any LID tests to exceed the specified limits, it did raise the question of test 'methodology validity, a concern also raised by the resident inspectors. Several valid points were identified in response to this: I. The accuracy of the scale used in the LID 40° Torque Test can contribute to misleading indicated opening and closing forces. Both spring and digital scales are used by the industry for these tests. 2. Measurement of the LID opening and closing forces for the surveillance are influenced by "dynamic effects," which are essentially a combination of factors such as "bouncing" (allowing the LID to hit the scale and rebound, even from a short distance) and air outrush during the tests (due to the existence of cold air static head in the ice condenser when the LID is opened). 3. The derived frictional component of the LID 40° Torque Test, whether it is positive or negative, is a sufficient indicator of the LID's freedom to move (i.e., recover and modulate) after a postulated Large Break or Small Break LOCA scenario. Each plant should evaluate the need to address these factors 'in the LID Opening Torque Test and the LID 40° Torque Test surveillance procedures. Based on the technical information and operating experience shared by the utilities, ICUG feels that the current LID surveillance requirements continue to be adequate and conservative in determining the functional capability of the LIDs, ICUG consensus is that the generic Ice Condenser Door Technical Specification (STS version) is acceptable and conservative as currently written, and that revisions to it, as necessary, should be handled on a plant-specific basis. Issue: Trending LID Surveillance Test Failures for Maintenance Rule All plants indicated similar general scoping of ice condenser components into the Maintenance Rule (MR) program, but the industry differed on the definition of what actually constitutes a functional failure (FF) of the ice condenser. All agreed that individual component "failures" (such as a LID) did not necessarily indicate an IIC FF (particularly when MR scoping is based on safety function rather than an individual component basis), but that it needed linkage to analytical bases such as the TMDILOTIC or TMD/GOTHlC models via a blockage limit (generally noted as 15% allowable blockage due to ice build-up). Some plants have clearly defined limits in this regard. Since this is a plant-specific determination, the industry agrees that different approaches to MR scoping will exist. Of more interest to the staff is the requirement to trend failures of high-risk, safety-significant components. As-found inspections of the LIDs provide the primary basis to identifY and trend failures of the doors within the plant's Corrective Action Program. It was generally agreed that, even though during an outage the LIDs are not required to be operable, LID surveillance test failures, if they occur, should be documented in a plant's Corrective Action Program, and that that would provide the required trending process to evaluate failures per Maintenance Rule, Each plant should evaIuate the need to document LID surveillance test failures in their Corrective Action Programs. At this stage, Paul L, provided the group with video footage of LID 400 torque tests performed at Cook Plant. The video depicted one test IllJl the way Cook initially did it (prior to February 2002) using a test rig mounted to the portal frame, one test run the revised way (post-2102) that provided for hand-held instrumentation, and then a demonstration of a newly-designed test rig ($150K worth), developed with Framatorne ANP, for testing the doors with a minimum of movement. The Framatome rig. . which Cook NP has not yet officially brought into action, attaches to a bolt head on the outside of the LID surface, and uses a digital scale for the hinge resistance. Motion in the LID during the torque test is kept at about 0.008", and experience with it shows that friction forces decreased significantly. Cook is still utilizing the air dams to prevent the dynamic effect ofroshing air. I : I I I 'I Enclosure 2 Request And Affidavit From WEC That Proprietary Information In Attadhment B of Enclosure 1 Be Withheld From Public Disclosure In Accordance With The Provisions of 10 CFR 2.390.Westnshhouse ElectuicCompany NudeV$rKSe~i V0P.O.Qb35S PitsbgPemnsylva'nia 15S230-0355 USA U.S. Nuclear Regullatoiy Comkmission Ofrect ml: (412) 374-63 DocunleAt Cont.7i Desk Ditct fa= (412) 314-3846 Washiogton, DC 205554001. -mail: grtshaja@wes1ivghotsc.com LTR-4C-D9-l5RS. 1m P-Anacbmcnt 0'wzct CAW-09-2643. Dalte August 14,-2M0 APPUCAnION FOR W.MHOLDINCI PRQPREARY ORMATON FROM POBUCf DMCLOSUR Subject "Sections of Appliable Text f, Lt.-MADA 106, Rev. 2" (proietary) The proprietary ifomnation, for which withholding is beingiequeed in the abov-refrenced report is f er identified in Affidavit CAW-09-2643 sign;d by t proprietary information, Westinghouse Electric CompanyM 'LWTe affidavitwhicli-accompanies this letter, sets forth the Isasis-pecificity theconsiderations listedn paragraph (bX4) ofl OCFR Sectin2.390 of the Commission's regulations. Accordingly, this letter authorizes the utilization of the accompanying affidavit by Duke Eergy.Correspondence with respec to the proprietary of the application for wittiding or the Westinghouse affidavit should refrenac'this letter, CAW-09-2643, and should be addressed to L. A. Gresham, Manager, Regplatory Compliance and Plant Licensing, Westinghouse Electric Company LLC, P.O. Box 35S,.Pittsbu-gh, pernrsylviama 15230-0355. -(NRC OWF.N2r-W) Thiokswes Enclosure 2 Request And Affidavit From WEe That Proprietary Information In Attachment B of Enclosure 1 Be Withheld From Public Disclosure In Accordance With The Provisions of 10 CFR 2.390. 1 r I J I u.s. RegUfatoty Commission Pocqll\ent Co-!lwl W<lShfugtQn, pC :4055>0001 WestiJlghouseElectric CoinPilIlY P:Q..11il1l3SS Pitt3burgh;Pennsylviini;J lS2JO.()355 lISA . inrca td: (412.) 374-4643 Oirecl fa: (412) 3074-<3846 c-mail;grcshaja@westitlgbolise.com Oou:"" CA W-Q9.2643 AUgust 14.:2009 APl>UCAtiONFOR WITHHOLDING PROPR,IEl"ARY INfORMATION FROM

Subject:

"Sedions(lf noll) L'tR-ruDA,.Q6..106, Rev.T' (proprietary) 

'flM: lntonnation for whicb withholding is the iibQvc-refeienced.report is further in Affidavit CAW-()9-264) prQprifllaJy infOlIlJatioo. WestingbouseElectric Company ILC. tbe,affitiavlt, Jetter, sets forth the bas!s onwhicbthe info.m¢ioo may withheJd ftom puislie diselosureby the with theconsidwations lisiedin pamgrnpb (b)(4) oflOCFR orUm Commi!!Sion's regulations. A(;COI"dingly, this letter allt!lorizes the oftbe awompanying affidavit by I>t)ke with to the proprieta:tjr aspect$ (If the applic.:3tioJl for WitlihOlding or the Westinghouse affidavit should referenCe*this letter. CA W-'C9-1643, and Should be addressed to 1. A.Gresham, Manager, Regplatoiy Compli3JIce and Piant Licensing, Westinghouse Electric LLC, P.O. Box 35$.Pittsburgb. 15230-0355. a:; 0. &cuta(NRC OWFN1J$.1) ; 1 1 I I I I* I Enclosure 2 Request And Affidavit From WEe That Proprietary Information In Attachment B of Enclosure 1 Be Withheld From Public Disclosure In Accordance With The Provisions of 10 CFR 2.390. 1 r I J I u.s. RegUfatoty Commission Pocqll\ent Co-!lwl W<lShfugtQn, pC :4055>0001 WestiJlghouseElectric CoinPilIlY P:Q..11il1l3SS Pitt3burgh;Pennsylviini;J lS2JO.()355 lISA . inrca td: (412.) 374-4643 Oirecl fa: (412) 3074-<3846 c-mail;grcshaja@westitlgbolise.com Oou:"" CA W-Q9.2643 AUgust 14.:2009 APl>UCAtiONFOR WITHHOLDING PROPR,IEl"ARY INfORMATION FROM

Subject:

"Sedions(lf noll) L'tR-ruDA,.Q6..106, Rev.T' (proprietary) 

'flM: lntonnation for whicb withholding is the iibQvc-refeienced.report is further in Affidavit CAW-()9-264) prQprifllaJy infOlIlJatioo. WestingbouseElectric Company ILC. tbe,affitiavlt, Jetter, sets forth the bas!s onwhicbthe info.m¢ioo may withheJd ftom puislie diselosureby the with theconsidwations lisiedin pamgrnpb (b)(4) oflOCFR orUm Commi!!Sion's regulations. A(;COI"dingly, this letter allt!lorizes the oftbe awompanying affidavit by I>t)ke with to the proprieta:tjr aspect$ (If the applic.:3tioJl for WitlihOlding or the Westinghouse affidavit should referenCe*this letter. CA W-'C9-1643, and Should be addressed to 1. A.Gresham, Manager, Regplatoiy Compli3JIce and Piant Licensing, Westinghouse Electric LLC, P.O. Box 35$.Pittsburgb. 15230-0355. a:; 0. &cuta(NRC OWFN1J$.1) ; 1 1 I I I I* I Enclosure 2 Request And Affidavit From WEC.That Proprietary Information In Attachment B of Enclosure 1 Be Withheld From Public Disclosure In Accordance With The Provisions of 10 CFR 2.390.CAW-09-2643 JAFFDAVIT -- OF PENNSYLVANMA: ss COUNTY OF ALOEWNY: Wore In, t ahe .u Id aufltiW, perstallyappeared A.C being by merduly swore A~COAingto bAw,.emses and says that he is authmoized to execute this Affidavit oni behalf of Westiuo1s tketrleCQo Pany LLC (Wuesiighous, and that the avcrments of fAct set forth = this Affdavit am tru ad convetto the best ofhis 4nowledge, infomatlon, and belief.SG-r-esham, Manager Regulatory Compliance and Plant Licensjug Sworn to and pbdbed before mn This 11h dfAy ogst2009"oýU tftzb -! .,..b_ _w TH Pdft Enclosure 2 Request And Affidavit FromWECThat Proprietary Information In Attachment B of Enclosure 1 Be Withheld From Public Disclosure In Accordance With The Provisions of 10 CFR 2.390. I I I ! ! CAW-Q9..2643 AFFIDAVIT COMMONWEAi1H OF PENNSnVANIA: ss B/lf())"e auth.orio/, I. A. GresIumJ,. who, being by me duly sworn says that be is authorized to el\(:I.mte this Affidavit 011 behalf of . WestinghoUse Compimy and Ibaltbe averments o'ffitct in Affidavit are ituc;i aDd the lie$lofbis!cnoWledge, informati!lf!.Ma Sworn .to This J41h day of Al!gUSt2009 Regulatory CompJiance and Plant

t. I ! I I Enclosure 2 Request And Affidavit FromWECThat Proprietary Information In Attachment B of Enclosure 1 Be Withheld From Public Disclosure In Accordance With The Provisions of 10 CFR 2.390. I I I ! ! CAW-Q9..2643 AFFIDAVIT COMMONWEAi1H OF PENNSnVANIA:

ss B/lf())"e auth.orio/, I. A. GresIumJ,. who, being by me duly sworn says that be is authorized to el\(:I.mte this Affidavit 011 behalf of . WestinghoUse Compimy and Ibaltbe averments o'ffitct in Affidavit are ituc;i aDd the lie$lofbis!cnoWledge, informati!lf!.Ma Sworn .to This J41h day of Al!gUSt2009 Regulatory CompJiance and Plant

t. I ! I I Enclosure 2 Request And Affidavit From WEC That Proprietary Information In Attachment B of Enclosure I Be Withheld From Public Disclosure in Accordance With The Provisions of 10 CFR 2.390.CAW-09-2643 (I) j am Manager, Regulatory Compliance and Plant Licensing, in Nuclear Sexvices, Wesinghos Electric Company LLC atiOnglo se), and as suck,! have been specifically delegated the function of reviewing-tho proprietary information sought to be withheld frompublic disclosure in connection with nuclear powenr plpt licensingand rulemaking proceedings, and am authorized to apply fo- as.

0on behalf 0twosnghouse. (2) l am makingthis Affidavit in conforac with the provisions of I CFR Section 2-390 of tie Commrission's regulations and j. mqonW with the Westinghouse -Application for* ! w oldine this Affdvit (3) I have-personal kltowledge-otfOn cReria and procedures utilized by Westinghouse in designating infornationas a .tado seorct, privileged, or as commenrcial or financial: information.(Pursuan to the provisions fpaAgraph (bX4) ofSection 2,390 of the Commission's regulations, the for consideration by the Commission in determining whether the iWformation soughtto be withheld tnm public distlos=x 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 .confidepte by Westinghouse and not customarilydiscdosed to the public. Westinghousechas a rational basis for detrining the.types of infomuation customarily held in confidence by it and, in that connection, utilizes a system to determine whenard wheter to hold cerain types of information in confidence. The application of that system and the substance of that system constitutes Westinghouge polmy and provides ftlrational~bAsis reNuited.Under that system, in Wo n is. held in:confidence ifit falls in one ormore of sevagai typ, the release of which might resnt- the oss of an &existingor potential compe6tive advantage, as follow=(a) no iWormat -veals the disteguishig aqmms of a process.(or Component, sbrctu, toolzt U ,&40) where peveafion of its use by any of Enclosure 2 Request And Affidavit From WEe That Proprietary Information In Attachment B of Enclosure 1 Be Withheld From Public Disclosure In Accordance With The Provisions of 10 CFR 2.390. I { I -, 3 CA W-09-2643 (I) J Am Manager, RegularoryComptill!ite aIirJ Pkint Licensing, in Nuclear Services. Electric Company al)(i as such, lhavel>een specifically the funciioo to be withheld from public disclosure in with nuelear plapt licensin)! lII!d ru!eJU:jking proceedings, and am authorized to apply for its.withbolc.ling on behalf (2) I am Affidavit in With the provisions ofIO:CFR Section 2.390 of the Commission's andln cQgjun<;Ijon with the Westinghouse

• for WItb/lOfdiDg" a<<ompanying this Affidavit (3) I cnteria and pt:oeeduresutmzed by Wesringhousein designating infoJtDliti,on.as il.#adc seoret. privileged, or as

'lOminercial odmandai information. , (4) :Ptusuant to the JlfO\'isiOns ofparagr.rph (bX4)ofSectioo 2J90 of tbe th.e ,(ODQWjDg fOr consideration i;>ytjJe Commission in determining whether the ibfOi'ination soughrtobe withheld m.m jlI!bIic di$l:I(ISJlre sbould be withheld_ (i) Thei!lformationsougbtto be withheld: frol!l public disclosure is owned and has been held incon/'idence by (iJ) The informatlQll is otatype customarily helll by Westinghouse and not customarily-disclosed III Westinghouse.has a rational basis for d¢tertniniIlg the.types ofinf'orlil;lqon held.in confidence it;md, in Ulat cormectioo, il system to determinewheo.aud whetbei" to bQl4 _of information in conficience. The oflhat Syst¢in ADd the substance of that s.Y$tem cQostitul!:S types. of which DJight rcsu1tin tbeJQSS of all (l( potentWt:ompetitiv.c: 3$ fol)Qws::

strucIlm; ofbs useby any of Enclosure 2 Request And Affidavit From WEe That Proprietary Information In Attachment B of Enclosure 1 Be Withheld From Public Disclosure In Accordance With The Provisions of 10 CFR 2.390. I { I -, 3 CA W-09-2643 (I) J Am Manager, RegularoryComptill!ite aIirJ Pkint Licensing, in Nuclear Services.

Electric Company al)(i as such, lhavel>een specifically the funciioo to be withheld from public disclosure in with nuelear plapt licensin)! lII!d ru!eJU:jking proceedings, and am authorized to apply for its.withbolc.ling on behalf (2) I am Affidavit in With the provisions ofIO:CFR Section 2.390 of the Commission's andln cQgjun<;Ijon with the Westinghouse

• for WItb/lOfdiDg" a<<ompanying this Affidavit (3) I cnteria and pt:oeeduresutmzed by Wesringhousein designating infoJtDliti,on.as il.#adc seoret. privileged, or as

'lOminercial odmandai information. , (4) :Ptusuant to the JlfO\'isiOns ofparagr.rph (bX4)ofSectioo 2J90 of tbe th.e ,(ODQWjDg fOr consideration i;>ytjJe Commission in determining whether the ibfOi'ination soughrtobe withheld m.m jlI!bIic di$l:I(ISJlre sbould be withheld_ (i) Thei!lformationsougbtto be withheld: frol!l public disclosure is owned and has been held incon/'idence by (iJ) The informatlQll is otatype customarily helll by Westinghouse and not customarily-disclosed III Westinghouse.has a rational basis for d¢tertniniIlg the.types ofinf'orlil;lqon held.in confidence it;md, in Ulat cormectioo, il system to determinewheo.aud whetbei" to bQl4 _of information in conficience. The oflhat Syst¢in ADd the substance of that s.Y$tem cQostitul!:S types. of which DJight rcsu1tin tbeJQSS of all (l( potentWt:ompetitiv.c: 3$ fol)Qws::

strucIlm; ofbs useby any of Enclosure 2 Request And Affidavit From WEC That Proprietary Information In Attachment B of Enclosure 1 Be Withheld From Public Disclosure In Accordance With The Provisions of 10 CFR 2.390.4 CAW-09-2643 Wemghýous competitors wtout lis from Westinghouse constitutes a competitive onorm advantage overotbe companies.(b) It consists of supPOrting data, including test daUa relative to a process (or component, tool, method, eta), the application of which data secures a competitive economic advantage, e.g, by optimization or improved I marketability.

.(c) _ Its use by acompetitor would reduciWs .ependteofresourcs improve s competilive. tion in the design m=fcture, shipment; installation, assurance of quait, or licensing a similarproduct (d) It reveals cost or-pice capacities, budget levels, or cOt~rwerciAl srategies of Westinghouse, its a omers ar suppjlier.(e) It reveals asptas ofpA* prCid, Wor-fiture WeStnghoUs or Customer funded development plans and programs ofpotential commercial value to Westinghouse: (f) It contains patentable ideas, for which patentprotction may be desirable. There are sound policy reasons behind the Wstix)ghousc system which include-the following: (a) The use of such information bY'Westi"ghusO gives a competitive advantagV over its co e jilerefore, withheld from disclosure to protect th Westinghouse ceenpetitiveýpMVitic.(b) It is -informafl-dtigi is marketabl& n many ways. The extent to which such i"f.onatiQn is aVailable to competitors diminishes the Westinghouse ability to sell product and =eivices involvin9g*6sof the hfomation. () Use by our competitor woul put Westinghouse at a competifi~v disovanag by reducingithis caenditar; offtwworce atpnexpens.. Enclosure 2 Request And Affidavit From WEC That Proprietary Information In Attachment B of Enclosure 1 Be Withheld From Public Disclosure In Accordance With The Provisions of 10 CFR 2.390. 4 CAW..@*2643 Westinghouse'$ COJJ.ipetitcml Witl).out from Westinghouse constitutes a oompeiitive adv:antage overo1her companies.. (b) It consists of data. tt$.data. rellitive to a proce$$ (or tool, method,ete.), the applie;ltion of which dafa secures a *competitiVl: .economic advantage, by llptimizalion or improved rnarlcetabiJity

• (c) __ Its use by acompetitorwouJdredllCetiisfllqlelldituteofi'eSoJlrCeS orilnproVl:

his in shipment; installation. assurtInce of quality. or li<:AAsiDg a similarproduct. (a) It reveals cost orpric;e. ilifotm<ltion. capacities, budget: levels, or COlnmerc:i1ll of Westinghouse,. itscustomets Or SUWlif!i'll.. (e) Westingbouse or customer funded pr.ms and programs of potential commercial 'Value to Westinghouse,. (f) It contains patentable [4c;as, for whicb palenlprotc;ction may be desirable. There are so\llld policy reasons bebind the sySteiD which include-the following: -** -............. _---'. . _._---_ ..... -.-***.. -.;,-.-; *.

• • • ---***. **

--** _._-_ *** -.<-** _-*** -(a) Tbeuse of acompel:itive _ over its!;OiI;Ipetito,I:s. Ii 1herefore. withheJd from disclosure to Wti$tingbopse (b) Itisinfuro'lationth:it is marlcetable"in mauyways. to which such isavail3ble ability to products and sesvice,o; lnv()\vin$1be'llSe cif I¢t'IUiIation. (c) Vse by our toJnpetitor wOuld put JJy redncing-hjs qftt:sowceS 4ItpUtexpeoSe... I-I I Enclosure 2 Request And Affidavit From WEC That Proprietary Information In Attachment B of Enclosure 1 Be Withheld From Public Disclosure In Accordance With The Provisions of 10 CFR 2.390. 4 CAW..@*2643 Westinghouse'$ COJJ.ipetitcml Witl).out from Westinghouse constitutes a oompeiitive adv:antage overo1her companies.. (b) It consists of data. tt$.data. rellitive to a proce$$ (or tool, method,ete.), the applie;ltion of which dafa secures a *competitiVl: .economic advantage, by llptimizalion or improved rnarlcetabiJity

• (c) __ Its use by acompetitorwouJdredllCetiisfllqlelldituteofi'eSoJlrCeS orilnproVl:

his in shipment; installation. assurtInce of quality. or li<:AAsiDg a similarproduct. (a) It reveals cost orpric;e. ilifotm<ltion. capacities, budget: levels, or COlnmerc:i1ll of Westinghouse,. itscustomets Or SUWlif!i'll.. (e) Westingbouse or customer funded pr.ms and programs of potential commercial 'Value to Westinghouse,. (f) It contains patentable [4c;as, for whicb palenlprotc;ction may be desirable. There are so\llld policy reasons bebind the sySteiD which include-the following: -** -............. _---'. . _._---_ ..... -.-***.. -.;,-.-; *.

• • • ---***. **

--** _._-_ *** -.<-** _-*** -(a) Tbeuse of acompel:itive _ over its!;OiI;Ipetito,I:s. Ii 1herefore. withheJd from disclosure to Wti$tingbopse (b) Itisinfuro'lationth:it is marlcetable"in mauyways. to which such isavail3ble ability to products and sesvice,o; lnv()\vin$1be'llSe cif I¢t'IUiIation. (c) Vse by our toJnpetitor wOuld put JJy redncing-hjs qftt:sowceS 4ItpUtexpeoSe... I-I I Enclosure 2 RegIquest And Affidavit From WEC That Proprietary Information In Attachment B of Enclosure 1 Be Withheld From Public Disclosure In Accordance With The Provisions of 10 CFR 2.390.CAW-09-2643 (d) Each component of pprietay information peinent to a p copt itive advantage is potentially as valuable as the total competitive adyantage-if competitors acqui components of proMietary ifrmatiod, any ot, cOmponent may be the key to the. entir puzi thereby depriving Westinghouse of a competitiva advantage.(e) Unri-,,ted disclosure would jeopardFze the position of p mn of Westinghou-in the worldmarfet, and thareby give a market advantage to tei-competition of thio.Ae countrWs (f) The Westinghose capacity tovt dtAiprte assets in research and"development depes up the s in obtaining and maietkirin$ga 1 compet.itive advantage. .(iii) The information is being-ttasxead to-ffwcCormmiss~ion in confideneatd., tmdd pMroI .oW of 10CFR Section 2390, it is to be received in onfidence by~tlh Commission. Qv) The information sought to be protected is-not available in public sources or ayailble infmomation has not been peviously employed in the same original manner or method to the best ofour knowledge and belieL (v) The proprietary infowntOn sought to be withheld in this submittal is that which is appropriately markY. in of Applicable Textfrom LTh-RIMDA6-06., 1Ry. 2-(proprietaxy) for submittal to tbo-Comnission, being troumitted by the Thike EheWn lottarmA tApplication for Withholding hrxietry Information from Publi DiselosaM tofthe Do= tCotrO Desk- TIe proprietary information as submitted by WestnghOse for Catawba Units I and 2 and MeGite Unift I amd 2 is:thatas .iatd wlthktstingof the lee Condenser tower inlet door flueimon.This WMAfornaio is Part Ofthat which will enable Weatigbmos to.(a) Spportlher-tllietieefflottin d*rmainiug the need frva~ioosiecon=dene wd Enclosure 2 Request And Affidavit From WEC That Proprietary Information In Attachment B of Enclosure 1 Be Withheld From Public Disclosure In Accordance With The Provisions of 10 CFR 2.390. 5 CAW-OO-2643 (d) Each comJK!llen! ofpropriet:uy information peIDl\Cllt to a advantage is potentially as as .the total If competitors infonnatioD,any may be key tp the. entm:*puzzle, thereby depriving ota competitive. advantage. (I) would jeopar4iZetheposition of prominence of Westingbousein the \\IOrldini!i'k!lt. lI)ld then:bygive a marlcetadvantageto the oftho$e. counlJies. (f) The to*iJ)vesJ in research and i -developi¢nt upon the sm:cess in and¢ainti\i1lil)g a i cOO!petitNe advantage. (iii) The information iii tofue-Commission in un4<<thc; lOCFR 8J:ction 2390, itis to be received in ComQ1ISlii9D. (iv) The SQ!lgbt to be protected is_not available in public sc;>uroes Of' ayaililble jnfonnationhas not been preYiously employed in the same original manner or method to the best of om-kr\owledge and _beHet (v) The sought to be withheld .01 t1Us submittal is that which is -. -------._-.- Textftom R.iW. 2'" - for to tbe:CommJssiOll, b¢ing by the Dpke Energy Application fur Proprietary In(QiJnation n:om Public DiseJosnJe, to the DocIJme:otCOiltrol Desk. proprietary information as subJ1ritted by forO!tawbaUnits) 1 w.ith:b:stingofthe roe lowet inlet function. . (a) I I I Enclosure 2 Request And Affidavit From WEC That Proprietary Information In Attachment B of Enclosure 1 Be Withheld From Public Disclosure In Accordance With The Provisions of 10 CFR 2.390. 5 CAW-OO-2643 (d) Each comJK!llen! ofpropriet:uy information peIDl\Cllt to a advantage is potentially as as .the total If competitors infonnatioD,any may be key tp the. entm:*puzzle, thereby depriving ota competitive. advantage. (I) would jeopar4iZetheposition of prominence of Westingbousein the \\IOrldini!i'k!lt. lI)ld then:bygive a marlcetadvantageto the oftho$e. counlJies. (f) The to*iJ)vesJ in research and i -developi¢nt upon the sm:cess in and¢ainti\i1lil)g a i cOO!petitNe advantage. (iii) The information iii tofue-Commission in un4<<thc; lOCFR 8J:ction 2390, itis to be received in ComQ1ISlii9D. (iv) The SQ!lgbt to be protected is_not available in public sc;>uroes Of' ayaililble jnfonnationhas not been preYiously employed in the same original manner or method to the best of om-kr\owledge and _beHet (v) The sought to be withheld .01 t1Us submittal is that which is -. -------._-.- Textftom R.iW. 2'" - for to tbe:CommJssiOll, b¢ing by the Dpke Energy Application fur Proprietary In(QiJnation n:om Public DiseJosnJe, to the DocIJme:otCOiltrol Desk. proprietary information as subJ1ritted by forO!tawbaUnits) 1 w.ith:b:stingofthe roe lowet inlet function. . (a) I I I Enclosure 2 Request And Affidavit From WEC That Proprietary Information In Attachment B of Enclosure 1 Be Withheld From Public Disclosure In Accordance With The Provisions of 10 CFR 2-390.f6 CAW-09-2643 Further this information has substantial commercial value as follows: ,(a) Westinghouse plans to sell the use of tde information to its customers for the purpose of futnre manucturing, repairs, and testing of-the ice condenser lower inet dos.() sell.suppor.and defens .of information re~garing future manuificturing,:rpaeims and testing of the ice codne lowertn:e door&0) iliformatiop requested to be withheld reveals the distinguishing aspects of a methodoloagy Webd was deveioped'by Westinghouse.P u l i d s l o u r f h i p o p r ie ta y fo is e l}'nbic di~omre fthiSpmpL in. hfonatiom .s filly to cause subsbtania harm to the c.gapeftitipositicn offWtstinghouse because it would eWnthealflityof.ospeitoxs to provide similar details regarding the Iower inilet door-t ing and manufacturingand censing defense srvices for conmeial power reactors without commensurate expenses. Also, public disclosure of the information would enable others to use the information to meet NRC rqurementsfor licensing documentation without purchasing the right to use the information. The development of tie 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 ofmoney.In order forcogpetitws:of Westinghouse toduplicate this infornmaion, similar technical prognaqs would have to be performed and. a significantmanpowgr effort, having the requisite aentand experience, vwould have to.be expended Further the dponent sayeth not Enclosure 2 Request And Affidavit From WEe That Proprietary Information In Attachment B of Enclosure 1 Be Withheld From Public Disclosure In Accordance With The Provisions of 10 CFR 2.390. I 6 CA W*09-2643 Further this information has substllDtial c;munerciaJ /IS follows: (a) Westi!lgbouse plans to sen the use. of tI!e infonJl;ltioo to i:tS for the purpose and _g of -the ice coodenset: lower (b) future Dlanilfiicturing, ,repairs, and testing of the ice condenser 'inlet d<iQJ:l!o

(c) The infOflJ'lation to be withheld reve.l\ls the distinguishing aspects ofa

\VJiicb Was developed 'by Westi!lghouse. Pubiicdiselosure ofihis,proprietarymfonnauQJI is likelY to cause substantial h3nn to iha . ofWi$nghol,lSe because it would enhan<:ethea!)j1ityQf . to provide simi1a1-details r.egardingihe l¢wer ;ii!tlIi door't!:Sting and manufactutingand licensing defense for reactorsWiihout .expenseS. Also, public disclosure oftheinfonnation woUld Qthc;rs 10 U$C the infotIDaUon to meet NRC requirements'for lice!lsi!1g docurn-mtation without purchasing the right to Use the informatioJJ. T/Itl development af tire recbnology described in. part by the infOmlatiQJI is the result of applying the results of many years of in an intensive Westinghouse effort and *** ______ '*_.", ** _ ..... .' *.* .. _. ___ ........ the expenllltiut of a Considerable sum of money. 10 onki fon:ompeti'tmf;lfWestingboll$e tll-duplicate this infomtation, similartec1uUcal havetQ be performed and.a effint, haVing tI!e W(lU!dbav.e to.be i I . ! I : ' Enclosure 2 Request And Affidavit From WEe That Proprietary Information In Attachment B of Enclosure 1 Be Withheld From Public Disclosure In Accordance With The Provisions of 10 CFR 2.390. I 6 CA W*09-2643 Further this information has substllDtial c;munerciaJ /IS follows: (a) Westi!lgbouse plans to sen the use. of tI!e infonJl;ltioo to i:tS for the purpose and _g of -the ice coodenset: lower (b) future Dlanilfiicturing, ,repairs, and testing of the ice condenser 'inlet d<iQJ:l!o

(c) The infOflJ'lation to be withheld reve.l\ls the distinguishing aspects ofa

\VJiicb Was developed 'by Westi!lghouse. Pubiicdiselosure ofihis,proprietarymfonnauQJI is likelY to cause substantial h3nn to iha . ofWi$nghol,lSe because it would enhan<:ethea!)j1ityQf . to provide simi1a1-details r.egardingihe l¢wer ;ii!tlIi door't!:Sting and manufactutingand licensing defense for reactorsWiihout .expenseS. Also, public disclosure oftheinfonnation woUld Qthc;rs 10 U$C the infotIDaUon to meet NRC requirements'for lice!lsi!1g docurn-mtation without purchasing the right to Use the informatioJJ. T/Itl development af tire recbnology described in. part by the infOmlatiQJI is the result of applying the results of many years of in an intensive Westinghouse effort and *** ______ '*_.", ** _ ..... .' *.* .. _. ___ ........ the expenllltiut of a Considerable sum of money. 10 onki fon:ompeti'tmf;lfWestingboll$e tll-duplicate this infomtation, similartec1uUcal havetQ be performed and.a effint, haVing tI!e W(lU!dbav.e to.be i I . ! I : ' Enclosure 2 Request And Affidavit From WEC That Proprietary Information In Attachment B of.Enclosure I Be Withheld From Public Disclosure In Accordance With The Provisions of 10 CFR 2.390.PROPZRUTARY INFORWMAION NOTICE Transnitted herewith are proprietary andlor nion-prOprietary versions otdocuments firnished to the NRC in connection with requests for generi and/or plant-specific review and approval.In order to conform to the1ireatniimentsof 10 CFR 2-39a of the Commission's regultions concering the protectio'n of p~roietory infonation so submitted to the MRC, the, information wjhic:h is proorietary in the propietauy virsions is contained within.brack, where the proprietary nformation has been deleted in tdi non-proprietary versions, onlythe brackets reMairi (.th information that was contained within the brackets in the proprietary'V41 yesi flb u Wne delete4 ibejustifleationi for claiming the iloraib tine so designated as prpprietaty is indicated in both versions by means of lower aWse Wie (a) through:() lated as a spodp immediately following the bra-,kta tnvlosing a4h item of infonnation being identified as proprietary or in the mari opposite sadh in/fonation. These lower case letters refer to the typesof infomnation Westingh ousstomarily holds in confidence identified in Sections (4)Xiia)thnough theaffidavit*ct npanying thistnsmittal pmsuant to 10 CFR 2390(bXl)." CO.PYRIGHr NOTICE-herePorts transmitte hedrewith each beara 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 rviews and approvals as well as the issuance, denial, amendment, transfer, renewal; odifiation, suspension, revocation, or violation of a license, permit, order, or regulation subject tbthe rquhnents of :10 CFR 2390 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 vetsions of these reportsý, the NRC is permitted to make the number of copies beyond those necessary for its internal. use whibbh are:necessary in order to have one copy available for public viewing in the appropriate docket files in the public document..oan in-WashingtomnDC and in meal publi document rooms as may be required b.y NRC reglatiosif the number of is insuffic t for this purpose. ýCopies made by the .NRC must include the copyright notice in all instanes and thmproprietary 4otice if the original was ideWti as proprietary. i Enclosure 2 Request And Affidavit From WEC That Proprietary Information In Attachment B of . Enclosure 1 Be Withheld From Public Disclosure In Accordance With The Provisions of 10 CFR 2.390. PROPlUl:TARY lNFORMATIQN NOTICE are proprielaJy and/or norrpropriei<lJy of documents furnished to the NRC in connection with I'!lquests for.generic and/or review and approval. In order to confonn CFR 2390 of the cOncerning protection Qf piIlprietlUY SO submilted to the .. tbe 1I!'()Qnaticln Whl¢b. is prQprietary in the ptQPtietaiy vezsiQilS is contained the inf'orrnafiODhas been deleted iii the nOD-propOetaJy versions. QD)ythe !!ra(:k$ (theinfonnation that wasconbiined withir! the bnckets in the ymionS delefed). Thejustification fur't;laiming the so designated 11$ is iildicated in both versions by dfloWer C3$e (a) through{£) located i!S a Ibe enclOsing tal;h being ideDMJed pfoprietary or in the sIJCll infcmiliItiQD. These iower caselettas refer to the t}'peS-ofinfonnati'on boids jn confidenceidentifled in Secti9ns(4)@(a) IOCFR,239O(\:J)(l),* . . CO.PYRIqur NonCE transmitted bea.ra Westinghouse copyrigbt notice. The NRC is peIDlitt!=d to maketheclllllllber of COpies afthe informatioo contained'in these reports Which are necessary for its internal use in ooooection wUhgenene:and pJant-sptei.6c ltv.ieWs and approvals as well as the issuance., denial, amendment, tmnsfer, rene.wal, revocation, or violation of a license, Pennit, .order, Olregulation subject lPibeieqwrements oflO CFR 2.390 regarding.restri.ctions on public disclosure tQ the flXtei.lt s1.icbild:ormatlolrbas Iieen identified as by Westinghouse, CQJ>Yright proteetiP!lnotwitbs,tanding. With respect futhellOtl-p1opiietary vetsions of ihese reports, the NRC is pennitted fu make the number oftopiesbeyoJld diose for its inJemal use whiCh arenecessmy in -*order to have one copy Wbli!< vit!wmg in the appropriate docket files in ihe plIbljc _____ . __ the numb¢cof tQpies,$iibmitted is insufficient for this plIIJlql;e. 'CoPIes ml;ldeby Ih¢ NRC mctUde . copyrighJuotlce in instanc:esand wasidenlified asproprietary. l I I ! :1 I Enclosure 2 Request And Affidavit From WEC That Proprietary Information In Attachment B of . Enclosure 1 Be Withheld From Public Disclosure In Accordance With The Provisions of 10 CFR 2.390. PROPlUl:TARY lNFORMATIQN NOTICE are proprielaJy and/or norrpropriei<lJy of documents furnished to the NRC in connection with I'!lquests for.generic and/or review and approval. In order to confonn CFR 2390 of the cOncerning protection Qf piIlprietlUY SO submilted to the .. tbe 1I!'()Qnaticln Whl¢b. is prQprietary in the ptQPtietaiy vezsiQilS is contained the inf'orrnafiODhas been deleted iii the nOD-propOetaJy versions. QD)ythe !!ra(:k$ (theinfonnation that wasconbiined withir! the bnckets in the ymionS delefed). Thejustification fur't;laiming the so designated 11$ is iildicated in both versions by dfloWer C3$e (a) through{£) located i!S a Ibe enclOsing tal;h being ideDMJed pfoprietary or in the sIJCll infcmiliItiQD. These iower caselettas refer to the t}'peS-ofinfonnati'on boids jn confidenceidentifled in Secti9ns(4)@(a) IOCFR,239O(\:J)(l),* . . CO.PYRIqur NonCE transmitted bea.ra Westinghouse copyrigbt notice. The NRC is peIDlitt!=d to maketheclllllllber of COpies afthe informatioo contained'in these reports Which are necessary for its internal use in ooooection wUhgenene:and pJant-sptei.6c ltv.ieWs and approvals as well as the issuance., denial, amendment, tmnsfer, rene.wal, revocation, or violation of a license, Pennit, .order, Olregulation subject lPibeieqwrements oflO CFR 2.390 regarding.restri.ctions on public disclosure tQ the flXtei.lt s1.icbild:ormatlolrbas Iieen identified as by Westinghouse, CQJ>Yright proteetiP!lnotwitbs,tanding. With respect futhellOtl-p1opiietary vetsions of ihese reports, the NRC is pennitted fu make the number oftopiesbeyoJld diose for its inJemal use whiCh arenecessmy in -*order to have one copy Wbli!< vit!wmg in the appropriate docket files in ihe plIbljc _____ . __ the numb¢cof tQpies,$iibmitted is insufficient for this plIIJlql;e. 'CoPIes ml;ldeby Ih¢ NRC mctUde . copyrighJuotlce in instanc:esand wasidenlified asproprietary. l I I ! :1 I Enclosure 3 Non-Proprietary Version of Attachment B in Enclosure 1 Westinghouse Proprietary Class 2 Page 1 of 2 Section of Applicable Text from LTR-RIDA-06-106 Rev. 2 Scope and Clarifications Number 8: A conclusion regarding the existence of an "analytical connection between the Tech Spec SR values and the safety analysis 1 1', and the resultant implications if the closing torque exceeds the opening torque," will be provided. I A measured closing torque that is [ ja than the opening torque is not a concern since this condition is caused by the springs' mechanical behavior []', which affects the door over a limited range as it approaches the open position. Since the closing, force being [greater]a than the opening force is also the source of the calculated [ )', it can be concluded that the []a is not indicative of problems with the hinges. The current surveillance test data provided by Duke Energy indicate that the [ ]a limit is considered to be met for the lower inlet doors, [[ ]C is an issue that could challenge containment integrity if not limited. If excessive steam locally enters a section of the ice condenser that section could melt out well before the overall ice bed proper-With that section melted out, the steam entering that section could then bypass the ice condenser (chimney effect) and flow directly to the upper compartment. If the upper containment heat sinks and containment sprays are not sufficient tolimit the pressurization due to this increased steam (plus any other steam resulting from bypass through the operating deck) then the containment design pressure could be exceeded. There was no explicit analytical connection between the Technical Specification Surveillance Requirement limits and the safety analysis []a identified. The only statement that was identified was contained in []a No [ were conducted relative to the [ ]a of the lower inlet door characteristics. However, based upon a review of []a for a similar design, the ice condenser design can tolerate [For example, if the [ ] have somewhat [I' and would therefore open and close with [ r resistance than the other [ -jthen substantial margin between [] was still observed. [ ]" was observed in these sensitivity This document is the property of and contains Proprietary Information owned by Westinghouse Electric Company LLC and/or its subcontractors and suppliers It is transmitted to you in confidence and trust, and you agree to treat this document in strict accordance with the terms and conditions of the agreement under which it was provided to you..Q 2009 Westinghouse Electric Company LLC All Rights Reserved Enclosure 3 Non-Proprietary Version of .Attachment B in Enclosure 1 Westinghouse Proprietary Class 2 Page 1 of2 Section of Applicable Text from LTR-RIDA-06-106 Rev. 2 Scope and Clarifications Number 8: A *conclusion regarding the existence of an "analytical connection between the Tech Spec SR values and the safety analysis ( t, and the resultant implications if the closing torque exceeds the opening torque," will be provided. ( ]" A measured closing torque that is [ r than the opening torque is not a concern since this condition is caused by the springs' mechanical behavior [ la, which affects the door over a limited range as it approaches the open position. Since the closing. force being [greater r than the opening force is also the source of the calculated [ ]a, it can be concluded that the [ t is not indicative of problems with the hinges. The current survei1lance test data provided by Duke Energy indicate that the [ . Ja limit is considered to be met for the lower inlet doors, [ t* [ t is an issue that could challenge containment integrity if not limited. If excessive steam locally enters a section of the ice condenser that section could melt out well before the overall ice bed proper. With that section melted out, the steam entering that section could then bypass the ice condenser (chimney effect) and flow directly to the upper compartment. If the upper containment heat sinks and containment sprays are not sufficient to limit the pressurization due to this increased steam (plus any other steam resulting from bypass through the operating deck) then the containment design pressure could be exceeded. There was no explicit analytical connection between the Technical Specification Surveillance Requirement limits and the safety analysis [ t identified. The only statement that was identified was contained in [ No [ ]C were conducted relative to the [ t of the lower inlet door characteristics. However, based upon a review of [ ]a for a similar design, the ice condenser design can tolerate [ Y For example, if the [ r have somewhat [ ]3 and would therefore open and close with [ r resistance than other [ substantial margin between [ observed. [ lathen ]3 was stilJ ]3 was observed in these sensitivity This document is the property of and contains Proprietary Information owned by Westinghouse Electric Company LlC and/or its subcontractors and suppliers. It is transmitted to you in confidence and trust, and you agree to treat this document in strict accordance with the terms and conditions of tile agreement under which it was provided to you .. @ 2009 Westinghouse 8ectric Company LLC All Rights Reserved i I I , .1 I I I I I* I I i ! I I ! I I I ! Enclosure 3 Non-Proprietary Version of .Attachment B in Enclosure 1 Westinghouse Proprietary Class 2 Page 1 of2 Section of Applicable Text from LTR-RIDA-06-106 Rev. 2 Scope and Clarifications Number 8: A *conclusion regarding the existence of an "analytical connection between the Tech Spec SR values and the safety analysis ( t, and the resultant implications if the closing torque exceeds the opening torque," will be provided. ( ]" A measured closing torque that is [ r than the opening torque is not a concern since this condition is caused by the springs' mechanical behavior [ la, which affects the door over a limited range as it approaches the open position. Since the closing. force being [greater r than the opening force is also the source of the calculated [ ]a, it can be concluded that the [ t is not indicative of problems with the hinges. The current survei1lance test data provided by Duke Energy indicate that the [ . Ja limit is considered to be met for the lower inlet doors, [ t* [ t is an issue that could challenge containment integrity if not limited. If excessive steam locally enters a section of the ice condenser that section could melt out well before the overall ice bed proper. With that section melted out, the steam entering that section could then bypass the ice condenser (chimney effect) and flow directly to the upper compartment. If the upper containment heat sinks and containment sprays are not sufficient to limit the pressurization due to this increased steam (plus any other steam resulting from bypass through the operating deck) then the containment design pressure could be exceeded. There was no explicit analytical connection between the Technical Specification Surveillance Requirement limits and the safety analysis [ t identified. The only statement that was identified was contained in [ No [ ]C were conducted relative to the [ t of the lower inlet door characteristics. However, based upon a review of [ ]a for a similar design, the ice condenser design can tolerate [ Y For example, if the [ r have somewhat [ ]3 and would therefore open and close with [ r resistance than other [ substantial margin between [ observed. [ lathen ]3 was stilJ ]3 was observed in these sensitivity This document is the property of and contains Proprietary Information owned by Westinghouse Electric Company LlC and/or its subcontractors and suppliers. It is transmitted to you in confidence and trust, and you agree to treat this document in strict accordance with the terms and conditions of tile agreement under which it was provided to you .. @ 2009 Westinghouse 8ectric Company LLC All Rights Reserved i I I , .1 I I I I I* I I i ! I I ! I I I ! Enclosure 3 Non-Proprietary Version of Attachment B in Enclosure 1 Westinghouse Proprietary Class 2 Page 2 of 2 studies. Additionally if the []a of allowable deck leakage was determined to be acceptable. For these latter cases, the integrated maldistribution based upon [ )f was greater than []a. Therefore; based upon this generic work, the [la criterion is an acceptable upper limit that ensures that the calculated containment pressure for [ ]a breaks, when the lower inlet doors are in the flow proportioning range, will remain below the containment design pressure for allowable deck leakage areas greater than the design value []a The information presented [ ] that for door frictional torques in the range of[ 1 a, the pressures required to open and close the doors are consistent with the characteristic curve used in the deck bypass sensitivities. Furthermore, based upon []a provided by Duke Energy determined that the surveillance test data fall within the range of the analytical data used for the Catawba and McGuire UFSAR analyses and the generic sensitivities. Therefore it is judged that the [Of note, the basis for value range of []a is to ensure that []a the sensitivity studies described above. [ ]a torque]a is considered acceptable as long as []a Another qualitative assurance of compliance with the maldistribution requirement can be taken from [ ]a For [ ]a differential pressure, [ ]a Stated another way,]2. Friction of this magnitude is considered [,a The exact friction values needed to []a This documentis the property of and contains Proprietary Information owned by Westinghouse Electric Company LLC and/or its subcDntractors and suppliers. Als transmited to you in confidence and trust and you agree to treat this document in strict accordance witbft terms and conditions of the agreement under wlnd, it was provided to you.© 2009 Westinghouse Electric Company LLC All Rights Reserved Enclosure 3 Non-Proprietary Version of Attachment B in Enclosure 1 Westinghouse Proprietary Class 2 Page 2 of2 studies. Additionally if the [ r of allowable deck leakage was determined to be acceptable. For these latter cases, the integrated maldistribution based upon [ )t was greater than [ t. Therefore; based upon this generic work, the [ t criterion is an acceptable upper limit that ensures that the calculated containment pressure for [ ]3 breaks, when the lower inlet doors are in the flow proportioning range, will remain below the containment design pressure for allowable deck leakage areas greater than the design value [ t The information presented [ r that for door frictional torques in the range off t, the pressures required to open and close the doors are consistent with the characteristic curve used in the deck bypass sensitivities. Furthermore, based upon [ }3 provided by Duke Energy determined that the surveillance test data fall within the range of the analytical data used for the Catawba and McGuire UFSAR analyses °and the generic sensitivities. Therefore it is judged that the [ Of note, the basis for [ t is to ensure that [ t the sensitivity studies described above. [ t torque value range of [ )3 is considered acceptable as long as [ Another qualitative assurance of compliance with the maJdistribution requirement can be taken from [ t For [ 1 a differential pressure, [ t Stated another way, [ t. Friction of this magnitude is considered [ t The exact friction values needed to [ This document is the property of and contains Proprietary Infonnation owned by Westinghouse EIecIIic Company LLC andIor its subcontractors and suppliers. It Is transmil!ed to you in confidence and trust. and you agree to treat this document in strict accordance with the terms and conditions of the agreement under which it was provided to you. @ 2009 Westinghouse EIecbic Company LLC All Rights Reserved f of i Enclosure 3 Non-Proprietary Version of Attachment B in Enclosure 1 Westinghouse Proprietary Class 2 Page 2 of2 studies. Additionally if the [ r of allowable deck leakage was determined to be acceptable. For these latter cases, the integrated maldistribution based upon [ )t was greater than [ t. Therefore; based upon this generic work, the [ t criterion is an acceptable upper limit that ensures that the calculated containment pressure for [ ]3 breaks, when the lower inlet doors are in the flow proportioning range, will remain below the containment design pressure for allowable deck leakage areas greater than the design value [ t The information presented [ r that for door frictional torques in the range off t, the pressures required to open and close the doors are consistent with the characteristic curve used in the deck bypass sensitivities. Furthermore, based upon [ }3 provided by Duke Energy determined that the surveillance test data fall within the range of the analytical data used for the Catawba and McGuire UFSAR analyses °and the generic sensitivities. Therefore it is judged that the [ Of note, the basis for [ t is to ensure that [ t the sensitivity studies described above. [ t torque value range of [ )3 is considered acceptable as long as [ Another qualitative assurance of compliance with the maJdistribution requirement can be taken from [ t For [ 1 a differential pressure, [ t Stated another way, [ t. Friction of this magnitude is considered [ t The exact friction values needed to [ This document is the property of and contains Proprietary Infonnation owned by Westinghouse EIecIIic Company LLC andIor its subcontractors and suppliers. It Is transmil!ed to you in confidence and trust. and you agree to treat this document in strict accordance with the terms and conditions of the agreement under which it was provided to you. @ 2009 Westinghouse EIecbic Company LLC All Rights Reserved f of i}}