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


==Subject:==
==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:==
==Subject:==
Energy Carolinas (DEC), LLC Duke Energy                        LLC Nuclear Station, Units I1 and 2 McGuire Nuclear McGuire 50-370 Docket Nos. 50-369 and 50-370 I
Catawba Nuclear Catawba    Nuclear Station, Units 1 and 2 50-414 Docket Nos. 50-413 and 50-414 License Amendment Request (LAR) for Technical Technical Specification Specification (TS) t Condenser Doors, Response to Request for Additional 3.6.13, Ice Condenser Information (RAJ)
Information  (RAI)                                                                                      I This letter 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 McGuireMcGuire and Catawba Catawba Nuclear Nuclear Stations.
The RAI was sent via electronic mail from Jon Thompson Thompson dated May May 21, 21, 2009. The                            \
draft response to the RAI was discussed discussed during during a conference conference call with the NRC staff on                          L 18, 2009. The NRC staffs questions June 18, Enclosure 1.
Enclosure questions and DEC's responses responses are provided in I
The additional                provided in this RAI does not impact the conclusions additional information provided                                      conclusions of the    the I
I' No Significant Hazards Hazards  Considerations  and  the  basis for the categorical  exclusion categorical exclusion        from                  i performing an Environmental/Impact performing        Environmental/Impact Statement Statement presented presented in the October 2. 2, 2008 LAR  LAR submittal. Specifically, the propOsed proposed revisions to TS T8 3.6.13 do not affect the current post-accident    Containment Response post-accident Containment      Response analysis of record.                .
Attachment B of Enclosure 1 Attachment                    I contains information information that the owner, Westinghouse Westinghouse Electric Electric Corporation (WEC), considers proprietary. In accordance accordance with the provisions provisions of 10 CFR 2.390, Enclosure 2 contains a request and affidavit CAW 2643 from WEC thaUhe            thatthe information identified in Attachment proprietary information*identified      Attachment B of Enclosure Enclosure 1 I be ~held withheld from public  public Enclosure 3 provides disclosure. Enclosure      provides the non-proprietary non-proprietary version of Enclosure Enclosure 1. 1, Attachment Attachment    B.
Aoo(
www  duke-energ.com www.duke-energy.com              N~
August25, August    25,2009 2009 Nuclear NuclearRegulatory RegulatoryCommission Commission Page Page22 This ThisRAI RAIresponse responsecontains containsno noregulatory regulatorycommitments commitmentsfor forMcGuire McGuireororCatawba.
Catawba.
Please Pleasedirect directany anyquestions questionswith withregard regardtotothis thismatter mattertotoJulius JUliusW.
W.Bryant Bryantatat(980)
(980)875-875-4162.
4162.
Very Verytruly trulyyours, yours, B.
B. H.
H. Hamilton Hamilton Enclosures Enclosures I
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                                                                                                    !
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                                                                                                ; :
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August25, August      25,2009 2009 Nuclear    Regulatory    Commission Nuclear Regulatory Commission Page 33 Page xcw/
xc    wi Enclosures Enclosures A. Reyes L.L. A. Reyes Regional    Administrator, Region Regional Administrator,        Region IIII U.S. Nuclear U.S. Nuclear Regulatory Regulatory Commission Commission Sam    Nunn    Atlanta  Federal Sam Nunn Atlanta Federal Center    Center 61 Forsyth 61              St., SW, Forsyth St.,    SW, Suite  23T85 Suite 23T85 Atlanta,    GA Atlanta, GA 30303  30303 J. B.
J. B. Brady Brady NRC Senior NRC      Senior Resident Resident Inspector Inspector "McGuire      Nuclear Station McGuire Nuclear          Station G. A. Hutto G.              III Hutto III NRC      Senior NRC Senior ResidentResident Inspector Inspector Catawba Nuclear Catawba      Nuclear Station Station J. H.
J. H. Thompson Thompson (addressee (addressee only)
Project    Manager (MNS Project Manager        (MNS and CNS)
CNS)
Nuclear Regulatory U.S. Nuclear        Regulatory Commission Mail Stop 0-8 Mail          0-8 G9A Washington, DC 20555-0001 B. O.0. Hall Section Chief Division of Radiation Radiation Protection Protection Section 1645 1645 Mail Service Center
" Raleigh, NC 27699 S.E. Jenkins Jenkins Section Manager Section    Manager Division Division of of Waste Management Management Carolina Department of South Carolina South                              of Health Health and Environmental Control and Environmental Control 2600    Bull 2600 Bull St. St.
Columbia, Columbia, SC  SC 29201 29201
August 25, 2009 August        2009 Regulatory Commission Nuclear Regulatory Nuclear Page 4 OATH AND AFFIRMATION Bruce H.                                    person who subscribed his name to the H. Hamilton affirms that he is the person                                the foregoing statement, and that all the matters foregoing                                                            herein are true and matters and facts set forth herein correct to the best of his knowledge.
Bruce H. Hamilton, Site Vice President President Subscribed Subscribed and sworn to me:        /iLgud ~ S; ;1.00"1 Date Date cl~ C. fh/Jnj N--otary otary Public                  U My commission              a;; I~
expires: (% /
commission expires:                  I, )0 I/
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              .                    ""1    Date Date I
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                                                                                          ,l
Enclosure 1 Enclosure Response to NRC Response        NRC Staff RAI Related Related to October 2, 2008 2008 LAR for TS 3.6.13, 3.6.13, IceIce Condenser Doors, NRC Staff Question SCVB#1 SCVB#I IThree (Three Parts; 1la,    b, and 11c) a, 1lb,      c)
Please provide the following clarifications on TS 3.6.13 as to how Condition A and Condition B  B are applied under the current TS versus how they are intended to be applied under the proposed TS.
SCVB#1a:
NRC Staff Question SeVB#1a:
Surveillance Requirement Technical Specification Surveillance        Requirement (TSSR) 3.6.13.1 3.6-13.1 and TSSR 3.6.13.4 3.6.13.4 are applicable to the lower inlet doors. TSSR 3.6.13.1 is performed performed at a frequency of 12 hours during modes 1, 2, 3,.&  3, & 4. TSSR 3.6.13.4 is conducted at a frequency of 18 months during outages. Please explain what condition statement    statement the plant will be in upon failure to pass TSSR 3.6.13.1 3.6.13.1 - "Verify all inlet doors indicate indicate closed by the InletInlet Monitoring System." Is itit Condition A, Door Position Monitoring                                    A, Condition Condition B, or both? 1f  If the answer 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    NRC Staff Question Question SCVB#1a:
SCVB#la:
Revision 3.0 of the Standard Technical Specifications                      Westinghouse Plants Specifications (STS) for Westinghouse (NUREG-1431) is worded such that Condition A of STS TS 3.6.16 applies only to the (NUREG-1431)                                                                                        the Inlet Doors ("Inlet Doors" and "Lower Inlet Doors" represent synonymous synonymous terms) 1. 1 However, the current McGuire/Catawba McGuire/Catawba TS 3.6.13 wording does      does not incorporate incorporate the-the-
"Inlet" or "Lower Lower Inlet" text into the Condition A description 2.. As a result, Condition A of the current McGuire/Catawba McGuire/Catawba TS 3.6.13 is applicable applicable to all Ice Condenser Condenser Doors (Lower Intermediate Deck Doors, and the Top Deck Doors). The proposed Inlet Doors, Intermediate                                                          proposed revision to the McGuire/Catawba McGuire/Catawba TS 3.6.13 wording adopts the Westinghouse                        clarification Westinghouse STS clarification in Condition Condition A (i.e.,
(i.e., by adding the descriptor descriptor "Lower Inlet") so that only the Lower Lower InletInlet Doors are    affected are affected    by  Condition  A.
For both both the current current McGuire/Catawba McGuire/Catawba TS 3.6.13 3.6.13 and the proposed McGuire/Catawba McGuire/Catawba TS 3.6.13, TSSR 3.6.13.1 is applicable applicable to the Lower Inlet Inlet Doors only ("Inlet Doors" and "Lower Inlet Inlet Doors" represent      synonymous terms). If a Lower Inlet Door (or more represent synonymous                                            more than than one Lower Inlet Inlet Door) opens while in aa Mode of Applicability Applicability (i.e., Modes Modes 1, 2, 3, or 4),
TSSR 3.6.13.1 3.6.13.1 is not met, and only Condition Condition B is entered entered since the Condition Condition as as described described for such an occurrence occurrence would be "not closed".
Under Under the the proposed proposed revision revision to McGuire/Catawba McGuire/Catawba TS 3.6.13,3.6.13, the one-hour one-hour Required Required Action Completion Completion Time for Condition Condition A would be entered entered only ifif one one or more more Lower Lower Inlet Ooor(s)
Door(s) is physically physically restrained restrained from from opening. Such a condition condition could could arise arise if a Lower Lower Inlet Inlet Door blocking blocking device, device, which which is temporarily temporarily installed installed during during outages outages to prevent inadvertent prevent  inadvertent opening of the doors, doors, is unintentionally unintentionally left in place and the UnitUnit is brought into aa Mode Mode of Applicability Applicability while in that  configuration.
that configuration.
Page 1 ofof66
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Enclosure 1 Enclosure                                                  .!
I
===Response===
Response to NRC Staff RAJ    RAI Related      October 2,2008 Related to October    2, 2008 LAR for TS 3.6.13, Ice  Ice Doors, Condenser Doors.
Condenser NRC Staff Question SCVB#1 NRC                      SCVB#1b:  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 discovered involving the the Intermediate Deck Doors or the Top Deck Doors. The applicable Intermediate                                                      applicable surveillance surveillance requirements are  are TSSR 3.6.1"3.2            Intermediate Deck Doors and TSSR 3.6.13.3 3.6.13.2 for the Intermediate                                3.6.13.3 for the Top Deck Doors. Please  Please explain which part of the surveillance        requirements surveillance requirements Condition A under could put the plant in Condition        under the current TS?
Response to NRC Staff Question SCVB#1b:
DEC Response                                    SCVB#1 b:
(NUREG-1431) is worded such that Westinghouse Plants (NUREG-1431)
Revision 3.0 of the STS for Westinghouse Condition A of STS TS 3.6.16 applies only to the Inlet Doors ("Inlet
.condition                                                              (uInlet Doors" and "Lower "Lower Inlet Doors" represent synonymous terms) 1~ However, the current McGuire/Catawba McGuire/Catawba TS 3.6.13 wording does not incorporate incorporate the "Inlet" or "Lower Inlet" text into the Condition Condition A description description 2.                  Condition A of the current McGuire/Catawba 2 As a result, Condition                        McGuire/Catawba TS 3.6.13 is Condenser Doors (Lower Inlet Dbors, applicable to all Ice Condenser applicable                                                            Intermediate Deck Doors, and Doors, Intermediate                      and the Top Deck Doors). Therefore, ifif TSSR 3.6.13.2 is not satisfied due        due to ice, frost oror debris physically restraining                    intermediate deck door(s) from opening and/or restraining one or more intermediate TSSR 3.6.13.3 is not satisfied due to condensation, frost, or ice physically restraining restraining more top deck door(s) from opening, the current McGuire/Catawba one or more                                                        McGuire/Catawba TS 3.6.133.6.13 wording would require entry into TS 3.6.13 Condition A.        A The proposed revision to the McGuire/Catawba McGuire/Catawba TS 3.6.133.6.13wording wording adopts the the clarification in Condition A (i.e., by adding the descriptor "Lower Westinghouse STS clarification Westinghouse                                                                              "Lower affected by Condition A 1.
Inlet") so that only the Lower Inlet Doors are affected                            1. Therefore, ifif satisfied for any reason, the proposed 3.6.13.2 and/or TSSR 3.6.13.3 are not satisfied TSSR 3.6.13.2 McGuire/Catawba TS 3.6.13 wording revised McGuire/Catawba                      wording would only require                      3.6.13 require entry into TS 3.6.13 Condition    B. This is  appropriate appropriate  since  the  Intermediate Intermediate    Deck  Doors  and  Top  Deck thermal/humidity barriers, and their time-dependent Doors are primarily thermal/humidity                                                  behavior during time-dependent behavior      during an accident scenario                                        air/non-condensable gases scenario (i.e., allowing the passage of air/non-condensable          gases from the the compartment to the upper lower compartment                upper compartment                    blowdown) is not quantified compartment during initial blowdown)              quantified containment response analysis in the containment                            3. As such, for the case where one or more analysis 3.
Intermediate Deck Door(s) or one or more Top Deck Door(s) is/are inoperable, Intermediate                                                                    inoperable, the 14 McGuire/Catawba TS 3.6.13 Condition B is Required Action Completion Time of McGuire/Catawba day Required appropriate and consistent with the Westinghouse appropriate                                Westinghouse STS.
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                                                                                                        !I Enclosure 1 Response to NRC Staff RAI Related Response                          Related to October 2. 2, 2008 LAR for TS 3.6.13.
3.6.13, Ice Ice      Ii Condenser Doors, Doors.
NRC' NRC Staff Question Question SCVB#lc:
SCVB#1 c:
I The tAR LAR proposes to add a new note to TS Actions            indicating entry into Condition B for Actions indicating Intermediate Deck and Top Deck Doors is not required due to personnel the Intermediate                                                              personnel standing on or opening doors for short durations to perform required surveillances, minor I
maintenance, or routine maintenance,      routine tasks.
performance of the same activities under What condition entries are made during the performance current TS? What is the duration it normally the current                                                                          activities?
normally takes to complete these activities?
Notes 1 and 2 under Actions in the proposed TS could allow multiple doors to be open description of the activities that will be covered provide a brief description at the same time. Please provide I
by the proposed Note 2 and if they in fact require multiple multiple doors to be opened concern staff has with these activities is potential simultaneously. The concern                                              potential for ice bed condenser flow.paths. Please address these concerns sublimation, melting, and ice condenser                                                concerns in your response.
Proposed Note 2 did not indicate Proposed                    indicate a      duration for these activities. However, a duration a' duration                                      duration of mentioned in the Bases section. What is the reason for not including
< 4 hours is mentioned                                                              including thethe time of < 4 hours in Note 2? Also, discuss              acceptability of < 4 hours time in your discuss the acceptability response to the question immediately immediately above.
Response to NRC Staff Question SCVB#1c:
DEC Response McGuire/Catawba TS 3.6.13 is entered Condition B of the current McGuire/Catawba                                          personnel open entered when personnel Intermediate Deck Door(s) or lop one or more Intermediate                                        Door(s) for any duration to perform Top Deck Ooor(s)                          perform maintenance, or routine tasks. All of these evolutions typically surveillances, minor maintenance, approximately 2 hours or less to complete. Condition entry for these tasks is not require approximately required if doors are not opened or if personnel personnel are standing on these doors.
The proposed new Note 2is                                        required surveillances, intended to relate only to required 2 is intended                                  surveillances, minor minor maintenance, and routine tasks as defined maintenance,                              defined in the License Amendment Amendment package package dated activities would include tasks that are necessary October 2, 2008. These activities' October                                                                  necessary to ensure ice  ice condenser operability condenser  operability (e.g                    inspection, light housekeeping),
(e.g...., door visual inspeGtion,        housekeeping), require only a amount of time to perform (typically 2 hours or less), and involve minimum amount                                                                involve a small number of personnel 3.
number                  3. These tasks would not be expected expected to require the opening of            I multiple doors simultaneously.                        maintenance activity (e.g. ice basket extended maintenance multiple        simultaneously. An extended weighing) could require multiple doors weighing) basket doors to be opened simultaneously. For this situation,              I Condition B of both the current and proposed          McGuire/Catawba TS 3.6.13 would be proposed McGuire/Catawba                            be
                                                                                                        .\
I temperature at least entered which requires monitoring of the ice bed temperature entered                                                                    least every every four hours approach the melting point 2.
temperatures do not approach to ensure maximum ice bed temperatures                                                    2 . In Condition B ensures there Completion Time of CondITion
                                                                                                        ~I addition, the 14 day Required Required Action Completion would not be a significant significant loss of ice from sublimation thro!Jgh the ice bed is not affected by the opening through sublimation 2.2. The flow channel clearance clearance opening of doors since the applicable doorsdoors    'I physically distinct from flow channels and these doors fUnction are in an area physically                                                        function mainly to Page 3 of6 of 6
Ii 1
Enclosure 1 Enclosure Response to NRC Staff RAI Related to October 2, 2008 LAR for TS 3.6.13, Response                                                                                    Ice 3.6.13, Ice I
I Condenser Condenser      Doors, open and relieve pressure blowdown phase of a large break Design blowdown Imy~r compartment pressure from the lower        compartment of containment during the Design Basis Accident (DBA). Therefore d.oor is already fulfilling this DBA function.
door the*
Therefore an open            I The general intent intent in adding the proposed Note 2 to the McGuire/Catawba McGuire/Catawba TS 3.6.13  3.6.13 Actions is the adoption            Westinghouse STS 3.6.16 Bases wording. During the adoption of the Westinghouse                                                      the internal review internal  review of the LAR submitted. October 2, 2008 (prior to submittal to NRC),
submitled.October'                                        NRC), it waswas determined that wording included in the STS 3.6.16 Bases that identifies determined                                                                  identifies criteria criteria for statement would be better positioned in the actual technical entering an action statement entering specification      Operator expediency), rather specification (for Operator                                                    document. The STS rather than in the Bases document.                STS
.3.6.16 Bases wording
*3.6.16            wording does not identify a timeframe timeframe for "short duration". Therefore, it was determined                Condition B four hour completion time for ice bed temperature determined that the Condition                                                        temperature verification would be invoked since itit represented a limit already prescribed by the          the specification and easily bounded the expected technical specification technical                                                          timeframe expected timeframe      for performing performing routine surveillances          inspections: The four hour timeframe defining a "short surveillances and inspections:
duration" entry is considered a technical specification          clarification, and as such was specification clarification,                  was determined to be better left in the TS Bases document.
determined                                            document.
NRC Staff Question SCVB#2 II reference to the attachments In reference          attachments containing                  UFSAR pages marked-up to show containing existing UFSAR
. the proposed proposed changes, please clarify if    if the changes are same as those referencedreferenced in the last paragraph        Section 2.2 of Attachment paragraph of Section            Attachment 1. If    Ifthey are different, give us a time time      II line        10CFR50.59 changes to the McGuire tine of the 10CFR50.59                                    UFSAR, and when it was recognized, McGuire UFSAR,                              recognized.        I proportioning characteristics that the flow proportioning                                                              requirement characteristics of the inlet doors is not a design requirement McGuire and Catawba.
for McGuire Question SCVB#2:
Response to NRC Staff Question DEC Response                                  SCVB#2:                                                        I marked-up McGuire The marked-up                  UFSAR pages included with the LAR package McGuire UFSAR                                            package dated      October dated October from the revisions that were made to the McGuire UFSAR as a different from 2, 2008 are different I OCFR50.59 evaluation result of the 10CFR50.59                  described in Section 2.2 of Attachment 1 of the evaluation described                                                the same same LAR package 3.                        Attachment 1 of the LAR describes the removal of
: 3. Section 2.2 of Attachment                                                          I description of the "double break" scenario, in which a small break LOCA event the description                                                                                                I occurs first, followed by a large break LOCA event in rapid succession.
occurs                                                                                    was succession. ' It was determined in early 2005 that the "double break" scenario was beyond the design basis determined                                                                                          basis
. of the  McGuire McGuire  station  (reference (reference  detail  in  Section  3.3.1  of Attachment Attachment 1  I  of  the LAR tAR package), and the UFSAR UFSAR was subsequently                            10CFR50.59 evaluation subsequently revised via a 10CFR50.59              evaluation in  in February of 2005 44.. The Catawba'UFSAR February                      Catawba UFSAR did not contain outdated  outdated references to the  the therefore did not need revision in 2005 to reflect this "double break" scenario, and therefore                                                        this        : ,
determination.
Page4of6 Page 4 of 6
Enclosure 1 Enclosure
===Response===
Response to NRC Staff RAI Related to October    October 2. 2, 2008 LAR for TS 3.6.13, Ice Condenser Condenser Doors, The conservative flow proportioning          characteristics of the Lower Inlet Doors was proportioning characteristics                                    was recognized prior to 2005 by the Ice Condenser Utility Group recognized                                                        Group (ICUG).
(ICUG). At the  ICUG ICUG Technical    Conference held at the Donald C. Cook plant in 2002, the subject was Technical Conference                                                                        was discussed at length 5.
discussed                                                meeting summary from that conference
: 5. The relevant pages of a meeting                                conference Enclosure in conjunction with the response Attachment A to this Enclosure included as Attachment are included                                                                          response to item SCVB#3 below. The proposed UFSAR changes shown in the LAR submitted
$CVB#3                                                                            submitted on implemented after NRC approval October 2, 2008 will be implemented October                                                    approval of that LAR.
NRC Staff Question NRC                      SCVB#3 Question SCVB#3 reference to the statements In reference                            paragraph 3 of Section statements in paragraph            Section 2.4 of of Attachment 1, please discussed in interpretation in 2002 that was discussed provide copies of relevant pages of ICUG interpretation                                              in that year's ICUG      Technical Conference.
ICUG Technical    Conference.
DEC Response to NRC Staff Question  Question SCVB#3:
interpretation of the Lower Inlet Door 40 Degree refers to the interpretation question refers The RAI question                                                                      Degree Torque Torque Test series (TSSR 3.6.13.6) results. Copies of relevant pages of the ICUG Technical Conference meeting summary Conference                summary held at the Donald C. Cook Nuclear  Nuclear Plant in Bridgman, Michigan Michigan    in  2002 are  included  in  Attachment included Attachment        A  to this Enclosure    5 5.
NRC Staff Question SCVB#4 It was stated                    Attachment 1 that inlet door movement stated in page 11 of Attachment                                          characteristics (after movement characteristics      (after directly to the Containment initially breaking away) are not tied directly              Containment response analysis and Westinghouse (OEM) letter. Please provide copies of relevant pages of referenced a Westinghouse referenced justification. Staff would also like to be informed if the appropriate justification.
the letter containing appropriate                                                                    the removal of TSSR 3.6.13.6 was discussed with the OEM, and if so, provide proposed removal proposed                                                                                              us provide us description of the OEM's response.
with a brief description Response to NRC Staff Question SCVB#4:
DEC Response RAI question refers The RAJ                          a refers to a letter written by the OEM (WEC) in responseresponse to a contracted task to formally document the original design basis of the lower contracted                                                                          Lower Inlet Doors Doors Catawba as it relates to the Technical McGuire and Catawba at McGuire                                                        Specifications. Copies of the Technical Specifications.                  the referenced OEM letter are included as Attachment B to this relevant pages of the referenced . 6 discussed in the LAR package As discussed                  package dated                                            (lBlOCA and accidents (LBLOCA dated October 2, 2008, the accidents SBLOCA) are separate SBlOCA)                                                      concurrently or in rapid succession. A separate events and cannot occur concurrently LBLOCA does not require the flow proportioning lBLOCA                                    proportioning    function          Lower Inlet Doors to of the lower energy; as under these high energy maldistribution of break energy; prevent maldistribution                                                    energy conditions        ports conditions the ports
                                              . Page 5 of of66                                              i
Enclosure Enclosure I1
===Response===
Response to  to NRC NRC Staff Staff RAI HAl Related Related to  to October October 2,  2, 2008 2008 LARLAR for for TS TS 3.6.13, 3.6.13, Ice Ice Condenser Condenser Doors,Doors, in in the the Crane Crane Wall Wall are are designed designed to  to distribute distribute thethe inflow inflow toto the the ice ice condenser.
condenser. The  The
: SBLOCA, SBLOCA, as  as anan independent independent low  low energy energy event, event, does does notnot propagate propagate to to aa LBLOCA LBLOCA and  and therefore    preventing      steam    bypass    from    getting  to  the therefore preventing steam bypass from getting to the upper compartment of upper    compartment      of containment containment (ostensibly (ostensibly prior prior to to aa subsequent subsequent LBLOCALBLOCA high  high energy energy event) event) is is not not necessary.
nece..fosary.
The The proposed proposed removal removal of  ofthe the TSSR TSSR 3.6.13.6 3.6.13.6 Lower Lower Inlet Inlet Door Door Torque Torque test test series series (and (and incorporation incorporation of  of aa freedom freedom of  of movement movement test  test into into SR SR 3.6.13.5) 3.6.13.5) was was not not formally formally discussed discussed withwith the the OEM.
OEM. As  As noted noted inin the the LAR LAR package package dateddated October October 2, 2, 2008, 2008, there there isis an    industry  precedent      (TSTF    429-A)    for an industry precedent (TSTF 429-A) for reviSing an    revising  an ice ice condenser-related condenser-related technical technical specification specification using using this this approach.
approach. TSTF TSTF 429-A 429-A was was approved approved by  by NRC NRC inin September September
: 2003, 2003, and and reflects reflects aa revision revision toto the the Ice Ice Condenser Condenser Ice  Ice Bed Bed Mass Mass Determination Determination statistical statistical analysis analysis and and sampling sampling methodology methodology governed governed by  by McGuire/Catawba McGuire/Catawba TSSR    TSSR 3.6.12.4 3.6.12.4 and and TSSR        3.6.12.5 7 .
TSSR 3.6.12.57.
Enclosure Enclosure I1 References References 1.
: 1. Westinghouse Westinghouse STS  STS 3.6.16 3.6.16 and and BASES BASES (NUREG-1431, (NUREG-1431, Rev. Rev. 3, 3, Volume Volume 1)  1)
: 2. Current  McGuire/Catawba          TS  3.6.13
: 2. Current McGuire/Catawba TS 3.6.13 and TS BASES      and  TS  BASES 3.
: 3. October October 2, 2, 2008 2008 LAR LAR package, package, Attachment Attachment 1,    1, page page 99 ofof2727
: 4. PIP  M-04-5115,
: 4. PIP M-Q4-5115, CA#34  CA#34 5.
: 5. ICUG ICUG Meeting Meeting Summary Summary -- July July 2002, 2002, PgsPgs 7-10 7-10 (see (see Attachment Attachment AA of  of Enclosure Enclosure 11 in in' this this submittal) submittal) 6.
: 6. Westinghouse Westinghouse LetterLetter LTR-RIDA-06-106, LTR-RIOA-06-106, Rev      Rev 2, 2, Portion Portion Titled Titled "Scope "Scope andand Clarifications Clarifications Number Number 8"  8" (see (see Attachment Attachment BB of  of Enclosure Enclosure 11 inin this this submittal) submittal) 7.
: 7. TSTF-429, TSTF-429, Revision Revision 3,  3, dated dated November November 2003  2003 Page Page66ofof66


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.
Attachment      Enclosure 1I Attachment A To Enclosure Summary For July Meeting Summary Selected Pages From Meeting                    16-18, 2002 Ice July 16-18,2002 Condenser Utility Group Technical Condenser                         Conference Technical Conference I
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.
:1 d
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.
                                                                ''1 d
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.
                                                                  ~I
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:
: I*
Document Control Desk "
                                                                  *1
                                                                  ,I
: :


==Subject:==
2002 ICUG Technical Technical Conference-Conference - Page 7 1.
        ). Primary focus of the guide would ,be    be to educate/enlighten educate/enlighten Work Control and plant management                    significance of management to the significance    of I/C surveillances the IIC  surveillances in an era of ever-shortening ever-shortening outages.
: 2. The IG would need to be comprehensive; comprehensive; i.e., it would encompass encompass all the IIC I/C TSs and the design principles principles behind them.
: 3. Guide would include include a reference section section that would lead to the public domain, so that the bases in the guide will tie to documents we all share.
docwnents
: 4. Operating experience would be included (both plant OE and regulatory  regulatory history).
: 5. A description description of the TS implementation procedures          and-associated maintenance procedures and.associated                              (such as AIMM maintenance practices (such methodology) methodology) from each plant would be included. included.
: 6. This would need to be assembled pretty quickly. Sequoyah Sequoyah NP might be the first to adopt the Ice Mass Deterinination Determination TS from NUREG-1431, NUREG-1431, and if so would do it in time for the spring 2003 RFO there. That schedule        schedule would mean at draft IG would need to be in place by early 2003 to support least a draft                                                                      implementation of the TS.
support the implementation From these comments, the following outline of the ICUG Implementation Implementation Guide was developed:
developed:
lo.
        .. Section Section 1:  Operating Experience I: Operating  Experience (plant (Plant and Regulatory)
Regulatory) o.
        .. Section n:
Section  IH: Design Philosophy (link to TSs) b.
        .. Section  m: Implementation Section III:  Implementation ofTS of TS I/ Maintenance Support Support b.
        .. Section Section IV:    References (linked to public domain)
N: References Paul L. and Russ took action to begin assembling information for Section II1,        Ill, with Paul taking the Ice Mass TS and Russ taking taking the I/C IIC Door TS LID issues. As this develops, assistance will    will be needed from ICUG members.
The next agenda item involved the recent  recent issues regarding        I/C Door TS, in particular, the surveillance tests surrounding the regarding the lIC Lower Inlet Doors. It bad had been determined detennined that, due to continuing continuing confusion about this subject by the staff and others, documentation of an industry
-documentation          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 addressingaddressing regulatory regulatory issues. Russ gave a synopsis of what  what brought this item to the ICUG agenda:
agenda: the NRC Resident Resident at Catawba Catawba had raised raised the issue of LID testing, in particular particular the fact that there was no process process installed installed at CNS for tracking "failures" of the LID tests after after an as-Ieft as-left surveillance. This was deemed a problem since, by 1JOCFR50.65 guidance (Maintenance
.problem                                        (Maintenance Rule), failures of      high-risk, safety-significant ofhigh-risk,  safety-significant systems needed to be trended. He issued issued a non-cited violation (against Criterion        XVI) to Catawba the week prior to the ICUG meeting, Criterion XVI)                                                meeting, as a result. He He had other issues as well, which tum  turn out to be similar to those surfaced surfaced by the Residents at the other Region 11 plants:
        .~
        ,    As-left testing versus versus as-found as-found testing.
testing, why not do both?
both?
o.
Do  Adequacy of the LID 40&deg;    401 Torque Test to determine operability
: o. MR
        .. MR trending trending The ICUG discussion discussion of this item at the meeting was extensive; what follows is aa summary  summary of it that also served as the industry position basis:
In February February of  2002, Cook Nuclear of2002,          Nuclear Plant Unit 1I entered a planned refueling outage, at which time the Ice Condenser Lower Inlet Doors (LIDs) were tested per the plant's surveillance surveillance requirements.
requirements. At Cook NP, the surveillances surveillances on the LIDs are performed in both the as-found and the as-left as-Ieft condition.
condition. The remaining ice condenser condenser plants (IV(TVA-Sequoyah, A-Sequoyah, TVA-Watts              Duke-Catawba TVA-Watts Bar, Duke-Catawba and Duke-McGuire, Duke-McGuire, all in Region Region IH)n) conduct conduct the LID surveillances surveillances only in the as-left condition. The LID testing performed at Cook NP Unit II was witnessed witnessed by NRC personnel, personnel, and at the time of    the tests several issues arose about the methodology being ofthe implemented to perform them. Ultimately, implemented                          Ultimately, Cook NP determined determined that their test procedure procedure for the LIDs was not adequate. Cook  Cook personnel persormel then corrected the test procedure and re-tested re-tested the Unit I LIDs.
LIDs.. Unit 2 LIDs were addressed through approval of an emergency emergency Technical Specification Specification amendment allowing Unit 2 to operate until its next outage without further    fuirther testing.


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.
1 I
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
2002 IICUG                    Conference - Page CUG Technical Conference               Page 8 As a result of these As                 these events, resident NRC inspectors queried personnel at the          the Region Region IIII plants plants regarding the LID LID tests, and during during I
: 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.
the spring 20022002 outage season LID testing and      and associated procedUres procedures were reviewed and in      in some cases witnessed by the staff staff at at those stations. Subsequently, NRC personnel   personnel atat Sequoyah Sequoyah and and Catawba Nuclear Stations Stations requested clarification clarification onon the the following issues:
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.
i-
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.
        ~                                as-left LID testing in lieu of as-found Basis for performing as-left                                as-foundLID testing. This This issue issue concerns a Licensee's Licensee's ability to show   I that the LIDs areare still still operable at the end of a cycle (or  (or at any otl!er other time after the current as-left as-left tests).                     r l
Enclosure 3 provides the non-proprietary version of Enclosure
        ~      Validity of the methodology for performing the        the LID 40&deg;40' "Torque Test" Test." This issue involves the evaluation evaluation of free LID i
: 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.
movement and friction in the LID hinges (required Process for trending LID (required by the current surveillance requirements)
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.
LID failures for Maintenance Rule. This     This issue requirements)..
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.
issue surfaced after it was noted by NRC that the LIDs   LIDs    I are included in MR as high-risk, safety  safety significant components.
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
components, but no process for trending trending failures exists since the LIDs cannot "fail" the as-left as-left surveillance surveillance test (LIDs (LIDs are not not required operable in Mode 55 when the SR tests are performed).
.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&deg; 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&deg; 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:
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
        )I.. LID design basis
: 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
: 2.                                 acceptance criteria basis (e.g" LID surveillance test acceptance                       (e.g;, empirical data, analysis, or other)
: 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.
: 3.               surveillance requirement Current surveillance     requirement link to IOCFR50.36 IOCFR50.36
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.
: 4.     Current industry procedures Current            procedures for identifying unexpected changes from last as-left LID tests
Combined industry operating experience has verified the absence of any mechanism for LID degradation during normal operation
: 5.     Current industry procedures procedures for performing the LID Opening Force Test
("innage").
: 6.     Current industry procedures procedures for performing the LID 400 Torque    Torque Test
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.
: 7.                 experience with the LID 400 Industry experience                      40' Torque Test and associated results
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.
: 8.     LID contribution        functional cap8bility contribution to :functional     capability ofIce of lee Condenser Condenser (Maintenance Rule)
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  
Representatives Representatives from each of the utilities provided plant-specificplant-specific information and recent experience experience related to the surveillance surveillance
-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.
-testing of LIDs. Salient
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&deg; "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.
-testing                Salient points from past discussions with resident inspectors were also exchanged,    exchanged, as well as past LID testing issues and plant events.
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).
While each utility has a different different approach approach for addressing the three outlined outlined issues brought brought by the NRC residents, the bases  bases behind the approaches approacbes is essentially the same and adequately adequately represents that the industry is not divergent divergent in its interpretation interpretation ofof the requirements set forth in the current Ice Condenser Door technical specification.
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
Issue: As-Left As-Left LID Surveillance Surveillance Testina Testing versus As-Found LID Surveillance Surveillance Testing Testing representatives agreed that as-left (post-ice bed maintenance)
: 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.
All representatives                                              maintenance) surveillance surveillance testing is sufficient to show the LIDs will be capable capable of performing their safety function. Combined industry operating          operating experience has verified verified the absence absence of any mechanism mechanism for LID degradation degradation during during normal operation operation ("innage"). Innage-related anomalies (e.g., a steam leak in containment
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.
("innage"). Innage-related                                                              excessive containment or excessive AHU drain pan AHU              pan leakage) that could potentially challenge LID performance performance are addressed addressed in each plant's Corrective Action Program including, Program        including, asas appropriate, appropriate, operability      evaluation per operability evaluation     per the guidance outlined outlined in Generic Letter 91-18.
Combined industry operating experience has verified the absence of any mechanism for LID degradation during normal operation
Outage-related Outage-related ice   i,ce bed bed maintenance, maintenance, however, does present present conditions conditions that commonly commonly degrade degrade LIDs. These These conditions conditions include exposure exposure of the LIDs to ice and     and water water outfall. As a result of these activities and the potential degradation degradation that they impose, LID  LID restoration is a normal activity activity at the conclusion conclusion of each maintenance maintenance outage.
("innage").
outage. Final restoration restoration activities activities include completion completion ofof the required required surveillance surveillance testing. During the coursecourse of performing this LID testing, "failures" "failures" (when (when they occur) have have typically typically been been attributed attributed to outage outage maintenance-induced maintenance-induced ice build-up on the LIDs, the compressive  compressive effect of LID blocking blocking hardware, or the known       sensitivity of known sensitivity        of the the test test parameters parameters when when performed by inexperienced inexperienced personnel.
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.
personnel. The satisfactory                            as-left satisfactory completion of this as-Ieft LID testing testing meets meets the the applicable applicable surveillance surveillance requirements requirements by assuring the limited condition for operation operation of the LIDs will be met  met for the duration of the surveillance surveillance interval as required by IOCFRS0.36 I0CFR50.36 (c)  (e) (3).
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
ICUG Technical 2002 ICUG    Technical Conference - Page 99 well were the existing as-found Noted as well                        as-foundvisual inspections inspections ofofthe LID area area performed performed after after Unit shut-down.
-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.
shut-down. Some utilities utilities visually inspect visually  inspect the the LID seal seal and and door surfaces, surfaces, while while others do a general visual visual inspection to ascertain ascertain anomalous conditions conditions that might affect LID operability, such as ice might                                          ice build-up or  or other degradation.
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&deg; "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.
degradation- These These as-found inspections inspections are are formal formal procedures procedures at  at some plants. Each plant (as(as appropriate) should evaluate evaluate the need to proceduralize proceduralize these inspections to verityverify that as-found LID condition is being evaluated condition            evaluated to appropriately appropriately identifY identify any Conditions Adverse to Quality (CAQ). If during the as-found    as-found inspection aa CAQ CAQ is  is discovered, discovered, further evaluation evaluation,of of the LID condition would be indicated, up to and including a surveillance surveillance test.
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).
It was determined during the discussion that LID       LID "cycling" "cycling" (i.e.,
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
(i.e., opening and and closing) prior to anyany as-found inspections or  or as-left as-left was practically surveillance tests was    practically unavoidable.
: 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.
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.
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.
LIDs, inadvertent LID All plants reported experiencing inadvertent            LID cycling during containment ventilation ventilation transients, which occur as the Unit changes modes and and as personnel air locks and    and containment containment equipment equipment hatches are  are opened in preparation      for outage work. In preparation for some plants addition, at some    plants the only ingress path to the ice condenser Lower Plenum after shutdown is through a LID, which requires one LID to be opened just to gain access to the area. There at least one                                                                There is is no failure mechanism being masked masked by this LID cycling.
Combined industry operating experience has verified the absence of any mechanism for LID degradation during normal operation
cycling.
("innage").
The seal design is such that the seal does not freeze to the door surface; any freezing condition      condition that restricts LID opening requires a significant build-up of ice or frost, which is identifiable during as-found visual inspections.
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 required by 10CFRSO, IOCFR50, Appendix B, any CAQ must be identified and corrected,        corrected, whether it is discovered via a surveillance test or other means. The as-found visual inspections inspections provide the primary basis for identifYing identifying CAQs..
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.
CAQs. LID maintenance maintenance performed at the cOIlclusion conclusion of the outage is generally defined as those routine activities needed to restore the doors from the effects of outage work. This maintenance, maintenance, since it is occurring prior to the as-Ieft  as-left surveillance tests, must be limited to maintenance maintenance that repairs a condition condition caused by other outage maintenance activities or a condition for which the as-found          as-found condition ofthe of the door has been evaluated.
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
evaluated, For example, allowed routine maintenancemaintenance 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 maintenance                      wouldneed to be evaluated to determine the cause of the condition/adjustment.
-Page 9Noted as well were the existing as-found visual inspections of the LID area performed after Unit shut-down.
condition/adjustment. After routine routine maintenance is performed, a "soak tim maintenance                                time"en is conservatively conservatively allotted before the surveillance tests are performed, performed, to allow the LID to settle. Each plant (as appropriate) senle.                    appropriate) should evaluate the need to establish allowed maintenance  maintenance practices and "soak times" prior to      to performing the as-left LID tests.
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.
Issue: Validity of LID 40'      "Torque Test" Methodology 40&deg; "Torgue            Methodology The primary focus of this issue centers centers on the function of the LIDs during the postulated postulated Design Basis Accident.
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.
Accident- For all ice ice condenser condenser plants, the Large Large Break Break LOCA (LBLOCA)(LBLOCA) is the bounding analysis. The only other licensing basis analysis      analysis is applicable 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.
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.
ICUG notes that the LIDs are intended int!!Jlded (and analytically analytically assumed) to open immediately immediately and evenly upon initiation oft)1e  of the Large Large
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.
, Break Break or Small Break LOCA, and then recover      recover their position position and modulate the longer-term 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              Force Test and the LID Torque Test, and supports supports the LBLOCA LBLOCA analysis modeled modeled by  by the TMD/LOTIC TMDILOTIC codes  codes as well as the SBLOCA MAAP    MAAP codecode for the Cook NP sump inventory analysis. The Duke plants are currently licensed to a TMD/GOTHIC    lMD/GOnnC code model which does allow cross-flow between              between elements elements and has a more detailed detailed nodalization nodalization than the original LOTIC  Lonc work. Analysis Analysis runs using the GOTHIC GOTHIC code code show that the LIDs do not need need to open open evenly evenly or recover recover and and modulate modulate steam flow into the ice    ice bed after after the DBA has initiated. While While not all ice condenser plants are are licensed to this model, model, it supports the ICUG view  view that the current current Ice Ice Condenser CondeDser Door technical specification specification is conservative.
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.
conservative.
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.
In order order to show show the functional functional capability capability of the LIDs to modulate modulate steam steam flow after after the initiation initiation of either the LBLOCA or    or SBLOCA, the surveillance SBLOCA,          surveillance test (the LID LID Torque Test) identifies identifies limits limits for opening opening torque, closing torque, and frictional frictional torque torque with the LID positioned at 40"  400 open open (this represents represents the the free opening opening position position of the doors before significant significant contact against the shock shock absorbers absorbers or foam bags). Generally, Generally, the the
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
ICUG Technical 2002 ICUG      Technical Conference Conference -- Page 10  10 opening and closing opening          closing forces forces are are determined by utilizing aa hand-held or      or rig-mounted scale scale (spring (spring or or digital), and the forces forces converted (as converted    (as appropriate) appropriate) to torque torque at at the hinges. Once the opening opening and closing closing values are determined determined by test, test, the the frictional component isis derived by taking component                        taking the the difference difference between between them andand dividing by 2. 2. Since Since the LIDs were notnot originally design-tested design-tested empirically or analytically in     in this this capacity, these numbers are representative of a new LID installed to applicable construction tolerances. By By definition; definition, deviation fromfrom these these limits would constitute aa degradation process warranting further    further evaluation.
-Page 9 Noted as well were the existing as-found visual inspections of the LID area performed after Unit shut-down.
During the discussion ofthis, During                       of this, all plants reported limited situations situations (past (past and present) present) where the indicated opening force on the required to open scale (that required          open the the LID further from the 40&deg;  40' open open position) actually measured measured less than the associated closing force (that required (that  required to bold hold the LID still at the the 40&deg; 400 open open position). While While this situation situation did not cause cause any LID tests to exceed exceed the limits, itit did raise specified limits,            raise the question of of test test 'methodology methodology validity, validity, aa concern concern also raised raised by the resident inspectors.
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.
inspectors. Several valid points were identified in response to this:
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.
valid I. The accuracy I.          accuracy of the scale used in    in the LID 40&deg; 400 Torque TestTest can contribute contribute to misleading misleading indicated opening and closingclosing forces. Both spring and digital scales are used by the        the industry industry for these tests.
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.
Measurement of the LID
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.
: 2. Measurement                    LID opening and closing forces forces for the the surveillance surveillance are influenced by "dynamic "dynamic effects," which are  are combination of factors such essentially a combination                      such as as "bouncing" (allowing the LID    LID to hit 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).
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.
: 3. The derived derived frictional component of the LID 400        40&deg; Torque Test, whether it is positive or negative, is a sufficient indicator  indicator of the LID's freedom to move (i.e., recover and modulate) after a postulated Large Break or Small Break LOCA scenario.
Conversely, hinge/spring adjustments are not routine maintenance activities, and would'need to be evaluated to determine the cause of the condition/adjustment.
Each plant should evaluate the need to address these factors 'in            in the LID Opening Torque Test and the LID 40&deg;        40' Torque Test surveillance procedures. Based on the technical information and operating experience surveillance                                                                                  experience shared by the utilities, ICUG feels that the surveillance requirements continue current LID surveillance                                                            conservative in determining the functional capability continue to be adequate and conservative                                                              the capability of the LIDs. ICUG LIDs,  ICUG consensus consensus is that the generic generic Ice Ice Condenser Condenser Door Door Technical      Specification (STS version) is acceptable and Technical Specification conservative as currently written, and that revisions to it, as necessary, conservative                                                              necessary, should be handled on a plant-specific plant-specific basis.
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&deg; "Torgue Test" Methodology The primary focus of this issue centers on the function of the LIDs during the postulated Design Basis Accident.
Trending LID Surveillance Issue: Trending            Surveillance Test Failures for Maintenance Maintenance Rule All plants indicated similar similar general general scoping scoping of ice condenser condenser components into the Maintenance Rule (MR) program, but the industry differed differed on the definition of what actually constitutes constitutes a functional failure (FF) of the ice condenser. All agreed that individual individual component "failures" (such as a LID) did not necessarily    necessarily indicate an IIC  I/C FF (particularly when MR scopingscoping is based on safety function rather than an individual component component basis), but that it needed linkage to analytical bases such as the TMD/LOTIC    TMDILOTIC or TMD/GOTHlC TMD/GOTHIC models via a blockage      blockage limit (generally (generally noted as 15% 15% allowable allowable blockage blockage due to ice build-up). Some plants have have clearly clearly defined limits in this regard. Since this is a plant-specific            determination, the industry agrees that different plant-specific determination,                                   different approaches approaches to MR scoping will exist.
For all ice condenser plants, the Large Break LOCA (LBLOCA) is the bounding analysis.
Of more interest to the staff is the requirement requirement to trend failures of high-risk, safety-significant safety-significant components. As-found inspections inspections of the LIDs provide provide the primary basis to identifyidentifY and trend failures of the doors within the plant's Corrective Action Program. It was generally generally agreed that, even though during an outage the LIDs are not required to be operable,            operable, as-left as~left LID surveillance surveillance test failures, if they occur, should be documented documented in a plant's Corrective Corrective Action Action Program, and that that would provide the required trending trending process process to evaluate evaluate failures per Maintenance Maintenance Rule, Rule. Each plant plant should evaIuate evaluate the need to document LID surveillance surveillance test failures in their Corrective Corrective Action Programs.
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.
At this stage, Paul L. L, provided provided the the group with videovideo footage ofof actual
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.
                                                                                ~tual LID 400 torque tests performed at Cook    Cook Plant Plant. The The video depicted one            run the way Cook initially did it (prior to February one test IllJl                                                February 2002) using a test rig mounted mounted to the portal frame, frame, one test run the run  the revised revised way way (post-2/02)
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.
(post-2102) that that provided provided forfor hand-held hand-held instrumentation, instrumentation, and and then a demonstration demonstration of aa newly-designed newly-designed test rig ($I50K
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
($150K worth), developed with Framatome  Framatorne ANP, for testing the doors with a minimum of              of movement movement. The Framatome Framatome rig.rig, .
-Page 9 Noted as well were the existing as-found visual inspections of the LID area performed after Unit shut-down.
which Cook NP has not yet officiallyofficially brought brought into action, attaches to a bolt  bolt head on the outside of the LID surface, surface, and uses a digital scale for the hinge resistance. Motion  Motion in the LID during the torque test is kept at about 0.008",   0.008", and and experience experience with it shows that friction friction forces decreased decreased significantly.
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.
significantly. Cook is still utilizing utilizing the air dams to prevent the dynamic dynamic effect effect of rushing air.
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.
ofroshing I
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.
:I I
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.
I
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.
                                                                                                                                                                'I
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&deg; "Torgue Test" Methodology The primary focus of this issue centers on the function of the LIDs during the postulated Design Basis Accident.
Enclosure 2 Enclosure Request And Affidavit From WEC            WEe That Proprietary    Proprietary Information In Attadhment                Attachment B of  Be Withheld Enclosure        Withheld From Public Disclosure In Accordance                          Accordance With The Provisions of 10 CFR 2.390.
For all ice condenser plants, the Large Break LOCA (LBLOCA) is the bounding analysis.
* Westnshhouse ElectuicCompany WestiJlghouseElectric CoinPilIlY NiJde~
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.
NudeV$rKSe~i V0P.O.Qb35S P:Q..11il1l3SS PitsbgPemnsylva'nia        15S230-0355 Pitt3burgh;Pennsylviini;J lS2JO.()355 lISA USA                            .
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.
u.s.
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.
U.S. Nlic~
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
Nuclear RegUfatoty Regullatoiy Comkmission Commission                                    inrca td:
-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.
Ofrect      (412) 374-4643 ml: (412.)  374-63 Pocqll\ent  Cont.7i D~
By definition, deviation from these limits would constitute a degradation process warranting further evaluation.
DocunleAt Co-!lwl    Desk                                                Ditct Oirecl fa=
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).
fa: (412) 314-3846 3074-<3846 Washiogton, pC W<lShfugtQn,   DC :4055>0001 205554001.                                                  -mail: grtshaja@wes1ivghotsc.com c-mail;grcshaja@westitlgbolise.com l.Ti!.~~15.:R.:V.11m LTR-4C-D9-l5RS.           p-~
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.
P-Anacbmcnt 0'wzct CA Oou:""          W-Q9.2643 CAW-09-2643.
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.
                                                                                                  .~                14.:2009 AUgust 14,-2M0 Dalte August APPUCAnION APl>UCAtiONFOR        FOR WITHHOLDING W.MHOLDINCI PROPR,IEl"ARY PRQPREARY ORMATON FROM INfORMATION                    p~l.rCD~OR;E; FROM POBUCf        DMCLOSUR Subject
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&deg; open position) actually measured less than the associated closing force (that required to bold the LID still at the 40&deg; 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&deg; 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&deg; 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&deg; 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&deg; open position) actually measured less than the associated closing force (that required to bold the LID still at the 40&deg; 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&deg; 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&deg; 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&deg; 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:==
==Subject:==
"Sedions(lf noll) L'tR-ruDA,.Q6..106, Rev.T' (proprietary)  
      "Sedions(lf     Appliable Text noll)
'flM: lntonnation for whicb withholding is the iibQvc-refeienced.report is further in Affidavit CAW-()9-264) prQprifllaJy infOlIlJatioo.
                              "Sections of AppJi<:aQIeT~t          f, L'tR-ruDA,.Q6..106, Lt.-MADA 106, Rev.T' Rev. 2" (proietary)
WestingbouseElectric Company ILC. tbe,affitiavlt, Jetter, sets forth the bas!s onwhicbthe info.m&#xa2;ioo may withheJd ftom puislie diselosureby the with theconsidwations lisiedin pamgrnpb (b)(4) oflOCFR orUm Commi!!Sion's regulations.
(proprietary)
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$.Pittsburgb.
The ~
              'flM: proprietary ifomnation, lntonnation for  for whicb which withholding withholding is    li&#xa2;ing~ed:in is beingiequeed      in the  abov-refrenced report is the iibQvc-refeienced.report       is f er identified further i~tified in in Affidavit    CAW-09-2643 sign;d Affidavit CAW-()9-264)         sign~by. by ~ ~ pf~          t prQprifllaJy proprietary information, infOlIlJatioo.
1                              Electric Company WestingbouseElectric                             tbe,affitiavlt, ILC. 'LWTe              wbich~ies.tbis          this Jetter,   sets forth forth the   bas!s r
I Westinghouse              CompanyM                  affidavitwhicli-accompanies onwhicbthe info.m&#xa2;ioo may ~ withheJd ftom puislie diselosureby the Com~Q-!lliild:addtesses with letter, sets        the Isasis J-          ~ity pecificity theconsidwations regulations.
theconsiderations listedn        paragraph (b)(4) lisiedin pamgrnpb      (bX4) ofl          Sec&n~90 of OCFR Sectin2.390 oflOCFR                         orUmthe Commi!!Sion's Commission's I
Accordingly, A(;COI"dingly, this letter allt!lorizes this letter  authorizes the     \lti~n oftbe the utilization  of the awompanying accompanying affidavit by I>t)ke         Eae~_
Duke Eergy.
Correspondence with respec to the proprietary                      of the application for wittiding or the Co~ndence with res~t to the proprieta:tjr aspect$ (If the applic.:3tioJl for WitlihOlding or the Westinghouse Westinghouse affidavit affidavit should      refrenac'this letter, should referenCe*this     letter. CAW-09-2643, CAW-'C9-1643, and should              addressed to Should be addressed       to L. A. Gresham, Manager,
: 1. A.Gresham, LLC, P.O.
Manager, Regplatory Regplatoiy Compliance Box 35$.Pittsburgb.
35S,.Pittsbu-gh, pernrsylviama and Compli3JIce and Plant      Licensing, Westinghouse Piant Licensing,   Westinghouse Electric         Com~y Electric Company LLC,   P.O. Box                         P~~I~ 15230-0355.
15230-0355.
15230-0355.
a:; 0. &cuta(NRC OWFN1J$.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.
a:; 0.- &cuta(NRC
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
                      *acth (NRC OWFN1J$.1)
OWF.N2r-W)
              ~~
Thiokswes
                                                                                                                                                    ;
1 1
II II*
I


==Subject:==
Enclosure 2 Request And Affidavit FromWECThat From WEC.That Proprietary    Proprietary Information Information In AttachmentAttachment B      B of Enclosure  Be Withheld From Public Disclosure            Disclosure In Accordance Accordance With The Provisions of 10 CFR 2.390.
"Sedions(lf noll) L'tR-ruDA,.Q6..106, Rev.T' (proprietary)
CAW-Q9..2643 CAW-09-2643 JAFFDAVIT                                                                                                            -        -
'flM: lntonnation for whicb withholding is the iibQvc-refeienced.report is further in Affidavit CAW-()9-264) prQprifllaJy infOlIlJatioo.
I AFFIDAVIT I
WestingbouseElectric Company ILC. tbe,affitiavlt, Jetter, sets forth the bas!s onwhicbthe info.m&#xa2;ioo may withheJd ftom puislie diselosureby the with theconsidwations lisiedin pamgrnpb (b)(4) oflOCFR orUm Commi!!Sion's regulations.
COMMONW*_A1TH OF COMMONWEAi1H              OF PENNSYLVANMA:
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,
PENNSnVANIA:
ss ss I
  !!
COUNTY OF ALOEWNY:
Wore      lnCf,tbeuDdetSi~ed B/lf())"e In,  t uahe          auth.orio/, ~yappeared
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Revision as of 00:37, 14 November 2019

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  Duke Energy icon.png
Issue date: 08/25/2009
From: Brandi Hamilton
Duke Energy Carolinas, Duke Energy Corp
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
Download: ML093430506 (24)
v • d • e


Text

{{#Wiki_filter:\ _Duke ATTACHMENT B ATIACHMENT B OF ENCLOSURE 1 OF ENCLOSURE I CONTAINS CONTAINS PROPRIETAY PROPRIETAY BRUCE H BRUCE H HAMILTON HAMILTON Vice President I U-OvEnergy. r",EnergYe INFORMATION REQUESTED TO BE WITHHELD FROM PUBLIC INFORMATION DISCLOSURE PER 10 CFR 2.390. WHEN DISCLOSURE WHEN SEPARATED SEPARATED FROM Vice President McGuire Nuclear McGuire Station 

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ATTACHMENT ATIACHMENT BB OF ENCLOSURE ENCLOSURE 1, THE BALANCE OF THIS Duke Energy Dulce Energy Corporation Corporation LETTER MAY BE CONSIDERED NON-PROPRIETARY. NON-PROPRIETARY. MGOI VP //12700 MGOl 12700 Hage*s Ferry Road H<JBMS Ferry 28078' Huntersville. NC 28078 Huntersville, Road I 704-875-5333 704*875*5333 704-875-4809 fax 704-875-4809 f<Jx bhhamilton@duke-eneraycorn bhhamilton@duke-energy.com August 25, 2009 U.S. Nuclear Regulatory Regulatory Commission Commission Document Control Desk Washington, DC 20555-001 ATTENTION: Document ATTENTION: Document Control Desk

Subject:

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Subject:

Energy Carolinas (DEC), LLC Duke Energy LLC Nuclear Station, Units I1 and 2 McGuire Nuclear McGuire 50-370 Docket Nos. 50-369 and 50-370 I Catawba Nuclear Catawba Nuclear Station, Units 1 and 2 50-414 Docket Nos. 50-413 and 50-414 License Amendment Request (LAR) for Technical Technical Specification Specification (TS) t Condenser Doors, Response to Request for Additional 3.6.13, Ice Condenser Information (RAJ) Information (RAI) I This letter 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 McGuireMcGuire and Catawba Catawba Nuclear Nuclear Stations. The RAI was sent via electronic mail from Jon Thompson Thompson dated May May 21, 21, 2009. The \ draft response to the RAI was discussed discussed during during a conference conference call with the NRC staff on L 18, 2009. The NRC staffs questions June 18, Enclosure 1. Enclosure questions and DEC's responses responses are provided in I The additional provided in this RAI does not impact the conclusions additional information provided conclusions of the the I I' No Significant Hazards Hazards Considerations and the basis for the categorical exclusion categorical exclusion from i performing an Environmental/Impact performing Environmental/Impact Statement Statement presented presented in the October 2. 2, 2008 LAR LAR submittal. Specifically, the propOsed proposed revisions to TS T8 3.6.13 do not affect the current post-accident Containment Response post-accident Containment Response analysis of record. . Attachment B of Enclosure 1 Attachment I contains information information that the owner, Westinghouse Westinghouse Electric Electric Corporation (WEC), considers proprietary. In accordance accordance with the provisions provisions of 10 CFR 2.390, Enclosure 2 contains a request and affidavit CAW 2643 from WEC thaUhe thatthe information identified in Attachment proprietary information*identified Attachment B of Enclosure Enclosure 1 I be ~held withheld from public public Enclosure 3 provides disclosure. Enclosure provides the non-proprietary non-proprietary version of Enclosure Enclosure 1. 1, Attachment Attachment B. Aoo( www duke-energ.com www.duke-energy.com N~

August25, August 25,2009 2009 Nuclear NuclearRegulatory RegulatoryCommission Commission Page Page22 This ThisRAI RAIresponse responsecontains containsno noregulatory regulatorycommitments commitmentsfor forMcGuire McGuireororCatawba. Catawba. Please Pleasedirect directany anyquestions questionswith withregard regardtotothis thismatter mattertotoJulius JUliusW. W.Bryant Bryantatat(980) (980)875-875-4162. 4162. Very Verytruly trulyyours, yours, B. B. H. H. Hamilton Hamilton Enclosures Enclosures I I 

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August25, August 25,2009 2009 Nuclear Regulatory Commission Nuclear Regulatory Commission Page 33 Page xcw/ xc wi Enclosures Enclosures A. Reyes L.L. A. Reyes Regional Administrator, Region Regional Administrator, Region IIII U.S. Nuclear U.S. Nuclear Regulatory Regulatory Commission Commission Sam Nunn Atlanta Federal Sam Nunn Atlanta Federal Center Center 61 Forsyth 61 St., SW, Forsyth St., SW, Suite 23T85 Suite 23T85 Atlanta, GA Atlanta, GA 30303 30303 J. B. J. B. Brady Brady NRC Senior NRC Senior Resident Resident Inspector Inspector "McGuire Nuclear Station McGuire Nuclear Station G. A. Hutto G. III Hutto III NRC Senior NRC Senior ResidentResident Inspector Inspector Catawba Nuclear Catawba Nuclear Station Station J. H. J. H. Thompson Thompson (addressee (addressee only) Project Manager (MNS Project Manager (MNS and CNS) CNS) Nuclear Regulatory U.S. Nuclear Regulatory Commission Mail Stop 0-8 Mail 0-8 G9A Washington, DC 20555-0001 B. O.0. Hall Section Chief Division of Radiation Radiation Protection Protection Section 1645 1645 Mail Service Center " Raleigh, NC 27699 S.E. Jenkins Jenkins Section Manager Section Manager Division Division of of Waste Management Management Carolina Department of South Carolina South of Health Health and Environmental Control and Environmental Control 2600 Bull 2600 Bull St. St. Columbia, Columbia, SC SC 29201 29201

August 25, 2009 August 2009 Regulatory Commission Nuclear Regulatory Nuclear Page 4 OATH AND AFFIRMATION Bruce H. person who subscribed his name to the H. Hamilton affirms that he is the person the foregoing statement, and that all the matters foregoing herein are true and matters and facts set forth herein correct to the best of his knowledge. Bruce H. Hamilton, Site Vice President President Subscribed Subscribed and sworn to me: /iLgud ~ S; ;1.00"1 Date Date cl~ C. fh/Jnj N--otary otary Public U My commission a;; I~ expires: (% / commission expires: I, )0 I/ I,? lo {;r 

             .                     ""1    Date Date I

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Enclosure 1 Enclosure Response to NRC Response NRC Staff RAI Related Related to October 2, 2008 2008 LAR for TS 3.6.13, 3.6.13, IceIce Condenser Doors, NRC Staff Question SCVB#1 SCVB#I IThree (Three Parts; 1la, b, and 11c) a, 1lb, c) Please provide the following clarifications on TS 3.6.13 as to how Condition A and Condition B B are applied under the current TS versus how they are intended to be applied under the proposed TS. SCVB#1a: NRC Staff Question SeVB#1a: Surveillance Requirement Technical Specification Surveillance Requirement (TSSR) 3.6.13.1 3.6-13.1 and TSSR 3.6.13.4 3.6.13.4 are applicable to the lower inlet doors. TSSR 3.6.13.1 is performed performed at a frequency of 12 hours during modes 1, 2, 3,.& 3, & 4. TSSR 3.6.13.4 is conducted at a frequency of 18 months during outages. Please explain what condition statement statement the plant will be in upon failure to pass TSSR 3.6.13.1 3.6.13.1 - "Verify all inlet doors indicate indicate closed by the InletInlet Monitoring System." Is itit Condition A, Door Position Monitoring A, Condition Condition B, or both? 1f If the answer 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 NRC Staff Question Question SCVB#1a: SCVB#la: Revision 3.0 of the Standard Technical Specifications Westinghouse Plants Specifications (STS) for Westinghouse (NUREG-1431) is worded such that Condition A of STS TS 3.6.16 applies only to the (NUREG-1431) the Inlet Doors ("Inlet Doors" and "Lower Inlet Doors" represent synonymous synonymous terms) 1. 1 However, the current McGuire/Catawba McGuire/Catawba TS 3.6.13 wording does does not incorporate incorporate the-the- "Inlet" or "Lower Lower Inlet" text into the Condition A description 2.. As a result, Condition A of the current McGuire/Catawba McGuire/Catawba TS 3.6.13 is applicable applicable to all Ice Condenser Condenser Doors (Lower Intermediate Deck Doors, and the Top Deck Doors). The proposed Inlet Doors, Intermediate proposed revision to the McGuire/Catawba McGuire/Catawba TS 3.6.13 wording adopts the Westinghouse clarification Westinghouse STS clarification in Condition Condition A (i.e., (i.e., by adding the descriptor descriptor "Lower Inlet") so that only the Lower Lower InletInlet Doors are affected are affected by Condition A. For both both the current current McGuire/Catawba McGuire/Catawba TS 3.6.13 3.6.13 and the proposed McGuire/Catawba McGuire/Catawba TS 3.6.13, TSSR 3.6.13.1 is applicable applicable to the Lower Inlet Inlet Doors only ("Inlet Doors" and "Lower Inlet Inlet Doors" represent synonymous terms). If a Lower Inlet Door (or more represent synonymous more than than one Lower Inlet Inlet Door) opens while in aa Mode of Applicability Applicability (i.e., Modes Modes 1, 2, 3, or 4), TSSR 3.6.13.1 3.6.13.1 is not met, and only Condition Condition B is entered entered since the Condition Condition as as described described for such an occurrence occurrence would be "not closed". Under Under the the proposed proposed revision revision to McGuire/Catawba McGuire/Catawba TS 3.6.13,3.6.13, the one-hour one-hour Required Required Action Completion Completion Time for Condition Condition A would be entered entered only ifif one one or more more Lower Lower Inlet Ooor(s) Door(s) is physically physically restrained restrained from from opening. Such a condition condition could could arise arise if a Lower Lower Inlet Inlet Door blocking blocking device, device, which which is temporarily temporarily installed installed during during outages outages to prevent inadvertent prevent inadvertent opening of the doors, doors, is unintentionally unintentionally left in place and the UnitUnit is brought into aa Mode Mode of Applicability Applicability while in that configuration. that configuration. Page 1 ofof66

I i Enclosure 1 Enclosure .! I

Response

Response to NRC Staff RAJ RAI Related October 2,2008 Related to October 2, 2008 LAR for TS 3.6.13, Ice Ice Doors, Condenser Doors. Condenser NRC Staff Question SCVB#1 NRC SCVB#1b: 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 discovered involving the the Intermediate Deck Doors or the Top Deck Doors. The applicable Intermediate applicable surveillance surveillance requirements are are TSSR 3.6.1"3.2 Intermediate Deck Doors and TSSR 3.6.13.3 3.6.13.2 for the Intermediate 3.6.13.3 for the Top Deck Doors. Please Please explain which part of the surveillance requirements surveillance requirements Condition A under could put the plant in Condition under the current TS? Response to NRC Staff Question SCVB#1b: DEC Response SCVB#1 b: (NUREG-1431) is worded such that Westinghouse Plants (NUREG-1431) Revision 3.0 of the STS for Westinghouse Condition A of STS TS 3.6.16 applies only to the Inlet Doors ("Inlet .condition (uInlet Doors" and "Lower "Lower Inlet Doors" represent synonymous terms) 1~ However, the current McGuire/Catawba McGuire/Catawba TS 3.6.13 wording does not incorporate incorporate the "Inlet" or "Lower Inlet" text into the Condition Condition A description description 2. Condition A of the current McGuire/Catawba 2 As a result, Condition McGuire/Catawba TS 3.6.13 is Condenser Doors (Lower Inlet Dbors, applicable to all Ice Condenser applicable Intermediate Deck Doors, and Doors, Intermediate and the Top Deck Doors). Therefore, ifif TSSR 3.6.13.2 is not satisfied due due to ice, frost oror debris physically restraining intermediate deck door(s) from opening and/or restraining one or more intermediate TSSR 3.6.13.3 is not satisfied due to condensation, frost, or ice physically restraining restraining more top deck door(s) from opening, the current McGuire/Catawba one or more McGuire/Catawba TS 3.6.133.6.13 wording would require entry into TS 3.6.13 Condition A. A The proposed revision to the McGuire/Catawba McGuire/Catawba TS 3.6.133.6.13wording wording adopts the the clarification in Condition A (i.e., by adding the descriptor "Lower Westinghouse STS clarification Westinghouse "Lower affected by Condition A 1. Inlet") so that only the Lower Inlet Doors are affected 1. Therefore, ifif satisfied for any reason, the proposed 3.6.13.2 and/or TSSR 3.6.13.3 are not satisfied TSSR 3.6.13.2 McGuire/Catawba TS 3.6.13 wording revised McGuire/Catawba wording would only require 3.6.13 require entry into TS 3.6.13 Condition B. This is appropriate appropriate since the Intermediate Intermediate Deck Doors and Top Deck thermal/humidity barriers, and their time-dependent Doors are primarily thermal/humidity behavior during time-dependent behavior during an accident scenario air/non-condensable gases scenario (i.e., allowing the passage of air/non-condensable gases from the the compartment to the upper lower compartment upper compartment blowdown) is not quantified compartment during initial blowdown) quantified containment response analysis in the containment 3. As such, for the case where one or more analysis 3. Intermediate Deck Door(s) or one or more Top Deck Door(s) is/are inoperable, Intermediate inoperable, the 14 McGuire/Catawba TS 3.6.13 Condition B is Required Action Completion Time of McGuire/Catawba day Required appropriate and consistent with the Westinghouse appropriate Westinghouse STS. of 6 Page 2 of6

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                                                                                                        !I Enclosure 1 Response to NRC Staff RAI Related Response                           Related to October 2. 2, 2008 LAR for TS 3.6.13.

3.6.13, Ice Ice Ii Condenser Doors, Doors. NRC' NRC Staff Question Question SCVB#lc: SCVB#1 c: I The tAR LAR proposes to add a new note to TS Actions indicating entry into Condition B for Actions indicating Intermediate Deck and Top Deck Doors is not required due to personnel the Intermediate personnel standing on or opening doors for short durations to perform required surveillances, minor I maintenance, or routine maintenance, routine tasks. performance of the same activities under What condition entries are made during the performance current TS? What is the duration it normally the current activities? normally takes to complete these activities? Notes 1 and 2 under Actions in the proposed TS could allow multiple doors to be open description of the activities that will be covered provide a brief description at the same time. Please provide I by the proposed Note 2 and if they in fact require multiple multiple doors to be opened concern staff has with these activities is potential simultaneously. The concern potential for ice bed condenser flow.paths. Please address these concerns sublimation, melting, and ice condenser concerns in your response. Proposed Note 2 did not indicate Proposed indicate a duration for these activities. However, a duration a' duration duration of mentioned in the Bases section. What is the reason for not including < 4 hours is mentioned including thethe time of < 4 hours in Note 2? Also, discuss acceptability of < 4 hours time in your discuss the acceptability response to the question immediately immediately above. Response to NRC Staff Question SCVB#1c: DEC Response McGuire/Catawba TS 3.6.13 is entered Condition B of the current McGuire/Catawba personnel open entered when personnel Intermediate Deck Door(s) or lop one or more Intermediate Door(s) for any duration to perform Top Deck Ooor(s) perform maintenance, or routine tasks. All of these evolutions typically surveillances, minor maintenance, approximately 2 hours or less to complete. Condition entry for these tasks is not require approximately required if doors are not opened or if personnel personnel are standing on these doors. The proposed new Note 2is required surveillances, intended to relate only to required 2 is intended surveillances, minor minor maintenance, and routine tasks as defined maintenance, defined in the License Amendment Amendment package package dated activities would include tasks that are necessary October 2, 2008. These activities' October necessary to ensure ice ice condenser operability condenser operability (e.g inspection, light housekeeping), (e.g...., door visual inspeGtion, housekeeping), require only a amount of time to perform (typically 2 hours or less), and involve minimum amount involve a small number of personnel 3. number 3. These tasks would not be expected expected to require the opening of I multiple doors simultaneously. maintenance activity (e.g. ice basket extended maintenance multiple simultaneously. An extended weighing) could require multiple doors weighing) basket doors to be opened simultaneously. For this situation, I Condition B of both the current and proposed McGuire/Catawba TS 3.6.13 would be proposed McGuire/Catawba be 

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I temperature at least entered which requires monitoring of the ice bed temperature entered least every every four hours approach the melting point 2. temperatures do not approach to ensure maximum ice bed temperatures 2 . In Condition B ensures there Completion Time of CondITion 

                                                                                                       ~I addition, the 14 day Required Required Action Completion would not be a significant significant loss of ice from sublimation thro!Jgh the ice bed is not affected by the opening through sublimation 2.2. The flow channel clearance clearance opening of doors since the applicable doorsdoors     'I physically distinct from flow channels and these doors fUnction are in an area physically                                                        function mainly to Page 3 of6 of 6

Ii 1 Enclosure 1 Enclosure Response to NRC Staff RAI Related to October 2, 2008 LAR for TS 3.6.13, Response Ice 3.6.13, Ice I I Condenser Condenser Doors, open and relieve pressure blowdown phase of a large break Design blowdown Imy~r compartment pressure from the lower compartment of containment during the Design Basis Accident (DBA). Therefore d.oor is already fulfilling this DBA function. door the* Therefore an open I The general intent intent in adding the proposed Note 2 to the McGuire/Catawba McGuire/Catawba TS 3.6.13 3.6.13 Actions is the adoption Westinghouse STS 3.6.16 Bases wording. During the adoption of the Westinghouse the internal review internal review of the LAR submitted. October 2, 2008 (prior to submittal to NRC), submitled.October' NRC), it waswas determined that wording included in the STS 3.6.16 Bases that identifies determined identifies criteria criteria for statement would be better positioned in the actual technical entering an action statement entering specification Operator expediency), rather specification (for Operator document. The STS rather than in the Bases document. STS 

.3.6.16 Bases wording
  • 3.6.16 wording does not identify a timeframe timeframe for "short duration". Therefore, it was determined Condition B four hour completion time for ice bed temperature determined that the Condition temperature verification would be invoked since itit represented a limit already prescribed by the the specification and easily bounded the expected technical specification technical timeframe expected timeframe for performing performing routine surveillances inspections: The four hour timeframe defining a "short surveillances and inspections:

duration" entry is considered a technical specification clarification, and as such was specification clarification, was determined to be better left in the TS Bases document. determined document. NRC Staff Question SCVB#2 II reference to the attachments In reference attachments containing UFSAR pages marked-up to show containing existing UFSAR . the proposed proposed changes, please clarify if if the changes are same as those referencedreferenced in the last paragraph Section 2.2 of Attachment paragraph of Section Attachment 1. If Ifthey are different, give us a time time II line 10CFR50.59 changes to the McGuire tine of the 10CFR50.59 UFSAR, and when it was recognized, McGuire UFSAR, recognized. I proportioning characteristics that the flow proportioning requirement characteristics of the inlet doors is not a design requirement McGuire and Catawba. for McGuire Question SCVB#2: Response to NRC Staff Question DEC Response SCVB#2: I marked-up McGuire The marked-up UFSAR pages included with the LAR package McGuire UFSAR package dated October dated October from the revisions that were made to the McGuire UFSAR as a different from 2, 2008 are different I OCFR50.59 evaluation result of the 10CFR50.59 described in Section 2.2 of Attachment 1 of the evaluation described the same same LAR package 3. Attachment 1 of the LAR describes the removal of

3. Section 2.2 of Attachment I description of the "double break" scenario, in which a small break LOCA event the description I occurs first, followed by a large break LOCA event in rapid succession.

occurs was succession. ' It was determined in early 2005 that the "double break" scenario was beyond the design basis determined basis . of the McGuire McGuire station (reference (reference detail in Section 3.3.1 of Attachment Attachment 1 I of the LAR tAR package), and the UFSAR UFSAR was subsequently 10CFR50.59 evaluation subsequently revised via a 10CFR50.59 evaluation in in February of 2005 44.. The Catawba'UFSAR February Catawba UFSAR did not contain outdated outdated references to the the therefore did not need revision in 2005 to reflect this "double break" scenario, and therefore this  : , determination. Page4of6 Page 4 of 6

Enclosure 1 Enclosure

Response

Response to NRC Staff RAI Related to October October 2. 2, 2008 LAR for TS 3.6.13, Ice Condenser Condenser Doors, The conservative flow proportioning characteristics of the Lower Inlet Doors was proportioning characteristics was recognized prior to 2005 by the Ice Condenser Utility Group recognized Group (ICUG). (ICUG). At the ICUG ICUG Technical Conference held at the Donald C. Cook plant in 2002, the subject was Technical Conference was discussed at length 5. discussed meeting summary from that conference

5. The relevant pages of a meeting conference Enclosure in conjunction with the response Attachment A to this Enclosure included as Attachment are included response to item SCVB#3 below. The proposed UFSAR changes shown in the LAR submitted

$CVB#3 submitted on implemented after NRC approval October 2, 2008 will be implemented October approval of that LAR. NRC Staff Question NRC SCVB#3 Question SCVB#3 reference to the statements In reference paragraph 3 of Section statements in paragraph Section 2.4 of of Attachment 1, please discussed in interpretation in 2002 that was discussed provide copies of relevant pages of ICUG interpretation in that year's ICUG Technical Conference. ICUG Technical Conference. DEC Response to NRC Staff Question Question SCVB#3: interpretation of the Lower Inlet Door 40 Degree refers to the interpretation question refers The RAI question Degree Torque Torque Test series (TSSR 3.6.13.6) results. Copies of relevant pages of the ICUG Technical Conference meeting summary Conference summary held at the Donald C. Cook Nuclear Nuclear Plant in Bridgman, Michigan Michigan in 2002 are included in Attachment included Attachment A to this Enclosure 5 5. NRC Staff Question SCVB#4 It was stated Attachment 1 that inlet door movement stated in page 11 of Attachment characteristics (after movement characteristics (after directly to the Containment initially breaking away) are not tied directly Containment response analysis and Westinghouse (OEM) letter. Please provide copies of relevant pages of referenced a Westinghouse referenced justification. Staff would also like to be informed if the appropriate justification. the letter containing appropriate the removal of TSSR 3.6.13.6 was discussed with the OEM, and if so, provide proposed removal proposed us provide us description of the OEM's response. with a brief description Response to NRC Staff Question SCVB#4: DEC Response RAI question refers The RAJ a refers to a letter written by the OEM (WEC) in responseresponse to a contracted task to formally document the original design basis of the lower contracted Lower Inlet Doors Doors Catawba as it relates to the Technical McGuire and Catawba at McGuire Specifications. Copies of the Technical Specifications. the referenced OEM letter are included as Attachment B to this relevant pages of the referenced . 6 discussed in the LAR package As discussed package dated (lBlOCA and accidents (LBLOCA dated October 2, 2008, the accidents SBLOCA) are separate SBlOCA) concurrently or in rapid succession. A separate events and cannot occur concurrently LBLOCA does not require the flow proportioning lBLOCA proportioning function Lower Inlet Doors to of the lower energy; as under these high energy maldistribution of break energy; prevent maldistribution energy conditions ports conditions the ports 

                                              . Page 5 of of66                                               i

Enclosure Enclosure I1

Response

Response to to NRC NRC Staff Staff RAI HAl Related Related to to October October 2, 2, 2008 2008 LARLAR for for TS TS 3.6.13, 3.6.13, Ice Ice Condenser Condenser Doors,Doors, in in the the Crane Crane Wall Wall are are designed designed to to distribute distribute thethe inflow inflow toto the the ice ice condenser. condenser. The The

SBLOCA, SBLOCA, as as anan independent independent low low energy energy event, event, does does notnot propagate propagate to to aa LBLOCA LBLOCA and and therefore preventing steam bypass from getting to the therefore preventing steam bypass from getting to the upper compartment of upper compartment of containment containment (ostensibly (ostensibly prior prior to to aa subsequent subsequent LBLOCALBLOCA high high energy energy event) event) is is not not necessary.

nece..fosary. The The proposed proposed removal removal of ofthe the TSSR TSSR 3.6.13.6 3.6.13.6 Lower Lower Inlet Inlet Door Door Torque Torque test test series series (and (and incorporation incorporation of of aa freedom freedom of of movement movement test test into into SR SR 3.6.13.5) 3.6.13.5) was was not not formally formally discussed discussed withwith the the OEM. OEM. As As noted noted inin the the LAR LAR package package dateddated October October 2, 2, 2008, 2008, there there isis an industry precedent (TSTF 429-A) for an industry precedent (TSTF 429-A) for reviSing an revising an ice ice condenser-related condenser-related technical technical specification specification using using this this approach. approach. TSTF TSTF 429-A 429-A was was approved approved by by NRC NRC inin September September

2003, 2003, and and reflects reflects aa revision revision toto the the Ice Ice Condenser Condenser Ice Ice Bed Bed Mass Mass Determination Determination statistical statistical analysis analysis and and sampling sampling methodology methodology governed governed by by McGuire/Catawba McGuire/Catawba TSSR TSSR 3.6.12.4 3.6.12.4 and and TSSR 3.6.12.5 7 .

TSSR 3.6.12.57. Enclosure Enclosure I1 References References 1.

1. Westinghouse Westinghouse STS STS 3.6.16 3.6.16 and and BASES BASES (NUREG-1431, (NUREG-1431, Rev. Rev. 3, 3, Volume Volume 1) 1)
2. Current McGuire/Catawba TS 3.6.13
2. Current McGuire/Catawba TS 3.6.13 and TS BASES and TS BASES 3.
3. October October 2, 2, 2008 2008 LAR LAR package, package, Attachment Attachment 1, 1, page page 99 ofof2727
4. PIP M-04-5115,
4. PIP M-Q4-5115, CA#34 CA#34 5.
5. ICUG ICUG Meeting Meeting Summary Summary -- July July 2002, 2002, PgsPgs 7-10 7-10 (see (see Attachment Attachment AA of of Enclosure Enclosure 11 in in' this this submittal) submittal) 6.
6. Westinghouse Westinghouse LetterLetter LTR-RIDA-06-106, LTR-RIOA-06-106, Rev Rev 2, 2, Portion Portion Titled Titled "Scope "Scope andand Clarifications Clarifications Number Number 8" 8" (see (see Attachment Attachment BB of of Enclosure Enclosure 11 inin this this submittal) submittal) 7.
7. TSTF-429, TSTF-429, Revision Revision 3, 3, dated dated November November 2003 2003 Page Page66ofof66

Attachment Enclosure 1I Attachment A To Enclosure Summary For July Meeting Summary Selected Pages From Meeting 16-18, 2002 Ice July 16-18,2002 Condenser Utility Group Technical Condenser Conference Technical Conference I 

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2002 ICUG Technical Technical Conference-Conference - Page 7 1. 

       ). Primary focus of the guide would ,be     be to educate/enlighten educate/enlighten Work Control and plant management                     significance of management to the significance     of I/C surveillances the IIC  surveillances in an era of ever-shortening ever-shortening outages.
2. The IG would need to be comprehensive; comprehensive; i.e., it would encompass encompass all the IIC I/C TSs and the design principles principles behind them.
3. Guide would include include a reference section section that would lead to the public domain, so that the bases in the guide will tie to documents we all share.

docwnents

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

support the implementation From these comments, the following outline of the ICUG Implementation Implementation Guide was developed: developed: lo. 

       .. Section Section 1:   Operating Experience I: Operating   Experience (plant (Plant and Regulatory)

Regulatory) o. 

       .. Section n:

Section IH: Design Philosophy (link to TSs) b. 

       .. Section   m: Implementation Section III:   Implementation ofTS of TS I/ Maintenance Support Support b.
       .. Section Section IV:    References (linked to public domain)

N: References Paul L. and Russ took action to begin assembling information for Section II1, Ill, with Paul taking the Ice Mass TS and Russ taking taking the I/C IIC Door TS LID issues. As this develops, assistance will will be needed from ICUG members. The next agenda item involved the recent recent issues regarding I/C Door TS, in particular, the surveillance tests surrounding the regarding the lIC Lower Inlet Doors. It bad had been determined detennined that, due to continuing continuing confusion about this subject by the staff and others, documentation of an industry -documentation 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 addressingaddressing regulatory regulatory issues. Russ gave a synopsis of what what brought this item to the ICUG agenda: agenda: the NRC Resident Resident at Catawba Catawba had raised raised the issue of LID testing, in particular particular the fact that there was no process process installed installed at CNS for tracking "failures" of the LID tests after after an as-Ieft as-left surveillance. This was deemed a problem since, by 1JOCFR50.65 guidance (Maintenance .problem (Maintenance Rule), failures of high-risk, safety-significant ofhigh-risk, safety-significant systems needed to be trended. He issued issued a non-cited violation (against Criterion XVI) to Catawba the week prior to the ICUG meeting, Criterion XVI) meeting, as a result. He He had other issues as well, which tum turn out to be similar to those surfaced surfaced by the Residents at the other Region 11 plants: 

       .~
       ,    As-left testing versus versus as-found as-found testing.

testing, why not do both? both? o. Do Adequacy of the LID 40° 401 Torque Test to determine operability

o. MR
       .. MR trending trending The ICUG discussion discussion of this item at the meeting was extensive; what follows is aa summary  summary of it that also served as the industry position basis:

In February February of 2002, Cook Nuclear of2002, Nuclear Plant Unit 1I entered a planned refueling outage, at which time the Ice Condenser Lower Inlet Doors (LIDs) were tested per the plant's surveillance surveillance requirements. requirements. At Cook NP, the surveillances surveillances on the LIDs are performed in both the as-found and the as-left as-Ieft condition. condition. The remaining ice condenser condenser plants (IV(TVA-Sequoyah, A-Sequoyah, TVA-Watts Duke-Catawba TVA-Watts Bar, Duke-Catawba and Duke-McGuire, Duke-McGuire, all in Region Region IH)n) conduct conduct the LID surveillances surveillances only in the as-left condition. The LID testing performed at Cook NP Unit II was witnessed witnessed by NRC personnel, personnel, and at the time of the tests several issues arose about the methodology being ofthe implemented to perform them. Ultimately, implemented Ultimately, Cook NP determined determined that their test procedure procedure for the LIDs was not adequate. Cook Cook personnel persormel then corrected the test procedure and re-tested re-tested the Unit I LIDs. LIDs.. Unit 2 LIDs were addressed through approval of an emergency emergency Technical Specification Specification amendment allowing Unit 2 to operate until its next outage without further fuirther testing.

1 I 2002 IICUG Conference - Page CUG Technical Conference Page 8 As a result of these As these events, resident NRC inspectors queried personnel at the the Region Region IIII plants plants regarding the LID LID tests, and during during I the spring 20022002 outage season LID testing and and associated procedUres procedures were reviewed and in in some cases witnessed by the staff staff at at those stations. Subsequently, NRC personnel personnel atat Sequoyah Sequoyah and and Catawba Nuclear Stations Stations requested clarification clarification onon the the following issues: i- 

        ~                                 as-left LID testing in lieu of as-found Basis for performing as-left                                 as-foundLID testing. This  This issue issue concerns a Licensee's Licensee's ability to show    I that the LIDs areare still still operable at the end of a cycle (or   (or at any otl!er other time after the current as-left as-left tests).                     r l
        ~      Validity of the methodology for performing the        the LID 40°40' "Torque Test" Test." This issue involves the evaluation evaluation of free LID i
       .~

movement and friction in the LID hinges (required Process for trending LID (required by the current surveillance requirements) LID failures for Maintenance Rule. This This issue requirements).. issue surfaced after it was noted by NRC that the LIDs LIDs I are included in MR as high-risk, safety safety significant components. components, but no process for trending trending failures exists since the LIDs cannot "fail" the as-left as-left surveillance surveillance test (LIDs (LIDs are not not required operable in Mode 55 when the SR tests are performed). Pursuant to the generic position, the following topics were discussed at length: 

        )I.. LID design basis
2. acceptance criteria basis (e.g" LID surveillance test acceptance (e.g;, empirical data, analysis, or other)
3. surveillance requirement Current surveillance requirement link to IOCFR50.36 IOCFR50.36
4. Current industry procedures Current procedures for identifying unexpected changes from last as-left LID tests
5. Current industry procedures procedures for performing the LID Opening Force Test
6. Current industry procedures procedures for performing the LID 400 Torque Torque Test
7. experience with the LID 400 Industry experience 40' Torque Test and associated results
8. LID contribution functional cap8bility contribution to :functional capability ofIce of lee Condenser Condenser (Maintenance Rule)

Representatives Representatives from each of the utilities provided plant-specificplant-specific information and recent experience experience related to the surveillance surveillance -testing of LIDs. Salient -testing Salient points from past discussions with resident inspectors were also exchanged, exchanged, as well as past LID testing issues and plant events. While each utility has a different different approach approach for addressing the three outlined outlined issues brought brought by the NRC residents, the bases bases behind the approaches approacbes is essentially the same and adequately adequately represents that the industry is not divergent divergent in its interpretation interpretation ofof the requirements set forth in the current Ice Condenser Door technical specification. Issue: As-Left As-Left LID Surveillance Surveillance Testina Testing versus As-Found LID Surveillance Surveillance Testing Testing representatives agreed that as-left (post-ice bed maintenance) All representatives maintenance) surveillance surveillance testing is sufficient to show the LIDs will be capable capable of performing their safety function. Combined industry operating operating experience has verified verified the absence absence of any mechanism mechanism for LID degradation degradation during during normal operation operation ("innage"). Innage-related anomalies (e.g., a steam leak in containment ("innage"). Innage-related excessive containment or excessive AHU drain pan AHU pan leakage) that could potentially challenge LID performance performance are addressed addressed in each plant's Corrective Action Program including, Program including, asas appropriate, appropriate, operability evaluation per operability evaluation per the guidance outlined outlined in Generic Letter 91-18. Outage-related Outage-related ice i,ce bed bed maintenance, maintenance, however, does present present conditions conditions that commonly commonly degrade degrade LIDs. These These conditions conditions include exposure exposure of the LIDs to ice and and water water outfall. As a result of these activities and the potential degradation degradation that they impose, LID LID restoration is a normal activity activity at the conclusion conclusion of each maintenance maintenance outage. outage. Final restoration restoration activities activities include completion completion ofof the required required surveillance surveillance testing. During the coursecourse of performing this LID testing, "failures" "failures" (when (when they occur) have have typically typically been been attributed attributed to outage outage maintenance-induced maintenance-induced ice build-up on the LIDs, the compressive compressive effect of LID blocking blocking hardware, or the known sensitivity of known sensitivity of the the test test parameters parameters when when performed by inexperienced inexperienced personnel. personnel. The satisfactory as-left satisfactory completion of this as-Ieft LID testing testing meets meets the the applicable applicable surveillance surveillance requirements requirements by assuring the limited condition for operation operation of the LIDs will be met met for the duration of the surveillance surveillance interval as required by IOCFRS0.36 I0CFR50.36 (c) (e) (3).

ICUG Technical 2002 ICUG Technical Conference - Page 99 well were the existing as-found Noted as well as-foundvisual inspections inspections ofofthe LID area area performed performed after after Unit shut-down. shut-down. Some utilities utilities visually inspect visually inspect the the LID seal seal and and door surfaces, surfaces, while while others do a general visual visual inspection to ascertain ascertain anomalous conditions conditions that might affect LID operability, such as ice might ice build-up or or other degradation. degradation- These These as-found inspections inspections are are formal formal procedures procedures at at some plants. Each plant (as(as appropriate) should evaluate evaluate the need to proceduralize proceduralize these inspections to verityverify that as-found LID condition is being evaluated condition evaluated to appropriately appropriately identifY identify any Conditions Adverse to Quality (CAQ). If during the as-found as-found inspection aa CAQ CAQ is is discovered, discovered, further evaluation evaluation,of of the LID condition would be indicated, up to and including a surveillance surveillance test. It was determined during the discussion that LID LID "cycling" "cycling" (i.e., (i.e., opening and and closing) prior to anyany as-found inspections or or as-left as-left was practically surveillance tests was practically unavoidable. 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. LIDs, inadvertent LID All plants reported experiencing inadvertent LID cycling during containment ventilation ventilation transients, which occur as the Unit changes modes and and as personnel air locks and and containment containment equipment equipment hatches are are opened in preparation for outage work. In preparation for some plants addition, at some plants the only ingress path to the ice condenser Lower Plenum after shutdown is through a LID, which requires one LID to be opened just to gain access to the area. There at least one There is is no failure mechanism being masked masked by this LID cycling. cycling. The seal design is such that the seal does not freeze to the door surface; any freezing condition 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 10CFRSO, IOCFR50, Appendix B, any CAQ must be identified and corrected, corrected, whether it is discovered via a surveillance test or other means. The as-found visual inspections inspections provide the primary basis for identifYing identifying CAQs.. CAQs. LID maintenance maintenance performed at the cOIlclusion conclusion of the outage is generally defined as those routine activities needed to restore the doors from the effects of outage work. This maintenance, maintenance, since it is occurring prior to the as-Ieft as-left surveillance tests, must be limited to maintenance maintenance that repairs a condition condition caused by other outage maintenance activities or a condition for which the as-found as-found condition ofthe of the door has been evaluated. evaluated, For example, allowed routine maintenancemaintenance 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 maintenance wouldneed to be evaluated to determine the cause of the condition/adjustment. condition/adjustment. After routine routine maintenance is performed, a "soak tim maintenance time"en is conservatively conservatively allotted before the surveillance tests are performed, performed, to allow the LID to settle. Each plant (as appropriate) senle. appropriate) should evaluate the need to establish allowed maintenance maintenance practices and "soak times" prior to to performing the as-left LID tests. Issue: Validity of LID 40' "Torque Test" Methodology 40° "Torgue Methodology The primary focus of this issue centers centers on the function of the LIDs during the postulated postulated Design Basis Accident. Accident- For all ice ice condenser condenser plants, the Large Large Break Break LOCA (LBLOCA)(LBLOCA) is the bounding analysis. The only other licensing basis analysis analysis is applicable 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 int!!Jlded (and analytically analytically assumed) to open immediately immediately and evenly upon initiation oft)1e of the Large Large , Break Break or Small Break LOCA, and then recover recover their position position and modulate the longer-term 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 Force Test and the LID Torque Test, and supports supports the LBLOCA LBLOCA analysis modeled modeled by by the TMD/LOTIC TMDILOTIC codes codes as well as the SBLOCA MAAP MAAP codecode for the Cook NP sump inventory analysis. The Duke plants are currently licensed to a TMD/GOTHIC lMD/GOnnC code model which does allow cross-flow between between elements elements and has a more detailed detailed nodalization nodalization than the original LOTIC Lonc work. Analysis Analysis runs using the GOTHIC GOTHIC code code show that the LIDs do not need need to open open evenly evenly or recover recover and and modulate modulate steam flow into the ice ice bed after after the DBA has initiated. While While not all ice condenser plants are are licensed to this model, model, it supports the ICUG view view that the current current Ice Ice Condenser CondeDser Door technical specification specification is conservative. conservative. In order order to show show the functional functional capability capability of the LIDs to modulate modulate steam steam flow after after the initiation initiation of either the LBLOCA or or SBLOCA, the surveillance SBLOCA, surveillance test (the LID LID Torque Test) identifies identifies limits limits for opening opening torque, closing torque, and frictional frictional torque torque with the LID positioned at 40" 400 open open (this represents represents the the free opening opening position position of the doors before significant significant contact against the shock shock absorbers absorbers or foam bags). Generally, Generally, the the

ICUG Technical 2002 ICUG Technical Conference Conference -- Page 10 10 opening and closing opening closing forces forces are are determined by utilizing aa hand-held or or rig-mounted scale scale (spring (spring or or digital), and the forces forces converted (as converted (as appropriate) appropriate) to torque torque at at the hinges. Once the opening opening and closing closing values are determined determined by test, test, the the frictional component isis derived by taking component taking the the difference difference between between them andand dividing by 2. 2. Since Since the LIDs were notnot originally design-tested design-tested empirically or analytically in in this this capacity, these numbers are representative of a new LID installed to applicable construction tolerances. By By definition; definition, deviation fromfrom these these limits would constitute aa degradation process warranting further further evaluation. During the discussion ofthis, During of this, all plants reported limited situations situations (past (past and present) present) where the indicated opening force on the required to open scale (that required open the the LID further from the 40° 40' open open position) actually measured measured less than the associated closing force (that required (that required to bold hold the LID still at the the 40° 400 open open position). While While this situation situation did not cause cause any LID tests to exceed exceed the limits, itit did raise specified limits, raise the question of of test test 'methodology methodology validity, validity, aa concern concern also raised raised by the resident inspectors. inspectors. Several valid points were identified in response to this: valid I. The accuracy I. accuracy of the scale used in in the LID 40° 400 Torque TestTest can contribute contribute to misleading misleading indicated opening and closingclosing forces. Both spring and digital scales are used by the the industry industry for these tests. Measurement of the LID

2. Measurement LID opening and closing forces forces for the the surveillance surveillance are influenced by "dynamic "dynamic effects," which are are combination of factors such essentially a combination such as as "bouncing" (allowing the LID LID to hit 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 derived frictional component of the LID 400 40° Torque Test, whether it is positive or negative, is a sufficient indicator 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 in the LID Opening Torque Test and the LID 40° 40' Torque Test surveillance procedures. Based on the technical information and operating experience surveillance experience shared by the utilities, ICUG feels that the surveillance requirements continue current LID surveillance conservative in determining the functional capability continue to be adequate and conservative the capability of the LIDs. ICUG LIDs, ICUG consensus consensus is that the generic generic Ice Ice Condenser Condenser Door Door Technical Specification (STS version) is acceptable and Technical Specification conservative as currently written, and that revisions to it, as necessary, conservative necessary, should be handled on a plant-specific plant-specific basis. Trending LID Surveillance Issue: Trending Surveillance Test Failures for Maintenance Maintenance Rule All plants indicated similar similar general general scoping scoping of ice condenser condenser components into the Maintenance Rule (MR) program, but the industry differed differed on the definition of what actually constitutes constitutes a functional failure (FF) of the ice condenser. All agreed that individual individual component "failures" (such as a LID) did not necessarily necessarily indicate an IIC I/C FF (particularly when MR scopingscoping is based on safety function rather than an individual component component basis), but that it needed linkage to analytical bases such as the TMD/LOTIC TMDILOTIC or TMD/GOTHlC TMD/GOTHIC models via a blockage blockage limit (generally (generally noted as 15% 15% allowable allowable blockage blockage due to ice build-up). Some plants have have clearly clearly defined limits in this regard. Since this is a plant-specific determination, the industry agrees that different plant-specific determination, different approaches approaches to MR scoping will exist. Of more interest to the staff is the requirement requirement to trend failures of high-risk, safety-significant safety-significant components. As-found inspections inspections of the LIDs provide provide the primary basis to identifyidentifY and trend failures of the doors within the plant's Corrective Action Program. It was generally generally agreed that, even though during an outage the LIDs are not required to be operable, operable, as-left as~left LID surveillance surveillance test failures, if they occur, should be documented documented in a plant's Corrective Corrective Action Action Program, and that that would provide the required trending trending process process to evaluate evaluate failures per Maintenance Maintenance Rule, Rule. Each plant plant should evaIuate evaluate the need to document LID surveillance surveillance test failures in their Corrective Corrective Action Programs. At this stage, Paul L. L, provided provided the the group with videovideo footage ofof actual 

                                                                               ~tual LID 400 torque tests performed at Cook     Cook Plant Plant. The The video depicted one            run the way Cook initially did it (prior to February one test IllJl                                                 February 2002) using a test rig mounted mounted to the portal frame, frame, one test run the run  the revised revised way way (post-2/02)

(post-2102) that that provided provided forfor hand-held hand-held instrumentation, instrumentation, and and then a demonstration demonstration of aa newly-designed newly-designed test rig ($I50K ($150K worth), developed with Framatome Framatorne ANP, for testing the doors with a minimum of of movement movement. The Framatome Framatome rig.rig, . which Cook NP has not yet officiallyofficially brought brought into action, attaches to a bolt bolt head on the outside of the LID surface, surface, and uses a digital scale for the hinge resistance. Motion Motion in the LID during the torque test is kept at about 0.008", 0.008", and and experience experience with it shows that friction friction forces decreased decreased significantly. significantly. Cook is still utilizing utilizing the air dams to prevent the dynamic dynamic effect effect of rushing air. ofroshing I

I I

I 

                                                                                                                                                               'I

Enclosure 2 Enclosure Request And Affidavit From WEC WEe That Proprietary Proprietary Information In Attadhment Attachment B of Be Withheld Enclosure Withheld From Public Disclosure In Accordance Accordance With The Provisions of 10 CFR 2.390.

  • Westnshhouse ElectuicCompany WestiJlghouseElectric CoinPilIlY NiJde~

NudeV$rKSe~i V0P.O.Qb35S P:Q..11il1l3SS PitsbgPemnsylva'nia 15S230-0355 Pitt3burgh;Pennsylviini;J lS2JO.()355 lISA USA . u.s. U.S. Nlic~ Nuclear RegUfatoty Regullatoiy Comkmission Commission inrca td: Ofrect (412) 374-4643 ml: (412.) 374-63 Pocqll\ent Cont.7i D~ DocunleAt Co-!lwl Desk Ditct Oirecl fa= fa: (412) 314-3846 3074-<3846 Washiogton, pC W<lShfugtQn, DC :4055>0001 205554001. -mail: grtshaja@wes1ivghotsc.com c-mail;grcshaja@westitlgbolise.com l.Ti!.~~15.:R.:V.11m LTR-4C-D9-l5RS. p-~ P-Anacbmcnt 0'wzct CA Oou:"" W-Q9.2643 CAW-09-2643. 

                                                                                                 .~                14.:2009 AUgust 14,-2M0 Dalte August APPUCAnION APl>UCAtiONFOR        FOR WITHHOLDING W.MHOLDINCI PROPR,IEl"ARY PRQPREARY ORMATON FROM INfORMATION                     p~l.rCD~OR;E; FROM POBUCf        DMCLOSUR Subject

Subject:

      "Sedions(lf     Appliable Text noll)
                              "Sections of AppJi<:aQIeT~t          f, L'tR-ruDA,.Q6..106, Lt.-MADA 106, Rev.T' Rev. 2" (proietary)

(proprietary) The ~ 

              'flM: proprietary ifomnation, lntonnation for  for whicb which withholding withholding is     li¢ing~ed:in is beingiequeed      in the   abov-refrenced report is the iibQvc-refeienced.report        is f er identified further  i~tified in in Affidavit     CAW-09-2643 sign;d Affidavit CAW-()9-264)          sign~by. by ~ ~ pf~          t prQprifllaJy proprietary information, infOlIlJatioo.

1 Electric Company WestingbouseElectric tbe,affitiavlt, ILC. 'LWTe wbich~ies.tbis this Jetter, sets forth forth the bas!s r I Westinghouse CompanyM affidavitwhicli-accompanies onwhicbthe info.m¢ioo may ~ withheJd ftom puislie diselosureby the Com~Q-!lliild:addtesses with letter, sets the Isasis J- ~ity pecificity theconsidwations regulations. theconsiderations listedn paragraph (b)(4) lisiedin pamgrnpb (bX4) ofl Sec&n~90 of OCFR Sectin2.390 oflOCFR orUmthe Commi!!Sion's Commission's I Accordingly, A(;COI"dingly, this letter allt!lorizes this letter authorizes the \lti~n oftbe the utilization of the awompanying accompanying affidavit by I>t)ke Eae~_ Duke Eergy. Correspondence with respec to the proprietary of the application for wittiding or the Co~ndence with res~t to the proprieta:tjr aspect$ (If the applic.:3tioJl for WitlihOlding or the Westinghouse Westinghouse affidavit affidavit should refrenac'this letter, should referenCe*this letter. CAW-09-2643, CAW-'C9-1643, and should addressed to Should be addressed to L. A. Gresham, Manager,

1. A.Gresham, LLC, P.O.

Manager, Regplatory Regplatoiy Compliance Box 35$.Pittsburgb. 35S,.Pittsbu-gh, pernrsylviama and Compli3JIce and Plant Licensing, Westinghouse Piant Licensing, Westinghouse Electric Com~y Electric Company LLC, P.O. Box P~~I~ 15230-0355. 15230-0355. a:; 0.- &cuta(NRC 

                      *acth (NRC OWFN1J$.1)

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1 1 II II* I

Enclosure 2 Request And Affidavit FromWECThat From WEC.That Proprietary Proprietary Information Information In AttachmentAttachment B B of Enclosure Be Withheld From Public Disclosure Disclosure In Accordance Accordance With The Provisions of 10 CFR 2.390. CAW-Q9..2643 CAW-09-2643 JAFFDAVIT - - I AFFIDAVIT I COMMONW*_A1TH OF COMMONWEAi1H OF PENNSYLVANMA: PENNSnVANIA: ss ss I 

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COUNTY OF ALOEWNY: Wore lnCf,tbeuDdetSi~ed B/lf())"e In, t uahe auth.orio/, ~yappeared 

                                             . Id aufltiW,      perstallyappeared I.A.C         ha*n.o, A. GresIumJ,. who, being by me      duly merduly swore A~COAingto bAw,.emses and says that he is authmoized to execute this Affidavit oni behalf of sworn ~inifO Iaw.'~and says that be is authorized to el\(:I.mte this Affidavit 011 behalf of .

Westiuo1s WestinghoUse 1lJeetri~ tketrleCQo ~ (Wuesiighous, Pany LLC Compimy (W~~), and that the avcrments and Ibaltbe of fAct ~ averments o'ffitct f~rtfJ in set forth = t~ this t. Affdavit am tru ad convetto the best ofhis Affidavit are ituc;i aDd ~to the lie$lofbis!cnoWledge, infomatlon, and ~Iief. 4nowledge, informati!lf!.Ma belief. I!

~

SG-r-esham, Manager I Regulatory Compliance and Plant Li~ng Regulatory CompJiance Licensjug Sworn .to to ~4 and pbdbed 11h day This J41h 

                          ~~bed'beforeme dfAy of before mn Al!gUSt2009 ogst2009 I
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Enclosure 22 Enclosure Request And Request And Affidavit Affidavit From From WEe WEC That That Proprietary Proprietary Information Information In Attachment B In Attachment B of of Enclosure I Be Withheld From Public Disclosure Be Withheld From Public Disclosure In Accordance With The Provisions of in Accordance With The Provisions of 10 CFR 10 CFR 2.390. 2.390. 3 CAW-09-2643 CAW-09-2643 (I) j am Manager, Regulatory Compliance and Plant Licensing, in Nuclear Sexvices, Wesinghos (I) J Am Manager, RegularoryComptill!ite aIirJ Pkint Licensing, in Nuclear Services. W~gbouse Electric Company LLC atiOnglo se), and as suck,! have been specifically delegated the Electric Company ):.LC'(W~~). al)(i as such, lhavel>een specifically d~egated the function of reviewing-tho proprietary information sought to be withheld frompublic disclosure in funciioo (lrreviewing'~ prOprietaryinformatiOnso~gIit to be withheld from public disclosure in connection COIlil:.~n withwith nuclear nuelearpowenr po~ plpt plaptlicensingand licensin)! lII!d rulemaking ru!eJU:jking proceedings, proceedings, and and am am authorized authorized to to apply fo- as. withhow*irg 0on behalf 0twosnghouse. apply for its.withbolc.ling on behalf Q(W~nghouse. (2) l am makingthis Affidavit in conforac with the provisions of I CFR Section 2-390 of tie I { 

    *!

(2) I am ~this Commrission's regulations w oldine ao*.payig this Affdvit in conf~ Affidavitand

j. mqonW With WItb/lOfdiDg" a<<ompanying this Affidavit the provisions ofIO:CFR Section 2.390 of the with the Westinghouse -Application for Commission's re&u~ti~ andln cQgjun<;Ijon with the Westinghouse
  • Appt~tiOQ for I (3)

(3) I have-personal kltowledge-otfOn cReria and procedures utilized by Westinghouse in designating I jJave'personalkg(lwledge(jf~ cnteria and pt:oeeduresutmzed by Wesringhousein designating infornationas a .tado seorct, privileged, or as confide*ntil commenrcial or financial: information. infoJtDliti,on.as il.#adc seoret. privileged, or as tQnfide~1 'lOminercial odmandai information. (Pursuan to the provisions fpaAgraph (bX4) ofSection 2,390 of the Commission's regulations, 

           , (4)      :Ptusuant to the JlfO\'isiOns ofparagr.rph (bX4)ofSectioo 2J90 of tbe OHnin~Qn's ~gulations, the fol*owing isi*.X,-Ied for consideration by the Commission in determining whether the th.e ,(ODQWjDg iS~ished fOr consideration i;>ytjJe Commission in determining whether the iWformation soughtto be withheld tnm public distlos=x should be withheld.

ibfOi'ination soughrtobe withheld m.m jlI!bIic di$l:I(ISJlre sbould be withheld_ (i) The information sought to be withheld from public disclosure, is owned and has been held (i) Thei!lformationsougbtto be withheld: frol!l public disclosure is owned and has been held in confidence by Westinghouse. incon/'idence by Westingh~. (ii) The information is of a type customarily held in .confidepte by Westinghouse and not (iJ) The informatlQll is otatype customarily helll in,coJl.f~ by Westinghouse and not customarilydiscdosed to the public. Westinghousechas a rational basis for detrining customarily-disclosed III th.ep~tic_ Westinghouse.has a rational basis for d¢tertniniIlg the.types of infomuation customarily held in confidence by it and, in that connection, the.types ofinf'orlil;lqon ~ held.in confidence ~y it;md, in Ulat cormectioo, utilizes a system to determine whenard wheter to hold cerain types of information in UtiI~ il system to determinewheo.aud whetbei" to bQl4 ~~ _of information in confidence. The application of that system and the substance of that system constitutes conficience. The appijca,~ oflhat Syst¢in ADd the substance of that s.Y$tem cQostitul!:S Westinghouge polmy and provides ftlrational~bAsis reNuited. W~ghQuSepo.iciy~pro~dllll.therationaJ,~required. Under that system, in Wo n is.held in:confidence ifit falls in one ormore of sevagai 

                                 !inderthatsysteni..~u.heldiil!X)ufidenceifft.falISiDoneot:moteQf~

typ, the release of which might resnt- the oss of an &existingorpotential compe6tive types. ~ l\l'~ of which DJight rcsu1tin tbeJQSS of all ~g (l( potentWt:ompetitiv.c: advantage, as follow= 

                                ~ 3$ fol)Qws::

(a) no iWormat -veals the disteguishig aqmms of a process.(or Component, (!l)~'Qd'~rewalstbedistiD~8*3$P.CCISofa~_(orcomponent, sbrctu, toolzt U ,&40) where peveafion of its use by any

strucIlm; tooJ.~~) ~ ~~ ofbs useby anyofof
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Enclosure 22 Enclosure Request And Request And Affidavit Affidavit From From WEC WEC That That ProprietaryProprietary Information Information In Attachment BB of In Attachment of 1 Be Enclosure Be Withheld Withheld From From Public Public Disclosure Disclosure In Accordance With In Accordance With The The Provisions Provisions of of 10 CFR 10 CFR 2.390. 2.390. 44 CAW-09-2643 CAW..@*2643 Wemghýous Westinghouse'$ competitors COJJ.ipetitcml wtout Witl).out lisl~ from Westinghouse Westinghouse constitutes constitutesaa oompeiitive ~ competitive onorm advantage adv:antage overotbe overo1her companies. companies.. (b) It It consists consistsof sup~g data, ofsupPOrting ~ test data. including tt$.data. daUa relative rellitive to to a process proce$$ (or (or component, Stuctux*, tool, method, eta), component,~, tool, method,ete.), the applie;ltion of which dafa secures the application of which data secures aa I competitive .economic 

                                                  *competitiVl:

rnarlcetabiJity* marketability. economic advantage, advantage, e.g, 

                                                                                                                 ~ by optimization llptimizalionor  or improved improved
                                       .(c)

(c) ___ Its Its use by acompetitor would reduciWs.ependteofresourcs orilnproVl: acompetitorwouJdredllCetiisfllqlelldituteofi'eSoJlrCeS improve his s competilive. compet)f.ive~t:ioil tion in in the 

                                                                                                    ~ design 4esj~ m=fcture,
                                                                                                                   ~ shipment; installation,         installation. assurance assurtInce of quait, or licensing a similarproduct of quality. or li<:AAsiDg a similarproduct.

(d) (a) It reveals It reveals cost or-pice ilifotm<ltion. cost orpric;e. afOx*atinproduction 

                                                                                                                    ~ capacities,     capacities, budget     levels, or budget: levels,       or cOt~rwerciAl srategies COlnmerc:i1ll         ~t;lgies of             of Westinghouse, Westinghouse,. its         a itscustomets       ar omers Or suppjlier.

SUWlif!i'll.. (e) (e) It reveals asptas ofpA* prCid, Wor-fiture Westingbouse ItreveaJs~Qfpast.pr~!irfuture WeStnghoUs or or customer Customer funded funded 

                                                   <!evelopmen~ pr.ms development              plans and       and programs programs of ofpotential         commercial value potential commercial          'Value to Westinghouse,.

Westinghouse: (f) (f) It contains It patentable [4c;as, contains patentable ideas, for whicb which patentprotction palenlprotc;ction may be desirable. desirable. There areare so\llld sound policy reasons bebind behind the W~gh!luse Wstix)ghousc sySteiD system which which include-the include-the following: - 

               ** - ............. _---'. ~ . _ . _ - - - _ ..... - . - ***..- . ; , - . - ; *. -.-~- *** - - - ***. -~ ** -,-.---~------. - -                     ** _ . _ - _ *** -.<- ** _ - *** -

(a) The use of socll.informationbyW~~ Tbeuse such information bY'Westi"ghusO ~Westiniho~ gives Westi*ghouse acompel:itive a competitive _ 

                                                 ~ over advantagV          over its             co e its!;OiI;Ipetito,I:s.          ~ 1herefore. withheld Ii jilerefore,           withheJd from disclosure disclosure to protect~            Westinghouse CODlpetitive-~

protect th Wti$tingbopse ceenpetitiveýpMVitic. (b) It is -informafl- dtigiis marlcetable"in Itisinfuro'lationth:it many ways. ne~t marketabl& n mauyways. The extent to to which such Ui~ is aVailable toeompetitors~~e i"f.onatiQn isavail3ble to competitors diminishes the W~ Westinghouse ability to to sell products 

                                                ~ll     product and      and sesvice,o; =eivices lnv()\vin$1be'llSe involvin9g*6sof           cif ~the I¢t'IUiIation.

hfomation. (c) () Vse Use by by our toJnpetitor competitor wOuld woul putput W~I!1~~~~ Westinghouse at a competifi~v disovanag JJy by reducingithis ~ redncing-hjs caenditar; qftt:sowceS atpnexpens.. offtwworce 4ItpUtexpeoSe... 

                                                                                                                                                                                                         ~

I-I I

Enclosure Enclosure 22 RegIquest Request And Affidavit From And Affidavit From WEC WEC That Proprietary Information That Proprietary Information In Attachment BB of In Attachment of 1 Be Enclosure Withheld From Be Withheld From Public Disclosure In Public Disclosure Accordance With In Accordance With The Provisions of The Provisions of 10 CFR 10 CFR 2.390. 2.390. 5 CAW-09-2643 CAW-OO-2643 (d) (d) Each Eachcomponent comJK!llen!of pprietay information ofpropriet:uy information peinent peIDl\Clltto toaap~coinpt;titiv~coptitive advantage is potentially as valuable as the total competitive advantage is potentially as va1uab~ as .the total CQJP~veaJyantage_ ifIf adyantage-competitors acqui components proMietary ifrmatiod, any ot, cOmponent competitors acqlJire~tsof 9f~ infonnatioD,any ~C(jmPQlltlilt may maybebethe 

                                                      ~keykeytotpthe.

the.entir puzi thereby entm:*puzzle, therebydepriving deprivingWestinghouse W~ngliOU$eof a ota competitiva advantage. competitive. advantage. (e) Unri-,,ted disclosure would jeopar4iZetheposition (I) tJ~eddisclosure wouldjeopardFze the positionof ofpprominence mn ofof Westinghou- in the worldmarfet, and thareby give a market advantage to tei Westingbousein the \\IOrldini!i'k!lt. lI)ld then:bygive a marlcetadvantageto the 

                                           -competition   of thio.Ae countrWs
                                            .co~pedf.io!i oftho$e. counlJies.

(f) The (f) TheWestinghose Westin~caP>IC~ capacity tovt to*iJ)vesJdtAiprte 

                                                                                            ~assets     ~in    inresearch researchand  and i-        1 "developmentdepes up the s developi¢nt ~ upon the sm:cessininobtaining compet.itive advantage.

obtainin~and maietkirin$ga a and¢ainti\i1lil)g i cOO!petitNe advantage. 

                       .(iii)   The information is being-ttasxead to-ffwcCormmiss~ion in confideneatd., tmdd (iii)     The information iii being~~ tofue-Commission in confjdence~, un4<<thc; pMroI         .oW of 10CFR Section 2390,ititis pi"9~of 10CFR 8J:ction2390,                    is totobebereceived receivedinin ~onfidence by~tlh by.~

Commission. ComQ1ISlii9D. Qv) (iv) The Theinformation sought to be protected is_notavailable 

                                        ~onnatioil SQ!lgbt to be protectedis-not            availableininpublic publicsources sc;>uroesorOf'ayailble ayaililble infmomation has not been peviously employed in the same original manner or method to jnfonnationhas not been preYiously employed in the same original manner or method to the thebest bestofour ofom-knowledge kr\owledgeand andbelieL

_beHet (v) The proprietary infowntOn sought to be withheld in this submittal is that which is (v) The ptQJ>ri~infOJllliltion sought to be withheld .01 t1Us submittal is that which is 

   -. - ----- -._-.- -.----~~Jy                   m~injn~ofApplic3b1e appropriately markY.           *Sections of Applicable Textfrom              LTR.-lUDA~06~1Ry.

TextftomLTh-RIMDA6-06., R.iW.2-2'"~--.--. - (proprietaxy) for ~tototbo-Comnission, (ptOpri~) forsubmittal tbe:CommJssiOll,being b¢ingtroumitted 1i'ansmi:rJ~bybythetheThike DpkeEheWnEnergy lottarmA tApplication 

                                 ~1IJ;\d Application      forfurWithholding W~hrxietry       ProprietaryInformation In(QiJnationfromn:omPubli PublicDiselosaM DiseJosnJe, tofthe Do=           tCotrO Desk- TIe proprietary information as submitted by to the DocIJme:otCOiltrol Desk. ~ proprietary information as subJ1ritted by WestnghOse for Catawba Units I and 2 and MeGite Unift I amd 2 is:thatas Wesiin~ forO!tawbaUnits) and2aIid~Units 1 ~;Zi:ithat~.iatd wlthktstingof the lee Condenser tower inlet door flueimon.

w.ith:b:stingofthe roe Con~ lowet inlet ~ function. . This WMAfornaio is Part Ofthat which will enable Weatigbmos to. (a)(a)Spportlher-tllietieefflottin d*rmainiug the need frva~ioosiecon=dene 

                                       $qppt!It~~~ffortmdetmniningtheneed*~.~CQndeD$et,dQot                                              wd
                                       .~
                                                                                                                                                              ~I I

I

Enclosure Enclosure 22 Request RequestAnd And Affidavit Affidavit From FromWEC WEe That Proprietary Information That Proprietary InformationInIn Attachment Attachment BBof of Be Withheld From Public Disclosure In Accordance With The Provisions of Enclosure 1 Be Withheld From Public Disclosure In Accordance With The Provisions of 10 10CFR CFR 2-390. 2.390. f6 6 CAW-09-2643 CA W*09-2643 Further Furtherthis thisinformation informationhas hassubstantial substllDtialcommercial c;munerciaJvalue ~as /ISfollows: follows: 

                                             ,(a)

(a) Westinghouse Westi!lgbouseplans purpose purposeof plansto tosell senthetheuse futnre manucturing, repairs, offu~,man:Ufiicturing, use.ofoftde 

                                                                                                       ~and                _g tI!einformation infonJl;ltioototoitsi:tScustomers andtesting of-the c,u~omersfor of-theice icecondenser forthe the coodenset:lower lower I                                           .()

(b) inet dos ihIel~ wesinhouse.¢*q sell.suppor.and defens .ofinformation re~garing future Westinghouse,~ selI,SUppOrt-~d def~ofiufmmation regard~g future manuificturing,:rpaeims and testing of the ice codne lowertn:e door& Dlanilfiicturing, ,repairs, and testing of the ice condenser lo~ 'inlet d<iQJ:l!o 0) 

                                             ;(c)      -M*

Theiliformatiop infOflJ'lationrequested J¢q~edto tobe bewithheld withheldreveals reve.l\lsthe thedistinguishing distinguishingaspects aspectsof a ofa methodoloagy Webd was deveioped'by Westinghouse. 1IJ~9Jogy \VJiicb Was developed'by Westi!lghouse. Pdu l}'nbic s il o urdi~omre f hi p oprieta yin.hfonatiom fo fthiSpmpL .sisfilly el to cause subsbtania harm to the Pubiicdiselosure ofihis,proprietarymfonnauQJI is likelY to cause substantial h3nn to iha 

                                           .c.gapeftitipositicn C9m~~itiQDoffWtstinghouse    ofWi$nghol,lSebecause  becauseititwouldwouldeWnthealflityof enhan<:ethea!)j1ityQf
                                           .ospeitoxs
                                            .~petit()(Stotoprovideprovidesimilar simi1a1-details detailsregarding r.egardingihe  the Iower l¢werinilet
                                                                                                                              ;ii!tlIidoor-t    ing and door't!:Sting and manufacturingand manufactutingand licensing  censing defense defensesrvices se¥V~for      forconmeial
                                                                                                                  ~poweT           power reactors     without reactorsWiihout commensurate
                                             ~m!l1eDSUl'3teexpenses.
                                                                  .expenseS. Also, Also,public publicdisclosure disclosureof        the information would oftheinfonnation           woUldenable
                                                                                                                                                     ~I¢othersQthc;rs to   use the   information      to meet   NRC    rqurementsfor              licensing 10 U$C the infotIDaUon to meet NRC requirements'for lice!lsi!1g docurn-mtation without   documentation     without purchasing purchasingthe   theright righttotouse   the information.

Use the informatioJJ. The T/Itldevelopment developmentof aftie tiretechnology recbnologydescribed describedinin.part partby bythe theinformation infOmlatiQJIisisthe theresult resultofof applying applyingthe theresults resultsofofmany manyyears yearsof ofexperience experien~ in inan anintensive intensiveWestinghouse Westinghouseeffort effortand and r~ *** _ _ _ _ _ _ '*_.", ** _ ..... 

                                     -_.:~~.   .'      *            .       *                                                                                      .. _ . _ _ _ ........ ~_.

the theexpenditure expenllltiutof ofaaconsiderable Considerablesum sumofmoney. ofmoney. i In10order onkiforcogpetitws:of Westinghouse toduplicate fon:ompeti'tmf;lfWestingboll$e tll-duplicatethis thisinfornmaion, infomtation,similar technical similartec1uUcal prognaqs 

                                            '~wou)d      would have havetQto be beperformed performedand.and.a  a significantmanpowgr significant:man~effort,           effint,having haVingthe tI!e requisite       aentand experience, vwould teCpJi.$itetakntand~ence,                         have to.be W(lU!dbav.e       to.beexpended
                                                                                                                ~

Further the dponent sayeth not I 

                                                                                                                                                                                                .!I
'

l I Enclosure Enclosure 22 Request And Request Affidavit From And Affidavit From WEC WEC That Proprietary Information That Proprietary Information InIn Attachment Attachment BB of of I 

.Enclosure 1I Be

.Enclosure Be Withheld Withheld From From Public Public Disclosure Disclosure In In Accordance Accordance With With The The Provisions Provisions of of 10 CFR 2.390. 10 CFR 2.390. PROPZRUTARY lNFORMATIQN PROPlUl:TARY INFORWMAION NOTICE NOTICE Transnitted herewith are TnlJIS1llitt~hen:with areproprielaJy proprietary and/or nion-prOprietary v~tsions andlornorrpropriei<lJy versions of otdocuments firnished to documents furnished tothe the NRC NRC ininconnection connection withwith I'!lquests requestsfor.generic for generi and/or and/orJ)1an~-~1C plant-specific review review andand approval. approval. InInorder order to to confonn conform tQthe:teqlii~t.s.tifl0 to the1ireatniimentsof 10 CFR CFR2390 2-39a ofofthe the Commi;sion'sre~l;¢oD$ Commission's regultions cOncerningconcering ~ the protectio'n Qf protection ofpiIlprietlUY p~roietory jnf~ propietauy vezsiQilS virsionsis infonation SO is contained contained wilbin.~ so submilted submitted to within.brack, ~ w~ the ~-c. to the where the 

                                                                                                         ..

MRC, tbe the,1I!'()Qnaticln the ~ wjhic:h is information Whl¢b. proprietary inf'orrnafiODhas proorietary in is prQprietary nformation has been in the the ptQPtietaiy been deleted deleted in the iii tdi nOD-propOetaJy non-proprietary versions. versions, QD)ythe brackets ~ onlythe !!ra(:k$ reMairi (theinfonnation (.th information that that wasconbiined within the was contained withir! the brackets in bnckets the pr~ in the proprietary'V41 yesi ~~'beI:o ymionS flb u Wnedelete4 Thejustification delefed). ibejustifleationi fur't;laiming for claiming the the ~iloraib tine sosodesignated designated 11$ as ~ prpprietaty is is iildicated indicated inin both both versions versions byby ~ means dfloWer of lower C3$e aWse~ Wie (a)(a) through{£) through:() lated i!S located as aa ~ spodp jrnmediatelyfulto~g immediately following Ibe the bra~i$ bra-,kta enclOsing tnvlosing tal;h a4h itemOfinf~tion item of infonnation being being identified~ ideDMJed as pfoprietary proprietary or or in in the the ~mari ~opposite sIJCll sadh infcmiliItiQD. in/fonation. These These iower lower caselettas case letters refer refer to to the typesof infomnation W~ t}'peS-ofinfonnati'on Westingh ousstomarily ~1y boids holds jn in confidenceidentifled confidence identified in in Secti9ns(4)@(a) Sections (4)Xiia) thnough 4)('*f)..of theaffidavit*ct thrQugh(4){ji)(f).qf~e.;ttli$vit~ying.ms.tnmsmittal.purslla!l'tto npanying thistnsmittal pmsuant to IOCFR,239O(\:J)(l),* 10 CFR 2390(bXl)." . CO.PYRIGHr NonCE 

                                                                           .CO.PYRIqur          NOTICE The~ -herePortstransmitted transmitte ~witli~

hedrewith each beara Westinghouse copyrigbt bea.ra Westinghouse copyright notice. notice. The The NRC NRC is peIDlitt!=d permitted to make the number of maketheclllllllber ofCOpies copies afthe ofthe informatioo information contained'in contained in these reports reports Which which are necessary for its its internal use internal use in in connection ooooection with generic and plant-specific wUhgenene:and rviews and pJant-sptei.6c ltv.ieWs and approvals as well as the issuance., issuance, denial, amendment, tmnsfer, denial, amendment, transfer, rene.wal, renewal; ~n. odifiation, ~ suspension, revocation, or violation of a license, permit, order, Olregulation Pennit, .order, or regulation subject subject lPibeieqwrements tbthe rquhnents oflO of :10 CFR 2390 regarding.restri.ctions CFR 2.390 regarding restrictions on -public public disclosure to disclosure tQ the extent such the flXtei.lt information'has been s1.icbild:ormatlolrbas Iieen identified identified as as proprietary prQ~ by by Westinghouse. copyright Westinghouse, CQJ>Yright protection notwithstanding. With proteetiP!lnotwitbs,tanding. respect futhellOtl-p1opiietary With respect to the non-proprietary vetsions of these ihese reportsý, reports, the the NRC NRC isis permitted pennitted fu to make make thethe number number of copies beyond those oftopiesbeyoJld diose necessary 

                                                                                              ~ for         for its  internal. use whiCh its inJemal          whibbh are:necessary arenecessmy in     in order to
                - *order        have one to have         copy available one copy     avaj~le:fpr'  for public Wbli!< viewing vit!wmg in the appropriate appropriate docket docket files in theihe public    docum~

plIbljc document 

                 . o
                     . an  in-WashingtomnDC            and inmeal publi document rooms as may be required b.y NRC reglatiosif

_____ .__ ---lU.OIDio.Wasbingto~DCind~J~~docomentroomsasmaybetequjJ~~yNRCregull!ti!mSiL the the number numb¢cof of eq*pes*s*bmitted tQpies,$iibmitted is is insuffic insufficientt for for this this purpose. plIIJlql;e. ýCopies 

                                                                                                          'CoPIes made       by the ml;ldeby  Ih¢.NRC      mu~ include NRC must       mctUde
                 . the
                   ~ copyright         notice in copyrighJuotlce      in all
                                                   ~I instanes instanc:esand and thmproprietary the~ 4otice         ~tice if if~     o.\'i~~ was the original         ideWti wasidenlified      as proprietary.

asproprietary. i 

                                                                                                                                                                                !
1 I

i Non-Proprietary Version of .Attachment Non-Proprietary Enclosure 3 Attachment B in in Enclosure 1 I Westinghouse Proprietary Class 2 Page 11 of2of 2 I, Section of Section ofApplicable Text Text from LTR-RIDA-06-106 LTR-RIDA-06-106 Rev. 22 Clarifications Number 8: Scope and Clarifications 8: .1 A *conclusion conclusion regarding the existence existence of of an "analytical "analytical connection between the Tech Spec I SR values and the safety analysis (1 t, 1', and the resultant implications if the closing torque exceeds the opening torque," will be provided. (I the 

                                                                                                            ]"                                                      I A measured closing torque that isis [[                         r than ja than the opening torque is not aa concern since              since this I

springs' mechanical mechanical behavior [ condition is caused by the springs' approaches the open position. Since the closing. approaches 

                                                                  ]', which affects the door over a limited range as it la,  which affects the door over a limited range as it closing, force being [greater            r

[greater]a than the opening force is is II* also the source of the calculated calculated [[ )', it can be concluded that the [ 

                                                                                  ]a,
                           ]a is not indicative of problems with the hinges. The current surveillance test t  is not indicative of problems with the hinges. The current survei1lance test                                                          I data provided by Duke Energy indicate that the [

considered to be met for the lower inlet doors, [[ 

                                                                                                                           . Ja ]a limit is                          Ii t*                                                                                                                                                      !

[[ t isis an 

                                ]C     an issue that could challenge containment integrity if not limited. If 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-could then bypass the ice condenser compartment. If the upper containment proper. With that section melted out, the steam entering condenser (chimney effect)   effect) and flow directly to the upper containment heat sinks and containment pressurization due to this increased steam limit the pressurization containment sprays entering that section upper sprays are not sufficient steam (plus any other steam resulting sufficient to resulting from bypass I

through the operating operating deck) then the containment containment design pressure could be exceeded. I There was no explicitexplicit analytical connection connection between the Technical Technical Specification Specification Surveillance Surveillance  ! Requirement Requirement limits and the safety safety analysis [ ]a identified. The only statement that was I t identified. The only statement that was identified was contained identified contained in [ I 

                                                                                                ]a No [                                                     ]C were were conducted conducted relative relative to the [                                 t
                                                                                                                                     ]a of of the lower inlet                characteristics. However, based upon a review inlet door characteristics.                                                review of [
                                          ]a for a similar design, the ice condenser design can tolerate [
                                          ]a for a similar design, the ice condenser design can                       tolerate [                                      I
                                                                                                                                                                      !

Y 

                                               ]* For example, if the [                                                r] have somewhat [[

I' and would therefore open and close with [ 

                                        ]3 and would therefore open and close with [

rr resistance than the resistance than ~e other [ - jthen lathen substantial substantial margin between [] margin between [ ]3 was stilJstill observed. [[ observed. ]" was 

                                                                                   ]3 was observed observed in these these sensitivity This This document document isis the the property property of  and contains of and  contains Proprietary Proprietary Information Information owned owned byby Westinghouse Westinghouse Electric Electric Company Company LLC  LlC and/or its its subcontractors subcontractors and and suppliers suppliers. It It is is transmitted transmitted toto you you in in confidence confidence and and trust, trust, and and you you agree   to treat agree to  treat this this document document inin strict strict accordance accordance with with the the terms terms and and conditions conditions of ofthe tile agreement agreement under under which   it was which it  was provided  to you..

provided to you.. Q 2009 Westinghouse Electric Company 

                                                       @ 2009 Westinghouse 8ectric Company LLC        LLC All All Rights Rights Reserved Reserved

Enclosure 3 Non-Proprietary Version of Non-Proprietary of Attachment B B in in Enclosure 11 Westinghouse ProprietaryProprietary Class 2 Page Page 2 of2 of 2 studies. Additionally if the [[ r]a ofof allowable allowable deck leakage was determined to be acceptable. For these latter cases, deck leakage was determined to be acceptable. For these latter cases, the integrated maldistribution maldistribution based upon [[ 

                                                ]a. Therefore; based upon this generic work, the [
                                                                                                    )t was greater than [
                                                                                                    )f
t. Therefore; based upon this generic work, the [

la criterion is an acceptable upper limit that ensures that the calculated t criterion is an acceptable upper limit that ensures that the calculated containment pressure containment pressure for for [[ ]a breaks, when the lower inlet doors are 

                                                                      ]3                                                        are in the flow proportioning proportioning range, will remain below the containment design pressure for allowable deck areas greater leakage areas leakage                        than the greater than                     value [[]a design value the design                               t The information presented [[                                               r
                                                                          ] that for doordoor frictional torques in the range of[

off t, 1a,the pressures required to open and close the doors are consistent with the characteristic curve characteristic curve used used in the deck bypass sensitivities. Furthermore, based upon [[ 

                                                                         ]a provided by Duke Energy determined that
                                                                         }3 provided by Duke Energy determined that surveillance test data fall within the range of the analytical data used for the Catawba and the surveillance McGuire UFSAR analyses °and             and the generic sensitivities. ThereforeTherefore it is judged  judged that the [

f of Of note, the basis for [ 

                                         ]a the sensitivity studies described above. [

t]a is is to to ensure ensure thatthat [[ t the sensitivity studies described above. [ t]a torque torque value range of [ ]a 

                                          )3 is considered considered acceptable as long as [
                                 ]a Another Another qualitative assurance of compliance     compliance with the maldistribution maJdistribution requirement can be taken from from [[                                                                                       t
                                                                                             ]a For [[               ]aa differential 1

pressure, [[ pressure, t 

                                                                                                                         ]a Stated Stated another way, [

t. 

                                                                                                ]2. Friction Friction of  of this this considered [[

magnitude is considered t The exact friction 

                                                                                                            ,a values needed needed to [
                                                                           ]a i

document is the This documentis property of the property of and and contains Proprietary Proprietary Information owned by Westinghouse Infonnation owned EIecIIic Company Westinghouse Electric Company LLC andIor its subcontractors LLC and/or subcDntractors and and suppliers. suppliers. Als It Is transmited transmil!ed to to you you in in confidence confidence and and trust trust. and and you you agree agree toto treat treat this document in this document in strict strict accordance accordance witbft with the terms terms and conditions of the agreement under conditions of the agreement underwlnd, it was which it was provided provided toto you. you. 

                                                     © 2009  Westinghouse     Electric Company
                                                     @ 2009 Westinghouse EIecbic Company LLC        LLC All All Rights Rights Reserved Reserved}}
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