ML093430506
| ML093430506 | |
| Person / Time | |
|---|---|
| Site: | Mcguire, Catawba, McGuire  |
| 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) | |
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
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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
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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
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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:
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, 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 ($150K worth), developed with Framatome Framatorne ANP, for testing the doors with a minimum of of movement movement. The Framatome Framatome rig.rig, . which Cook NP has not yet officiallyofficially brought brought into action, attaches to a bolt bolt head on the outside of the LID surface, surface, and uses a digital scale for the hinge resistance. Motion Motion in the LID during the torque test is kept at about 0.008", 0.008", and and experience experience with it shows that friction friction forces decreased decreased significantly. significantly. Cook is still utilizing utilizing the air dams to prevent the dynamic dynamic effect effect of rushing air. ofroshing I
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Enclosure 2 Enclosure Request And Affidavit From WEC WEe That Proprietary Proprietary Information In Attadhment Attachment B of Be Withheld Enclosure Withheld From Public Disclosure In Accordance Accordance With The Provisions of 10 CFR 2.390.
- Westnshhouse ElectuicCompany WestiJlghouseElectric CoinPilIlY NiJde~
NudeV$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:
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"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
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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!
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SG-r-esham, Manager I Regulatory Compliance and Plant Li~ng Regulatory CompJiance Licensjug Sworn .to to ~4 and pbdbed 11h day This J41h
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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 {
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(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$tem cQostitul!:S Westinghouge polmy and provides ftlrational~bAsis reNuited. W~ghQuSepo.iciy~pro~dllll.therationaJ,~required. Under that system, in Wo n is.held in:confidence ifit falls in one ormore of sevagai
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typ, the release of which might resnt- the oss of an &existingorpotential compe6tive types. ~ l\l'~ of which DJight rcsu1tin tbeJQSS of all ~g (l( potentWt:ompetitiv.c: advantage, as follow=
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(a) no iWormat -veals the disteguishig aqmms of a process.(or Component, (!l)~'Qd'~rewalstbedistiD~8*3$P.CCISofa~_(orcomponent, sbrctu, toolzt U ,&40) where peveafion of its use by any
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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,
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.(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
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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
!
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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}}