ML061280111

ER-W3-2004-0122-000, Pressurizer Heater Sleeve and Instrument Nozzle Repair

ML061280111
Person / Time
Site:	Waterford
Issue date:	06/06/2005
From:	Payne G Entergy Nuclear South
To:	Office of Nuclear Reactor Regulation
References
ER-W3-2004-0122-000
Download: ML061280111 (17)

Text

{{#Wiki_filter:50.59 REVIEW FORM Page 't of 17 Facility. Waterford 3 Document Reviewed : ER-W3-2004-tT122-4}00, RCNA0, ERCN-11 ChangslRev. : 0 System Designator(s)Moscription. RC C Reactor Coolant Dascriptlon of Proposed Chmnga t.,t-101.41, Rev. 7 Effective Date : 213105 The W-3 pressurizer contains 30 heater sleeves, four trap mounted instrument nozzles, one side mounted temperature nozzle, and two bottom mounted instrument nozzles. Top mounted instrument nozzles A and C were found leaking during RF-09 and they were repaired (ref. ER-M-1999-018"O) with new Alloy 680 nozzles using a partial nozzle weld repair, During RF-10 trip mounted instrument nozzles B and C} were also pro-actively repaired (ref. FR-W3-1939-0184-02) with new Alloy 690 nozzles using the partial nozzle repair design. In addition, during RF-09 heater sleeve F-4 (ref. ER-W3-1999-0184-07) was discovered to be leaking and it was repaired by removing the heater and installing are Alloy 694 welded plug. During Refuel 12 heater sleeves C-1 and C-3 were found to he leaking and they were temporarily repaired using the mechanical nozzle seal assembly (MNSAY2 seat assembly (ref, ER-W3-2001-1211-00). During a design review performed in 2004 it was discovered that the repair of top mounted instrument nozzles A and C was inadvertently implemented utilizing filter metal that is susceptible to future Primary Water Stress Corrosion Cracking (PWSCC) (Ref. CR-bt13-2004-4035). ER-W3-204+1-0122-000 authorizes the pre-emptive permanent weld repair of twenty nine pressurizer hooter sleeves. and clamped heater sleeves C-1 and C-3 : In addition, it authorizes the pre-emialve weld repair of the two bottom pressurizer instrument nozzles and one side shell temperature nozzle, and the re-welding of top mountW instrument nozzles A and C using PWSCC resistant tiller metal. Heater sleeve F-4 will remain pfugged. For the twenty-nine heater sleeves, the new raid-wall repair design will be used. The design removes the lower portion of the existing Alloy 600 sleeve and installs a new Alloy 694 sleeve. The remaining section (remnant) of fussy 640 sleeve will remain in place . The RG:S pressure boundary will be formed by this new mid-wail geld, by the Alloy 694 heater slave, and Uy ttFa fillet welU between Me hewer sleeve anti tree neater. t ne connguration is snown to Figure 1 section A-A. The repair of heater sleeves C-1 and C-3 previously repaired with the MNSA-2 will also use the mid-wall repair with a specially designed sleeve as shown in Figure 2 Section C-C. The repair of the two bottom mounted instrument nozzles and the side shelf temperature nozzle are shown in Figure 1 Section B-B, and Figure 3 Section A-A. The design also removes a portion of the existing Alloy 600 instrument nozzles, and installs a new Alloy 690 nozzle. In these cases, the nozzle will be J-groove welded to new weld pans which are installed on the outside surface, of the vessel. This ER also authorizes the reinstallation of existing heaters removed for nozzle repairs and the replacement of pressurizer heaters with an equivakant heater, having the seine fbi ¬n, tit, and function as the existing heater . Due to heater removal problems, one heater will be abandoned in-place and two heater nozzles will bo capped. Two additional heaters will be identified as spares_ Following implementation of this mnelifinatinn. thAre will he 175¬3 kW of pressurizer heater capacity available, assuming that elf remaining pressurizer heaters are functional,

LI-1fl1-¬31, Rcrv. 7 Effective Data: 213105 Figure 1 Sections Showing Heater Sleeve and Instrument Nozzle Repair Figure ;z Sections Showing Heater Sleeve and Instrument Nozzle Repairs at Previous MNSA and QC} Pad Locations

OSRC : 17 LI-t©i-ij9, Rev. 7 Efoctiv* Dato : 213/055 Figure 3 Section Showing Side Shelf Instrument (Temperature) Nozzle Repair 9 REVIEW FORM NOTE Figures 1, 2 and 3 are included f¬rt information only to show the design configuration. Check the applicable reviews) : (Only the sections iridlcated must be included in 9* Review.) Chairman's Name (print) ; Signature i Date, ' [Reguirod only for Pmgrammafic txdusion screenirigs and 50 59 Evaluations.] I C i EWORIAL CHANGE of a Licensing Basis Document "ction t SCREENING Sections F and If required 5¬1.55 EVALUATION EXEMPTION. Sections I, It, and Iii required ( 50.5s EVALUATION (# : 05 -° Sections I, i(, and IV required

it. SCREENINGS A. lfcen ing.8 6 E curn t R sri rv 1. Does the proposed activity impact the facility or a procedure as described in any of the following Uoensipq Basis Documents? t firs,' see Ssr:tim 5?4

q. NO LSD Charge & TGQL&~

if "Y~M" Mtfy' respc~rszbi d rattrri~rtt and ensure a 5d1.SE EVek:aGW is pertmed. aiiaCrr ¬hs ~i7. t avt~-:~. - Cbar++,fea tiS thss+Cm"y P ;on, F lm F:roEaaccfz~a Frc>~4s8sn, -yrsu L?ICaiirt Ozatim rwdtwtdttCut A93n" must ije 3Wt1YECi L^1 7?3 USFtC Sri acmr-anoa Mth NWA OM-'113: R ff °YES:" evat¬eata L"FU 01atnVe irr dcxziruarrw -:in rise rtotAfar11ents Of Ttla taai ty's Operatog i.iCenSe CondiWr, or under 50 58, 3s apprapriate. Lt-101-81, Rav> 3 Effective fate : 213105 LSDs controlled under 50.59 YES NO CHANGE # (if applicable) andldr SECTIONS IMPACTED j r FSAR DRN fly-0899, Table 5.2-3,5.4-6, Section 5,4.3.2, ? Figure 5.4-6 DRN 06-0980; Table 8.3-9, Tattle 8.1-2. Figure 8_3-33 TS Bases 1 Technical R"uirements Manual Core Uperating Limits Report I NRC Safety Evaluation Report and I C1 9 j supplements far the, initial FSAR' ¬ F NRO safety evaluatlons for C( i i afrerdments to the Operating f ' License' f tt °YES', perform an Exemption Review per Section III OR perform a 50.59 Evaluation per S csn N m QR obtain NRC approval prkw to implementing the change. if obtaining NRC approval, document th s initista mplamentod urn f spprov4d by the MAC. AND an LSD chans in &*oOrdeaan with MM E.NS-L.t-'513. Operating License YES NO_E CHANGE # andlor SECTIONS IMPACTED Operating License f TS NRC Orders ` tf "YES", obtain NRC approval prior try implementing the change by initiating an LSD chance in accordance with NMM ENS-E.l 113.- (See Section 5.2[131 for exceptions.} LI3D3 conhViled under ottaer YES No C A"GF 9 (if appttcabtu) sndfar SZCTIONO regulations IMPACTED t]s,tality Assurance Pram 0 4' ~Emerg AAaeruat~ cy Pian o' Fire Protection Program ©, (includes the Fire Hazards Anolysis) ( i `'- T ite Dose Calwlalons Manual d i i r-~._... j "YES", evaluate any changes rn accordance with the R OrOiK" 'aGF

{ regulation Initiate an LRO

't I change In accordance With NMM ENS-11. I-113. No further 50.59 roview is required.

2 Does the proposed activity involve a tst or o eriment not described in the FSAR?

3.

Basis it "Yes," perform a SOZ9 Evaluation per motion IV,QR obtain NRC approval prior to impkmenbng the change AND initiate an LSD change ire accordance with Nmm U-4"!3. If obtaining NRC approval, document the change in Section RAS, no further SOM review is required_ However, the change cannot be implemented until approved by the NRC. U.1M_01, Rev_ 7 Effective Date : 213105 Yes

~ No

Page6af17 Explain why the proposed activity dices or does not impact the Operabrrg UrensetTecfmica[ Specifications nrsdlcr ft FEAR and why tho propoacd activity doss or doss not tnvolv* a new cast or ascpersmem not previtotsFy dsscribod in FSAR. t3iscu ether 6s if rcrrpacter3. Adequate basis must trc provkfed fir! 'he ScreaniN s~~h that a thirtj,pacty reviewer can mach ;he same conclusi¬ . 5irrOy fling that the change da03 riot affect TS Or the FSAR ds not an acceptable basis. Documen fl ratin License Technical Specifications, NRC Orders The Operating License was reviewed but it does not contain a detailed description of the reactor cooiant system or pressurizer penetration design so thero is n* impact to that document. Technical Specifi tions-TS 314.4 Reactor Coolant System and TS 314.4.5 Reactor Coolant System Leakage were reviewed for potential impact during repair activities. TS 3.4.1.5 Cold Shutdown - Loops Not Htled is not applicable because repair activities will not affect operability or availability of two "ins of shutdown cooling. Watertight plugs will be installed during repair activities to altos* refueling activities its proceed in parallel with pressurzer repairs and repairs do not require RCS water level to be lowered betuw elevation 18 feet which is considered "reduced inventory° with loops filled. TS 314.4.3; Pressurizer, requires 150 kW (nominal) of heater capacity per train and TRM 314.4.3 'Pressurizer floaters" require a pre"urzer heater capacity of 65{1 kW (nominal) in addition try the heater capacity specified in TS 314,4.3. Those veto*$ Oro not impacted by this modification. NRC Orders-No Circiars were lentiled which are atsfAitsble to tire de*iyrr of tile pressurize¬, L13Qs Gor trolied under 50-59 (1=.caAF, TS Bases. TRM. COLR. NRC SERB) FSAR. Changes to the! F 5AR are named to remove references to the mechanical clamp seats as well as update various seQtio¬is to latest heater configurations. Revise FSAR Chapter 5 to change material specification for heater sleeves in Table 5.2-3 from SB-167 to SB-166 and acid information about capped stoeves, to revige the rnfitallRd heater capacity to 1250 kW in Table 5.4-6 and add reference to capped heater sleeves, to delete discussion about Heater Sleeves C1 and C3, and MNSA-2 from Section 5.4.3.2 and update Figure 5.4-6 with capped heaters. Revise FSAR Chapter 8 to revise / add notes to, Table 8_3-1, Table 8.1-2 and Figure 8.3-33 to reflect latest heater configurations. TS 9:s:~ua TRrvr- °r5 314.4.3 Pressurizer Heaters and 314.4,9 Structural integrity wero reviewed and no changes are required as a result of the proposed repairs to the pressurizer tar hater element upgrade_ Likewise; no TS Bases changes, TRK or COLR changes are necessary. LDQs controlled under other regulations (QAPM, Emorgenoy Plan, Fir Protec ©#f_site--Dose. alculat o s Manual) The QAPM, FP ; FP Program and ODCM were considered hot none of these programs car docurneritz deuGritxed ttie design of the pre"urzer and none were impacted by the repairs proposes( by R-W3-2{104-0122-00 ¬x. Tests or Experiments Conclusions-The change being evaluated is the physical repair of the pressurizer heater sleeves and instrument nuzzles with superior materials that are less susceptible to PWSCC. No unusual tests or experiments are required other than routine installation and acceptance testing, U-1tt1.01, Rev. 7 Effective Date : 213!05 50.59 REVIEW FORM

Pane 7 of 17

4.

Rafer0Miks 517.59 REVIEW FORM Discuss the rrs hado~y for pedorring LBO starches. State the location of relevant kenos¬ng dccument s,,jformat~on a"ad c~ ; ',:n scope of the review sixh as elsctronic search criteria used keywords) or the general extort of manual semhes per Section 5.5_115Xd7 of U-101_ NOTE : Ensure that rnanuat sesrctma aaa pa~rfemwd u%¬ng controlled copies of the documents. It you have any "stions, contact your site Licensing department. Controlled copies of the PSAR end TS for Wi;3 from the on-Hne library were reviewed. The fo4 ing documents were also reviewed : Calculation G-S03-0171 Revision O'YSafety Analysis Groundrufes" ER-M-1999-0184-M, ER-VV3-1993-018"2; ER-i1V3-1999-0184-07: R-W3-21301-1211-00 Design Specification DES-411-022, RAv . 1, Prassurizer Heaters St Drawings 04152, FRO, 04139, RO - Sheets 1 and 2 Additional reterences. A f SP&V Codes, Sections 111, K ¬ > 1I and tX CE Owners Gmup - CECG Cask 537 "Corrosion and Erosion Testing of Pressurizer Sheit Materlal Exposed to Berated Water CE Report No. 99-TR-FSW-006 Rev. 0 `Waterford 3 Pressurizer Half-Nozzle Repair Cartoon Steel Corrosion Evnluation" Procedure 3=P-001-016 "riot work", Procedure UNT-007-059 'Fret=" CR 943-0204, C -W3-20G4-4{135 EPRI NP-3784, A survey of literature on low-alloy steel fastener corrosion in PWR power plants Drawing 1564-1186 showing prersurizsr surge line with screen LGIS/Docurnents reviewed via keyword ooarch : Koywords. LRS_ 50.59 Search LBDs/Documents reviewers manually. Technical Specifications 3.1.1. 3.3.2, 3.3.3.5, 3.3.3.6, 3.4.3, 3.4.5.2, 3.4.7, 3:4.3 FGAR Sections 3.1.29, 5.2.3, 5.4.3.2, 5.4.10, 6.2, 7.6.1.9, 9.3, 9.5, 15.6 FSAR Tables 3.5-4, 5.2-3, 5.4-6, 8.1-2, 8.3-1 FSAR Figures 6.4.6, 8,3...33 Lt-1411-111, Rev. 7 Effective Date : 213105 m urizer heater slt;eve", ressurizer heater element', 600", "Alloy 69¬3"

50.50 REVIEW FOR Page 8 of 17

5.

Is the validity of this Review dependent on any other change? Yes No If "YES", list the required changestsubmittals. The changes c*vered bar this 50.50 Review cannot be implernetfd witnout approval of the other identMed changes (e.H, Ihcenae amencinWnt request). Establish an appropriate notification mechanlsrn to ensure this action is completed. I3-R&R-003 ; Ambient Temperature Topper Bead Welding (Code Case N-638) requests an alternate ambient temperature machine CTAW temper bead technique for dissimilar metal weld repairs. Note that verbal approval from the NRC; was received, and an ERD Action has peen assigned to document written NRC approval of the relief request. The following ASME III end A5ME X1 calculations are being performed by Structural Integrity Associates (SIA) in support of this modification package. The ASME ill calculations will be reviewed for acceptability prior to returning the pressurizer to service. A Post Action ¬n EIRD will track the final approval and issuance of the ASME III and ASME XI documents as identified in DRN 05-382. SIR-85-036. Rev. 0, "Design Report, Waterford Steam Electric Station Pressurizer Bottom Head Heater Sleeve Nozzle Repairs" SIR-05-0737, Rev. Et, "Design Report, Waterford Steam Electric Station Pressurizer Bottom Head Instrument Nozzle Repairs" + SIR-t75-1738, Rev_ n, 'Design Report, Waterford Steam Electric Station Pressurizer Side Shell Instrument Nozzle Repktir' SIR-05-839, Rev. ¬), `Fracture Mechanics Evaluation of Potential Remnant Cracks in Waterford Pressurizer Bottom Head Heater Sleeve Nozzles" SIR-05-040, Rev. 0, `Fracture Mechanics Evaluation of Potential Remnant Cracks in Waterford Pressurizer Bottom Head Instrument Nozzles" SIR-05-1741, Rev, 0, "Fracture Mechanics Evaluation of Potential Remnant Cracks in Waterford Pressurtzer Side linen Instrument Nozzle-Westinghouse issued a Nuclear Safety Advisory Letter (NSAL-04-5) advising Entergy of potential inourga ancf autcurgo trancionta on tho CZ procsurizors. Oo"ndinq an spacific plant rianion anti operation, these transients can potentially occur during plant heatup or coddown. These transients may not have been fully considered as part of the original design basis for the pressurizer. Therefore, if these are unevaluated transients, the original predicted fatigue usage factor of the lower vessel region, and existing flays analyses may not be bounding. Westinghouse has stated that this condition is not an immediate safety concern, and that it is below the threshold for Part 22 notification. Condition Report CR-WF3-2004-172734 tracks this potential insurge and outsurge transients issue and the Corrective Actions for this CR will provide the required qualification and document update. U-101-01, Rev. 7 Effective Date : 213105

Noe g of 't7 B. ENAARONMENTAL SCREENING If any of the following questions is answered "yes," an Environmental Review must be performed in accordance with NMM Procedure FENS-1V-145, "Environmental Evaluations," and attached to this 50.55 Review. Consider both routine and ruin-routine (emergency) discharges when answering these questions, Nil the proposed Change being evaluated ; Yes NA 2. Involve a land disturbance of undisturbed land areas (Le., grading activities, construction. excavations, reforestation, creating, or removing ponds)? 4.

5.

0 1. 8. 0 ED 10 $0.59 REVIEW Involve a land diWturboroe of previously disturbed lend areas in excess of one acre (i.a_ grading activities, construction of buildings, excavabon8, reforestation, creation or removal of poi Mrs)? lnvnlvp drMGin(; antivifiws in a lake, river, pored, car strum? Increase the amount of thermal heat being discharged to the river or lake? increase the concen"tion or quantity of chemicals being discharged to the river, take, or air? Discharge any chemicals new or different from that previously discharged? Change the design or option of the Intake or discharge structures? or operation of the cooling tower that will change water or air flow Madly the de characteristics? Modify the design or operation of the plant that wilt change the path of an existing water discharge or that will result in a new water discharge? Modify existing stationary fuel burning equipment (i.e,, diaSel fuel nil, butane, propane, and kerosene)?' 11. rl Vg Involve the installation ot stattonary rue! burning equipment or use of portable fuel burning equipment (i.e., diesel fuel oil, butane, gasoline, propane, and kerosene)?' 12 Involve the installation or use of equipment that will reult in a r or additional air emission discharge?

13.

(l 2 Involve t installation or modification of a stationary or mobile tank? 14, Involve the use or storage of rails or chemicals that could be directly released into the environment? 15. ] involve burial or placement of any solid wastes in the site area that may affect nrnaff, siffacv water, or groundwater? See N MM procedure ENS-E11-117, 'Air Emissions Management Program,' for guidance in answering the question. l-t"7lli.fi'!, Rev. 7 Effective Date : 213105

c.-. SECURITY P SCREEN)NO If any of the following questions is answered "yes," a Security Plan Review must be performed by the Security Department to determine actual impact to the F"ta and the need for a change to the Alan. Could the proposed activity being evaluated: Documentation for accepting any "yea' statement !Ar these reviews will be attar-hod to this 50.59 Review or referenced below. 1-1.101-01, Rev. 7 Effective Date. 2131115 Yes t 0 Add, Mete, modify ; or otherwise affect Securty department responsibilities (e.U.. incJud ¬ng fire brigade, tire watch, and confined spite rescue operations)?

2. 0 Result in a breach to any security barrier(s) (e.g., HVAC ductwork, fences, doors, watts, ceilings, floors, penetrations, and ballistic barriers)?

© Cause materials car equipment to be placed or Installed within the Security Isolation Zone? © Affect (block, move, or alter) security lighting by adding or dai2fno lights, strueAires, buildings. or temporary facilities?

5.

[] Modify or otherwise affect the intrusion detection systems (e-g,, E-fields, microwave, fiber Optics)?

8.

Modify or otherwise affect the operation or field of view of the security cameras? Modify or otherwise affect (block, move, or alter) installed access control equipment, intrusion detection equipment, or other security equipment?

8.

13 0 Modify or otherwise affect primary or secondary power supplies to access control equiptnettt, itiuusiu ¬ destt3LAion equipment, other security equipment, or tv the Central term Station or the Secondary Alarm Station?

9.

odify or otherwise affect the facility's security-relaters sigruage or land vehicle barriers, rr)Oudf! ¬g dccetss rueciways? tg. C3 N Modify or otherwise affect the facility's telephone or secu radsu systems?

~: INDEPENDENT SPENT" FUEL STORAGE INSTALLATION (tSFS1) SCREENING LQT,A : This section its not appti ie to Waterford 3 and may be removed from 50.53 Reviews Performed for Waterford 3 proposed activities:) If any of the fattowing questions to anawsred "yea," an ISM Review must be performed in accordance with INMM Procedure ENS-1-11-112, "?'2.48 Review," and attached to this Review. Will the proposed Change being evaluated. Any activity that directly impacts spent fuel cask storage or loading operations? InvQtvo the Indapandent Spent Fuel Storage Installation (ISM) including the concrete pad. security fence, and lighting? 3. Irwoive a change to the on-site transport equipment or path from the Fuel Building to the iSF8t? 4. U 0 involve a change to the design or operation of the Fuss Building fuel bridge including setpoints and limit switches? 5_ © J Involve a change to the Fuei Building or Control Rooms) radiation monitoring? 6. E} Z involve a change to the Fuel Building poets including pool levels, cask pool gates, cooling water sources and water chernlstry? 7. ~] Involve a change to the Fuel Building handling equipment (e.g., bridges and cask cranes. structures, load paths, lighting, auxiliary services, etc)?

8.

Z Involve a change to the Fuel Building electrical power? g, Ej [E Involve a ehaNe to the Fuel Building ventilation?

10.

C,J" 0 involve a change to the ISFSI security? 11. C1 0 Involve a change to off-site radiological release projections from non-ISFSI sources? 12. D 0 Invove a change to spent fuel characteristics? 13. (1 Redefinefchange heavy load pathways? 14. C, S Fire and explosion protection near or in the on-site transport paths or near the IBM? 15 0 lnvntve a rhange to the Inodina hay ar suppnrfng nnmpnnent0 16. F1 2 New structures near the ISFSI? 17_ ID 2; Modificatiors to any punt systems that support dry fuel storage activities? 18. L]. Z involve a change to the nitrogen supply, service air, der ineralized water or borated water system in the Fuel Soi;ding? L I-101-01, Rev. 7 Effective Date : 2}31¬115

12 of 17 50.59 EVALUATION P Icsnee Aittmgrx- ¬3~terminAtlon Do" the propoeed CherW being evaluated represent a ultange try a frtedCxl of evaluation L'] Yea ONLY? "'Yes," Questions I - 7 are not appikable; answer only Question $. If "No," answer 0 No all questions below. Do" the proposed Change : Result in more than a minimal increase in the frequency of occurrence of are accident 0 Yes previously evaluated ¬n the FSAR? RASIS U-1oa-01, Rov, 7 Effective Data : 21V05 50.59 REVIEW FORM No The accidents previously evaluated that are applicable to this change are described ¬n Chapters 6 and 15 of the FSAR. These accidents are the Loss Of Coolant Accident (LOCA) and the Inadvertent Operation of the Frnergoncy Core Cooling System (ECCS). Although the failure of a pressurizer heater sleeve is not specifically discussed, the frequency of occurrence of the LOCA could potentially be increased if the integrity of t RCS pressure boundary is degraded as a result of modification implementation. The Inadvertent Operation of the ECCS could be potentially affected because pressurizer instrumentation provides input to the Safety Injection Actuation Signal (SIAS) and Containment Isolation Actuation Signal (CIAS) functions of the Engineered Safety Features Actuation System (ESFAS), Tile design of the repairs proposed for the pressurizer heater sleeves (it iduding twu crapped nozzles) and instrument nozzles comply with all applicable ASME Section 111, Class 1 requirements, except where relief is requested as described in the response to Park I LA Question 5. The fabrication and installation of the nozzta repairs i$ in accordance with ASME Section XI requirements, consistent with Waterford 3 ASME Section XI program per 1QCFR5D,5 . The partial penetration J-groove welds and fillet welds wilt be controlled by vendor wolding procedures (at Entergy welding procedures) that will biep reviewed acrd approved by qualifted Watefrd 3 personnel, Non-destructive examination will be performed to verify acceptability of the welds in accordance with ASME requirements. The new nozzles/sleeves will tso rna.^hira2ri as a nna-pitarA dACign (marhined fmm either Alloy 690 forainas or bar stock). Replacement heater elements, when used, meet or exceed all applicable ASME Code requirements. The welding of new sleeves or nozzles to the pressurizer will be performed by either Waterford 3 or qualified vendor personnel in accordance with applicable requirements of ASME Sectk)n XI. The installation of the one-piece designed heater sleeve at the pressurizer read-wall (ASME 533 Gr. S, Classl) will require a bimeWlic weld using ambient temperature temper bead welding in accordance with ASME Code Case N-63&f3. Depositirxn of weld metal pads on the exterior of the pressurizer will also require ambient temperature temper toad welding in accordance with ASME Code Case N-838-f1. A finite element analyses has been prepared to demonstrate that the repair designs comply with the applicable ASME Code requirements. These analyses, which fallow the males of ASME Section Ill Sub-Article NE3-3200, reflect that all calculated primary and membrane stresses in the critical weld sections meet the ASME Code Allowable stress values (ref. Structural Integrity Calculations SIR-05-036, SIR-f15-037. SIR-05-¬733). in addition, there are no design changes to any instrumentation lines associated with this modillcatlon. Ali original analyzed Wrtfigurations are maintained. The proper Operation of all affected instrument loops is verfed by past modification testing prior to the unit being returned to service. In scamfnary. the proposed changes associated with implementation of pressurizer hooter and Enstrijmant nozzle repairs meet all design and licensing basis requirements and therefore the

pressurizer vessel integrity and the RGS pressure boundary integrity are maintained consistent with original design. Tho frequency of occurrence of the accidents d4ascribed above or any other accident that is described in FSAR Chapter 15 is not increased. Additional design considerations related to this charge are discussed below Fracture Mechanics # Creek Propagation-A portion of the original Allay 600 heater sleeve or nozzle and the original J-groove weld attachment and cladding will remain in place where stress corrosion cracking could initiate or propagate. An evaluation was performed which demonstrated that PWSCC cracking would arrest at the low alloy steel and crack propagation by fatigue would be acceptable for the remaining life of the plant (including life extension) and not challenge the pressurizer structural integrity (ref. Structural Integrity Calculations SIR-{76-030, SIR-(l5-040, SIR-05-041), Corrosion The repair design allows for thermal expansion of the remnant sleeve or nozzle welded to the inside of the pressurizer and the new sleeve or nozzle welded to the outside or mid-wall of me pressurizer. In all cases a small gap is created where the low alloy steel of the pressurizer will be exposed try the RG5 ladle acrd environment. A corrosion analysis ties determined that potential txirrcgsion would be minimal and acceptable as follows: Carbon stint/boric acid corrncion menhanisms typically involve evaporation of a relatively dilute and non-corrosive boric acid solution into a concentrated and corrosive acid With a pH of less than 3. However, RCS pH is maintained by procedure between 4.5 and 11 (ref. CE-002-0, where the corrosion rate is substantially' reduced. In addition, the lower RmR of the contained water volume, the specified boron concentration, and the prtysical size (approximately fjUO,oUu gallons) of the RWSP also ensure a pH value of between 7.01 and 11.13 for the solution redmulated within containment after a LOCA. Concentrated boric acid can cause high general dissolution corrosion (wastage) of localized regions of hot carbon steal surfaces. The corrosion rate for this form of corrosion is most severe in the temperature range of 350OF to 40(YE and it diminishes on either side of this band. Then normal operating temperature for the RCS is well above 400OF and normal shutdown temperature is less than 15f3'F. Therefore. because the duration of RCS heat -up and cool-down in the corrosive bared is very short, significant corrosion. will not occur. In the unlikely event that the pressurizer temperature was maintained for a period of this in the undesirable temperature ranges of 350OF to 400'-F. accelerated corrosion would not occur because the oxygen levels would be tow, me pH is well above 3, and the wetting and drying conditions would not exist. Also, the conditions required to concentrate boric. acid to a corrosive pH level are not present in the locations of the pressurizer where the low alloy steel is exposed. Specifically, it is under conditions of wetting and drying that boric acid will concentrate and eventually form a saturated solubu¬r. Saturated bodu acid at 200 degrees F has a pH of less thet ¬ 3 (Ref.. EPRI NP=3184, a survey of literature on tow-alloy steel fastener corrosion in PWR power plants). Boric acid concentration in the vessel penetration areas will be limited below saturation because there is no wetting and drying process at those to cations, During infrequent refueling outages when the pressurizer slevestnozzles may t~e allowed to cloy, trig.` temperatures are well below the 3501F to 400OF range when corrosion is most significant. Further CE has submitted an evaluation (Report 09-TR-FSVU-006, Carbon Steel Corrosion Evaluation, Revision 0 including calculation EC 9-1-011) concluding that the estimated fetime of a half-nozzles repair ;vie over 450 year:,. The evaluation consisted of a review of industry experience and laboratory testing, including an assessment of potential galvanic corrosion. Stress Corrosion Cracking : The pressurizer material is SA-533, Grade B, Class 1, which is considered to be a low alloy steel (LAS) (carbon steel with saTalt per cent of Mo and Nr). ,I ire yield strength of SA-53:x, Grade Class 1 is approximately 50 Ksi, which is far below ravels typical of SCC attacked materials Li-101-01, Rev. 7 Effective Date: 213105

referenced in the EPR} NP-3784. The pressurizer LAS material has high fracture toughness and an inherently high resistance to PWSCC. Therefore, stress corrosion crat;kino which initiates in Alloy 600 components would self-arrest if it propagated and reaches the lost alloy steel of the pressurizer. The only mechanism available for further crack propagation in the low alloy steel material is fatigue.. Therefore, stress rrsrmsion cradling of the pressurizef materiel exposed to primary water will not occur. Hydrogen mbrittlement. the susceptibillty of a material to hydro n embrittlement generally doperxls on the etrength lever of this stcof, and resistance to emttirittfement decreases with increasing strength (Metals Handbook), In addition, hydrogen emhrittlement decreases with increasing temperature. The preszurizer shelf is fabricated from SA-533. Grade 8 material with a yield strength of approximately 50 ksi. Although this material has a high toughness it is not considered a high strength steel. In addition, the internal stainless steel cladding of the shell, while providing . a barrier to boric acid, provides no barrier to hydrogen migration into the base metal. Hydrog n can permeate throughout the cladding and saturate the base metal. This modification has no effect on the susceptibility of the base metal to hydrogen embrittlement because the baste metal has always been expnsad try hydrogen through the stainless steel cladding. 2. Result in more than a minimal increase in the likelihood of occurrence of a malfunction of a structum, system, or component important to safety previously evaluateff in the FSAR? BA5i5', The structure, system, or component (SCC) important to safety that is related to the proposed activity is the pressurizer vessel and the RCS pressure t~oundary. A comprehensive diswssion is provided in answering the previous question that provides the basis car why the pressurizer and RCS pressure boundary are being maintained equal to or better than the original design. There are no r system interactions or connections, and there are no new fa ilttm rrXsdes associated with equipment important to safety. floe pressurizer heater elements serve no safely function except that a portion of the heater forms part of the RCS pressure boundary where it is welded to the bottom end of the heater sleeve. This portion of the heater elements are designed and manufactured in accordance witty ASM Section Ill requirements to ensure pressure boundary integrity. The replacement nozzles aM heater sleeves as well as the welts filler materials have superior resistance to PWSCC. All applicable ASME stress allowables are saattSilea for Me repairs, the A3MC W1s uvrr Xt frzsc;turo rnachani** otmao onolycic rsrti+~ats that potential crack growth are within allowable limits ; and potential boric acid corrosion or metal wastage of exposed low alloy steel within the vessel wall is insignificant. Prior to implementation of this modification, there was 1350 kVV of pre urizer healer capacity installed. Following implementation of this meditation, there will be 1251 kW of pressurizer heater capacity available. Calculation EC-S03-M1 Revision 0 "Safety Analysis Crourutrules" item PLC.g sposifies that the rnimmurn combined pressurizer propartiunal and backup heater capacity for cycle 14 will be 9511 kW . The 9501 kW of pressurizer heater capacity is based on the requirements of Technical Specification (TS) 3/4.4.3 "Pressurizer' which requires 150 kW (nominal) of heater capacity per train artd Technical Requirements Manual (TRM) 314.4.3 'Pressurizer Heaters' which requires a pressurizer heater capacity of 650 kW (nominal) In addition to the heater capacity specified in TS 3/4.4_3. the planned installation of 25 heaters will provide a wxninal capacity 1250 kW. This provides a margin of 300 kW of heater capacity that can be used to compensate for degraded performance er heater failure over the cycle, in addition, adequate pressurizer heater capacity will be verified prior to startup from the Refuel 13 outage and as any pressurizer ti ters are removed from service or fail during ryrIA 14. Therefore, this rnodification doses riot adversely affect the &sign function of the pressurizer heaters as the minimum pressurzer heater capacity required by TS and the TRM is maintained and a margin of 300 kW of excess pressurizer heater roparity above the requirements of the TS anti TRM wilt be available: Therefore, the likelihood of occurrence of a rralfunctfon of a SCC L1-1171-01, Rev. ? Effective Hate : 2131115 Yes No

important to safety will not be increased with the proposed changes. Result in More than a minimal increase in f Consequences of an accident previously Q Yea lusted in the I^SAR? BASIS : The RCS is a fission product barrier credited with mitigating the consequences of a toss of Coolant Accident. The pressurizer pressure instrumentation loops provide input to the RPS and also to the SIAS and CIAS functions of the ESF'AS Although top instrument nozzles A & C are being re-welded to remove Alloy 182 material, post modification testing will erasure that the function of the associated instruments are fully restored. No changes are being made to the design o¬ the pressurizer pressure instruments or instrument loops. Upon completion of the work activities, backfilling of the instrument sensing lines and functional testing, will verify that the instrument loops attached to the nozzles are functionifig properly. Therefore, the instrumentation and its interface with the TAPS and FSFAS will continue to function to mitigate the consequences o ¬ accidents as currently designed. The integrity of the RCS pressure boundary will be maintained by continued conformance to all applieahte ASM Code requirements and the integrity will be improved try replacing Alloy 600 pressure boundary materials with either Alloy 69© or stainless steel materials that are more corrosion resistant to PVVSCC. As a result, it car, be concluded that this modification dales not result in more than a minimal increase in the consequences of an accident previously evaluated in the FSAR. 4. Result in more than a minimal increase in the consequences of a malfunction of a structure, 0 Yes system, Or oumponent important to safety previously evaluated in the FSAR? 9 No BASIS: The proposed actin¬ty does not result in more than a minimal increase in the consequences of a malfunction of a SCC important to safety previously evaluated in the FSAR because the integrity of the RCa will be either maintained or unproved. The function and mitigation requirements of the ICS are not modified and no changes in the assumptions concerning equipment availability or failure modes have been made. The proposed repair activity has no impact on the pressurizer pressure instruments or instrvmont loops, therefom, the ostrurrantation and its it liwface with the RPS and ESFAS will continue to function to mitigate the consequences of accidents as designed.

5.

Create a possibility for an amdent of a dtf orent type thwr al ly rxesvicusiy evaiuattw in the i~ Yeu FSAR? No BAST& U"1#1i-0i, Rev. 7 Effecaive Date: 213105 0 No The proposed repairs will not create a possibility far an accident of a different type than any previously evaluated in the FSAR because the function and integrity of the RCS has not been altered or degraded . The ICS will continue to meet all applicable design requirements so the integrity will be maintained or unproved. There are no new system interactions or connections, and there are no new failure modes associated with equipment important to safety. The pressurizer heater elements serve no safety function except that a portion of the heater forms part of the RCS pressure boundary where it is welded to the bottom end of ttur neater sieve. This portion of the heater elements are designed and manufactured in accordance with ASME Section lit requirements to ensure pressure boundary integrity. The pressurizer repairs Will be implemented during a plant outage white the RCS is depressurized, To allow refueling activities to prod in parallel with pressurizer repairs and to avoid the Mood to operate the RCS at rpdr.irTA inventory, watertight plugs will be used to seal the instrument nozzles and heater sleeves during some repair activities, The watertight plugs will be hydrostatic ally tested to ensure that they can withstand ra pressure greater than the Statia Head Pressure exerted by 'i0 feel of water in the pressurizer and reactor cavity multiplied by a factor of 2 try conservatively account for potential seismic acceleration. it is also planned that secondary backup plugs will be installed in heater sleeves and instrument nozzles whenever repair activities

Page t0 of 17 U-101-t11, Rev. 7 Effective pate : 213105 50,59 RMEW FORM allow,, providing redundant sealing capability. Heater sleeves and instrument nozzles will be uleaned bar grinding or flapping prior to plug insertion to ensure that an ideal seA! ¬ng surface is provided-In the unlikely event that minor leakage occurs, and adjustment of the secondary seal is unsuccessful in eliminating the leakage, 'leak collection will be installed and the repair of the sleeve will be rescheduled during a drain-dawn window. Even in the unlikely worst case event where a plug were completely ejected, the bottom of the pressurizer is higher than the RCS loops so the ability to maintain shutdown cooling would not ¬ affected. Create a possibility for a rnafunction of a structure, system, or component important to safety 0 Yes with a different resuf thari any previously evaluated in the FSAR? 0 Nu As described in the response to questions t through 5, the integrity and operability of the RCS pressure boundary and components will not be degraded by the proposed repairs. Also the functional capability of the instrumentation will not ho affected by the proposed repairs because the intemal dimensions of the instrument nozzles are not changed and proper operation will ( e vedfied by post modification testing. Replacement beaters, when used, are like the existing heaters in terms of form; fit and function. The proposed change provides a functionally equivalent design, and there era no new failure modes or system interactions created. The potential for the remaining portion of the original r zzlwheater sleeve to fall into the pressurizer is extrertiely low, In order for this to occur, the cracking Notrld h Ave to progress or form, completely around the circumference of the existing nox4elheater sleeve. Industry experience and stress aralyses have shown that the cracks typically propagate and grow axially. Multip ¬o axial Ir ks will relieve the stresses in the muzzle and arrest further cracking initiation. Therefore, substantial weld acrd nozzle ligament will remain and prevent the nozzle or newer sleeve sttub piece from falling into the pressurizer. The modification of the original partial penetration weld sleevelnozzle design moves the partial penetration weld joint to either the mid-wall or the outside Surface of the pressurizes vessel where previously thu joint war; on the inside surface . The remnant sleevelnozzle is no longer part of the RCS pressure boundary. In addition, there is a screen filter over the pressurizer surge line which will prevent a loose part from migrating into the RCS flow path, oven, in the unlikely event. it did fall into the pressurizer The Refueling Water Level Indicating System (RWLIS) is designed to monitor the water level in than RCS and the refueling pool curing refueling operations. This system is also used to monitor the water level in the RCS hot leg during maintenance operations that require the RCS to be drained down to the vicinity of the hot leg. The reference leg for this level indicating system is attadied try one of the pressurizer upper tread nozzles (ref. value RC-311). C3u" that implementation of this modincation the reference leg for RWLIS will bo disconnected from the pressurizer, This is acceptable because typically when R LIS is in service during a refueling outage the pressurizer man-way is open to atmosphent, and after the reference leg is disconnected from the pr"surizer, it will still s atmnspheric pressure. Therefore disconnecting the reference leg from the pressurizer will not . affect the operability of the RVVUS. Therpfrre this modification will not increase the probability of occurrence of a madunction of

equipment important tc safety of a different type than previously evaluated, Result in d design basis limit for a fission product barrier as described in i 8 FSM being C Yeas exceeded or altered? No BASIS : The fission product barriers identified in the WF3 Licensing Bases are the fuel cladding, the Reactor Coolant System, and the Containment Building. The pressurizer is a part of the RCS pressure boundary, but the proposed actMty dew not alter or exceed a pressurzer/RCS design basis limit_ The new heater sleeve designs are rated for the design pressure and temperature of the pressurizer (2,5821 psia and 7Df)"F) ; therefore, the proposed activity clues not change or exceed the pressun7pr design basis pressure and temperature limits as described in FSAR Table 5.4-6. Furthermore, the near pressurizes heater sleeve designs will conform to the applicable ASME Code Section tit requirements for Class 1 Lumpor7ent5. Therefore, the stress design limits (Code allowables) Far the pressurizes and the design basis Iirnits for fission barriers as described in the FSAR will not be exceeded or altered. 8 : Result in a departure from a method of evaluation cescrrbed in Me FSAR used ire miWishing EJ Yes the design bases or in the safety analyses?. BASIS : U-101-01, Rev. 7 Effective Date : 213105 No The analyses for the new heater sleeve and instrument nozzle designs have been properly and completely reconcired with the regoimmants of the original construction code for t VVF3 pressurizer (ASME Section Ill ; 1! 71 Edition. Summer 1871 Addenda). The new pressurizer heaters meet the appropriate requirements of the original construction code. ASME Boiler and Pressure Vessel Code, Section III, Subsection NB, 1971 Edition through Summer 1971 Addenda. As an alternative, the replacement pressurizer heaters may be supplied to a later Edition and/or Addenda of ASME Section III provided the Edition/Addenda used was endorsed by the NRC per 1f3CFR54:55a and the use of the later Edition/Addenda of ASME Section III is "~conciled, by the supplier, in accordance with the recondiiation provision,; of they 1995 Edition/19% Addenda of ASME Section XI. The proposed activity is strictly a structurall echanical design change and does not impact the pressurizer size, capacity, control systarns of affect a change to a method of evaluation described in the FSAR used in establishing the design bases or in the safety analyses. If any of the above questions Is chocked "YES". obtain NRC approval prior to implementing, the change by initiating x change to the Operating License in accordance with NMM Procedure EN3-Lt-193.}}