ML061450148

BC 359513, Rev 0, Quad Cities Unit 2, Design Considerations Summary (Per Section 4.0 and Attachment 1A of Procedure CC-AA-102).

ML061450148
Person / Time
Site:	Quad Cities
Issue date:	04/27/2006
From:	Exelon Generation Co, Exelon Nuclear
To:	Office of Nuclear Reactor Regulation
References
CC-AA-102 BC 359513, Rev 0
Download: ML061450148 (61)

Text

Exelon EC 359513 Quad Cities Station DCS Unit 2 Revision 0 EXELON Quad Cities Nuclear Generating Station Unit 2 DESIGN CONSIDERATIONS

SUMMARY

(DCS)

(Per Section 4.0 and Attachment 1A of Procedure CC-AA-102)

EC 359513 Revision 0 Electromatic Relief Valve (ERV) Actuator Replacement (Unit 2)

Safety Related Page 1 of 24

Exelon EC 359513 Quad Cities Station DCS Unit 2 Revision 0 DESIGN CONSIDERATIONS

SUMMARY

The design attributes addressed in this document are those identified in Attachment IA, "Design Change Attribute Review" of procedure CC-AA-102, and are numbered accordingly.

Background:

The main functions of the Main Steam (MS) System are:

• To supply steam to the turbine-generator from the reactor vessel,

• To limit pressure transients on the reactor vessel during abnormal conditions, and

• To relieve pressure rapidly for low pressure Emergency Core Cooling System (ECCS). The system also provides various balance of plant steam requirements.

The main steam system consists of four steam lines to a pressure-equalizing header, which leads to the high-pressure turbine. The safety-related portion (i.e. reactor coolant pressure boundary) of the MS System extends from the reactor to the outside containment valves. The remainder of the system from the outboard containment isolation valves to the turbine is non safety-related, with the exception of main steam line low pressure switches, which provide Group I primary containment isolation signals.

Connected to the safety-related MS System are Electromatic Relief Valves (ERVs), Target Rock relief valves and the safety relief valves (SVs). In total there are eight SVs, four ERVs, and one Target Rock valve, which serves as both a safety valve and a relief valve. Each ERV has a discharge line that is routed to the suppression pool. The safety functions for the ERVs are to:

• Open as part of the Automatic Depressurization System (ADS) to decrease reactor vessel pressure for low-pressure Emergency Cooling System operation under an assumed Loss-Of-Coolant-Accident (LOCA).

• Open when manually energized to provide a means of relieving steam generated by core decay heat to the suppression pool in the event that the main condenser is not available as a heat sink after reactor shutdown and until Residual Heat Removal (RHR) steam condensing mode of operation is initiated.

• Open to provide an alternate means to cool and shutdown the reactor by passing water from the reactor to the suppression pool in the unlikely event that the (RHR) shutdown suction line is not available to transmit water from the reactor to the (RHR) heat exchangers while the Residual Heat Removal/Low Pressure Coolant Injection (RHR/LPC1) pumps are injecting water into the reactor.

• Open when energized by pressure sensing circuitry to relieve reactor pressure and reduce challenges to safety valves.

The ERV consists of a main valve, a pilot valve and a solenoid actuator. To open the valve, the solenoid actuator actuates the pilot valve reducing the pressure under the main valve disc. To Page 2 of 24

Exelon EC 359513 Quad Cities Station DCS Unit 2 Revision 0 close the valve, the solenoid actuator releases to the normal position, closing the pilot valve and the pressure under the main disc is increased. The solenoid is used to convert electrical energy into straight-line mechanical energy. A pushing action is used to exert a mechanical force on the lever arm of the pilot valve to operate the pilot.

This EC also provides for a change in the quick disconnects/cables from the junction box terminal board to the ERV actuator. This change is due to a General Electric (GE) recommended wiring change as a result of ERV "Hardened Actuator" testing/qualification and is documented in GE Nuclear Energy Field Disposition Instruction, FDI-0187.

This EC also provides for a new electrical junction box (2RB-168) to be replaced and relocated in Unit 2. The new configuration will provide more clearance between the ASB end flange and the electrical junction box. A new junction box is required to accommodate the new orientation of the EGS quick disconnects connecting from the junction box to the solenoid actuator. The conduit entrance, mounting holes, and quick disconnect holes are to be drilled into the new electrical junction box.

This EC also replaces the terminal board terminations for the ERV solenoid coil circuit inside the junction boxes with Environmentally Qualified (EQ) splices. Electrical work associated with EC 356659 is now superceded by EC 359513 electrical work. The EQ splice change inside the junction box is being performed due to the potential for ERV's to not de-energize during LOCA conditions. Currently the ERV solenoid power is carried in 6 conductors that are part of the same cable with each conductor terminated individually at a terminal block. The 6 parallel paths to ground, given the presence of condensation following a LOCA event, may prevent the ERV from de-energizing. The use of EQ splices prevents the ERVs from not de-energizing.

4.1A.1 Basic System Functions The ERVs are automatically actuated by a high reactor vessel pressure signal, or can be manually operated from the Control Room.

The ERV valves are identified as RV2-0203-3B, RV2-0203-3C, RV2-0203-3D, & RV2-0203-3E.

In the current configuration, the ERVs are physically located in the 6-inch branch line off of the Main Steam (MS) header. The ERV pilot valve is directly connected to the ERV valve by a 4-inch long pilot tube that provides the inlet steam to the pilot valve, and also by a turnbuckle support that provides structural support of the pilot valve. Directly on top of the pilot valve is the actuator (i.e. solenoid). The entire pilot valve and actuator assembly is directly supported off of the main ERV valve.

As a result of original and Extended Power Uprate (EPU) power levels, a significant acoustic resonance frequency has occurred in these MS branch lines resulting in increased loads and damage to the ERV actuators. During the root cause inspection (ATI# 435858-07), it was observed that there was damage to actuator components such as the guideposts and upper guide bracket.

To prevent detrimental vibration damage to the ERV actuator, Exelon has decided to replace the existing actuators on each of the four (4) ERV assemblies with new "Hardened Actuators" supplied by GE. This EC will provide for the physical replacement of the ERV actuators and the Page 3 of 24

Exelon EC 359513 Quad Cities Station DCS Unit 2 Revision 0 qualification documentation (Environmental Qualification, Seismic Qualification, etc.) for the replacement.

The solenoid actuator power is from the 125 VDC Distribution System and is provided via appropriate sized cables to minimize voltage drop considerations. Control power is also provided to the actuator's control circuit for Control Room indication and solenoid protection (power cutout).

4.1.4.2 Configuration Change Safety Classification The safety classification for this design change is Safety Related.

The work associated with replacing the existing ERV actuators with a new GE "Hardened Actuators" is part of the over-pressurization protection system attached to the reactor coolant pressure boundary and is therefore safety related.

4.1A.3 Seismic Classification This configuration change package is classified as Seismic Category I.

This installation takes place in the Unit 2 Drywell, which is a safety-related, seismic structure.

This classification is based on Section 3.9 of the UFSAR and General Work Specification Maintenance/Modification Work Quad Cities Station - Unit 1 and 2, R-4411 Table 1511.7 (Piping System Installation Requirements) being classified as Seismic Category L The installation of EQ splices is qualified as Seismic Category I to ensure that it will not reduce the function of plant features important to safety in the event of an earthquake. Refer to Section 4.1.40 in the DCS for the analysis of the seismic requirements.

4.1.5 Performance Requirements The work associated with this design change has no impact on any MS System flow or pressure requirements. There will be no functional change to the MS System. The new GE "Hardened Actuator" will have no impact on the response characteristics of the ERV.

A response time test was performed by NWS Technologies (Ref.: NWS Technologies, "ERV Pilot/Main Operability & Seat Tightness"). The new GE "Hardened Actuator" was tested along with the existing actuator design. Both actuators demonstrated consistent total response times (254.0 to 271.5 msec for the new GE "Hardened Actuator" design and 255.5 to 263.0 msec for the existing actuator design) at 125 VDC. The new GE "Hardened Actuator" design was also tested at 87 VDC and had a total response time of 293.5 msec.

The ERV "Hardened Actuator" will also meet the required surveillance testing and acceptance testing as defined in Section 4.1.6 of the DCS below.

4.1.6 Desian Features Required for Surveillance Testing or Acceptance Testing The required testing is specified in accordance with Procedure T&RM CC-AA-107-1001 with specific testing identified on form CC-AA-107, Attachment 1 contained in Tab 5 of this EC.

Page 4 of 24

Exelon EC 359513 Quad Cities Station DCS Unit 2 Revision 0 No specific design features of the connectors are required. However, the relief valves are inspected per approved station procedures and post modification testing will be performed for the new GE "Hardened Actuator" installation. Vibration monitoring testing will also be performed during power ascension to ensure acceptable vibration levels at the ERV actuator. Acceptance criteria for this testing will be added to CC-AA-107, Attachment 1.

4.1.7 Specifications. Codes. Standards, or Regulatorv Requirements This modification shall be installed in accordance with the Codes and procedures contained in the WPI, Section 9, Applicable Installation Codes and Specifications.

4.1.8 Identify Design Conditions The ERV consists of a main valve, a pilot valve and a solenoid actuator. The ERVs are automatically actuated by a high reactor vessel pressure signal, or can be manually operated from the Control Room. To open the valve, the solenoid actuator actuates the pilot valve reducing the pressure under the main valve disc. To protect against overpressure, ERVs are provided that can discharge steam from the RCS to the suppression pool. As listed in UFSAR 5.4.13.3, each ERV is replaced at least every second refueling outage with a rebuilt valve (i.e., typically 50% of the valves are replaced every refueling outage). Per Rev. 8 of the UFSAR, ERV 1-0203-3E is replaced every outage.

Capacity 558,000 Ibm/hr each @ 1120 psig Pressure Setting < 1115 psig (2-0203-3B & 3C)

< 1135 psig (2-0203-3D & 3E)

Opening Time, shall not be less than** 0.054 seconds (to reach 75% of valve orifice)

Total Opening Time, should be less than** 0.600 seconds Valve Orifice Area, in2 11.702

• • Per EC 343933 - Based on the DIT-QC-EXT-0185-02 dated 1/27/94. This DIT is attached to Calculation No. EMD-041935, Addendum E issued on 8/25/94.

The work associated with this design change will not change these design settings for the existing ERVs. There will be no functional change to the Main Steam System or the Automatic Depressurization System (ADS) as a result of the design change.

The 125 VDC Distribution System shall provide power to the solenoid coil circuit such that adequate power is provided for ERV actuator operation during potential degraded voltage conditions. The ERV actuator control circuit shall provided indication in the Control Room and provided for protection of the solenoid coil.

Page 5 of 24

Exelon EC 359513 Quad Cities Station DCS Unit 2 Revision 0 4.1.9 Calculations or Design Analysis/Documentation Affected Stress and Structural Support Analysis:

The existing MS header piping stress analyses and associated support analysis have been revised to reflect replacement of the existing actuator with the new GE "Hardened Actuator" design using the same Code equations and load combinations as currently used. These calculation changes were made in conjunction with the piping stress and support analysis changes for the Acoustic Side Branch (ASB) modifications performed at each SV and ERV. These analyses are as follows:

• Calculation 041935 (EMD), Main Steam Piping (2MS-B)

• Calculation 041942 (EMD), Main Steam Piping (2MS-C)

• Calculation 041941 (EMD), Main Steam Piping (2MS-D)

• Calculation 5486-23-E4, SRV Line Restraint (Mark I Containment)

The stress acceptance criteria shall remain the same. Piping and support calculation revisions are documented as minor revisions to the calculations. The revised calculations must be submitted for Owner's Review and Acceptance. These have already been documented in EC 359004 and are listed as Posted in this EC.

Electrical Analysis:

The following electrical calculation has been revised for this EC only to incorporate minor changes to the calculation (to incorporate the EC wiring changes and to address other EPU operational issues as noted in Section 4.1.36 of this DCS).

• Calculation QDC-0203-E-0943, Voltage Drop Calculation For Unit 1 and Unit 2 Electromatic Relief Valves (ERV) - ADS System EO Analysis / Evaluation:

The following calculations are issued in order to support operational issues associated with the ERV or in support of the new GE "Hardened Actuator" qualification.

• EQC-DQ-001, Dresden and Quad Cities Stations Report on Multiple Grounds in DC (Superseded by Calculation QDC-0000-E-1533, "Quad Cities Station Report On Multiple Grounds In Dc Distribution Systems, In Response To NRC IN 88-86, Supplement 1)

• QDC-0000-E-1005, EQ Evaluation for Extended Power Uprate-Quad Cities Binders

• Calculation 660-254-001 Rev. 2, "Review of Raychem Reformulated Splicing Products for use at Designated Exelon Nuclear Stations". This calculation is listed in EC 359906.

Reference Calculation EQC-DQ-001 Revision 00, per this EC, the connectors, to which the ERV solenoid connectors will be attached, will be spliced in their respective junction box and not wired via the terminal block. By splicing the connector wires, this eliminates concerns with potential problems that could be caused from water collecting on the terminal strips. This action is per the recommendations provided by IR 00298438.

Page 6 of 24

Exelon EC 359513 Quad Cities Station DCS Unit 2 Revision 0 Based on this information, Calculation EQC-DQ-001 Revision 00 is revised to indicate added component resistance without requiring a re-calculation of the inadvertent pick-up voltage. The existing calculation is bounding as the installation of splices removes the low insulation resistance point (terminal blocks) in this calculation for these valves.

Reference Calculation QDC-0000-E-1005, per this EC, provides justification for operation at EPU environmental conditions with adequate margin. The existing acceptance criteria as specified in the EQ binders (EQ41 Q) is utilized in the calculation.

All of the work associated with replacing terminal board terminations in the junction box for Unit 2 ERV solenoid coil circuits with environmentally qualified Raychem splice NPKP-241B(N) or engineering approved equivalent will be performed under EC 359513. The environmental qualification of Raychem splice kit NPKP is addressed separately in EC 359906.

Vendor Documentation/Evaluations:

The approved versions of the following vendor documentation and/or evaluations are required to form the design basis of the new GE "Hardened Actuator" design.

1. Stevenson & Associates (S&A) Document No. 06Q4568-DR-005 Rev. 1, "Quad Cities ERV Pilot Valve Actuator Vibration Test Report", April 11, 2006 Report that documents a test program to evaluate the effect of operations vibrations on the ERV actuators. Several degradation issues were documented in the report along with the repair that took place to combat the degradation.

2. GE Nuclear Energy 26A6925 Rev. 1, "ERV Actuator Assembly Instructions", March 30,2006 This document provides assembly instructions for the new ERV actuator assembly.

3. GE Nuclear Energy 352B2632 Rev. 0, ERV Actuator Assembly Drawing, March 7, 2006 The ERV actuator assembly drawing lists, envelope dimensions, and identifying parts that are listed in the actuator parts list PL352B2632.

4. GE Nuclear Energy PL352B2632 Rev. 0, ERV Actuator Parts List, March 7,2006 The actuator parts lists gives an itemized list of all the parts identified on the actuator assembly drawing as well as the document type, name, identifications, seismic classification, etc.

5. General Electric (GE) Document No. GENE4000-0051-3159 Rev 0, (DRF 0000-0049-8118), "Similarity Analysis ERV Actuator 352B2632G001 vs. Original Design" March 10,2006 Similarity evaluation of the Dresser 1525 VX Electromatic Relief Valve (ERV) actuator vs. the 352B2632G001 design. Analysis provides justification to the new components added to the new actuator design. An environmental qualification evaluation is also detailed in this report.

6. Structural Integrity Associates (SIA) Calculation Package, File No. QC-33Q-305 Rev. 2, "Calculation of Allowable Turnbuckle Weld Shrinkage and Evaluation", March 17, 2006 Page 7 of 24

Exelon EC 359513 Quad Cities Station DCS Unit 2 Revision 0 Calculation to compute the allowable weld shrinkage for the turnbuckle groove weld.

Calculation of weld stress for the turnbuckleslboss circumferential welds between the turnbuckle and the boss, and the turnbuckle and the main valve. Combined stresses were compared based upon SSE and OBE evaluations to see if the stresses are within the ASME Code[7].

7. Dresser Flow Control Reconciliation OS334-91-03.009 Rev. 2 "Turnbuckle Groove Weld, 1525VX Relief Valve", March 14,2006 Dresser document verifying the circumferential groove weld that is made on the turnbuckle to boss connection.

8. NWS Technologies, "ERV Pilot/Main Operability & Seat Tightness", February 28, 2006 Tests for the response time of the old ERV actuator design vs. the new Hardened Actuator design at 125 VDC. An additional test of the new Hardened Actuator design at 87 VDC.

9. Welding Services Inc., "EMRV Turnbuckle Welding WSI Reference No.: 102894A",

March 6,2006 Report identifies the procedure used to weld a circumferential groove weld on a turnbuckle to boss connection at NWS facility. Based upon the WSI procedure the amount of weld shrinkage was measured.

10. MPR Associates Inc., "Vibration Acceptance Criteria for ERV Valve Actuators" April, 132006 Details the acceptable vibration acceptance criteria for the vibration spectrum of the new ERV actuators. Report is based upon the vibration testing performed by Stevenson &

Associates.

11. Assignment Report (AR 00469121), "Quad Cities ASB and ERV Technical Challenge Meeting", March, 21, 2006 (Orig Change)

Report contains a matrix of FMEA summary for reference only.

Reports 1, 6, and 10 above have been added to the ADL as calculations that require owners review and acceptance. The remaining documents are included by reference to this design change package and will be incorporated into the appropriate design basis documents (i.e., vendor drawings, VETIP manual, EQ Binderetc.) during the EC package closeout.

4.1.10 Redundancy. Diversity or Separation Requirement:

The replacement of the existing actuator with the new "Hardened Actuator" design has not created any new unanalyzed interfaces between redundant safe shutdown equipment. Any potential seismic interaction between the ERV actuators and existing safety related or safe shutdown components or structures has been addressed. The addition of the ERV actuators per this EC does not affect the redundancy, diversity or separation requirements of any plant systems, structures, or components.

Page 8 of 24

Exelon EC 359513 Quad Cities Station DCS Unit 2 Revision 0 4.1.11 Failure Effects Requirements The intent of this design change is to replace the existing actuators on each of the four (4) ERV assemblies with new "Hardened Actuators" supplied by GE. The new "Hardened Actuators" are designed to withstand detrimental vibration damage. Therefore, failure effects due to acoustic resonance vibration, which has caused wear to the actuator components, will be reduced and the replacement actuator will improve the reliability of the system. Per the GE FDI-0187, the safety function of the actuator design is not affected and has not introduced any new conditions for a failure mode effects analysis. AR 00469121 has been created which lists a matrix of failure modes, failure effects, and resolution. The AR report is attached to Tab 8 of this EC. Note that the matrix in AR 00469121 is for reference only. (Note that information exists within AR00469121 that are not applicable to this EC). All of the components replaced in the "Hardened Actuator" are equivalent to or better than the existing actuator fit and function. The form is only minimally changed due to the slight actuator casing dimension increase, and will be verified for acceptability per installer's walkdown.

4.1.12 Fire Protection or Appendix R Safe Shutdown Requirements The screening questions of the Fire Protection Program (FPP) Impact Review, Attachment 2 to CC-AA-102 were reviewed with respect to the proposed design change and all questions were answered "No" impact on the Fire Protection Program or the Safe Shutdown Analysis Report.

The new GE "Hardened Actuator" design has not changed the combustible loading in the area. In addition, the operation and the functionality of the existing ERV/pilot valve/actuator is the same as with the new GE "Hardened Actuator" installed. Therefore, this design change does not change any structure, system, or component different from the originally analyzed fire/safe shutdown configuration.

4.1.13 Material Required The material that is required for this EC is the purchase of the new "Hardened Actuator" from GE. See "Engineering Change Material List (ECML)", Attachment "H" of CC-AA-103 for the items required as well as a brief description of each item. The ECML is located in Tab 4 of this EC. The actuator is supplied safety related with unique quality documentation requirements.

4.1.14 Material Suitability Requirements The material suitability requirements for the new GE "Hardened Actuator" design is documented and qualified by the vendor documents listed below. These documents along with specific vendor testing provide a comprehensive list of the ERV actuator components as well as material descriptions. The evaluation of the modified components per these documents forms the design bases for material acceptance and ERV operational assurance to fit and function. The form is only minimally changed due to the slight actuator casing dimension increase, and will be verified for acceptability per installer's walkdown.

Page 9 of 24

Exelon EC 359513 Quad Cities Station DCS Unit 2 Revision 0

• Stevenson & Associates (S&A) Document No. 06Q4568-DR-005, "Quad Cities ERV Pilot Valve Actuator Vibration Test Report"

• GE Nuclear Energy Field Disposition Instruction FDI-01 87, "Main Steam Relief Valve Actuator Dresser ERV"

• General Electric (GE) Document No. GENE-0000-0051-3159, (DRF 0000-0049-8118),

"Similarity Analysis ERV Actuator 352B2632G001 vs. Original Design"

• MPR Associates Inc., "Vibration Acceptance Criteria for ERV Valve Actuators" The materials that have been included in the new GE "Hardened Actuator" design are equivalent to or better than the material on the existing GE actuators. As with the original actuator design, the new actuator is supplied safety related. The design changes to the ERV/pilot valve/actuator assembly is in compliance with the Dresser design basis for the relief valve function.

EQ splices meet requirements for high temperature and high radiation as per EQ Binder (EQ-GEN25).

4.1.15 Environmental Conditions or Environmental Imnacts The new GE "Hardened Actuator" for this design change will be installed in the Unit 2 drywell.

The drywell is considered a harsh environmental zone and is designed to operate in a potentially high, temperature, high humidity and high radiation area. The environmental requirements were considered within the original design parameters and the changes required under this EC would not affect those requirements. The new materials that were added for this EC include a silicon gasket added under the solenoid base plate, Stellite 6B material for the guideposts and bushings, and Loctite 272 or equal per EC 358821 added to the bolt connections. Other material changes include upgrading material from carbon steel to stainless steel. The new ERV components are not affected by the environmental conditions experienced in the Unit 2 drywell area. Therefore, there are no environmental conditions or restrictions being added or affected by this design change. An analysis of the environmental qualification of the new ERV actuator can be found in Section 4.1.16 of the DCS.

4.1.16 Environmental Oualification (EO)

This EC is for the replacement of the solenoid actuator and therefore, there is no change to the drywell environment. The evaluation of the EQ qualification of the new ERV solenoid actuator has been analyzed CC-AA-203, Attachment 1 (EQ Evaluation) which is included in Tab 8 of this EC. Based upon the EQ evaluation, the new ERV solenoid actuator is environmentally qualified and is consistent with the original EQ qualification of the Dresser ERVs in accordance with 10 CFR 50.49, "Environmental Qualification of Electrical Equipment Important to Safety for Nuclear Power Plants". A summary of the EQ evaluation (CC-AA-203) form is below.

Wiring changes are shown on drawing 4E-2816H of this EC. Since the ERV's are located in a harsh environment and are required to function in the event of a small break LOCA, EQ splices will be performed. EQ splices are operable in plant postulated LOCA and High Energy Line Break (HELB) accidents. Splice will be installed in accordance with QCEM 0700-04 or engineering approved equivalent.

Page 10 of 24

Exelon EC 359513 Quad Cities Station DCS Unit 2 Revision 0 This EC supercedes the design changes from EC 356659, "Replace Termination with EQ Splice on ERV Solenoid Circuits". since modifications are now being performed on the power/control quick disconnect cables from the junction box to the ERV actuator. All of the work associated with replacing terminal board terminations in the junction box for Unit 2 ERV solenoid coil circuits with environmentally qualified Raychem splice NPKP-2-41B(N) or engineering approved equivalent will be performed under EC 359513. The environmental qualification of Raychem splice kit NPKP is addressed separately in EC 359906 and EQ binder EQ-GEN029 respectively.

The electrical changes in this EC are due to a GE's recommended wiring change as a result of ERV "Hardened Actuator" testing/qualification and is documented in GE Nuclear Energy Field Disposition Instruction, FDI-0187.

The existing quick disconnect cables (QDCs) are being replaced with new QDCs due to a change in wire size. The existing QDC for solenoid circuits with 6 pins/#10 AWG wire configuration will be replaced with a new QDC that has 3 pins/#8 AWG wire configuration. Since there are no changes to non-metallic materials in the replacement QDC, it is qualified by similarity to the existing QDC. The QDC for limit switches are also being replaced. However, the QDC associated with the limit switches are not subject to the EQ requirements as stated in EQ binder EQ-GEN017.

Based upon the test results performed by NWS Technologies (Ref.:NWS Technologies, "ERV Pilot/Main Operability & Seat Tightness") As well as the voltage drop calculation (QDC-0203-E-0943) the minimum operability voltage requirement for the new actuator solenoid is satisfied.

There are only two changes in the modified design of the solenoid DD233A3620P001 where non-metallic materials are used. The use of Loctite and the addition of a silicone rubber gasket will not have any impact on the environmental qualification of the solenoid.

According to Section 4.1.15 and Section 4.1.16 of the DCS for EC 359004, there is no change to the drywell environment as a result of the ASB design change. Therefore, this EC has no impact on the qualification of the solenoid valves.

4.1.17 Overatina Experience (OPEX)

The INPO website was searched for operating experience on the ERV actuators. As part of Extended Power Uprate (EPU), several design reviews have been performed. It has been determined that the additional flow requirements of EPU have increased the acoustic resonance created by the safety valve branch lines. Flow-induced problems have occurred in safety related valves at fossil and nuclear power plants. These problems consist of chronic leakage, excessive noise, chatter, and failure of the valve components. The increase in resonance observed at Quad Cities is believed to be a contributing factor in damage to the steam dryer (Ref. GENE-0000-0018-3359 Rev. 0, Technical Assessment, Quad Cities Unit 2, Steam Dryer Failure -

Determination of Root Cause and Extent of Conditions).

For the EQ splice change a review was completed as part of EC 350113, "EOC Install ERV Cable Quick Disconnects to Unit 1".

Page 11 of 24

Exelon EC 359513 Quad Cities Station DCS Unit 2 Revision 0 4.1.18 Equipment Performance Information Exchange (EPIX)

The INPO website was searched for equipment related changes related to this design change. As seen for the design change associated with EC 359513 there is no affect the current design parameters for the Main Steam System and the Automatic Depressurization System (ADS). The installation of the new GE "Hardened Actuator" design will ensure reliability of the systems via a more durable actuator design.

For the EQ splice change a review was completed as part of EC 350113, "EOC Install ERV Cable Quick Disconnects to Unit 1".

4.1.19 Probability Risk Assessment (PRA) Imnact The replacement of the existing ERV actuator with the new GE "Hardened Actuator" design does not affect the operation of the ERVs or the current operation of the Main Steam System or the Automatic Depressurization System (ADS). The design change does not affect the seismic capability of the actuator or other components in the area. Therefore, the design does not affect nor increase the probabilities of failures or shutdown risks of any other equipment on the site.

The Probability Risk Assessment (PRA) model applicability checklist (CC-AA-102, Attachment

4) was used as an aid to make this determination. The ECCS availability (i.e., ADS and 125 VDC station battery systems) as noted in UFSAR Table 6.3-15 are not impacted by the GE "Hardened Actuator" changes.

4.1.20 System Operational Requirements There are no changes to the system operating requirements of the Main Steam System or the Automatic Depressurization System (ADS) as a result of this design change. The new GE "Hardened Actuators" installation (including wiring changes) will operate in the same manner as the previous ERV actuator design. The NWS testing discussed in Section 4.1.5 of the DCS conforms that the addition of "Hardened Actuators" will have no impact on systems operations or response time of the actuator.

4.1.22 Procedure Changes Refer to CC-AA-102, Attachment 9 and the ADL for a list of affected procedures by the implementation of this EC. No new operating procedures are required for this design change.

However, existing maintenance procedure will require revision to document the new GE "Hardened Actuator" design. GE document 26A6925, "ERV Actuator Assembly Instructions" gives detailed assembly instructions for the new ERV actuator assembly. This GE document can be used as a reference for procedure changes, where applicable. The responsible departments for coordinating procedure changes are listed in Section 5 of the WPI. The following primary procedures are impacted by this EC. Others may be affected as listed in Attachment 9 and on the ADL.

• QCEMS 0250-13 "Dresser Electromatic Solenoid Actuator Installation. Replacement, Inspection. and EQ Surveillance

• QCMM 0203-21 "Electromatic Relief Valve Removal and Installation" Page 12 of 24

Exelon EC 359513 Quad Cities Station DCS Unit 2 Revision 0

• MA-AA-734-460 "Electromatic Relief Valve Inspection and Maintenance"

• MA-MW-734-459 "Electromatic Relief Valve Pilot Replacement" 4.1.23 Training Requirements This design change is not expected to require any operations training. The ERVs do not impact how the plant is operated or any controls and displays in the control room. Procedure/Training impacted by EC 359513 is documented in CC-AA-102, Attachment 9. Mechanical and Electrical Maintenance will not require training in the installation and removal of the new GE "Hardened Actuators". The actuator change will not impact the simulator since there is no change in the Technical Specification limit for actuator/ERV valve response time. The valves are tested in accordance with approved procedures to ensure this limit is maintained with margin.

4.1.24 System Interface There is additional work that is taking place during the refueling outage that is directly related to the ERVs. The work must be coordinated appropriately as discussed in Section 4 of the WPI.

The work activities associated with EC 359513 will interface with the 125 VDC power system in addition to the direct interface with the MS System and the Automatic Depressurization System (ADS). Coordination with other EC modifications or planned maintenance activities shall be reviewed to ensure proper coordination and ALARA considerations are addressed.

EC 359512 is the work associated with ERV actuator replacement in Unit 1, which is scheduled to take place after Unit 2 ERVs are installed. With the exception of EC 359512, the following work activities associated with these design changes shall be coordinated with this design change:

• EC 359004, "Addition of Acoustic Side Branch to Safety Relief Valves"

• EC 356659, "Equivalent Change Package to Replace Termination with EQ splice on ERV Solenoid Circuits" (See Note below)

• TCCP 359074, "Main Steam System Load Reduction and ERV Hardening Vibration Monitoring Instrumentation"

• EC 359512, "Electromatic Relief Valve (ERV) Actuator Replacement-Unit 1" This EC shall be coordinated with EC 359004 for the addition of Acoustic Side Branches (ASB) to the inlet piping to the ERVs. The ASBs are being added to the ERV steam inlet lines to mitigate acoustical resonance vibration in the Main Steam System piping. Installation activities between EC 359004 and this EC must be properly coordinated.

Note: Installation of the EQ splices per EC 356659 have now been incorporated into the work scope of this EC. Additional wiring changes associated with the quick disconnect cables has initiated this change. Appropriate Work Order changes are being made for the modification work.

Installation of the accelerometers per TCCP 359074 on the ERV actuators shall not affect the function or operation of the relief valves and thus their ability to provide discharge capability is not impacted.

Page 13 of 24

Exelon EC 359513 Quad Cities Station DCS Unit 2 Revision 0 4.1.26 Radiation Protection (ALARA)

The work associated with the removal and installation of the ERV actuator will be performed in a radiologically controlled area (RCA) in the Unit 2 drywell. An ALARA applicability review was performed in accordance with CC-AA-102, Attachment 5 and this EC is a radiologically significant Configuration Change (Note: ATI No. 298438-09 was created for the original work scope for EC 356659. See Section 4.1.24 for inclusion of work scope in EC 359513.). ALARA design review and installation reviews were completed in accordance with CC-AA-212-1001, Attachments 1 and 2, respectively, for this EC. All applicable site procedures for work in the RCA shall be followed.

4.1.27 Walkdowns A Designer's Walkdown (in the drywell) was not performed due to lack of area accessibility. An Installer's Walkdown will be performed in accordance with Procedure CC-AA-106-1001 prior to the installation of this EC. The Installer's Walkdown is included in Tab 8 of the design change package. A Work Order task will track completion of the Installer's Walkdown.

4.1.28 Need for Maintenance Access (IST)

The ERVs and pilot valves are replaced periodically and are interchangeable. Access is required for this maintenance operation, but the load path will not change. As listed in UPSAR 5.4.13.3, each ERV is replaced at least every second refueling outage with a rebuilt valve (i.e., typically 50% of the valves are replaced every refueling outage), except for the 1-0203-3E ERV, which per rev. 8 of the UFSAR, is replaced every outage. Valves are typically removed and replaced with new or rebuilt relief valves. Access is required for this maintenance operation. All maintenance work shall be performed according to the appropriate valve maintenance procedure documented in Section 4.1.22 of the DCS. This design change does not affect the maintenance procedure and has no impact to the access of these ERVs.

4.1.29 Special Transport / Special Handling / Special Shinning Requirements All rigging of ERVs shall comply with existing station procedures and good working practices.

This includes the transportation of material from the first level of the drywell to the second level.

Approved lifting points for the rigging of the ERVs are provided in Procedure QCMM 0203-21, Attachment 2. These rigging points are unchanged by the new GE "Hardened Actuator" design.

The disposal of removed components shall be addressed by Station ALARA procedures.

Transport of the existing ERVs to the vendor facilities for modifications shall be performed in accordance with approved station procedure and ALARA considerations.

4.1.32 Impact on Nuclear Fuel, Core Components. Core Desi2n, Reactivity Management, Criticality Control and Accountability of Nuclear Materials, and Transient Analyses, and Accident Analyses:

The installation of the new GE "Hardened Actuator" per this EC will not alter the characteristics of any valve in the Main Steam (MS) System or Automatic Depressurization System (ADS). It does not alter any reactor vessel connected piping. The function or the analyses of the Page 14 of 24

Exelon EC 359513 Quad Cities Station DCS Unit 2 Revision 0 Emergency Core Cooling System (ECCS) and the function of the MS System/ADS will remain untagged. The solenoid response time remains unchanged.

4.1.34 Mechanical Reguirements This design change does not require any piping changes and will not change the function of the ERVs. The new GE "Hardened Actuator" design will have no affect on current system operation of the Main Steam (MS) or Automatic Depressurization System (ADS). The existing piping analyses for the affected ERVs have been updated to include the new weight of the actuator and are identified in Section 4.1.9 of this DCS. This weight change is minimal compared to the weight of the piping systems (see Section 4.1.39 of this DCS for Civil/Structural requirements).

Based on the piping analysis updates, which also includes the evaluation for the addition of the Acoustic Side Branch (ASB) per EC 359004 to the standpipe of each and ERV, the added load is acceptable. Therefore, implementation of EC 359513 will be coordinated with EC 359004.

(Note: This design change does not perform any pressure boundary Code welding. Welding of the turnbuckle is a structural weld performed in accordance with approved station welding practices)

The ASBs are being installed into Unit 2 per EC 359004 to mitigate acoustical resonance vibration in the Main Steam System piping. That modification along with the installation of the GE "Hardened Actuator" will ensure improved durability and integrity of the relief valves.

The new GE "Hardened Actuator" mechanical design basis is documented and qualified by the following vendor documents:

• Stevenson & Associates (S&A) Document No. 06Q4568-DR-005 "Quad Cities ERV Pilot Valve Actuator Vibration Test Report"

• GE Nuclear Energy Field Disposition Instruction FDI-0187, "Main Steam Relief Valve Actuator Dresser ERV"

• GE Nuclear Energy 26A6925, "ERV Actuator Assembly Instructions"

• GE Nuclear Energy 352B2632, "ERV Actuator-Assembly Drawing"

• GE Nuclear Energy 2B2632, "ERV Actuator-Parts List"

• General Electric (GE) Document No. GENE-0000-0051-3159 (DRF 0000-0049-8118),

"Similarity Analysis ERV Actuator 352B2632G001 vs. Original Design"

• NWS Technologies, "ERV Pilot/Main Operability & Seat Tightness"

• MPR Associates Inc., "Vibration Acceptance Criteria for ERV Valve Actuators" The GE FDI-0187 document provides the material characteristics of the new GE "Hardened Actuators". The above documents mechanically qualify the new actuator design. The new actuator design will perform in a manner equivalent to the current actuator design and will not degrade the qualification of the relief valve. As noted in these documents, the addition of the new GE "Hardened Actuators" will have no impact on MS System operations or response time of the actuator. The actuator response time has been verified through NWS Technologies and summarized in Section 4.1.5 of the DCS. The NWS testing was performed to ensure the improved design will not change the required response time for pilot valve depressurization of the ERV and therefore ERV opening. In addition to vendor testing, the installed GE "Hardened Page 15 of 24

Exelon EC 359513 Quad Cities Station DCS Unit 2 Revision 0 Actuator" will be functionally tested in accordance with the acceptance criteria provided in Tab 5 of this design change package. These testing requirements have been developed in accordance with CC-AA-107, Attachment 1.

The similarity analysis that GE has provided gives a detailed explanation as to the changes to the ERV actuator and the impact the changes have on the performance and operation of the actuator.

The items below are changes to the ERV actuator as discussed in the similarity analysis provided in GENE-0000-0041-3159. The list below is provided for reference only. A complete listing of the changes shall be obtained from the documents listed above in Section 4.1.34.

• Non-buckling compression zinc-plated springs have a larger diameter and the number of springs on each guidepost will increase from one to two.

• The upper bracket is common thicker single piece and consists of a hardened bushing toleranced fit to the bracket.

• An additional top brace is provided to secure the guideposts as well as allow the guideposts to be bolted in place.

• Two side braces are bolted to the bottom bracket as well bolted to the top rigid fixed bracket.

The guideposts are threaded into the bottom bracket and pass through the upper bracket and bushing, to the upper bracket and held in place with a nut.

• A lower guide is placed on each guidepost, separating the two springs.

• The guideposts, lower guides, and upper guides are made out of Stellite 6B material.

• A silicon rubber gasket is added between the solenoid and base plate. The actuator will then be bolted to the solenoid plate separated by the gasket.

• The solenoid is modified to include gussets for the lower angle bracket and Nitronic 60 actuating lever pivot pins and bushings.

• Associated bolting will be secured with a thread lock compound such as Loctite 272 or equal.

• Where applicable, the bolts will have different lengths to accommodate thicker bracket attachments. The bolt material and plating remains the same, however socket head screws will be used where applicable.

The vibration acceptance criteria for testing during power ascension is listed in CC-AA-107, located in Tab 5 of this EC. (Ref.: MPR Associates Inc., "Vibration Acceptance Criteria for ERV Valve Actuators") and is part of the start up test plan.

These changes to the actuator will not change the fit or function of the actuator or the mechanical interface. The form is only minimally changed due to the slight actuator casing dimension increase, and will be verified for acceptability per installer's walkdown. Existing procedure may be utilized for maintenance activities. Minor changes to the procedures will be required for some of the new "Hardened Actuator" components.

As discussed in EC 359004, the addition of the ASB to the ERV does not impact the heat loading and drywell HVAC System. Impact on the drywell heat load is insignificant, since the amount of piping (insulated piping) added to the drywell by EC 359004 is minimal. The maximum Page 16 of 24

Exelon EC 359513 Quad Cities Station DCS Unit 2 Revision 0 operating temperature of the drywell will remain unchanged as discussed in the DCS, Section 4.1.34, of EC 359004. Therefore, the new GE "Hardened Actuator" will not be impacted by ASB installation per EC 359004.

4.1.36 Electrical Requirements There are no changes to any electrical requirements as a result of this design change (i.e., actuator power requirements). Existing power and control cables to and from the existing junction boxes to the ERV actuators will be disconnected at the quick disconnects and removed with the actuator for incorporation into the new "Hardened Actuator" design. The flex conduit and associated connections will be reused, however, the quick disconnects and associated cables for power and control will be modified. This change is due to a GE's recommended wiring change as a result of ERV "Hardened Actuator" testing/qualification and is documented in GE FDI-0187.

Therefore, this EC provides for a change in the quick disconnects/cables from the junction box terminal board to the ERV actuator. The power/control cable quick disconnect will be changed to allow for the proper sized wire (Per GE recommendation in FDI-0187) to be landed at the actuator. This will entail the replacement of the existing quick disconnect cables and associated components as shown on drawing 4E-2816H of this EC. (Note: New material may be supplied to replace-in-kind the existing components (i.e., flex conduit, connectors, junction box, etc. as originally installed per EC 343933)).

This EC also replaces the terminal board terminations for the ERV solenoid coil circuit inside the junction boxes with Environmentally Qualified (EQ) splices. EQ splice change, previously included as part of EC 356659, was for in-line butt-splice with one wire on each side. Electrical work associated with EC 356659 is now superceded by EC 359513 electrical work. The change that will be incorporated in EC 359513 is for a wye-splice with one #8 AWG wire each for both the positive and negative side of the power supply connection for the solenoid. The EQ splice change inside the junction box is being performed due to the potential for ERV's to not de-energize during LOCA conditions. Currently the ERV solenoid power is carried in 6 conductors that are part of the same cable with each conductor terminated individually at a terminal block.

The 6 parallel paths to ground, given the presence of condensation following a LOCA event, may prevent the ERV from de-energizing. The use of EQ splices prevents the ERV's from not de-energizing. The electrical terminations for the control circuit will be re-terminated in their current configuration as shown on drawing 4E-2816H of this EC.

This EC also provides for a new electrical junction box (2RB-168) to be replaced and relocated in Unit 2. The new configuration will provide more clearance between the ASB end flange and the electrical junction box. A new junction box is required to accommodate the new orientation of the EGS quick disconnects connecting from the junction box to the solenoid actuator. The conduit entrance, mounting holes, and quick disconnect holes are to be drilled into the new electrical junction box. Drawing 4E-6541H has been revised and updated to list the new junction box dimensions for 2RB-168. The structural analysis of the new junction box is listed in Section 4.1.39 of the DCS.

The design of the new GE "Hardened Actuator" uses the same baseplate design as used in the existing actuator. All electrical equipment attachments are made through the baseplate and therefore the electrical interfaces have not changed. Existing procedures will be utilized for removal of the existing actuator and re-installation of the new GE "Hardened Actuator". Since Page 17 of 24

Exelon EC 359513 Quad Cities Station DCS Unit 2 Revision 0 there is no change to the power and control cable destination, the existing routing will remain the same. Therefore, no new support qualification will be required for the cable routing.

The new GE "Hardened Actuator" design will function in the same manner as the existing actuator. New mechanical component parts have been added to the actuator to ensure the durability and reliability of the actuator. The following documents provide the design details of the changes made to the actuator design:

• Stevenson & Associates (S&A) Document No. 06Q4568-DR-005, "Quad Cities ERV Pilot Valve Actuator Vibration Test Report"

• GE Nuclear Energy Field Disposition Instruction FDI-0187, "Main Steam Relief Valve Actuator Dresser ERV"

• General Electric (GE) Document No. GENE-0000-0051-3159, (DRF 0000-0049-8118),

"Similarity Analysis ERV Actuator 352B2632G001 vs. Original Design"

• NWS Technologies, "ERV Pilot/Main Operability & Seat Tightness" As per the documents listed above, the new actuator design and the associated component replacement parts will be equal to or better than the existing actuator design. When the new actuator is correctly installed it will perform in the same manner equivalent to the existing actuator and moreover will not degrade the operation of the ERVs. The cover for the GE "Hardened Actuator" will be taller and wider than the existing cover to allow for increased height and width of the actuator (i.e., center height increased by approximately 2", width increased by approximately 1/4"). With the new guidepost design, four actuator springs will be utilized, however, the effective spring constant and free length will remain the same as the existing actuator design. This change along with the use of the same solenoid model type, which has been modified to include bottom angle bracket gussets and hardened pivot pins and associated bushings, will not change the electrical parameters for operation. The actuator design changes allow the solenoid to be more resistant to environmental vibration. The increased resistance was verified by vibration testing in comparison to the existing actuator design.

Per the referenced documents noted above, the solenoid electrical characteristics are the same as the existing actuator design. Therefore, EC 359513 does not impact the existing 125 VDC power requirements for the ERV solenoids, which have been analyzed by Calculation QDC-0203-E-0943, "Voltage Drop Calculation For Unit 1 and Unit 2 Electromatic Relief Valves (ERV) - ADS System". The calculation shows that solenoids have voltage for their operation in the existing field cable configuration.

Calculation QDC-0203-E-0943 has been updated for the new control cable configuration with quick disconnect connectors and has been listed as an affected document on the ADL of this design change. The minor changes to the calculation do not affect the overall conclusions of the calculation. This calculation is referenced to establish testing acceptance criteria for vendor testing of the "Hardened Actuator" design at different voltage conditions to ensure adequate operation of the new "Hardened Actuator" design at 'worst voltage' conditions. The results of the tests as documented in Section 4.1.5 of the DCS showed that the new actuator design performs in accordance with station design basis requirements.

Reference Calculation EQC-DQ-001 Revision 00, per this EC, the connectors, to which the ERV solenoid connectors will be attached, will be spliced in their respective junction box and not Page 18 of 24

Exelon EC 359513 Quad Cities Station DCS Unit 2 Revision 0 wired via the terminal block. Splicing the connector wires eliminates concerns for potential problems of water collecting on the terminal strips. This action reflects the recommendations provided by IR 00298438.

Based on this information, Calculation EQC-DQ-001 Revision 00 is revised for these valves to remove terminal block insulation resistance due to the implementation of splicing. Calculation QDC-0000-E-1533, "Quad Cities Station Report On Multiple Grounds In Dc Distribution Systems, In Response To NRC IN 88-86, Supplement 1" has been issued. This calculation supersedes Calculation EQC-DQ-001 revision 00 for Quad Cities Station only. This calculation has been prepared, reviewed, and approved considering the affects of both EC 359513 and EC 359512. EC 359224 revision 00 will be used to issue this calculation, as such calculation EQC-DQ-001 will not be updated as a result of this modification and calculation QDC-0000-E-1533 will be shown as posted in the ADL of this modification.

Reference Calculation QDC-0000-E-1005, per this EC, provides justification for operation at EPU environmental conditions with adequate margin. The existing acceptance criterion as specified in the EQ binders (EQ41Q) is utilized in the calculation. This calculation has been updated under EC 357981, as such this calculation will be shown as posted in the ADL for this modification.

The visual inspections and electrical test, which are required to satisfy EQ requirements, will continually be performed in accordance with Procedure QCEMS 0250-13. This includes the maintenance and surveillance actions necessary to ensure continuing qualification of the ERV actuators that are part of the EQ program. The testing per the current procedure will continually provide assurance of the electrical continuity to the solenoids and allow for required functional testing verification of the actuator/solenoid/pilot valve configuration. However, minor changes will be required to this procedure for the new "Hardened Actuator" design.

Wiring inside the actuator is inspected per Procedures QCEMS 0250-13 and MA-MW-734-459 when maintenance is performed on the actuator or pilot valve. Steps within the procedure required inspection of the wiring prior to installing the cover to ensure no pinched wires or other anomalies. This includes the check to ensure the wiring does not interfere with the cutout switch and other actuator parts. Procedure QCEMS 0250-13 allows for training the actuator wiring to ensure adequate clearance. This will be done to provide assurance that the wiring is adequately bounded to prevent damage of the wiring or solenoid terminals due to vibration. Section 3 of the WPI gives work instructions for training the electrical wire.

An error was identified on Drawing 4E-2581: ERV 3B was incorrectly identified as 38 for annunciator tile D-13 of Panel 902-3, and is corrected for reference in this EC.

4.1.37 Instrument and Control Requirements The replacement of the existing ERV actuator with the new GE "Hardened Actuator" does not impact the existing instrumentation installed on the main steam SVs and ERVs. This includes temperature, pressure, and acoustical resonance monitoring instrumentation. New temporary instrumentation will be installed on the ERV actuators via Temporary Configuration Change Package (TCCP) 359074, "Main Steam System Load Reduction and ERV Hardening Vibration Monitoring Instrumentation". Each ERV inlet flange, pilot valve, and actuator will be equipped Page 19 of 24

Exelon EC 359513 Quad Cities Station DCS Unit 2 Revision 0 with an accelerometer. The data gathered will be used to analyze piping and ERV performance and vibration levels.

The ERV control circuit wiring changes will not impact the control or operation of the ERVs.

This wiring change will ensure adequate cable/wire terminations at the ERV actuator's switches.

Wiring changes will be in accordance with drawing 4E-2816H of this EC and station procedures.

4.1.39 Civil / Structural Requirements The replacement of the existing ERV actuator with the new GE "Hardened Actuator" does not significantly affect the main steam seismic qualification and pipe stresses. Changes in mass due to the ERV actuator replacement are small compared to the overall system design. Therefore, these design change results in a minimal change to the analytical models used in the piping seismic analyses or existing pipe stress analyses. The piping stress calculations have been revised to include the actuator weight change as a result of this design change. The affected calculations are listed in the ADL and identified in Section 4.1.9 of the DCS. These calculations have been revised in conjunction with EC 359004, which adds an Acoustic Side Branch (ASB) to the standpipe of each SV and ERV to mitigate acoustical resonance vibration.

The ERV turnbuckle to boss connection will be modified as part of this EC to provide a sturdier attachment that does not rely on the threads within the turnbuckle. The new connection will consist of two full circumferential groove welds at each end of the turnbuckle to boss gap.

During the conceptual design phase, a concern was raised regarding the possibility of excessive stresses in the turnbuckle and pilot tube existing attachment welds due to weld shrinkage of the new weld during cooling. Both analytical methods and physical testing disposition this issue.

The result of these analyses has provided a specific set of weld criteria that must be met while performing the attachment welds.

The analysis of the new welds consists of a calculation (Ref.: Structural Integrity Associates (SIA) Calculation Package, File No. QC-33Q-305, "Calculation of Allowable Turnbuckle Weld Shrinkage and Evaluation") that concludes the maximum allowed weld shrinkage while welding the turnbuckles is 0.025 inches. Concurrently, a test was performed by WSI using accepted welding practices for this type of weld to measure the amount of shrinkage that would be expected. The test indicates a shrinkage of 0.006 inches was measured (Ref.: Welding Services Inc., "EMRV Turnbuckle Welding WSI Ref. No.: 102894A"). It is therefore reasonable to conclude that these welds can be successfully performed without over stressing the attachment welds provided the same techniques, restrictions and guidance are followed. This conclusion is substantiated by the valve manufacturer, Dresser Flow Control Company (Ref. Dresser Flow Control Reconciliation OS334-91-03.009 "Turnbuckle Groove Weld, 1525VX Relief Valve").

As referenced above, a similar circumferential weld was performed on the turnbuckle by WSI and the amount of shrinkage measured was a factor of four less than the allowable given in the SIA calculation. The design criteria specifies accepted welding practices that will reduce the heat input during the weld process and closely match the test weld performed by WSI. Provided these design criteria are met, the turnbuckle to boss welds can be satisfactorily performed without creating excessive stresses in the attachment welds to the main valve or pilot valve and still provide the necessary structural support required.

Page 20 of 24

Exelon EC 359513 Quad Cities Station DCS Unit 2 Revision 0 The seismic stress of the weld was calculated in the SIA calculation (Ref.: Structural Integrity Associates (SIA) Calculation Package, File No. QC-33Q-305, "Calculation of Allowable Turnbuckle Weld Shrinkage and Evaluation"). The combined stresses based upon Operating Basic Earthquake (OBE) and Safe Shutdown Earthquake (SSE) and taking into account the weight increase of approx. 1ib. show that both weld stresses are within the ASME Code [7]

allowable and therefore acceptable.

The existing junction box, 12"X12"X6", is to be replaced with a new junction box 20"X16"X6".

Referring to sketch E-SK1 attached to the WPI in Tab 2 of this EC, the existing box is mounted to a C4X5.4 that is welded to the structural steel. The top of the existing box is more than 50" above the supporting steel and weighs approximately 13 lbs. The top of the new box is less than 48.5" above the top of the supporting steel and weighs approximately 26 lbs. Based on the support configuration, very small box weight, and the proposed changes, the revised support configuration is judged to be adequate in comparison to original configuration.

4.1A0 Seismic / Dynamic Requirements The current seismic qualification of these actuators is SQUG. An evaluation of the changes to the actuator found that SQUG is still applicable. This is documented in EC 360366.

As mentioned in Section 4.1.39 of the DCS, the two single bevel full circumferential groove welds to be added to the turnbuckle and boss connection will result in a sturdier attachment that does not rely on the threads.

A similarity analysis comparing the original and existing designs with the new GE "Hardened Actuator" has been conducted (Ref.: General Electric (GE) Document No. GENE-0000-0051-3159 Rev 0, (DRF 0000-0049-8118), "Similarity Analysis ERV Actuator 352B2632G001 vs.

Original Design" March 10, 2006). As stated in the similarity report, the new GE "Hardened Actuators" are equal to or better than the original and existing actuator designs. Mechanical changes that have been made to the new GE "Hardened Actuator" are listed in Section 4.1.34 of this DCS. A summary of those pertinent changes can be found in EC 360366.

According to GE FDI-01 87, the actuator changes have increased the overall weight of the actuator from 60 lbs. to 66 lbs. The added weight has been evaluated as part of the MS Line piping seismic loads and found to be acceptable.

Frequency analyses of the actuator/pilot/turmbuckle using the original weight in one model and the increased weight in the second model show that both models have fundamental frequency above 50Hz. The first model frequency is about 60Hz and the second model frequency is about 56Hz. As stated in EC 360366 this change is considered a minor change and will not affect the seismic response.

Page 21 of 24

Exelon EC 359513 Quad Cities Station DCS Unit 2 Revision 0 As detailed in the GE similarity analysis the changes made to the new hardened actuators have made the actuators better than the previous versions. The actuator modifications have been specifically designed to be more resistant to system vibrations. Comparative aging tests have been performed on the old, existing and new actuators (Ref.: Stevenson & Associates (S&A)

Document No. 06Q4568-DR-005, "Quad Cities ERV Pilot Valve Actuator Vibration Test Report"). The new hardened actuators were found to withstand extensive vibration testing successfully and lasted much longer than the other actuators. Moreover, any damage that was observed on the actuator during the vibration testing was repaired and upgraded prior to resuming vibration testing. The upgrades were incorporated in the new GE "Hardened Actuator" design.

These tests demonstrate the hardened actuators have been significantly strengthened over previous actuators.

Aging vibration tests were performed on the ERV actuators at Quanta Labs. The aging tests did not completely encompass the seismic frequency range. However, swept sine tests were performed on the prototype and production actuators and it was shown from these tests that there were no significant actuator modes in the impact zone. Given that the aging accelerations were applied in the resonant frequency range of the actuator and that the accelerations were significantly higher than those experienced in the plant at EPU power levels and that the aging accelerations were applied for hours at a time, the aging tests demonstrate that the actuator is capable of sustaining the required seismic loads. The vibration tests also demonstrated that based upon the testing in the laboratory, the new GE design production actuator was not susceptible to significant guidepost wear, the new hardened steel pivot pins were not susceptible to wear and the new cover boxes with stiffeners would function without elongating the bolt holes or breaking the bolts. (Ref.: Stevenson & Associates (S&A) Document No. 06Q4568-DR-005, "Quad Cities ERV Pilot Valve Actuator Vibration Test Report")

Quad Cities station is in the process of implementing modifications to lower the vibration level in the main steam lines during extended power uprate (EPU) in Unit 2. It is anticipated that on the average, the modifications will lower the vibration level to that of pre-EPU or even lower. In addition, enhancement of the actuator internal components and cover of the ERVs actuator are made to increase their durability.

This EC also considers the possibility of seismic interaction with surrounding components.

Based on photos of the current Unit 2 ERV/pilot valve/actuator assembly, which is mounted from the main steam piping, it has been determined that there is no possible interaction with surrounding items. This will be confirmed via an Installer's Walkdown (See Tab 8 for Installer's Walkdown) as documented in Section 4.1.27 of this DCS.

4.1A1 Personnel Requirements and Limitations The design changes performed by this EC will be performed by skilled and qualified labor in accordance with approved procedures and processes. There are no changes to the personnel requirements and limitations due to the design changes of this EC. Vendors will be utilized to perform welding services that will be controlled under approved QA programs. Work performed in the drywell will be completed in accordance with station procedures and will be performed in accordance with CC-AA-212-1001, RP-AA-400, and RP-AA-401 to address ALARA considerations.

Page 22 of 24

Exelon EC 359513 Quad Cities Station DCS Unit 2 Revision 0 4.1A2 Special Procedures or Special Installation Specification The removal and reinstallation of the ERV main valve and ERV pilot valve shall be in accordance with QCMM-0203-21. Replacement of the existing solenoid actuator with the new "Hardened Actuator" will be in accordance with QCEMS 0250-13. Installation testing shall be per the requirements of CC-AA-107, Attachment 1, "Configuration Change Acceptance Checklist".

Installation of the turnbuckle circumferential weld will be performed offsite in accordance with approved vendor procedures. The welding process ensures a high quality weld and the structural integrity of the turnbuckle design.

4.1A3 Interfacing Departments Interfacing department impacts are addressed and documented on the CC-AA-102 Attachment 10 forms. There is an impact on Operations, Plant Engineering, Engineering Programs, Maintenance, Training and Radiation Protection departments as a result of the EC. The design being incorporated will not change the function or normal operation of any affected system or any interfacing systems.

4.1AS Nuclear Electric Insurance Limited (NEIL) and Other Insurance Standards The EC as designed complies with the current NEIL insurance requirements.

4.1A6 Single Point Vulnerability Single Point Vulnerability A Single Point Vulnerability (SPV) review has been performed for the configuration change. The purpose of the review was to identify all events that can result in unplanned reactor scrams in a proactive manner, with the intent of taking action to prevent such events.

The ERVs experienced degraded conditions due to vibration wear of the actuator component parts. The replacement of the existing GE actuator with an improved GE "Hardened Actuator" design will ensure the ERV/pilot valve/actuator assemblies, including all component parts, will operate as per design, if needed. The addition of the turnbuckle circumferential weld ensures the structural support integrity of the ERV/pilot valve/actuator support design.

The replacement of the terminal strip terminations with EQ splices for the ERV power circuit prevents the ERV's from not de-energizing following a LOCA event.

By implementation of the proposed EC modifications, there are no new SPVs identified and the potential to cause an unplanned reactor SCRAM following start-up is reduced if not eliminated.

In accordance with CC-AA-102, the following questions were addressed:

Page 23 of 24

Exelon EC 359513 Quad Cities Station DCS Unit 2 Revision 0

• Does the configuration change add any unnecessary challenges associated with the operation of the system?

• Does the configuration change modify existing or require the development of new operating procedures, maintenance or system testing activities such that these procedures or activities could result in an unnecessary risk of losing the system function?

• Could the configuration change lead to a plant SCRAM or Derate?

Implementation of this design change in conjunction with EC 359004, which adds an Acoustic Side Branch (ASB) to the standpipe of each SV and ERV to mitigate acoustical resonance vibration, will ensure improved durability and integrity of the relief valves.

Latent Point Vulnerability A Single Point Vulnerability Assessment (SPV) review has been performed to identify any latent failures in redundant non-safety related trip circuits. Since this configuration change is safety related there are no non-safety related trip circuits and thus there is no latent failure vulnerability.

4.4 Configuration Control Activities Impacts to the configuration control activities have been reviewed and addressed via Procedure CC-AA-102, Attachment 7. This includes the performance of an Installer's Walkdown, which is required prior to Op Authorization. Other configuration control activities include addressing the existing open operability determination and updating of the Passport Bill of Material (or CAT ID incorporation) with respect to the new GE "Hardened Actuator" installation per this design change.

4.5 Affected Programs Impacts to plant Programs have been reviewed and addressed via Procedure CC-AA-102, Attachment 8. The affected programs include an EQ Program updates for EQ Binder EQ-4lQ and EQ-GEN017. This EC shall be coordinated with EC 359004 to track ERV valve replacement per Procedure QCMM 0203-21. ASME XI and ISI program requirements shall be completed as needed (i.e., tracking or part/EID NoJSerial No. per QCMM 0203-21, Section 5.3).

Page 24 of 24

Work Planning Instructions (WPIs)

Preparer: James Smith (Sargent & Lundy 312-269-2177)

Quad Cities Site Engineering Department has reviewed and approves for use the subject engineering change (EC 359513) in accordance with CC-AA-103 and applicable Exelon quality requirements.

1. DCP

Description:

The basic function of the main steam relief valves is to protect the Reactor Pressure Vessel (RPV) from over pressurization, and rapidly depressurize the reactor to allow the Low Pressure Coolant Injection (LPCI) and Core Spray Systems to function. Connected to the Main Steam (MS) System are the Electromatic Relief Valves (ERVs), Target Rock relief valves, and the Safety Relief Valves (SVs).

The ERV valves are identified as RV2-0203-3B, RV2-0203-3C, RV2-0203-3D, & RV2-0203-3E. In the current configuration, the ERVs are physically located in the 6-inch branch line off of the MS header. The ERV consists of a main valve, a pilot valve and a solenoid actuator. To open the valve, the solenoid actuator actuates the pilot valve reducing the pressure under the main valve disc. To close the valve, the solenoid actuator releases to the normal position, closing the pilot valve, and the pressure under the main disc is increased. The solenoid is used to convert electrical energy into straight-line mechanical energy. A pushing action is used to exert a mechanical force on the lever arm of the pilot valve to operate the pilot.

As a result of original and Extended Power Uprate (EPU) levels of power operation, a significant acoustic resonance frequency has occurred in these MS branch lines resulting in increased loads on, and damage to the ERV actuators. During Root Cause Analysis (ATI # 435858-07), it was observed that there was damage to actuator components such as the guideposts and upper guide bracket.

To prevent detrimental vibration damage to the ERV actuator, Exelon has decided to replace the existing actuators on each of the four (4) ERV assemblies with new "Hardened Actuators" supplied by General Electric (GE). This EC will provide for the physical replacement of the ERV actuators and the qualification documentation (Environmental Qualification, Seismic Qualification, etc.) for the replacement.

This EC also provides for the rework of the turnbucklelboss connection to a full circumferential groove weld.

Installation of the turnbuckle circumferential groove weld will be in accordance with drawing 3NC120, Sheet 6 and Section 3 of the WPI. The welding process used will ensure a high quality weld and the structural integrity of the turnbuckle design.

GE document FDI-0187 recommends that the power cable and control cable connections at the solenoid actuator be modified. Therefore, this EC also provides for a change in the quick disconnects/cables from the junction box to the actuator. The power and control cable quick disconnect will be changed to allow for the proper sized wire to be landed at the actuator. This will entail the replacement of the existing quick disconnect cables and associated components.

This EC also provides for a new electrical junction box (2RB-168) to be replaced and relocated in Unit 2.

The new configuration will provide more clearance between the ASB end flange and the electrical junction box. A new junction box is required to accommodate the new orientation of the EGS quick disconnects connecting from the junction box to the solenoid actuator.

This EC also replaces the terminal board terminations for the ERV solenoid coil circuit inside the junction boses with Environmentally Qualified (EQ) splices. The EQ splice change, previously included as part of EC 356659, was for in-line butt-splice with one wire on each side. Electrical work associated with EC

356659 is now superseded by EC 359513 electrical work. The change that will be incorporated in EC 359513 is for a wye-splice with one #8 AWG wire each for both the positive and negative side of the power supply connection for the solenoid. The EQ splice change inside the junction box is being performed due to the potential for ERVs to not de-energize during LOCA conditions. Currently the ERV solenoid power is carried in 6 conductors that are part of the same cable with each conductor terminated individually at a terminal block. The six parallel paths to ground, given the presence of condensation following a LOCA event, may prevent the ERV from de-energizing.

2. Plant Mode(s) Apnlicability/Outage Requirements:

The work associated with this design change will be performed during Modes 4 or 5 (Cold Shutdown or Refueling) inside the Unit 2 drywell, currently scheduled for refueling outage Q2R18 in March 2006.

Preliminary staging and/or fabrication of the new hardened actuators will take place prior to or during the scheduled outage. Non-intrusive work associated with the quick disconnect cable replacement may be performed prior to the outage. Upon completion of this design change, the new ERV actuator components will be acceptable in all modes of operation.

3. Installation Details:

General Notes

• Installation coordination is required for this EC. Refer to Section 4 & Section 7 of the WPI.

• This EC supersedes the design changes that were originally part of EC 356659. Applicable plant drawing, 4E-2816H has been revised for this design change to provide the necessary details for the installation of the design change.

• An Installer's Walkdown is performed to check the installation and operational clearance of the new actuator design in the drywell. There must be sufficient space in the drywell to accommodate installation clearance as well as seismic interaction clearance. As discussed in GE document FDI-0187, the new ERV hardened actuator will have increased center height of 2 inches and have an increased width of 1/4 inches compared to the existing ERV actuator. Seismic interaction clearance is required based upon the seismic qualification of the new actuator. The Installer's Walkdown form CC-AA-106-1001 provides details as to the sufficient seismic interaction clearances that are required for the new ERV actuator.

• Testing is to be performed as identified in CC-AA-107, Attachment 1, "Configuration Change Acceptance Criteria", attached in Tab 5 of this EC.

• Prior to the installation of the new ERV "Hardened Actuators" is the coordination of the work associated with additional ECs planned for the Unit 1 ERVs during the scheduled outage. The installation of the new ERV "Hardened Actuators" shall be carefully coordinated with the additional work mentioned in Section 7 of the WPI. The Acoustic Side Branch (ASB) will be added to the standpipe of each ERV in Unit 1 prior to the completion of this EC. The EQ splice on the ERV solenoid circuits will take place in the junction box adjacent to the ERV actuator prior to the completion of this EC. Also, the addition of vibration monitoring instrumentation will take place prior to the completion of this EC.

• The following is a general outline of the installation sequencing. The Work Analyst may add to or deviate from this sequence based upon the coordination and installation of the other scheduled associated work or based on plant conditions, accessibility, etc.

Installation Sequencing:

a) Disconnect the EGS quick disconnects at each Junction Box (i.e., at 2RB-166, 167, 168 & 169) end in accordance with Procedure QCEMS 0250-13.

b) The ERV solenoid actuator cover is removed per the requirements and direction of Procedure QCEMS 0250-13.

c) The ERV solenoid actuator is to be removed from the solenoid bracket per the requirements and direction of Procedure QCEMS 0250-13. The ERV solenoid actuator will be taken out of the drywell to an approved location area.

d) Field to disconnect the solenoid cable for each solenoid terminated on terminals SI (i.e., from Pins A, B

& C connected together) & S2 (i.e., from Pins D, E & F connected together).

e) The ERV valve and leak-off piping is removed via EC 359004 per the requirements and direction of procedure QCMM 0203-21. The ERV valve will be taken out of the drywell to an approved location area.

f) The turnbuckle/boss connection is reworked to a full circumferential groove weld. Installation of the turnbuckle circumferential groove weld will take place in an approved location area and will be in accordance with drawing 3NC120, Sheet 6 and the following criteria:

• The weld prep shall be a single bevel groove with a maximum of 45-degree angle on the turnbuckle and no prep required on the boss. See EC drawing 3NC120, Sheet 6. Ensure a minimum root opening of 1/8".

• Clean the welding area with acetone or acceptable equivalent to remove any residual thread lubricant prior to pre-heating.

• Stamp end bosses with 2 sets of points 90 degrees apart such that weld shrinkage can be determined. Record pre-weld distance between corresponding points to the nearest 0.001".

• Use Exelon Nuclear Weld procedure WPS 1-1-GTSM-PWHT, Revision 1 or equivalent.

• Pre-heat the weld joint to 200 degrees F and hold for 10 minutes prior to welding.

• The weld joint should be performed using a minimum of three passes using a SMAW process.

• The weld shall be made with E7018 3/32" diameter weld rod.

• A maximum interpass temperature of 350 degrees F shall be followed.

• The root pass shall be quarter welded at 80 to 100 amps.

• Subsequent fill passes shall be quarter welded at 70 to 90 amps.

• Travel speed shall be at least 3 inches per minute. The size of the weld bead shall be small to minimize the heat input of each weld pass.

• The weld cap shall be a maximum of 5/32" per ASME B3 1.1 Table 127.4.2

• A visual inspection shall be performed on the final weld in accordance with ASME B31.1 paragraph 136.4.2 per the 2004 edition.

• Record post-weld distances between corresponding points to the nearest 0.001".

• Weld shrinkage shall be less than 0.020". If greater, contact cognizant engineer.

g) After the completion of the turnbuckle circumferential groove weld the ERV main valve is ready for re-installation in Unit 2. The ERV main valve is reinstalled via EC 359004 per the requirements and direction of procedure QCMM 0203-21. (Note: this step is carefully coordinated with EC 359004 and shall take place after the ASB assembly is installed on the sweepolet) h) Install new power and control quick disconnect cables at the solenoid actuator end in accordance with drawing 4E-2816H.

i) The new ERV actuators are installed on the solenoid bracket per the requirements and direction of procedure QCEMS 0250-13.

j) Electrical junction box (2RB-168) is to be replaced and relocated on the same electrical conduit in the drywell of Unit 2. The relocation of junction box (2RB-168) will be in accordance with the following criteria along with installation sketch E-SK1 attached to the WPI:

• Determinate wires injunction box (2RB-168) located on the terminal block.

• Remove terminal block from junction box (2RB-168). (Note: terminal block may be reused for new junction box)

• Disconnect junction box (2RB-168) from Unistrut support.

• Remove conduit fitting injunction box (2RB-168)

• Remove junction box (2RB-168). Save Unistrut fasteners if necessary. (Caution: do not damage field cable while performing next step).

• Disconnect the conduit section that spanned from junction box (2RB-168) to the conduit connector shown on sketch E-SK1.

• Modify the junction box support per sketch E-SK 1. (Caution: work with Radiation Protection to address lead shielding nearby this junction box)

• Use the left side box for cable entry and termination to the extent possible while meeting the applicable installation standards. Ensure holes are sized to accept existing conduit in the lower right hand side and quick disconnects in the upper left hand portion of the junction box as shown on sketch E-SK1.

• Engineering to verify and approve that the EGS connector hole positions are acceptable prior to drilling the holes in the junction box.

• Drill holes in the junction box per the engineering approved location. (Note: work is to take place in an approved location work area)

• Mount new junction box (2RB-168) using new or existing hardware.

• Connect conduit fitting to new junction box.

• Install new or existing terminal block (EQ point 12) and back panel insert in the new junction box toward the center/left side of the box as shown on sketch E-SK1.

k) Connect quick disconnect at the junction box in accordance with drawing 4E-2816H. This entails wire determinations and re-terminations for the control cable wiring in the junction box and the installation of EQ cable splices for the power cable wiring as shown on drawing 4E-2816H. (Note: junction box and associated components may be replaced like for like to minimize work in the drywell and the flex conduit with associated fittings will be reused, as needed).

1) Qualified EQ cable splices shall be performed with QCEM 0700-04 (Raychem) or engineering approved equivalent for each of the field cable listed in Item a) above.

m) Connect the EGS quick disconnects at each Junction Box (i.e., at 2RB-166, 167, 168 & 169) end. Ensure the quick disconnect is installed to the correct torque as noted per the requirements and direction of procedure QCEMS 0250-13. Ensure that instrumentation is properly restored to its required location.

n) Field to install EQ tape (3M Scotch Brand 33+ or equivalent) as needed on the wire leads to the solenoid per the requirements and direction of QCEMS 0250-13. The wires are to be trained as necessary using EQ qualified tape. Minimize EQ tape use by installing only at potential wear points. (Note: Installation of EQ tape to be done in a manner to avoid flagging) o) The ERV solenoid cover is reinstalled per the requirements and direction of Procedure QCEMS 0250-13.

p) Vibration monitoring instrumentation is mounted on the new ERV "Hardened Actuator" via TCCP 359074.

4. Special Installation Seguencing and Considerations:

Removal and installation associated with the electrical connection work and ERV actuator work is scheduled will take place in a radiologically controlled area (RCA) in the Unit 2 drywell, therefore RP-AA-400 "ALARA Program" and RP-AA-401 "Operation ALARA Planning and Controls" shall be followed during implementation of this EC.

All ALARA attachments can be found in Tab 8 of this EC. All applicable site procedures for work in the RCA shall be followed. This EC shall be coordinated with the work activities of EC 359004 for the

removal of the ERVs and SVs. Before the ERV valve is reinstalled to the standpipe, the ASB must be properly welded in place. All pressure boundary welds will be performed as part of EC359004.

5. Engineering Instructions Requiring Work Order Tasks:

The following Engineering Instructions requiring Work Order (WO) tasks are to be written by the Maintenance Planner. The following activities will be required prior to Operations Acceptance and require a WO task for each activity. The task should be associated with the work order, which will complete final installation.

Activity Activity Responsible Dept Required Issuance of required procedures (See CC-AA-102, Attachment 9 in Responsible Tab 8 of this EC for departmental requirements) eartment Acceptance of Test Results by the System Manager System Manager i Performance of the Ops Briefing Design Eng.

Performance of Installers and Designers Walkdown prior to Installer/Design proceeding with work when access for walkdown was previously Eng.

limited (The walkdown requirements per form CC-AA-106-1001 are listed in Tab 8 of this EC)

Completion of training that had to be completed prior to ops Training acceptance (ex: operations and maintenance training) 1 Completion of calculations or analysis prior to proceeding with Design Eng.

certain implementation steps or prior to placing the affected SSCs into service 2 Completion of Owners/Users Walkdown Ops/Installer 2 Performance of any additional post installation walkdown to verify Design Eng.

conditions conform to those intended by the design that could not be verified by testing, e.g., electrical separation, structural supports and snubbers

6. Enyineering Restraint Items or Unverified Assumptions:

There are INSTALLATION and OPERATIONAL HOLDS associated with this EC package for completion and owners acceptance of the following analyses. These holds must be removed prior to installation activities within the drywell or declaring this EC operational. A planned revision to this EC package may be required, following completion and owners acceptance of the analyses/documentation, to remove these INSTALLATION and OPERATIONAL HOLDS. See Section 4.1.9,4.1.27, and 4.1.40 of the DCS for additional discussion associated with these "Holds" and their release signoff.

For the EC "Hold" see Milestone 630 that has been established in PassPort to document engineering "Hold". Completion of Milestone 630 in PassPort will release the "Hold".

Hold 3-Vendor Documentation:

Operations authorization of this EC package is dependent on final vendor documentation acceptance.

This acceptance consists of the following documents:

• MPR Associates Inc., "Vibration Acceptance Criteria for ERV Valve Actuators"

7. Impact of Pending or Related Configuration Change Packages and Temporary Configuration Changes:

There is additional work that is taking place related to the ERVs. The work must be coordinated appropriately as discussed in Section 4 of the WPI. With the exception of EC 359513, the following work needs to be complete before this design change can be completed:

• EC 359004, "Addition of Acoustic Side Branch to Safety Relief Valves"

• TCCP 359074, "Main Steam System Load Reduction and ERV Hardening Vibration Monitoring Instrumentation"

• EC 356659, "Equivalent Change Package to Replace Termination with EQ splice on ERV Solenoid circuits" (See Note Below)

• EC 359512, "Electromatic Relief Valve (ERV) Actuator Replacement-Unit 1" Note: Installation of the EQ splices per EC 356659 has now been superseded by the work associated with this EC. Additional wiring changes associated with the quick disconnect cables has initiated this change.

Appropriate work order changes are being made for the modification work.

8. Confizuration Change Package Classification:

This configuration change package is classified as Safety Related, Seismic Category I. The work associated with replacing the existing ERV actuators with a new GE "Hardened Actuators" is part of the over-pressurization protection system attached to the reactor coolant pressure boundary and is therefore safety related.

This installation takes place in the Unit 2 Drywell, which is a safety-related, seismic structure. This classification is based on Section 3.9 of the UFSAR and General Work Specification Maintenance/Modification Work Quad Cities Station - Unit 1 and 2, R-441 1 Table 1511.7 (Piping System Installation Requirements) being classified as Seismic Category I. The installation of EQ splices is qualified as Seismic Category I to ensure that it will not reduce the function of plant features important to safety in the event of an earthquake. Refer to Section 4.1.40 in the DCS for the analysis of the seismic requirements.

9. Applicable Installation Codes and Specifications:

All work shall be performed in accordance with the latest revision of the following specificationstdocuments or other applicable approved Exelon procedures for Quad Cities Station:

Document No. Title Specification R-441 1 General Work Specification, Maintenance/Modification Work Specification R-4412 Specification for Standard Electrical Supports Specification T-3382 Electrical Installation Work Specification/Mod Work (Dresden and Quad Cities)

NEIS Standards Electrical Installation Standards for Nuclear Generating Stations MA-MW-736-600 Torquing and Tightening of Bolted Connections MA-AA-716-008 Foreign Material Exclusion (WME) Program MA-AA-716-021 Rigging and Lifting Program MA-AA-716-022 Control of Heavy Loads Program MA-MW-726-022 Electrical Cable Termination and Inspection

Document No. Title MA-MW-773-039 Nuclear Operational Analysis Departmental Testing of Control Units MA-AA-734-460 Electromatic Relief Valve Inspection and Maintenance MA-MW-734-459 Electromatic Relief Valve Pilot Replacement NSWP Nuclear Station Work Procedures ASME Section IX Welding and Brazing Qualifications ASME B3 1.1 Power Piping (2004 Edition)

WPS 1-1-GTSM- Exelon Nuclear-ASME Weld Procedure (Revision 1, or Equivalent)

PWHT CC-AA-203 Environmental Qualification Program CC-AA-501-1003 Exelon Nuclear Welding Program Visual Weld Acceptance Criteria RP-AA-400 ALARA Program RP-AA-401 Operational ALARA Planning and Controls RP-AA-502 Catch Containment Program QCMM 0203-21 Electromatic Relief Valve Removal and Installation QCEMS 0250-13 Dresser Electromatic Solenoid Actuator Installation, Replacement, Inspection, and EQ Surveillance QCEM 0700-04 Raychem Heat shrink Installation Instructions QCEM 0700-07 Electrical Connections and Relay Configuration EQ Binder EQ-GEN25

10. Procurement/Materials Engineering Recuirements:

The material that is required for this EC is the purchase of the new hardened actuator from GE. See "Engineering Change Material List (ECML)", Attachment "H" of CC-AA-103 for a list of items required as well as a brief description of each item. The ECML is located in Tab 4 of this EC.

11. Testing Requirements:

All tests are identified by the Work Planner 1AW guidance in CC-AA-107, Attachment 1 whereas, all additional, non-standard, or special tests will be specified by the Responsible Engineer/System Manager.

12. Other pertinent Information:

The 10CFR50.59 Review Coversheet Form and 10CFR50.59 Screening Form No. QC-S-2006-0028 were prepared in accordance with the latest revision of LS-AA-104-1001 and LS-AA-104-1003, respectively, as part of this EC package. The documents are included in Tab 2 of this EC package.

During drawing incorporation, the following note shall be added to drawing 3NC120 Sheets 1, 2, 2A, 3B, 5, SB, 6, 6A, 6B, 6C, 6D, and 6E: "For GE "Hardened Actuator" changes see drawings PL352B2632 and 352B2632 for Unit 2.

Enclosed in the WPI is the GE FDI-0187 document (Rev. 2, 4/3/06). This FDI provides information required for the replacement of the ERV solenoid actuators.

Enclosed is Sketch E-SK1 which is used as an installation aide in Section 3 of the WPI for the relocation and replacement of junction box (2RB-168).

(Note: GE FDI-0187 and Sketch E-SK1 are enclosed as a hard copy to this EC package)

50.59 SCREENING FORM LS-AA-104-1003 Revision I Page I of 4 50.59 Screening No. OC-S-2006-0028 Rev. No. 0 ActivityfDocument Number: EC 359512 and EC 359513 Revision Number: 0 I. 50.59 Screening Questions (Check correct response and provide separate written response providing the basis for the answer to each question)(See Section 5 of the Resource Manual (RM) for additional guidance):

I Does the proposed Activity involve a change to an SSC that adversely affects an UFSAR _ YES _X_ NO described design function? (See Section 5.2.2.1 of the RM)

The function of the ADS system is to provide an alternative to HPCI in depressurization of the RPV for small breaks (UFSAR 6.3.1.4). ADS is also utilized to depressurize the RPV in an Appendix R fire event (FPR, Vol 2, 3.1.3 and 3.1.5). The replacement of the actuator with a functionally equivalent actuator does not impact the function of the ADS valves, the actuation logic of the valves (UFSAR 6.3.2.4.2 & 7.3.1.4), or the physical separation requirements of the ADS components (UFSAR 3.5.1). The Code requirements for the valves given in UFSAR Section 3.2.8.3 are not changed by the modification.

The mounting of the ERVs is briefly discussed in UFSAR section 5.2.2.5, but the valve actuators are not described nor is the design weld of the turnbuckle.

The functional performance of the ADS system is determined by the relief valve sizing as described in UFSAR Section 5.2 and Table 5.1-1. Analysis and testing has been done to verify that the replacement of the actuator has no impact on the performance, setpoint or response time of the valves (GENE-0000-0051-3159). Therefore there is no impact on the LJFSAR described functional requirements.

The capacity, setpoint, opening time and discharge line configuration of the valves is not being changed by this activity. Therefore, the impact on torus loading and temperature due to operation of these valves is not impacted (UFSAR 6.2.1.3.4.2).

The impact of an ECCS single valve failure for a relief valve as presented in UFSAR Table 6.3-13 is not impacted by this modification as the function, controls and capacity of the valves are unchanged. The modification of the actuator does not impact the ECCS Availability as presented in UFSAR Table 6.3-15.

The modified actuator has been evaluated and is seismically qualified in accordance with the design requirements in UFSAR Section 3.10. The summary of stresses for relief valves in Table 5.2-1 reflects the original condition as stated in the note and is considered "historical".

Replacement of the actuator with a functionally equivalent component has no impact on the primary pressure boundary of the main steam system. There is no impact on any fission product barrier.

The modified electrical connection for the actuators is functionally equivalent and qualified to the existing connection. The current details for the connection are not described in the UFSAR.

This activity modifies the configuration of the valve actuators to make them less susceptible to an existing degradation mechanism (vibration). This modified ERV valve actuator functionally maintains the same performance requirements (setpoint, response time or capacity) of the valve.

Therefore, this activity has no adverse impact on any design function described in the UFSAR.

2. Does the proposed Activity involve a change to a procedure that adversely affects how UFSAR __ YES _X_ NO described SSC design functions are performed or controlled? (See Section 5.2.2.2 of the RM)

This activity replaces the ERV valve actuators with a functionally equivalent component without impacting the function, performance or controls associated with the valves or the ADS system.

The inspection/testing of the system as described in UFSAR Section 5.4.13 is not impacted by this

50.59 SCREENING FORM LS-AA-104-1003 Revision 1 Page 2 of 4 50.59 Screening No. OC-S-2006-0028 Rev. No. 0 Activity/Document Number: EC 359512 and EC 359513 Revision Number: 0 change. There is no change to any design function. There are no procedure changes associated with this activity that affects how a UFSAR described design function is performed or controlled.

3. Does the proposed Activity involve an adverse change to an element of a UFSAR described _ YES _X_ NO evaluation methodology, or use of an alternative evaluation methodology, that is used in establishing the design bases or used in the safety analyses? (See Section 5.2.2.3 of the RM)

The ADS subsystem is involved in response to a number of accident and transient events. The modification involved in this activity does not change the performance of the design function of the valves. The valve input parameters are the same as shown in UFSAR Table 6.3-3. Therefore the evaluations based on these input parameters remain valid and no re-analyses is needed in support of the modification. All evaluation methodology remains applicable.

The function and controls of the ERV valves are not changed by this activity. Therefore, the response of these valves in relationship to the assumed failure of other systems as shown in UFSAR Table 6.3-7 is not impacted and there is no change in methodology or the design basis of any system.

4. Does the proposed Activity involve a test or experiment not described in the UFSAR, where an YES _X NO SSC is utilized or controlled in a manner that is outside the reference bounds of the design for that SSC or is inconsistent with analyses or descriptions in the UFSAR? (See Section 5.2.2.4 of the RM)

This activity modifies the configuration of the valve actuators to make them less susceptible to an existing degradation mechanism (vibration). This change does not alter the component function, systems function or performance requirements. The new model actuator and valve have been analyzed and have been tested offsite to ensure that there is no impact on the function or performance of the component. There is no in-plant test or experiment that differs from the system functions and bounds as described in the UFSAR.

5. Does the proposed Activity require a change in the Technical Specifications or Operating YES _X_ NO License? (See Section 5.2.2.5 of the RM)

This activity replaces the ERV valve actuator with a functionally equivalent component without impacting the function or performance (setpoint, response time or capacity) of the valve. This activity has no impact on the operability and valve setpoint requirements given in T.S. Section 3.4.3. The activity has no impact on the operability requirements for low set relief valves given in section 3.6.1.6. The activity does not impact the requirements on ADS valve availability given in section 3.5.1. The design details of the actuator are not described in the Technical Specification or the Operating License. The modified configuration is functionally equivalent to the current configuration.

The modification does not impact the structural integrity of the pipe contained in TRM Section 3.4a.

The modification does not impact the requirements for temperature and acoustic monitoring required to determine valve position in accordance with TRM Section 3.3b.

Therefore, there are no changes required to these documents.

50.59 SCREENING FORM LS-AA-104-1003 Revision 1 Page 3 of 4 50.59 Screening No. OC-S-2006-0028 Rev. No. 0 Activity/Document Number: EC 359512 and EC 359513 Revision Number: 0 II. List the documents (e.g., UFSAR, Technical Specifications, other licensing basis, technical, commitments, etc.) reviewed, including sections numbers where relevant information was found (if not identified in the response to each question).

Ouad Cities UFSAR Rev. 8 3.0 Design of Structures, Components, Equipment & Systems 3.2 Classification of Structures, Components and Systems 3.2.8.3 Main Steam Isolation, Safety & Relief Valves 3.5.1 Physical Separation Criteria 3.9.3 ASME Code Class 1, 2, and 3 Components, Component Supports, and Core Support Structures 3.10 Seismic Qualification of Class I Instrumentation and Electrical Equipment 5.2.2 Overpressure Protection 5.2.2.5 Mounting of Pressure Relief Devices 5.4.13 Safety/Relief Valves 6.2.1.3.4.2 Summary Description of Safety Relief Valve Discharge Load Effects 6.3.1.4 Automatic Depressurization Subsystem 6.3.2.4.2 Subsystem Characteristics 7.3.1.4 Automatic Depressurization System Instrumentation and Controls 15.6.1 Inadvertent Opening of a Safety Valve, Relief Valve or Safety Valve Table 5.1-1 Reactor Coolant System Data Table 5.2-1 Summary of Stresses on Relief Valve Parts for Unit One Table 6.3-3 Significant Input Parameters Used in LOCA Analysis Table 6.3-7 Single Failure Evaluation Table 6.3-13 ECCS Single Valve Failure Analysis Table 6.3-15 ECCS Availability, Small Break with Auxiliary Power Pending UFSAR Change Log - None Affected Technical Specifications DPR-29/30 including Amendments 228/223 & Bases Rev. 27 3.4.3 Safety & Relief Valves 3.5.1 ECCS - Operating 3.6.1.6 Low Set Relief Valves Technical Requirements Manual Section 3.3b Post Accident Monitoring Section 3.4a Structural Integrity Fire Protection Report, Rev. 17, Volume 2, Safe Shutdown Report 3.1.3 Hot Shutdown Reactor Pressure Control and Decay Heat Removal from the Reactor 3.1.5 Reactor Cool Down and Cold Shutdown Decay Heat Removal 5.2.1.5.2 Automatic Depressurization System (ADS)

Pending FPR Change Log - None Affected Other Documents GENE-0000-0051-3159 Similarity Analysis ERV Actuator, Rev. 0 10CFR50.59 Evaluation QC-E-2004-0001

50.59 SCREENING FORM LS-AA-104-1003 Revision 1 Page 4 of 4 50.59 Screening No. QC-S-2006-0028 Rev. No. 0 Activity/Document Number: EC 359512 and EC 359513 Revision Number: 0

m. Select the appropriate conditions:

X If all questions are answered NO, then complete the 50.59 Screening and implement the Activity per the applicable governing procedure.

If question 1, 2, 3, or 4 is answered YES and question 5 is answered NO, then a 50.59 Evaluation shall be performed.

If questions 1, 2, 3, and 4 are answered NO and question 5 is answered YES, then a License Amendment is required prior to implementation of the Activity.

If question 5 is answered YES for any portion of an Activity, then a License Amendment is required prior to implementation of that portion of the Activity. In addition, if question 1, 2, 3, or 4 is answered YES for the remaining portions of the Activity, then a 50.59 Evaluation shall be performed for the remaining portions of the Activity.

IV. Screening Signoffs:

50.59 Screener: R. J. Goebbert Sign: R. J. Goebbert Date: 03/20/06 (Print name) (Signature) 50.59 Reviewer: Douglas F. Collins Sign: Douglas F. Collins Date: 03/21/06 (Print name) (Signature)

50.59 REVIEW COVERSHEET FORM LS-AA-104-1001 Revision 2 Page I of 2 Station/Unit(s): Ouad Cities Unit I and Unit 2 Activity/Document Number: EC 359512 & EC 359513 Revision Number. 0

Title:

Electromatic Relief Valve (ERV) Uperade NOTE: For 50.59 Evaluations, information on this form will provide the basis for preparing the biennial summary report submitted to the NRC in accordance with the requirements of 10 CFR 50.59(d)(2).

Description of Activity:

(Provide a brief, concise description of what the proposed activity involves.)

This activity modifies the actuators of the four Electromatic Relief Valves (ERVs), EPN numbers 1(2)-0203-3B, C, D & E, to make them less susceptible to degradation of the actuators due to vibration from acoustic loading of the main steam lines experienced during Extended Power Uprate (EPU) operation. The modification replaces the actuator with a design that is functionally equivalent to the existing actuator but will be less susceptible to degradation. The modification increases the weld on the turnbuckle connection. The function and performance of the valves are not changed.

Reason for Activity:

(Discuss why the proposed activity is being performed.)

Operation of the Main Steam system under EPU flow conditions has resulted in acoustic resonances being established by the inlet piping configurations of the safety valves and the ERVs. This has resulted in acoustic loads on the ERVs that has degraded the performance of the ERV actuators. This has been documented in Root Cause Analysis (ATI #43585807).

Effect of Activity:

(Discuss how the activity impacts plant operations, design bases, or safety analyses described in the UFSAR.)

This activity replaces the actuators to the ERV valves. The actuators will remain mounted on the valves but the design is hardened to withstand loads caused by the acoustic vibration. The function and performance of the valves will not change. The new configuration has been analyzed and physically tested to ensure that there is no adverse impact on the valve response time, setpoint or flow rates. The control system for the valves will not be modified. The ERVs will remain seismically and environmentally qualified in the new configuration. The new configuration of the valves is designed for the loads associated with EPU and will be implemented along with the load mitigation being accomplished under EC 359004 and EC 359006. Vibration monitoring of the system during start-up will ensure the operating environment of the valves remains within the qualified bounds of the ERVs.

The ERV turnbuckle to boss connection will be modified with two full circumferential groove welds at each end of the turnbuckle to boss gap as part of the activity to provide a sturdier attachment that does not rely on the threads within the turnbuckle.

The electrical connection to the valve is being modified with a functionally equivalent and qualified connection.

Summary of Conclusion for the Activity's 50.59 Review:

(Provide justification for the conclusion, including sufficient detail to recognize and understand the essential arguments leading to the conclusion. Provide more than a simple statement that a 50.59 Screening, 50.59 Evaluation, or a License Amendment Request, as applicable, is not required.)

This activity replaces the actuators of the Electromatic Relief Valves with a new design to make them less susceptible to degradation caused by acoustic loading on the Main Steam lines during Extended Power Uprate (EPU) operation. The modified actuators will maintain the function, performance and control requirements of the ERV valves as described in the UFSAR. The valves will remain seismically and environmentally qualified in the new configuration. The ADS function as described in the UFSAR is not impacted by the change. The impact of valve operation on the containment and torus structures is not changed by the activity. The change in overall valve weight is insignificant and no support or structural steel changes are required.

The new actuator has the same function as the current component and there are no changes to any operating procedures required by the equivalent substitution. No new system operating configurations are established, and no component is operated beyond its design parameters. The configuration has been analyzed and also tested at a test laboratory prior to installation in the plant to

50.59 REVIEW COVERSHEET FORM LS-AA-104-1001 Revision 2 Page 2 of 2 Station/Unit(s): Quad Cities Unit 1 and Unit 2 Activity/Document Number: EC 359512 & EC 359513 Revision Number: 0

Title:

Electromatic Relief Valve (ERV) Upgrade verify that there is no adverse impact on valve performance. No test or experiment is being performed in the plant. Normal system operability testing will be performed after installation.

The activity will not impact the Technical Specification requirements for setpoints or minimum operability requirements associated with these valves (Sections 3.4.3, 3.6.1.6 & 3.5.1). No change is required to the Technical Specifications or Operating License of the Unit.

This activity can proceed in accordance with the governing procedure without a 10 CFR 50.59 Evaluation or prior NRC review required.

Attachments:

Attach all 50.59 Review forms completed, as appropriate.

(NOTE: if both a Screening and Evaluation are completed, no Screening No. is required.)

Forms Attached: (Check all that apply.)

Applicability Review X 50.59 Screening 50.59 Screening No. QC-S-2006-0028 Rev. 0

_ 50.59 Evaluation 50.59 Evaluation No. Rev.

Ptc-Cc -

- c

)ICti sQvl 7: c Vure, (O

'- CA-u r,,:, -1 Tl~ck,,f s

?p\c,~~c C)

- c C-re.

)IcAuce- t.-)-

pt c A--j vC,

\

-PcA\)cktf~

?Ic -c ko Is i

9\ck~ l v

PkCtfck I1 FPi cklu e- IS

-Xk -A--cre- \

),C)

"WP, k)cc v)

,Pk (--j < a a

~C~xf&P)