ML081550014

Entergy'S Answer Opposing Pilgrim Watch'S Motion to Strike and Request to Reopen the Hearing

ML081550014
Person / Time
Site:	Pilgrim
Issue date:	05/27/2008
From:	Gaukler P, Doris Lewis Entergy Nuclear Generation Co, Entergy Nuclear Operations, Pillsbury, Winthrop, Shaw, Pittman, LLP
To:	Atomic Safety and Licensing Board Panel
SECY RAS
References
50-293-LR, ASLBP 06-848-02-LR, RAS J-134
Download: ML081550014 (111)

Text

May 27, 2008 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the AtomicBefoe Safety and Licensing SfftDOCKETED th AtoicBoard Panel USNRC In the Matter of ) May 28, 2008 8:00 am

) OFFICE OF SECRETARY Entergy Nuclear Generation Company and ) Docket No. 50-293-LR RULEMAKINGS AND Entergy Nuclear Operations, Inc. ) ASLBP No. 06-848-02-LR ADJUDICATIONS STAFF

)

(Pilgrim Nuclear Power Station) )

ENTERGY'S ANSWER OPPOSING PILGRIM WATCH'S MOTION TO STRIKE AND REQUEST TO REOPEN THE HEARING I. INTRODUCTION Entergy Nuclear Generation Company and Entergy Nuclear Operations, Inc.

(collectively, "Entergy") hereby answer and oppose "Pilgrim Watch Motion to Strike Incorrect and Misleading Testimony from the Record," filed on May 15, 2008 ("Motion"). The Motion, which seeks to strike prior testimony or reopen the hearing,1 lacks merit. The serious accusations that Pilgrim Watch levels against the NRC Staff, Entergy, and their witnesses are baseless. Rather, the Motion simply reflects that Pilgrim Watch failed to properly prepare for the hearing in April, and having failed to present a credible case, now wants to revise the record to 2

make up for its own lack of diligence.

The hearing on this matter concluded on April 10, 2008. On May 12, 2008, the Board directed that all parties should file findings of fact and conclusions of law, and reply findings and conclusions, on June 9 and June 23, respectively. Order (Setting Deadlines for Provisional Proposed Findings and Conclusions on Contention 1, and for Pleadings Related to Pilgrim Watch's Recent Motion Regarding CUFs) (May 12, 2008) slip op. at 3. On May 16, 2008, the Commission directed that the Board close the evidentiary record on Pilgrim Watch Contention 1 and proceed with its stated schedule for the filing of findings of fact and conclusions of law. CLI-08-09, 67 N.R.C.

(2008).

This is but the latest of Pilgrim Watch's continuing efforts to delay and improperly expand the scope of the proceeding. See Pilgrim Watch Motion to Extend Hearing Schedule (Dec. 12, 2007); Pilgrim Watch Motion to Reset Hearing Schedule (Dec. 14, 2007); Pilgrim Watch Motion on Admissibility of Factual Evidence (Dec. 15, 2007); Pilgrim Watch Motion for Clarification (Dec. 21, 2007); Pilgrim Watch Motion for Reconsideration (Dec.

28, 2007); Pilgrim Watch's Motion for Cross Examination (Mar. 17, 2008); Pilgrim Watch Motion to Permit Late Filed Exhibits (Mar. 24, 2008); Pilgrim Watch Motion Requesting the Record be Held Open So that the Board

Pilgrim Watch's Motion accuses Entergy of failing to disclose the "Miller Pipeline paper,"' 3 a document authored by a third party for presentation to a construction trade organization thathas been publicly available for over four years. Pilgrim Watch fails to show that Entergy had possession, custody or control of the Miller Pipeline paper. Entergy is under no obligation to perform a literature or internet search for publicly available documents it does not possess. More importantly, the "key facts" that Pilgrim Watch accuses Entergy of failing to disclose were, in fact, disclosed in official project documents produced to Pilgrim Watch by Entergy in accordance with NRC rules. If Pilgrim Watch was unaware of these facts at the hearing, it is only because Pilgrim Watch failed to adequately review the documents that Entergy had produced. 4 Entergy should not be penalized for Pilgrim Watch's failure to do its own research prior to the hearing.

Similarly, Pilgrim Watch's use of the May 12, 2008 letter from John Fitzgerald5 and other cathodic protection documents to attack the testimony of the NRC Staff's witness, Dr.

Davis, is inappropriate. The issue of cathodic protection was introduced by Pilgrim Watch's witness, Mr. Gundersen, who Pilgrim Watch put forth as a competent expert. There is simply no May Address a New and Significant Issue [Method to Calculate Cumulative Usage Factors (CUF)] Sua Sponte and Provide Pilgrim Watch an Opportunity for Hearing (Apr. 9, 2008); Pilgrim Watch Motion Regarding the Cumulative Usage Factor (CUF) (May 5, 2008). And just today, Pilgrim Watch filed yet another such motion.

See Pilgrim Watch Motion to Include as Part of the Record Exhibits Attached to Pilgrim Watch Motion to Strike Incorrect and Misleading Testimony from the Record of May 15, 2008 (May 27, 2008). This conduct is dilatory, oppressive, and inappropriate.

3 Motion at 2; Jonathan Raymer, Pilgrim Nuclear Power Station: Salt Service Water Discharge Piping Trenchless Rehabilitation Challenges, Miller Pipeline Corp., Indianapolis, IN ("Miller Pipeline paper").

4 There have been a number of indications that Pilgrim Watch failed to adequately review Entergy's disclosures in preparation for hearing, including (1) Pilgrim Watch's inaccurate testimony concerning the drawings that Entergy had produced (see Entergy's Motion in Limine to Exclude Pilgrim Watch Testimony and Exhibits (Mar. 10, 2008) at 33-34; Pilgrim Watch's Motion to Permit Late Filed Exhibits (Mar. 24, 2008), in which Pilgrim Watch sought to introduce documents from Entergy's disclosures after the deadline for submission of exhibits); and Mr.

Gundersen's testimony that Pilgrim Watch had not given him photographs disclosed by Entergy when Mr.

Gundersen prepared his testimony (Tr. 629),

5 Letter from John H. Fitzgerald III, P.E. to Mary Lampert (May 12, 2008) ("May 12 Letter").

2

basis for Pilgrim Watch to strike Dr. Davis' testimony or to introduce Mr. Fitzgerald's post hoc critique.

Finally, as shown specifically below, there is no merit to Pilgrim Watch's claims that Entergy and the NRC Staff provided inaccurate and misleading testimony. In sum, Pilgrim Watch's Motion is nothing more than an attempt by Pilgrim Watch to get a second, unwarranted bite at the apple. Accordingly, its Motion should be denied.

1I. PILGRIM WATCH PROVIDES NO BASIS FOR ITS MOTION TO STRIKE At the outset, a motion to strike already presented testimony is inappropriate. A motion to strike is limited in scope and function and is used as "an appropriate mechanism for seeking the removal of information from a pleading or other submission that is 'irrelevant"' or "contain[s] technical arguments based on questionable competence." Private Fuel Storage, L.L.C., LBP-05-20, 62 N.R.C. 187, 228 (2005), citing Power Authority of the State of New York (James A. Fitzpatrick Nuclear Power Plant; Indian Point, Unit 3), CLI-01-14, 53 N.R.C. 488, 514 (2001); see also Florida Power & Light Co. (Turkey Point Nuclear Generating Plant, Units 3 and 4), LBP-85-29, 22 N.R.C. 300, 305 (1985). See also 10 C.F.R. § 2.233(b) (permitting the Presiding Officer to strike argumentative, repetitious, cumulative, unreliable, immaterial, or irrelevant testimony). No provisions in the rules permit a motion to strike testimony on the grounds that the movant disagrees with it.

Rather, the appropriate mechanism for a party to respond to testimony with which it disagrees is to provide contrary testimony and evidence at hearing and present counter argument in its proposed findings of fact. See, e.g., 10 C.F.R. § 2.1209. Pilgrim Watch had a full opportunity to develop rebuttal testimony and present its case at the hearing.

3

Likewise, Pilgrim Watch's claims that Entergy failed to produce a copy of the Miller Pipeline paper in discovery provides no basis for a motion to strike. Motion at 2. The Commission's regulations require that Entergy produce only those documents "in the possession, custody, or control of [Entergy] that are relevant to the contentions." 10 C.F.R. § 2.3 36(a)(2)(i).

As Pilgrim Watch concedes, the document was neither authored by nor presented to Entergy (Motion at 2 & n.2), but rather is a paper presented by a third party to a construction trade association. Moreover, in discharge of its disclosure obligations under the Commission's regulations, Entergy performed a reasonable search for relevant materials in its possession, custody, or control. This search identified and produced over 10,000 pages of documents relevant to Pilgrim Watch Contention 1. This search did not identify the Miller Pipeline paper, and Pilgrim Watch has made no showing that Entergy ever had possession, custody, or control of this document.

Furthermore, there is no basis to Pilgrim Watch's admitted speculation that Entergy may have engaged Miller Pipeline as an expert in this proceeding "and decided not to disclose that fact." Motion at 2. Entergy did not retain Miller Pipeline in this proceeding. Entergy has not had any contractual relationship with Miller Pipeline during this license renewal proceeding.

Moreover, the facts discussed in the Miller Pipeline paper are fully described in greater detail in official project documents that Entergy did disclose to Pilgrim Watch as part of the discovery process. Pilgrim Watch had these documents months before the hearing yet never raised these issues at the hearing. For example, Entergy provided the project document for the design and analysis of the CIPP liner that fully describes the design, installation, repairs, and 4

testing of the CIPP liner for both discharge loops of the Salt Service Water ("SSW") system.6 The use of different materials for the CIPP in the Loop "A" and Loop "B" SSW discharge lines and the cracking and repair at the elbows during the installation of the CIPP liner are fully described in this document.7 That Pilgrim Watch simply ignored this and other documents demonstrates that it failed to properly prepare for this proceeding. Such lack of diligence provides no basis to strike testimony - even assuming a motion to strike were the proper mechanism for challenging testimony contrary to a party's position, which as discussed above, we respectfully submit it is not.

Il. PILGRIM WATCH FAILS TO SATISFY, OR EVEN ADDRESS, THE COMMISSION'S REQUIREMENTS FOR REOPENING AN EVIDENTIARY RECORD As with Pilgrim Watch's other recent motions to belatedly expand the record and scope of this proceeding, Pilgrim Watch fails even to acknowledge and address the Commission's requirements for reopening an evidentiary record set forth in 10 C.F.R. § 2.326, much less demonstrate that it has met these requirements. In order to reopen a closed record to consider additional evidence, Pilgrim Watch must, among other criteria, (1) demonstrate that its Motion is timely, (2) show that the new evidence would materially affect the outcome of the proceeding, and (3) submit evidentiary affidavits setting forth the factual and technical basis of its claims.

See 10 C.F.R. § 2.326. Pilgrim Watch's Motion fails to address, much less satisfy, these requirements.

6 SSW Discharge Piping CIPP Liner Design, Document Number M-1031 Rev. 1" (May 14, 2003) at 6-14 (PILLROO46106-114) ("M- 1031").

7 Id. See also discussion at Section III.B. 1.b infra.

5

A. Pilgrim Watch's Motion To Reopen the Hearing is Inexcusably Late At the outset, Pilgrim Watch's Motion for the Board to consider new evidence is not timely. Commission case law has long established that to reopen a closed evidentiary record, a movant must "act promptly after the relevant information bec[omes] available." Public Service Company of New Hampshire (Seabrook Station, Units 1 and 2), CLI-90-06, 31 N.R.C. 483, 487 (1990), citing Duke Power Co. (Catawba Nuclear Station, Units 1 and 2), CLI-83-17, 17 N.R.C.

1041, 1048-50 (1983). Further, the movant must show that the issue sought to be raised could not have been raised earlier. Pacific Gas & Electric Co. (Diablo Canyon Nuclear Plant, Units 1

& 2), ALAB-775, 19 N.R.C. 1361, 1366 (1984). A Board must reject a motion to reopen the record predicated on information that has been available for more than a year. Metropolitan Edison Co. (Three Mile Island Nuclear Station, Unit 1), ALAB-815, 22 N.R.C. 198, 201 (1985).

Here, the Miller Pipeline paper relied on by Pilgrim Watch was dated March 22-24, 2004 and thus has been available to the public for over four years - indeed, for approximately two years before intervention petitions were due in this proceeding. Pilgrim Watch has made no showing that this document was not available to it long before now. The facts discussed in the Miller Pipeline paper are described in greater detail in the project documents that Entergy affirmatively disclosed to Pilgrim Watch as part of the discovery process and which Pilgrim Watch had several months before the hearing. See discussion supra Section II and infra Section III.B. 1.b. Each of the major claims regarding CIPP raised by Pilgrim Watch is discussed in more detail in these documents than in the Miller Pipeline paper.

Likewise, Pilgrim Watch has made no showing that the purported cathodic protection evidence on which it seeks to rely hasbeen unavailable to it before now. Pilgrim Watch has had ample opportunity to litigate its concerns here. Indeed, Mr. Arnold Gundersen, Pilgrim Watch's 6

8 testifying expert, raised cathodic protection as an issue in his testimony and rebuttal testimony.

Pilgrim Watch offers no reason why it could not have proffered the cathodic protection information it seeks to raise here before now, or retained an additional expert if the subject matter exceeded Mr. Gundersen's competence. Indeed, Pilgrim Watch suggests that the Board "perform a simple GOOGLE search" on various key phrases related to cathodic protection, which allegedly turns up "countless, instructive hits" on this issue. Motion at 14. In light of the ease with which Pilgrim Watch has found this publicly available information, Pilgrim Watch should have heeded its own advice and performed its research prior to the hearing, not after. In short, it is now too late for Pilgrim Watch to seek to reopen the record based on this information.

B. Pilgrim Watch Has Failed to Demonstrate that a Materially Different Result Would Be Likely To reopen a closed evidentiary record, Pilgrim Watch also "must demonstrate that a materially different result would be or would have been likely had the newly proffered evidence been considered initially." 10 C.F.R. § 2.326(a)(3). Pilgrim Watch has also failed to meet this standard.

Although no decision has in fact yet been reached on Pilgrim Watch Contention 1, the record is closed "on the portion of the proceeding with respect to which new information is being proffered" and it is therefore appropriate to consider "whether the additional information might potentially alter the result [the Board] would reach in its absence." Houston Lighting & Power Co. (South Texas Project, Units 1 and 2), LBP-85-42, 22 N.R.C. 795, 799 (1985); see also Private Fuel Storage L.L.C. (Independent Spent Fuel Storage Installation), CLI-05-12, 61 N.R.C.

345, 350 (2005) ("reopening requires a showing that new information will 'likely' trigger a Declaration of Arnold Gundersen Supporting Pilgrim Watch's Petition for Contention 1 (Jan. 26, 2008) at pp. 5, 8-9, 13, 19; Testimony of Arnold Gundersen Supporting Pilgrim Watch's Contention 1 (Mar. 6, 2008) at pp. 25, 43, 45, 48, 49, 53.

7

'different result"'). In considering the significance of newly proffered information, it is necessary to consider whether the information is new factual information. LBP-85-42, 22 N.R.C. at 799. In this regard, "[d]iffering analyses of experts of factual information already in the record do not normally constitute the type of information for which reopening of the record would be warranted." Id., citing Pacific Gas & Electric Co. (Diablo Canyon Nuclear Power Plant, Units 1 and 2), ALAB-644, 13 N.R.C. 903, 994-95 (1981) (rejecting a motion to reopen a hearing record based on a new seismic analysis where the seismic motion records were not new and "either were or might have been addressed" at hearing) (emphasis added); see also LBP 42, 22 N.R.C. at 799.

Pilgrim Watch fails to show that the additional information might potentially alter the result that the Board would reach in its absence. The information on which Pilgrim Watch relies (even if it were timely raised) discusses information either contained in documents disclosed to Pilgrim Watch in discovery, or otherwise available to Pilgrim Watch, which might have been addressed by Pilgrim Watch at the hearing. Moreover, Pilgrim Watch has failed to make any showing that the assertedly new information would materially affect the result of the hearing.

1. Pilgrim Watch Makes No Showing of a Materially Different Result with Respect to the CIPP Liner The Miller Pipeline paper is fully consistent with Entergy's testimony. Many of Pilgrim Watch's claims allegedly based on the Miller Pipeline paper are nowhere to be found within the four comers of the paper. Moreover, Pilgrim Watch ignores conclusions stated in the Miller paper that the CIPP, as ultimately installed, met the specifications. See, e.g., Miller Pipeline paper at 9 ("The results of testing were used to confirm compliance with physical property specifications"); id. ("final inspection revealed that the cured in place pipe liner fit tight to the 8

interior surface of the host pipe"). Moreover, official project documents disclosed by Entergy during the discovery process fully cover the topics and matters discussed in the Miller Pipeline paper. 9 This information was fully available to Pilgrim Watch to raise at the hearing, but it simply failed to do so.

a. Buried Piping within the Scope of Contention 1 Pilgrim Watch erroneously claims (Motion at 3) that the Miller Pipeline paper contradicts Entergy's sworn testimony regarding application of CIPP to the buried SSW system discharge piping. The scope of Contention 1 is limited to buried pipe, and therefore Entergy's expert testimony only addresses buried pipe that is part of relevant systems. Entergy's prefiled testimony of Steven Woods and Brian Sullivan makes clear that the entire lengths of the buried SSW discharge pipe, Loops "A" and "B," are lined with CIPP.I 0 The non-buried portions of the SSW system are outside the scope of Contention 1 and are not addressed in Entergy's testimony.

Nothing in the Miller Pipeline paper contradicts Entergy's testimony. Nowhere does the Miller Pipeline paper suggest that any portion of buried SSW discharge system piping is not lined with CIPP. The only contradictions are with Pilgrim Watch's erroneous simplification and interpretation of the Miller paper.

Pilgrim Watch claims that "Entergy incorrectly stated that the entire piping was lined; when in fact the liner was not applied in an area near and inside the auxiliary building -

approximately 10 feet outside the building and an indeterminate footage inside the building."

9 See infra Section III.B.1.b (discussing Entergy documents M-1031 and M-624).

10 Testimony of Alan Cox, Brian Sullivan, Steve Woods,and William Spataro on Pilgrim Watch Contention 1, Regarding Adequacy of Aging Management Program for Buried Pipes and Tanks and Potential Need for Monitoring Wells to Supplement Program (Jan. 28, 2008) ("Entergy Expert Testimony") at A42.

9

Motion at 3.11 However, as reflected in Figures 2, 3, and 5 provided in the Miller Pipeline paper, the statement upon which Pilgrim Watch relies refers to the portion of the SSW system contained within the access vault adjacent to the auxiliary building. 12 SSW piping inside of the vault adjacent to the auxiliary building is not buried and is fully accessible. Entergy never stated that the piping in the vault or inside the auxiliary building was lined with CIPP, and indeed such piping (i.e., that which is not buried) is simply beyond the scope of Contention 1.

Thus, the information in the Miller Pipeline paper does not contradict either evidence presented by Entergy or developed by the NRC Staff. Indeed, the Miller Pipeline paper expressly states as follows:

In April 2001, PNPS developed a specification for lining Loop "A" and Loop "B" from the last flange connection at the 3 Auxiliary Building piping vault to the end of the discharge pipe at the outfall.'

In short, the Miller Pipeline paper fully confirms, consistent with the testimony of Entergy's witnesses, that the entire lengths of the buried SSW discharge pipe, Loops "A" and "B," are lined with CIPP.

b. "Field application" of the CIPP Liner Pilgrim Watch erroneously claims that Entergy failed to disclose or mention information related to the installation of the CIPP liner. Motion at 1, 3. Pilgrim Watch is simply incorrect, as Entergy has disclosed official project documents that discuss the design and installation of the CIPP liner at length.

11Pilgrim Watch accuses the NRC Staff of the same inconsistency:

PW notes that this same factual inaccuracy is repeated by NRC Staff in the SER, 3-37, "Since then, the entire length of both SSW buried discharge loops have been lined internally with pipe linings cured in place - "B" Loop in 2001 and "A" Loop in 2003."

Motion at 3 n.3 (emphasis added).

12 Miller Pipeline paper at 4, 5, 8.

13 Miller Pipeline paper at 3 (emphasis added); see also id. at 7 ("preparation... included opening the vault").

10

Specifically, in M-1031,14 in a section aptly titled "Results from CIPP Installation &

Testing SSW Loop "B" in RFO-13," the installation, repairs, and testing of the CIPP liner in SSW discharge pipe loop "B" are discussed in detail. 15 Similarly, in a section entitled "Results from CIPP Installation & Testing SSW Loop "A" in RFO-14," M-1031 provides the same detailed information regarding the installation, repairs, and testing of the CIPP liner in SSW discharge pipe loop "A."'16 The discussions in these sections describe the high temperatures reached in the curing of the epoxy resin in Loop B, the splitting and repair of the CIPP liner at the bends, and the use of a different, but equivalent polyester resin for Loop A. Moreover, as reflected in M- 1031, Entergy conducted inspections and tests of the CIPP liner for both Loop "B" and Loop "A" which demonstrated that the CIPP, as installed, met the design specifications. 17 All of this information is provided in greater detail than is summarized in the Miller Pipeline paper and nothing in the Miller Pipeline paper is inconsistent with M-1031.

Thus, it appears that Pilgrim Watch simply failed to review, prior to the hearing, the information provided in Entergy's disclosures on installation of the CIPP. Failure to prepare one's own case is surely not cause to reopen the record. Because Pilgrim Watch in fact had the information that it mistakenly asserts was missing, the matters Pilgrim Watch raised "might have been addressed" at hearing and thus are not the proper subject of a motion to reopen the record.

Diablo Canyon, ALAB-644, 13 N.R.C. at 994-95. Accordingly, Pilgrim Watch cannot show that the Miller Pipeline paper is materially different from the information that was in Pilgrim 14 A copy of M- 1031 is provided for the Board's information as Attachment A. It is recognized in this respect that a response to motion to reopen the record may supply documents that may be considered in ruling on the motion.

See Private Fuel Storage L.L.C., supra, CLI-05-12, 61 N.R.C. at 350-55.

'5 M-1031 at 6-9 (PILLROO46106-109).

16 Id. at 10-14 (PILLROO46110-114).

17 Id. at 6-14 (PILLROO46106-114).

11

Watch's possession prior to the hearing. Rather, Pilgrim Watch is complaining of information that was not presented due to its own lack of diligence.

Furthermore, Pilgrim Watch's claims that the testimony of Entergy's witnesses is contradicted by newly discovered information concerning the field application of the CIPP are simply false. Pilgrim Watch's claims are not supported by the Miller Pipeline paper or any other evidence or document. As such, they provide no basis for reopening the record.

First, Pilgrim Watch claims that, because Loops "A" and "B" utilize different CIPP liner material as indicated in the Miller paper, the two loops are not "equivalent so that their performance and 'life expectancy' cannot be assumed to be the same." Motion at 4. However, the Miller Pipeline paper makes no such statement, so this claim is nothing more than unsupported speculation by Pilgrim Watch. Indeed, contrary to Pilgrim Watch's unsupported claim, the Miller Pipeline paper notes that Entergy employed a resin specialist to ensure that polyester resin could be used "in place of epoxy and still meet the design requirements."' 18 This is fully confirmed by the official project design document, M-1031.19 Contrary to Pilgrim Watch's claims, this information is consistent with the testimony of Entergy's witnesses. Entergy's witnesses clearly specified in their pre-filed testimony that the CIPP liner material for Loop "A" "consists of a nonwoven polyester felt tube that is saturated with a resin and catalyst system" whereas the CIPP liner for Loop "B" uses "an epoxy resin and 18Miller Pipeline paper at 7.

19 M- 1031 states in relevant part as follows:

Based on the RFO 13 experience, it was decided to use a different resin for the Loop-A discharge line CIPP. The resin selected is a isophthalic polyester rather than an epoxy.

The principle design parameters remain identical and there are no changes to the required strength characteristics or the resulting thickness required for the CIPP. The physical parameters for the polyester resin, including flexural and tensile strength, coefficient of thermal expansion, and long-term stability are comparable to the epoxy resin.

M-1031 at 10 (PILLROO461 10) (emphasis added).

12

hardener system... with a polyurethane or polyethylene inner membrane." 20 Furthermore, Entergy's expert witness, William Spataro, testified to the characteristics of both types of liners as follows:

The 1/2" thick CIPP liner, consisting of polyester felt material with a resin and catalyst system or an epoxy resin and hardener system, forms a smooth, hard surface that resists moisture intrusion and abrasion, and is resistant to most chemicals and all waters. The CIPP liner is superior to the rubber liner since it is an epoxy and polyester thermosetting resin that cures in place with a smooth hard surface that is resistant to biofouling and other forms of degradation. Such an impervious membrane forms an excellent protective barrier protecting the carbon steel from internal corrosion.

Entergy Expert Testimony at A45 (emphasis added).

Thus, there are no contradictions between Entergy's testimony and the information that Pilgrim Watch incorrectly characterizes as new. Based on Entergy's sworn expert testimony and documents Entergy produced, it is clear that the CIPP liner in loops "A" and "B" are equivalent.

Pilgrim Watch has not produced any evidence that claims otherwise. The Miller Pipeline paper does not declare that the CIPP liners in loops "A" and "B" have different characteristics; neither does Pilgrim Watch's expert. Rather, it is solely Pilgrim Watch's representative that makes this naked assertion. Pilgrim Watch fails to-produce any evidence at all, let alone evidence that could demonstrate that a materially different result would be likely.

Again with no supporting evidence, Pilgrim Watch also declares that the repaired portions of Loop "B" are inferior in quality. Motion at 4-5. This claim is a fabrication from whole cloth with no support other than the naked assertion of Pilgrim Watch's representative.

Both the Miller Pipeline paper and M- 1031 clearly describe how the CIPP liner was repaired using Belzona 1311 Ceramic-R-Metal epoxy compound. M- 1031 goes further and says that

"[t]he 1311 repair compound is a modified epoxy with strength properties that are considerably 20 Entergy Expert Testimony at A43.

13

higher than the CIPP liner epoxy felt composite and was installed to a thickness greater than the nominal 1/2" thickness of the liner." M-1031 at 7 (PILLROO46107). Therefore, Pilgrim Watch again utterly fails to demonstrate that consideration of the Miller Pipeline paper would likely trigger a materially different result.

Pilgrim Watch also claims "there is no indication that samples from patched areas and elbows were tested." Motion at 7. Again, Pilgrim Watch has failed to review Entergy documents. M-1031 says, "[t]esting was also performed on specimens cast from a sample of Belzona 1311 Ceramic R-Metal epoxy compound that was used for CIPP lining repairs...."

M-1031 at 14 (PILLROO46114). In fact, Entergy tested samples not only from the repair Belzona material, but also from both loops upon completing installation. According to Entergy's specification for the CIPP, M-624, "the finished CIPP shall be inspected by visual examination over the entire length and shall be free of significant voids (air bubbles, dry spots, pits, and cracks)." The document goes on to say "cracks are not permitted and any affected areas of CIPP shall be removed by cutting or excavating to completely remove the crack.",21 Once more, Pilgrim Watch is simply making an unsubstantiated and incorrect assertion that reflects its failure to have reviewed documents disclosed by Entergy. Once more, Pilgrim Watch fails to demonstrate that a materially different result would be likely.

Finally, Pilgrim Watch claims that "the probability of worker error is increased if the task is challenging," referring to the need to install the CIPP liner during a refueling outage. Motion at 5. As in the other instances, Pilgrim Watch offers no evidence whatsoever to support the claimed materiality of this assertion. The Miller Pipeline paper provides no evidence of worker 21 Pilgrim Nuclear Power Station Specification for Cured-In Place-Pipe (CIPP) Lining for SSW Discharge Piping Specification Number M-624 ("M-624") (March 12, 2003) at 10. Entergy also provided this document to Pilgrim Watch as part of its document disclosures, and a copy of M-624 is provided for the Board's information at Attachment B.

14

error, and indeed expressly refers to inspections and other activities specifically intended to ensure conformance of the work with specifications and other requirements. 22 Furthermore, the Pilgrim nuclear power plant has a well-experienced staff with processes and controls in place to 23 correctly perform challenging tasks.

In short, the asserted newly discovered evidence supports none of the claims advanced by Pilgrim Watch in its motion. The testimony of Entergy is wholly consistent with this information, and Pilgrim Watch has made no showing that a materially different result would likely be triggered by consideration of this new information.

c. No Contradiction Regarding the Structural Integrity of the CIPP Exists Pilgrim Watch also claims that the Miller Pipeline paper contradicts "Entergy's statements at the hearing" that the CIPP liner "has the structural integrity of a pipe." Motion at 5-6. However, Entergy clearly stated at the hearing that the CIPP is not relied upon to maintain structural integrity under seismic loads. Tr. at 618 ("it's the pipe that's relied on to meet the seismic stresses") (Counsel for Entergy arguing objections to introduction of proposed Pilgrim Watch exhibit); Tr. at 621 ("the cured in place piping inside it is not relied on to meet the seismic stresses") (Counsel for Entergy arguing objections to introduction of proposed Pilgrim Watch exhibit).

22 See, e.g., Miller Pipeline paper at 9 ("final inspection revealed the cured in place pipe liner fit tight to the interior surface of the host pipe"). See also id. at 7 ("team spent several days performing quality assurance inspections and reports to confirm that the materials conformed to specifications").

23 Pilgrim Watch also claims that the vendor did not provide a warranty for the CIPP liner. Motion at 6. However, Entergy never claimed in any of its documents or testimony that the CIPP liner was warranted by the manufacturer. The basis for the 35 year expected life of the CIPP is actual field experience with such epoxy and polyester liners. See Tr. at 655, 723 (Sullivan); at 681 (Spataro) As discussed at the hearing, Entergy will perform inspections at 10 year periodic intervals to confirm the CIPP is performing as expected, with the first such inspection being prior to period of extended operation under the renewed license. Tr. at 774 (Sullivan); at 776 (Cox).

15

The testimony of Alan Cox cited by Pilgrim Watch is not to the contrary. His testimony refers solely to pressure loads and not external structural loads, such as seismic or soil overburden. Mr. Cox's testimony clearly stated that the CIPP was analyzed to withstand pressure loads inside and outside: "it's actually analyzed to be able to stand the pressure loads and the loads from outside the hydraulic pressures of the water above it as if there was no outside pipe." Tr. at 678. Although the statement is mischaracterized, the portion of Mr. Cox's testimony quoted by Pilgrim Watch in fact makes the topic of his discussion clear, It is analyzed for the head of water above it and the -- because the pipe runs downhill, it actually draws a vacuum in parts of it. So it's analyzed to a negative 11 pounds per square inch from the outside, and it's analyzed to -- I can't remember the -- whatever the design pressure is from the inside.

The cured-in-place-pipe has a separate analysis. It says it can withstand the normal pressure loads acting within and from outside.

Motion at 6; see also Tr. at 678 (emphasis added).

This distinction drawn by Mr. Cox between pressure loads for which the CIPP is analyzed and structural loads for which it is not analyzed was clearly understood by Pilgrim Watch's witness, if not Pilgrim Watch's representative. Tr. at 706 ("This liner, just to make sure, is not a seismic barrier. It is. a pressure barrier.") (Gundersen). Thus, Pilgrim Watch's assertion (Motion at 5-6) that Entergy claims that the CIPP liner "has the structural integrity of a pipe," is "earthquake proof," and is designed to "withstand ground movement" (Motion at 5-6) is simply wrong. Entergy has never argued or implied that the CIPP liner is relied on for structural integrity or seismic loads and Pilgrim Watch's attempt to so characterize Entergy's testimony fails. The asserted contradiction with the Miller Pipeline paper simply does not exist.

16

d. Pilgrim Watch's Other Claims of Contradiction and Incorrect and Misleading Testimony are Wholly Without Merit As demonstrated above, Pilgrim Watch's claims that Entergy's witnesses gave incorrect and misleading testimony that is contradicted by the Miller Pipeline paper are simply not true.

The testimony of Entergy's witnesses is fully consistent with the Miller Pipeline paper and official project documents concerning the CIPP. It is Pilgrim Watch - not Entergy - that has fabricated claims from whole cloth that are unsupported by facts or evidence.

Likewise Pilgrim Watch's other claims regarding alleged incorrect and misleading testimony by Entergy witnesses are simply untrue. Citing a draft document not in evidence, Pilgrim Watch claims that the parties "all agree that the SSW Discharge rubber liner is not credited with a protective function." Motion at 1. The document reads, however, since "L.fQ identifying aging effects the liner is not credited with a protective function, aging effects are identified for carbon steel in contact with salt water." Motion at 2 (emphasis added). The document does not state that the liner is not properly credited as part of the aging management program consistent with the GALL Report.

As explained by Entergy's witness Mr. Cox with respect to similar language in the aging management review report for the SSW system (discussed below), if Entergy had credited a qualified protective life for the rubber liner, CIPP or coating (whatever the protective covering),

there would be no aging effects on the underlying metal and no need for an aging management program. Hence, in determining the need for an aging management program, no protective function is credited, but the aging management program includes reliance on the protective coating or liner combined with inspections to ensure that it remains in place. In short, there is no 17

contradiction as claimed by Pilgrim Watch and as essentially acknowledged by Pilgrim Watch's 24 expert.

Similarly, Pilgrim Watch's argument that the Board should strike allegedly inaccurate and misleading testimony from the record concerning the protective capability of coatings (Motion at 7-8) is both inappropriate and wrong. Again, Pilgrim Watch's sole basis is language from the aging management review report for the SSW system that "[s]ince the coating does not have a specified life, aging effects are evaluated as if the carbon steel was not coated.", 25 Again, the point is that, if specified life were assumed for the coating, there would be no need for an aging management program. As explained by Mr. Cox at the hearing:

What [the quote] simply means is if [Entergy] had a specified life of the coating, a guaranteed life, [Entergy] would have no aging effects. We would have no entries in the aging -- in the license renewal application for that component. We would have none listed as the aging effect. We would have no aging management program listed or required to manage aging effects. What we've done here is since there is no qualified life of the coating we have said that loss of material of that underlying metal is possible, so we have to have an aging management program. The aging management program in this case is actually relying on the coating and the inspections that we26 do periodically of the coating to prevent the loss of material from that surface.

In short, there is absolutely no basis for Pilgrim Watch's wholly inappropriate effort to strike Entergy's testimony, or reopen the record, on the basis of this language.

Finally, Pilgrim Watch argues that Entergy ignores the fact that the CIPP liners "simply protect the interior from corrosion," whereas the real issue is corrosion from the exterior attacking the metal." Motion at 7. This argument in the context of discussing the CIPP is a non sequitur. As the Board well knows, Entergy has an entirely separate aging management program 24 See Tr. at 748-49 (Gundersen).

25 See Board Exhibit 70 ("Aging Management Review of the Salt Service Water System") at 10.

26 Tr. at 748 (Cox) (emphasis added).

18

in place for the exterior surface of the pipe. Pilgrim Watch's follow on statement that "[w]e know, from Entergy's own disclosures and the vendor's paper that coating can deteriorate in months and cannot be relied upon" (Motion at 7) is a wholly irrelevant, gratuitous and completely inaccurate and unsupported statement. The record has a plethora of evidence concerning the protective capability of coatings (and liners) that will be set forth in Entergy's findings.

In short, Pilgrim Watch's other arguments of allegedly inaccurate and misleading testimony by Entergy witnesses are inappropriate for a motion to strike or reopen the record and moreover are simply untrue.

2. Pilgrim Watch Makes No Showing of a Materially Different Result with Respect to Cathodic Protection Wholly apart from the inexcusable lateness of Pilgrim Watch's claims of asserted newly found evidence on cathodic protection discussed above, the Motion makes no showing that its proffered information on cathodic protection, even if considered, would likely trigger a materially different result. Pilgrim Watch's belated information (1) does not take into account the unique circumstances of operating cathodic protection at a nuclear power plant, and (2) ignores the fact that cathodic protection is but one of two acceptable alternatives for the license renewal aging management of buried pipes.

Dr. Davis testified that the NRC did not mandate the use of cathodic protection as part of the license renewal aging management program for buried piping because of a concern that the rectifiers may be safety-related equipment such that the failure of a rectifier could result in operation under a "limited condition of operation" ("LCO") of the plant's technical specifications that could require shutdown of the plant until the rectifier were repaired. Tr. at 19

770 (Davis). Pilgrim Watch's newly found expert, Mr. Fitzgerald, states in response that

"[uInless there is a NRC rule requiring this, there is no reason to have to shut down the plant if the rectifier should go off.",27 The Motion transforms Mr. Fitzgerald's qualified statement to the unequivocal declaration that "[t]here is no reason to have to shut down the plant if the rectifier should go off." Motion at 10 (emphasis in original).

Obviously, neither Mr. Fitzgerald 28 nor Pilgrim Watch's representative are familiar with the NRC regulations concerning LCOs that are included in the technical specifications for operating nuclear power plants. The NRC's regulations expressly require that when a LCO "is not met, the licensee shall shut down the reactor or follow any remedial action permitted by the technical specifications until the condition can be met." 10 C.F.R. § 50.36(c)(2) (emphasis added). Thus, the failure of a safety-related rectifier, should cathodic protection be required, could result in an LCO and plant shutdown as Dr. Davis testified. Thus, unlike other applications of cathodic protection where the outage of a rectifier for a short time is of no operational concern, 29 even the temporary outage of a safety-related rectifier at a nuclear power plant could place a large burden on plant operations for little material benefit.

Hence, the development of an alternative license renewal aging management program for buried piping that does not rely upon cathodic protection. Tr. at 770 (Davis). As explained by Entergy's witness Mr. Cox, the GALL Report 30 accordingly provides for two alternative license renewal aging management programs for buried piping. These are M-28 (which employs cathodic protection) and M-34 (which employs protective coatings and inspections in lieu of 27 May 12 Letter at 2 (emphasis added).

28 While reflecting some work on cathodic protection systems at nuclear power plants, Mr. Fitzgerald's resume shows no experience in nuclear power plant operations.

29 See May 12 Letter at 2.

30 Generic Aging Lessons Learned (GALL) Report (NUREG-1801) Rev. 1 (2005).

20

cathodic protection). "They are alternatives" and "either one is acceptable." Tr. at 769 (Cox)

(emphasis added). 31 Here, Pilgrim is employing protective coatings and related inspections under M-34 and not cathodic protection under M-28.

In short, Pilgrim Watch can make no showing that the assertedly new found evidence concerning cathodic protection, even if considered, could likely trigger a materially different result. At bottom, argument on the technical feasibility of employing cathodic protection at nuclear plants is irrelevant because cathodic protection is just one acceptable option for the aging management of buried pipes. Entergy does not rely on cathodic protection as an element of its buried pipe aging management program, and therefore the myriad of issues that Pilgrim Watch seeks to raise and litigate at this late stage of the proceeding are wholly irrelevant and would not lead to a materially different result even if considered by the Board.

C. Pilgrim Watch Has Failed to Submit Affidavits Setting Forth the Factual and/or Technical Basis of its Claims Finally, Pilgrim Watch's attempt to reopen the evidentiary hearing record must also fail because the Motion is not accompanied by any affidavit setting forth the factual and/or technical bases for its claims. 10 C.F.R. § 2.326(b). The Miller Pipeline paper (Exhibit 1), the letter from Mr. Fitzpatrick (Exhibit 2), and the emails discussed in the Motion and also attached at Exhibit 3 are not sworn, notarized statements and are therefore not affidavits. The regulation governing motions to reopen the record requires that affidavits be submitted in support of the factual and/or technical bases therein. 10 C.F.R. § 2.326(b).

31 In the table on page 9 of the Motion, this testimony of Mr. Cox is incorrectly cited to transcript page 770. Pilgrim Watch seeks to strike this allegedly "incorrect statement made by Mr. Cox, Entergy's expert." Motion at 8.

However, Pilgrim Watch provides no argument why this statement is allegedly incorrect, much less why it should be stricken. The argument in the table on page 9 of the Motion solely concerns Dr. Davis's testimony and does not address Mr. Cox's testimony. Moreover, the May 12 letter of Mr. Fitzgerald discusses neither Mr. Cox's testimony nor acceptable aging management programs under the GALL Report.

21

IV. CONCLUSION For the foregoing reasons, the Board should deny Pilgrim Watch's Motion.

Respectfully Submitted, David R. Lewis Paul A. Gaukler PILLSBURY WINTHROP SHAW PITTMAN LLP 2300 N Street, NW Washington, DC 20037-1128 Tel. (202) 663-8000 Dated: May 27, 2008 Counsel for Entergy 22

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensina Board In the Matter of )

)

Entergy Nuclear Generation Company and ) Docket No. 50-293-LR Entergy Nuclear Operations, Inc. ) ASLBP No. 06-848-02-LR

)

(Pilgrim Nuclear Power Station) )

CERTIFICATE OF SERVICE I hereby certify that copies of"Entergy's Answer Opposing Pilgrim Watch's Motion to Strike and Request to Reopen the Evidentiary Hearing," dated May 27, 2008, were served on the persons listed below by deposit in the U.S. Mail, first class, postage prepaid, and where indicated by an asterisk, by electronic mail, this 27th day of May 2008.

• Administrative Judge *Administrative Judge Ann Marshall Young, Esq., Chair Dr. Richard F. Cole Atomic Safety and Licensing Board Atomic Safety and Licensing Board Mail Stop T-3 F23 Mail Stop T-3 F23 U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Washington, DC 20555-0001 amv(anrc.gov rfc1 (l~nrc.gov

• Administrative Judge *Secretary Paul B. Abramson Att'n: Rulemakings and Adjudications Staff Atomic Safety and Licensing Board Mail Stop 0-16 C l Mail Stop. T-3 F23 U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Washington, DC 20555-0001 secy@nrc.gov, hearingdocket@nrc. gov pba(dnrc.gov Office of Commission Appellate Atomic Safety and Licensing Board Adjudication Mail Stop T-3 F23 Mail Stop 0-16 Cl U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Washington, DC 20555-0001

• Susan L. Uttal, Esq. *Mr. Mark D. Sylvia

• Kimberly Sexton, Esq. Town Manager

• James E. Adler, Esq. Town of Plymouth Office of the General Counsel 11 Lincoln St.

Mail Stop 0- 15 D21 Plymouth, MA 02360 U.S. Nuclear Regulatory Commission msylvia(ýtownhall.plymouth.ma.us Washington, DC 20555-0001 slu(anrc.gov; kas2(@,nrc. gov; jeal @nrc.gov

• Ms. Mary Lampert *Chief Kevin M. Nord 148 Washington Street Fire Chief and Director, Duxbury Emergency Duxbury, MA 02332 Management Agency marv.lampertgcomcast.net 688 Tremont Street P.O. Box 2824 Duxbury, MA 02331 nord@town.duxbury.ma.us

• Sheila Slocum Hollis, Esq. *Richard R. MacDonald Duane Morris LLP Town Manager 505 9th Street, N.W. 878 Tremont Street Suite 1000 Duxbury, MA 02332 Washington, DC 20006 macdonald(Wtown.duxburv.ma.us sshollis@duanemorris.com

• James R. Milkey *Diane Curran Assistant Attorney General, Chief Harmon, Curran, Spielberg, & Eisenberg, LLP Environmental Protection Division 1726 M Street N.W., Suite 600 Office of the Attorney General Washington, DC 20036 One Ashburton Place dcurran(@harmoncurran. com Boston, MA 02108 Jim.milkey(@state.ma.us Paul A. Gauller 2

400828231v3

Attachment A Sheet 1 of 2 RTYPE A2.20 NUCLEAR ORGANIZATION CONTROLLEDl DOCUMENT CHANGE NOTICE t0DCN*

MONTSOLLED DOCUMENT CHANGE NOTICE 1013M LI C og No.-

• A'NUAL TITLE: M~ech~anical Calculations IRTYPE 64.01_.

iDOCUMENT TITLE: _,SSW Discharge Piping _CIPP Liner Design,,

DOCUMENTNO: L4-1031 Rev1l l.

REVISION NO.: 1 OTHER KNOWN DOCUMENTS AFFECTED NO. OF PAGES ATTACHED:

SECTION(S) AFFECTED:,

Ln GENERAL REASON FOR CHANGE El Change in Work Process El Change In Related Document E- Error in Previous Revision C El Other:

SPECIFIC PURPOSE AND SuIMMARY OF CHANGES (attach additional oaoes if necessarv0 Calculation update for RFO-14 Installation of SSW LooomA CIPP liner under PDC 01'-19.

,OP'Y ATrACNEb Is

, g 'CC CAPTuPŽ.-

Signature of initiator. Owner: P_M,,

Date Initiated: 0_______ _ ....

IDate Issued by Document i ,=, -

Services .=n.31 f HOT ISSUED MAY 2 1 2003 DOCUMENT CONTROL CENTER PNPS NOP83A7 Rev 15 PILLROO461 00

PlH_-Rand4aI1A N

• iCALC M-1031 Rev .1 S h ee t __, o f 3 I ENN-DC-126 ATrACHMNB'9.6 REV. 2 CALCULATnON RECORD OF REVISIONS RECORD OF REVISIONS Calculation Number:  :-1.-03L Revision Description of Change Reason For Change No.

Original issue of calculation in accordance with PDC 01-09 Including D as-built CIPP material test results for N/A SSW Loop-B Installed In RFO-13.

Update calculation In accordance with PDC 01-09 including Completed CIPP installation for both N

1 as-built CIPP material test results for C p WdscIharge loops.

SSW Loop-A installedIn RFO-14.

C C

C PILLRO046102

PILlRtflf4R 03 CALCULATION SHEET CALC. M-1031 REV. I DATE 14-MAY-2003 SHEET OF VOI A. Statement of Problem This calculation provides the design for a Cured-In-Place-Pipe (CIPP) lining for the Salt Service Water (SSW) buried discharge piping at Pilgrim Nuclear Power Station (PNPS),

The purpose of the CIPP is to provide a new internal lining for the existing steel pipe that can withstand the imposed hydraulic and mechanical loads while maintaining the structural integrity of the discharge pipe for soil, overburden, seismic, and live loads (Ref. 1].

The SSW piping to receive the CIPP is the discharge piping for Loop "A" and Loop "B" from the last flange connection in the Auxiliary Building piping vault to the end of the discharge pipe at the Seal Well opening.

The Loop "A" discharge piping is approximately 240 ft total (length to be lined) with tbree(3) 45-degree elbows and one(I) 90-degre long radius elbow fRef. 2}.

The Loop "B" discharge piping is approximately 225 ft total (length to be lined) with.

Ln four(4) 45-degree elbows and onec(l) 90-degree long radius elbow [Ref. 3].

This calculation also includes the as-built CIPP material test results from lining the Loop "B" discharge in RFO-13 and the Loop "A" discharge in RFO-14.

C)*

PlLLR0040lad

CALCULATION.SHEET. ,

CALC. # M-103i REV. 1 DATE 14-MAY-2003 SHEET S' OF 3 B. Summary of ResulI The CIPP minimum required thickness (t mn) is 0.450". The final CIPP nominal design thicitness (t Nom) based on the minimum Tequired thickness increased by 10% to account for thickness variations in the actual installation is 0.495'. A standard 13.5 mrm (0.531) liner thickness is the appropriate thickness to use.

The analysis demonstrates that stresses in the CIPP liner remain within acceptable limits for all internal or external pressure loading on the liner plus other sustained and occasional mechanical and differential thermal expansion loads including those that result from interaction with the original steel pipe..

0 Pill I P*fAi.RIN

CALCULATION SHEET OAL.# M.. 031 REV. 1 DATE 14-MAY-2003 SHEET _ __ OF -L.

Results from CIPP Installation & Testing SSW Loop "B" in RFO-13 This section of the calculation was added after the installation, inspection, and testing for the SSW discharge line CIPP work in RFO-13 was completed for Loop-B in accordance with PDC 01-09 (Ref. 13].

SSW Loop-B discharge piping received a successful CIPP lining installation in RFO- 13 under PDC 01-09. An attempt to also line SSW Loop-A discharge piping was aborted when problems developed with the epoxy beginning to cure after the wetout process but prior to starting the inversion process. These problems were attributed to unusually high ambient temperature conditions ( > 90'F) during the epoxy batching and wetout process.

C' The SSW Loop-B liner was cured at elevated temperature using a steam/air mixture at 3approximately I 801F. Inspection of Loop-B after the CIPP installation revealed that the liner had severed circumferenfially and separated in three locations during the cooldown after curing as reported in NCR 01-038 [Ref. 17]. The first severed location was after the second horizontal 45-degree elbow from the inlet end. The second and third severed Clocations were in both ends of the vertical 45-degree elbow turning down to the seal well discharge. These three locations where the epoxy liner had severed were attributed to restrained thermal contraction upon cooldown following the curing process. Each of the locations is at an elbow at the end of a long straight run of pipe that is constrained C2 between two elbows.

- It is apparent based on the evidence that the epoxy sets (the term 'gel" is often used) at an elevated temperature in excess of I80 'F (actual peak epoxy temperature is not known) and fully cures into the solid structural compound at this elevated temperature, Upon o cooling down, restrained thermal contraction occurs and builds tensile stress over the entire decreasing temperature range from at least I 0*F down to the normal ambient of

• approximately 500F.

It had previously been considered that the potential to build up high tensile stress during the first cooldown from curing would be minimized by a plastic creep or relaxation effect that would relieve these initial stresses. It is apparent that this relaxation of stress during cooldown did not occur, The large ( > 130°F differential) temperature reduction during the cooldown caused the thermal contraction stress to exceed the tensile strength of the liner, which resulted in the severing and separation that was seen in the Loop-B installation for each long run that was restrained between two elbows, The restrained thermal contraction stresses, which were induced by the first-time cooldown from elevated temperature curing, were completely relieved by the severing that occurred at the three elbow locations, The CIPP lining was repaired as described below. Subsequent to the relieving of the thermal stresses and the epoxy repair, the assumptions in this calculation for itt-service restrained thermal contraction stresses over the temperature range from 30 to 100°F are valid for the life of the CIPP installation, PIl I PRlf'RiRlA

CALCULATION SHEET CAL.v. 1 1031 REV. I1 DATE MAY-2003 SHE 7 or- 37 The CIPP liner was repaired using Belzona 1311 Ceramic R-Metal epoxy compoutid in accordance with FRN 01-09-02 [Ref. 14] and CGI-861 [Ref. 211. The CIPP polyurethane membrane was removed by abrasion for approximately a 2" width back from the severed edges and the epoxy surface was roughened and scored as a means to achieve a good surface for bonding to the repair epoxy, The 2311 epoxy compound was installed by troweling and contouring such that the repair was built up to a greater thickness than the CIPP lining with a crown that was contoured onto the roughened surface of the severed ends. The entire repair at each location was performed as a single application to the full thickness.

The 1311 repair compound is a modified epoxy with strength properties that are considerably higher than the CIPP liner epoxy felt composite and was installed to a thickness greater than the nominal 1/2" thickness of the liner The repair was required to meet the same minimum flexural and tensile properties as the CIPP liner.

Tesdng of samples from the CIPP installation was performed in accordance with oSpecification M-624 [Ref. l] and CGI-860 [Ref. 4]. The following physical properties were measured for the test specimens described below, and are critical characteristics that provided the basis for acceptance of the CIPP ir.ntallation:

Average Thickness Flexural Modulus of Elasticity oD Flexural Strength Tensile Strength Flexural testing was performed on three specimens taken at both the entrance and termination point (total six specimens) to determine the Flexural Modulus of Elasticity

-:-- and the Flexural Strength in accordance with AST.M Standard D790 [Ref. 23]. Testing was required only for the flatwise orientation of the specimens.

Tensile testing was performed on three specimens taken at both the entrance and termination point (total six specimens) to determine the Tensile Strength in accordance with ASTM Standard D638 [Ref. 22].

The average thickness of all samples was ? 0.495".

Pil I PnAArfl7

CALCULATION SHEET CALC. # M-1031 REV. 1 DATE 14.MAY-2003 SHEET OF 37 Testing was performed on samples taken from the SSW Loop-B CIPP liner for the parameters in the following table (see attached report). The test results for Flexural Modulus and Flexural Strength exceeded the rated values while the test results for Tensile Strength were below the rated values as shown below:

Rated SSW Loop-B SSW Loop-B Physical Property Short-Term Value Inlet Sample Outlet Sample Flexural Modulus 300,000 PSI 407,400 PSI 375,600 PSI Flexural Strength = 4,000 PSI 5,518 PSI 4,173 PSI Tensile Strength = 4,000 PSI 2,711 PSI 3,316 PSI (Test results from Massachusetts Materials Research)

C%,"

C3 These test results were accepted as satisfactory via NCR 01-048 [Ref. 18]. The design analysis for the CIPP installation is included in this calculation. The actual tensile

~n strength value used in the analysis is 1,333 PSI, which is one-third of (he rated value of 4,000 PSI. The reduction factor of three applied to the rated values is to account for Cenvironmental effects. The above test data shows that the lowest measured value is more than two times the tensile strength value used (2,711 / 1,333 = 2.03).

An additional Loop-B inlet sample was tested independently and showed more favorable results (see below). Nonetheless, the reduction factor of three used in the analysis was known to be very conservative for epoxy resin materials, which are far more stable than O:* other polymers and do not deteriorate or age significantly even for long-term service.

Furthermore, this analysis includes an additional factor of safety equal to two for the allowable primary stresses. Therefore, these results are acceptable and the SSW Loop-B CIP? installation is considered to meet the design requirements in this analysis.

An additional Loop-B inlet sample was sent to a different independent test lab that is known to have particular expertise in testing of composite plastics (see attached report).

These results were as follows:

Rated SSW Loop-B Physical Property Short-Term Value Inlet Sample Flexural Modulus 300,000 PSI 337,995 PSI Flexural Strength 4,000 PSI 6,325 PSI Tensile Strength = 4,000 PSI 3,629 PSI (Test results from HTS Inc,)

PHI I IRflfl.ARnR

CALCULATION SHEET CALO. # M-1031 REV. 1 DATE 14-MAY-2003 SHEET . j OF Testing was also performed on specimens cast from a sample of the Belzona 1311 Ceramic R-Metal epoxy compound that was used for the CIPP lining repairs in accordance with CGI-861 [Ref. 21], Flexural testing was performed on three specimens and tensile testing was performed on three specimens (total six specimens). The test resuths for Flexural Modulus, Flexural Strength, and Tensile Strength exceeded the rated values as shown below (see attached report):

Rated Belzona 1311 Physical Property Short-Term Value Ceramic R-Metal Flexural Modulus = 300.000 PSI 2,920,000 PSI Flexural Strength 4.000 PSI 11,168 PSI Tensile Strength 4,000 PSI 5,648 PSI (Test results torn Massachusetts Materials Research)

Lfl 0

0 M~p 0

p1:11 i Pfl*f fql

CALCULATION SHEET CALO. M-10D1 REV. I DATE 14-MAY-2003 SHEET to OF _7 Results from CIPP Installation & Testine SSW Loop 'A" in RFO-14 This section of the calculation was added by Revision I after the remaining installation, inspection, and testing for the SSW Loop-A discharge line CIPP work was completed during RFO-14 in accordance with PDC 01-09 [Ref. 133.

SSW Loop-A discharge piping received a successful CIPP lining installation in RFO-14 under PDC 01-09. The previous attempt to line the SSW Loop-A discharge piping in RFO-1 3 had been aborted when problems developed with the epoxy beginning to cure after the wetout process but prior to starting the inversion process. These problems were attributed to unusually high ambient temperature conditions (:>90'F) during the epoxy batching and welout process. As a result of that experience, an alternate CIPP resin system was selected for the Loop-A CIPP liner installation based on the lessons learned in CR-PNP-2001-02301 [Ref. 24].

Following is additional information from the Root Cause Analysis in CR-PNP-2001-Lt 02301 and the resulting lessons-leamed from ihe RFO-13 experience in which the CIPP liner was successfully installed in the Loop-B discharge line but the installation attempt was aborted for the Loop-A discharge line.

The aborted installation attempt for the Loop-A discharge in RFO-13 is described and evaluated in CR-PNP-2001-02301 and the lessons-learned from this experience were incorporated into the RiFO-14 installation effort. The Root Cause Analysis results and Corrective Actions to Preclude Recurrence did not involve design issues nor did they Ospecifically require that the CIPP design be changed from that successfully used in the M Loop-B discharge line.

o The problems identified were primarily with the project implementation process at PNPS, the level of knowledge of the PNPS and vendor personnel directly and indirectly involved

- with (he work, and the handling of the aborted CLPP liner and materials. This review resulted in the decision to use a different resin system that has improved workability as described below. Once the epoxy resin/curing agent mixture saturating the liner tube began to polymerize after the wet-out process was completed, the liner became unusable and the polymerization process had to be allowed to continue until the epoxidation reaction was complete.

Based on the RFO-13 experience, it was decided to use a different resin for the Loop-A discharge line CIP. The resin selected is an isophthalie polyester rather than an epoxy.

The principle design parameters remain identical and there awe no changes to the required strength characteristics or the resulting thickness required for the CIPP. The physical parameters for the polyester resin, including flexural and tensile strength, coefficient of thermal expansion, and long-term stability are comparable to the epoxy resin.

Pl1 I RnmsiI1

CALCULATION SHEET OALC. # M-1031 REV. I DATE %4MAY-2003 SHEET If OF _3 The significant benefit of the polyester resin is the much longer "pot life" inthe wet-out condition. This is significant because the RFO- 13 aborted attempt was due to the spontaneous reaction of the wet-out liner prior to installation. Epoxy resins have a shorter pot life once mixed with their curing agents and are more sensitive to ambient temperature and ultra-violet light impingement. In R1FO.13, the combination of unusually hot weather conditions and bright sunlight caused the epoxidation reaction to begin during the wet-out or subsequent handling of the liner. The short pot life for epoxy resin was the principle reason for performing the wet-out process at the installation site rather than offsite.

The corrective actions to preclude recurrence of these problems included performing the L.1 wet-out process in a controlled environment. The optimum method is to perform the wet-out at a dedicated offsite CIPP wet-out facilit)' and then transport the fully wet-out liner to CO the site ina refrigerated truck. To do this, the pot-life of the resin must be sufficiently long to accommodate the handling and transport time p)us adequate margin for potential delays. This pot life requirement simply cannot be met by the epoxy resin but is readily C accommodated by the polyester resin. In the refrigerated condition (approximately 30 to 401F), the pot life is approximately 5 days for the epoxy while it is 21 days for the polyester resin.

This design analysis is applicable to Loop-A with the one substitution that the term "epoxy" with respect to the Loop-B CIPP liner resin be replaced with the term 3 "isophthalic polyester" as applied to the "A"discharge line only. The flexural modulus and the flexural and tensile strength requirements are the same for the epoxy and

.polyester resins. The coefficients of thermal expansion for the epoxy and polyester resins with synthetic fiber filler are also equivalent.

-- The SSW Loop-A liner was cured at elevated temperature using heated circulating water at approximately 180OF maximum. Inspection of Loop-A after the CIPP installation and curing were complete showed that the liner had not severed or separated during the cooldown due to restrained thermal contraction as had the Loop-B lining. Therefore, in accordance with the PDC 01-09 instructions given in FPN 01-09-04, the restrained thermal contraction tensile stresses were relieved by intentionally making cuts at designated locations if severing did not occur upon cooldown. The first stress relief location was after the first horizontal 45-degree elbow from the inlet end [Ref. 15]. The separation that occurred at this location was approximately V"and, based on this being the longest straight run of pipe that is restrained between two elbows at 118-2" versus the next longest straight run at only 24'-4112', no further stress relief cuts were made.

The restrained thermal contraction stresses, which were induced by the first-time cooldown from elevated temperature curing, were relieved by the severing that was done at the first elbow location. The CIPP lining was repaired as described below. Subsequent to the relieving of the thermal stresses and the epoxy repair, the assumptions inthis calculation for in-service restrained thermal contraction stresses over the temperature range from 30 to 1001F are valid for the life of the CIPP installation.

PlH I PnndA111

CALCULATION SHEET CALC. # M-1D31 REV. 1 DATE 14-MAY-2003 SHEET /. OFr The CIPP liner was repaired using Belzona 1311 Ceramic R-Metal epoxy compound in accordance with FRN 01-09-02 [Ref. 14] and CGI-B61 [Ref. 213. The C]PP polyethylene membrane was removed by abrasion for approximately a 2" width back from the severed edges and the epoxy surface was roughened and scored as a means to achieve a good surface for bonding to the repair epoxy. The 1311 epoxy compound was installed by troweling and contouring such that the repair was built up to a greater thickness than the CIPP lining with a crown that was contoured onto the roughened surface of the severed ends. The entire repair was performed as a single application to the full thickness.

The 1311 repair compound is a modified epoxy with strength properties that are considerably higher than the CIPP liner epoxy felt composite and was installed to a thickness greater than the nominal 112" thictness of the liner The repair was required to meet the same minimum flexural and tensile properties as the CIPP liner.

Lr Testing of samples from the CIPP installation was performed in accordance with Specification M-624 [Ref. I] and CGI-860 [Ref. 4], The following physical properties were measured for the test specimens described below, and are critical characteristics that provided the basis for acceptance of the CIPP installation:

Average Thickness Flexural Modulus of Elasticity Flexural Strength Tensile Strength Flexural testing was performed on three specimens taken at both the entrance and o termination point (total six specimens) to determine the Flexural Modulus of Elasticity and the Flexural Strength in accordance with ASTM Standard D790 [Ref. 23]. Testing was required only for the flatwise orientation of the specimens.

Tensile testing was performed on three specimens taken at both the entrance and termination point (total six specimens) to determine the Tensile Strength in accordance with ASTM Standard D638 [Ref. 22].

The CIPP nominal design wall thickness is 0.495", The controlling parameter for the design thickness of the liner is an external pressure of 25 ht w.g. (-11 PSIG). This design value for external pressure is based on the Calculation M-630 SSW System Hydraulic Analysis [Ref. 8]. The SSW discharge piping downstream of the system RBCCW and TBCCW heat exchangers operates at negative pressure under certain flow conditions due to a "siphon" effect based on the piping elevations and flow rates. The lowest absolute pressure occurs at equivalent piping nodes in Loop "A" and Loop "B " that are at the highest elevation of the discharge piping downstream of the heat exchangers in the Auxiliary Bay vault flanges at EL (+)15.6 ft.

Pill I 1flfi119

CALCULATION SHEET CALO. M-1031 REV. 1 DATE 14-MAY-2003 SHEET 13 o OF _77 The limiting case for lowest absolute pressure occurs for emergency operation at the design low tide level. The piping negative pressure is combined with potential external hydrostatic pressure to give an equivalent total external pressure acting on the pipe of 25 ft w.g. (equivalent to -II PSIG internal pressure). The CIPP liner is also designed based on a positive internal pressure of 30 PSIG, which is greater than the design pressure included in Specification M-300 that applies to the SSW discharge lines downstream of the last valve in the system.

CIPPliner thickness was measured at both the inlet end in the Auxiliary Bay vault and at the discharge outlet in the seawater discharge seal well. The inlet end CIPP thickness was greater than the nominal design wall thickness of 0.495". For the discharge end t: samples, NCR 03-027 [Ref. 19] reported the thickness to range from 0.466" to 0.507" with an average thickness of 0.490" (including the membrane). Based on a review of the actual installed finer, the condition reported in NCR 03-027 was determined to be "Accept-As-ls". This nonconformance was dispositioned with the following information.

For the installation of the CIPP liner in the SSW discharge line, it has been observed that there is an "end effect" that occurs at the discharge outlet that causes thinning of the end of the lining run after the last 90-degree elbow. This thinning is caused by stretching that occurs as the inversion is ended at the discharge pipe opening and the closed end of the inverted water-filled liner is held back at that position. The configuration of the SSW discharge lines adds to this end effect because there is a 17.4 ft drop in elevation just before going into the last 90-degree elbow at the discharge, This additional static head of water, together with the axial tension from the closed end of the tube inversion, results in liner rbinn)ng at the outlet end of the run. The only outlet-end thickness measurement is at the end of the liner where there is acut made to install the outlet WEKD seal. This C location is less than 8" from the pipe outlet and is heavily influenced by the end effect, From the design of the CIPP liner, it can be seen that the required thickness at the outlet end of the SSW discharge pipe is significant)y )ower than it is at the inlet end. When the SSW line drops from EL 1 ft to -6.4 ft there is a change in the hydraulic design conditions from negative pressure to positive pressure. The maximum internal operating pressure range for the outlet section of the SSW discharge lines is less than 9.0 PSI occurring at the discharge outlet elevation for the design storm tide at EL +13.5 ft

[Ref. 8). There is no point in the discharge line that experiences greater than a 9 PSI range of pressure.

The CIPP design minimum required wall thickness (Miu, ,) is 0.450 inch, which corresponds to a maximum negative (external) pressure of- I I PSIG and a maximum internal pressure of 30 PSIG. The value of 0.450 inch ,'as increased by I07o to give the final CIPP nominal design wall thickness (ttoM ) equal to 0.495 inch. The actual nominal thickness ofthe CIPF liner (based on the tube thickness used) is 0.531 inch, which corresponds closely with the actual inlet end thickness measurements. The average of the outlet end thickness measurements is 0.490 inch. The polyethylene membrane is no greater than 0.012 inch thickness.

PI I RflfldRol.

CALCULATION SHEET CALC. # M-1031 REV. I DATE 14-MAY-2003 SHEET /4 OF -37 Testing was performed on samples token from the SSW Loop-A CIPP liner for the parameters in the following table (see attached report). The test results for Flexural Modulus and Flexural Strength exceeded the rated values while the test results for Tensile Strength were below the rated values as shown below:

Rated SSW Loop-A SSW Loop.A Physical Property Short-Term Value Intel Sample Outlet Sample Flexural Modulus 300,000 PSI 472,000 PSI 411,000 PSI Flexural Strength 4,000 PSI 4,240 PSI 5,640 PSI Tensile Strength 4,000 PSI 2,720 PSI 3,960 PSI (Test results from M&P Laboratory)

C-7 CZY These test results were accepted as satisfactory via NCR 03-039 [Ref. 20]. The desig analysis for the CIPP installation is included in this calculation, The actual tensile Wf strength value used in the analysis is 1,333 PSI, which is one-third of the rated value of 4,000 PSI. The reduction factor of three applied to the rated values is to account for c environmental effects. The above test data shows that the lowest measured value is more than two times the tensile strength value used (2,720 / 1,333 = 2.04).

The reduction factor of three used in the analysis was known to be very conservative for epoxy and isophihalic polyester resin and catalyst systems, which are far more stable than other polymers and do not deteriorate or age significantly even for long-term service.

C Furthermore, this analysis includes an additional factor of safety equal to two for the allowable primary stresses. Therefore, these results are acceptable and the SSW Loop-A CIPP installation is considered to meet the design requirements in this analysis.

Testing was also performed on specimens cast from a sample of the Belzona 1311 Ceramic R-Metal epoxy compound that was used for the CIPP lining repairs in accordance with CGI-861 [Ref. 21]. Flexural testing was performed on three specimens and tensie testing was performed on three specimens (total six specimens). The test results for Flexural Modulus, Flexural Strength, and Tensile Strength exceeded the rated values as shown below (see attached report):

Belzona 1311 Belzona 1311 Hated Ceramic R-Metat Ceramic R-Metal Physical Property Short-Term Value Lot 1 Lot 2 Flexural Modulus = 300,000 PSI 1,170,000 PSI 1,260,000 PSI Flexural Strength = 4,000 PSI 6,350 PSI 9,100 PSI Tensile Strength = 4,000 PSI 4,700 PSI 4,9B0 PSI (Test results from M&P Laboratory)

PILLROO4611A

PILLROO4611I CALCULATION SHEET CALC, # M-1031 REV. 1 DATE 14-MAY-2003 SHEET OF The flat plate analysis is a bending stress calculation in which the controlling parameters are the CIPP diameter, thickness, and flexural strength. There is a maximum diameter hole in the existing pipe above which the CIPP flat plate loading case is less limiting than the ring tension case above.

To confirm the adequacy of the CIPP design for all imposed loads and conditions, an additional pipe stress analysis is also performed. The additional analysis considers the effects of all sustained and occasional pressure, mechanical and restrained thermal expansion loads. To perform a rational analysis that explicitly accounts for both primary and secondary stresses and their effects, a methodology based on ASME B&PV Code Section III Subsections NB-3200 and N'B-3650 is used. This is not meant to imply that C the CIPP liner is designed in accordance with the totality of the ASME Code Section MII 0% criteria but rather uses the methodology to evaluate primary and secondary stresses due to all imposed loads as presented in this calculation.

0tT CD PIII PIlflninA.iL4

~i PnnfAA147 CALCULATION SHEET CALM. # M.1031 REV. 1 DATE 14-MAV-2003 SHEET CF OF

9. For the external pressure design case, the analysis of the CIPP liner is based on the original.steel pipe being in a partially deteriorated condition. A "partially deteriorated pipe" is one that can support the soil and overburden loads throughout the design life of the installation (see below). For the external pressure case, the original pipe is assumed to provide support to the CIPP liner to resist the ovalizing effect that external pressure can create, However, the original pipe is not required to be integral or free of flaws, cracks, or corrosion, The steel pipe will be inspected prior to the CIPP installation and will be confirmed to meet the original design requirements with repairs made as needed.

The "partially deteriorated pipe" is considered to exist at the end of life condition for the CIPP installation [Ref. 5].

10. For the external load analysis, the design equations used shall be for the "Partially Deteriorated Gravity Pipe Condition" in ASTM Fl216. For the negative pressure CIO (vacuum) design condition, the CIPP shall be designed as a gravity pipe with the external hydrostatic pressure increased by an amount equal to the negative pressure [Ref. 51.

1. For the internal positive pressure design case, the analysis of the CIPP liner is based on C* the original steel pipe being in a fully deteriorated condition. A "fully deteriorated pipe" is one that is not structurally sound and cannot support the soil and overburden loads and for which the surrounding soil does not provide adequate side support. The CIPP liner is designed for the positive pressure of 30 PSIG with no assumption of support from the steel pipe. The basis for this requirement is that the CIPP liner is intended to be a pressure boundary that protects the steel pipe from the SSW and therefore shall withstand CD the maximum SSW pressure based only on the strength of the CIPP liner [Ref. I].

12. An additional internal pressure design case is based on the original steel pipe being in the partially deteriorated condition where the existing pipe provides support but has a hole or Oopening across which the CIPP liner span is not supportedby the pipe, For this case, the

-. CIPP is considered to be a circular flat plate fixed at the edge and subjected to the full internal differential pressure. The maximum diameter hole (d) in the existing pipe for which the flat plate loading case remains applicable is determined and the allowable hole size for the highest design pressure anywhere in the SSW system of 100 PSIG [Ref, 7).

13. For the internal pressure analysis, the design equations used shall be for the "Fully Deteriorated Pressure Pipe Condition" in ASTM F1216. For the additional case described above, the design shall be based on the "Partially Deteriorated Pressure Condition" in ASTM F1216 [Ref. 5).

14. This calculation considers a "partially deteriorated" condition to exist for the'original steel discharge line at the end of life for the CIPP installation (35 years). The partially deteriorated steel pipe condition is realistic based on PNPS plant experience, inspection results, and observation of the intact condition of the pipe and external pipe wrap on previously excavated spools coupled with the following explanation otf corrosion, Future corrosion from the MD will be inhibited by the new CIPP liner. The OD of the steel pipe experiences conditions that are not highly conducive to corrosion, i.e., external pipe wrap, minimal ground water, and soil conditions of compacted backfill.

011 f'I, .

CALCULATION SHEET CALC.# M-1031 REV. 1 DATE 14-MAY-2003 SHEET jq OF

15. Localized corrosion of the steel pipe that might occur despite theabove considerations is known to occur at an extremely slow rate (well less than 10 mils/year at the most aggressive localized conditions). This localized corrosion would be expected to involve the formation of "tubercles". which are mounds of corrosion products that cap localized regions of metal loss. The tuberculation corrosion process is essentially self-limiting and causes minimal long-term wastage of the base metal for this type of buried steel pipe installation. The long term corrosion that might occur will be bounded by the allowable extent of localized wall thinningincluded in the SSW buried piping design analysis calculation M-976 [Ref. 9].

16. The long-term (time-temperature corrected) Flexural Modulus of Elasticity (ErL) shall be reduced from the short-term by multiplying the short-term value by 0.50. An Enhancement Factor (K) value of 7.0 shall be used. An Ovality Reduction Factor (C) of 0.90 shall be used, based on a 0.250 inch maximum to mean inside diameter differential

[Ref. 13, 117 17. The long-term (time-temperature corrected) flexural strength (Sn..) and tensile strength (S'r.) shall be equal to one-third the rated short-term strength values listed below [Ref. I].

18. The maximum allowable stress for the external load and internal pressure analyses shall be equal to one-half the long-term flexural and tensile strengths, that is, a Factor of Safety (N) equal to 2 shall be used inthe design equations [Ref. 1).

19. The SSW discharge piping downstream of the system RBCCW and TBCCW heat exchangers operates at negative pressure under certain flow conditions due to a "siphon" effect based on the piping elevations and flow rates. The piping negative pressure is combined with potential external hydrostatic pressure to give an equivalent total external pressure acting on the pipe of 25 ft w.g. (equivalent to -Il PSIG internal pressure). The C[PP liner is designed based on this same external hydrostatic pressure since the original steel pipe is not required to provide a complete pressure boundary. The CIPP liner is also designed based on a positive internal pressure of 30 PSIG, which is greater than the design pressure included in Specification M-300, that applies only to the SSW discharge lines downstream of the last valve in the system [Ref. 7].

20. The short-term design values to be used shall be as follows [Ref. 1]:

Rated Physical Property Short-Term Value Flexural Modulus 300,000 PSI Flexural Strength 4,000 PSI Tensile Strength = 4,000 PSI onl I P*l'l I Q

CALCULATION SHEET CALC. I# M-1031 REV. i DATE 14oMAY-2003 SHEET '0 OF L

21. The design loadings shall be as follows [Ref. Q1:

Design Parameter Design Value Maximum Internal PressurefTemperature = 30 PSIG @ 100 0F Minimum Operating Temperature 302F Maximum External Differential Pressure (Minimum internal Pressure) 25 ft wmg. (-11 PSIG Internal)

Portions of the SSW discharge piping are normally operating at negative pressure. The Maximum External Differential Pressure of 25 ft w.g. is based on the highest negative 0", operating pressure for the discharge piping plus an accounting for groundwater pressure acting externally. External soil, overburden, seismic, and live loads do not act upon the CIPP liner because the steel pipe will remain the structural component.

C 22. For a stress intensity range analysis that uses the range of pressures over which the piping operates, the actual maximum internal operating pressure range for the affected section of the SSW discharge lines is less than 9.0 PSI occurring at the discharge outlet elevation in the piping for the design storm tide at EL 413.5 ft, and the maximum range for negative pressure is also less than 9.0 PSI occurring at the highest point in the discharge line at EL +15.6 ft (this pressure range does not include the additional 5 ft external groundwater 0 hydrostatic head included in the external pressure analysis). There is no point in the discharge line that experiences greater than a 9 PSI range of pressure [Ref. 8].

23. The maximum temperature range of operation for the affected section of the¢SSW discharge lines is 30'F to 100'F [Ref. 7].

24. A tensile modulus of elasticity value of 300,000 PSI is used for stress analysis in conjunction with the long-term tensile strength of 1,333 PSI, This is conservative since the long-erm modulus of elasticity is reduced from the short-term by 0.50 while the long-term tensile strength is only one-third the short-term value. Rated short-term value for tensile strength is 4,000 PSI and tensile modulus of elasticity is 550,000 PSI for felt composites [Ref. 10]. Therefore, using 1,333 PSI tensile strength with a modulus of elasticity value of 300,000 PSI will be bounding for all short to long-term conditions.

25. The coefficient of thermal expansion for the CIPP epoxy and polyester resin is equal to or less than 4.0 x 10"5 inchlinch-°F (7.2 x I0"s inc./inch-0 C) [Refs. 10 & I 11.

26, The coefficient of thermal expansion for the Belzona 1311 repair epoxy is equal to or less than 2.0 x 20*" inch/inch-°F (3.6 x 10's inchlinch-aC) [Ref. 12].

I"111 I ,=,t^ - - --

CALCULATION SHOET CAL. # M.1 031 REV, 1 DATE 14-MAY-2003 SHEET OF o_

E, Calculations / AnalqSes Definition of Terms Do Outside diameierforthe CIPPlining, inches d Hole or opening diameter in e-isting pipe wall, inches t Wall thickniess, inches txwr%, Minimum requiredwall thickness, inches INo.m Nominal design wall thickness, inches PE External hydrostaticdesign pressure,PSIG ti P, Internalhydrostaticdesign pressure,PSIG P.AX Actuat maximum operatingpressurerange, PSI K Enhancementfactorof the soil and existing pipe adjacentto the CIPP WL EFS Short.rerntflexuralmodulus of elasticity,PSI C En- Long-term (time-temperaturecorrecred)flexitral modulus of elasticity, PSI En Long-term (time-temperature corrected) tensile modulus of elasticity,PSI SDR StandardDimensionRatio = (Do / 1)

C Ovaliry reductionfactor C2 q Percentage ovatihy of originalpipe M Resultant moment from design loads, inch-lbs N Factorof safety B. Primarystress index for internalpressure B2 Primarystressindexfor moment loading C1 Secondary stress indexfor internalpressure C2 Secondary stress indexfor moment loading C3 Secondary stress indexfor thermal loading rz 3,Mean pipe radius= (Do - 0/2, inch R Bend radius of elbow(long radius)- (1.5 x Do), inch or Thermal expansion stressfrom restraintaffree end displacement,PSI at, Tensile stressfrom pressurein hoop or longitudinaldirection, PSI 6r Tensile stressfrom mechanical loads, PSI v Poisson'sratio SFL Long-temi (time-temperaturecorrected)flexuralstrength, PSI

$TS Short-term tensile strength, PSI Sn. Long-term (tine-temperaturecorrected)tensile strength, PSI 6SStrain, inch/inch a Coefficient of thermal expansion, inch/inch- 'F 0Il I DMIArA.nA

CALCULATION SHEET CALM.# M-1031 REV. 1 DATE 14-MAV-2003 SHEE=T 92, OF -

Design Equations CTPP Design for Extezal Pre~ssure Partiallydeteriorated existing pipe condition (ASTM F1216 Equation X1. 1):

2K* E S= I c EQ I her - ) (siR ato -

e.* Wherc the StandardDimension Ratio (SDR) is:

Lf1 SDR = Po V7 EQ 2 I

The Ovalitiy Reduction Factor(C) is:

C EQ 3 0

The percentage ovality of originalpipe (q) is:

q 1 00* (MlaxirnwnlnsideDiameter-Meanlnsideoiarneter)

EQ4 MeanInsideDitmJeter CIPP Design for Internal Pressumi Fully deteriorated existing pipe condition (ASTM F1216 Equation XI.7):

2STL EQ 5 (SDR- 2) N DII I mnflt'Ag4l"

CALCULATION SHEET CALC, # M-1031 REV. 1 DATE 14-MAY-2003 SHEET 23 OF .3 .

Partially deteriorated existing pipe condition (ASTM F1216 Equation X1.6):

P1 =__L33 Rb SFLEQ 6 (SDR 1): d* N The maximum diameter hole (d) in the existing pipe for which the CIPP can be considered to be a circular flat plate fixed at the edge and subjected to transverse pressure P.. is determined using the following relation (ASTM Fl 216 Equation X1.5):

S- 1.83 EQ 7 The calculations above determine the appropriate value for the CIPP minimum required wall thickness (tMW), which is then used to determine the final CIPP nominal design wall thickness:

CD t1oM = t *

',K 1IO EQ 8 03 PII I Rnfl/AR19-

CALCULATION SHEET CALC, 9 M-1031 REV. I DATE 14-MAY-2W3 sjqF--7 -9.4- OF Y?

CIPP Design Calculations The mean inside diameter of the existing pipe to be lined:

ý 22.0001, Pipe O.D.

(2xD.375") = 00.750" Pipe wall (2 x 0. 188") = (-) 0.375" Rubber fin ing 20.875" Mean I.D.

The value 20.875" will be the outside diameter(Do ) for the CIPP lining used in the following design equations.

U7 The existing pipe is assurned to have an ovality wizb a maximum differential between the maximurn and mew inside diameter of 0.250", therefore the ovality reduction factor is:

q =too [(20,875 + 0.250) - 20.975]

20-875 C3 C) 3 C 1+ L.20 0.90 100 The long-term (time-remperaturecorrected)fle--curalmodulus of elasticirY (EFL) is'.

EFL = 0.50(EFs) = 0.50(300,000) = 150,D00 PSI The long-term (time-temperaturecorrected)fieritrulstrength (Sn) is:

SFL == 0.333(El:s) = 0.333(4,DOO) = 1,333 PSI The lon8-tenn (time-remperaturecorrected)tensile strength (Sn) is:

STI, = 0.333(ETs) = 0.333(4,000) = 1,333 PSI pit i PnnAr.19A

CALCULATION SHEET CALC. # M-1031 REV. I DATE 14-MAY.2003 SHEET 2._it' OF 37 CIpp design involves finding the StandardDimension Ratio (SDR) that sa0isfies the internal and external pressure design cases using the design values for the flexural and tensile properties for the liner. ,

The StandardDimension Ratio is calculated for a CIPP thickness of 0.450":

SDR = 20.975 0.4-50 = 46.4 (dimensionless)

The design external hydrostatic pressure corresponding to the partially deteriorated C't existing pipe condition is:

0, 2 (7.0),(150,000) _ 0.90 PE-

_((.3)2 - (46.4-1) '2 The design internal hydrostatic pressure corresponding to the fully deteriorated existing pipe condition is:

2 * (1,333) 30.0 PSIG (internal)

C P, = (46.4-2)"2 An internal hydrostatic pressure design case is also considered for (he partially deteriorated existing pipe condition where the existing pipe provides support but has a hole or opening across which the CIPP liner span is not supported by the pipe. For this case, the CIPP is considere! to be a circular flat plate fixed at the edge and subjected to the full internal differential pressure. The maximum diameter hole (d) in the existing pipe for which the flat plate loading case remains applicable is:

d ( 0'450

.875--- 1'8 20."75/

Therefore, the maximum hole diameter for flat plate loading (dMAX) is-(0.450 10.5 dMAx = 20.975

• 1.8320-45) = 5.609"

(~20.875)' 569 cmI i PnAr%1~9!n,

CALCULATION SHEET CALC. t M-1031 REV. I DATE 14-MAY.2003 SHEET 26 OF S?

For the design case, the allowable hole diameter (d) corresponding to an internal pressure of 30 PSIG with flat plate loading is found to be 5.000" as follows:

5.33 20.875 2 1.333 P,=-*1.- ) ' 2

=30PSIG (46.4_1)2 5,000 For smaller hole sizes, the CIPP liner remains within design for higher internal pressures.

The highest design pressure anywhere in the SSW system is 100 PSIG. The allowable hole diameter (d) corresponding to an internal pressure of 100 PSIG with flat plate e*r loading is found to be 2.740" as follows:

)5.33

,* r20.8752)1,3_ =I10PSIG P, (46.4-1)2 (2." 4). 2 The calculations above determine that the appropriate value for the CIPP minimum required wall thickness (rtIrN ) is 0.450", which is then increased by 10% to give the final CIPP nominal design wall thickness:

CZ StNoM = 0.450

• 1.10 = 0,495" The next standard CIPP millimeter (mm) thickness greater than the nominal design wall MD thickness is 13.5 mm:

13.5 mm 25.4 0.531" linchj The percent difference between the 13.5 mm standard CIPP thickness and the minimum required thickness (tbu) is:

( E )0"531)100=+18%

S0.450")

P11 I RflflAR19R

CALCULATION SHEET, CALCM# M-1031 REV. 1 DATE 14-MAY.2003 SHEET 2_ OF, - ,,

Calculation or Design External Pressure Value The design value for external pressure is based on the SSW hydraulic analysis in Calculation M-630 [Ref. 8). The SSW discharge piping downstream of the system RBCCW and TBCCW heat exchangers operates at negative pressure under certain flow conditions due to a "siphon" effect based on the piping elevations and flow rates. The lowest absolute pressure occurs at equivalent piping nodes in Loop "A" and Loop "B" that are at the highest elevation or the discharge piping in the Auxiliary Bfay vault flanges at EL (+)15.6 ft. The limiting case for lowest absolute pressure occurs for emergency operation at the design low tide level. The piping negative pressure is combined with potential external hydrostatic pressure due to a groundwater 5 foot static head to give an equivalent total external pressure acting on the pipe.

,; Atmospheric Pressure = 14.70 PSIA Absolute Pressure @ Node (+)EL 15.6 ft = (-) 6.00 PSIA Convert to External Static Head = (x) 2.31 ft w.g./PS1 Add 5 ft External Groundwater Head = (+) 5.00 ft w.g.

Equivalent Total External Static Head = 25.10 ft w.g.

oConvert to External Pressure = (x) 0.433 PSI/ft w.g.

Equivalent Total External Pressure = 10.90 PSIG o* This confirms the design value given in Specification M-624 for equivalent negative pressure acting on the pipe of -I I PSIG internal pressure. The CIPP liner is designed based on the equivalent external hydrostatic pressure.

P11 I Rf'OA.6197

CALCULATION SHEET CALM. # M-1031 REV. 1 DATE 14-.MAY-2003 SHEET _2-8 OF _ _

CI[PP Pipe Stress Analysts To confirm the adequacy of the CIPP design for all imposed loads and conditions, the following analysis is performed. This additional analysis considers the effects of other sustained and occasional pressure, mechanical, and thermal expansion loads. To perform a rational analysis that explicitly accounts for both primary and secondary stresses and their effects, the methodology used is based on ASME B&PV Code Section TMI (Ref. 6]

Subsections NB-3200 "Design by Analysis" and NB-3650 "Analysis of Piping Products" as shown below.

The following correlations are based on the general relationship that S.V (membrane stress) is equal to the lesser of (25)Sy or (1/3)Su.

0The combination of primary membrane plus bending stress intensity has an allowable stress intensity of I. 55Mas follows:

oPL + PBE-1.5SM,= Sy = 0. 5 SU The combination of primary membrane plus secondary bending and thermal expansion stress intensity has an allowable stress intensity of 3.10S as follows:

PL +PB + 7E :-3 .OSM = 2Sy = Su High strength epoxy compounds do not exhibit a true yield point intheir stress-strain curves. The elongation at break for the epoxy-felt composite being used is 1.5%,. Using the rated short term tensile strength and linear modulus of elasticity, the elongation at break is:

• =- .- ,000 = 0.0133 = 1.33% versus 1.5%aibreak ErS 300,000 This shows that there is very little yielding before reaching the tensile strength, Therefore, the definition that SA, is equal to (113)Su is applicable.

PlLI_Rnd.142R

CALCULATION SHEET CALC. # M-1031 REV. 1 DATE 14-MAY-2003 SHEET  : OF 37 The CIPP liner is encased within the original steel SSW pipe, which remains the structural component of the discharge line. The design calculations above ensure that the CIPP can withstand the internal design pressure hoop stress and the external design pressure buckling loads. There are other loads that may be imposed on the CIPP directly from the structural steel pipe due to the strain (E) experienced from the loads imposed on the steel pipe. These piping strains, i.e., displacements, will then be imposed on the CIPP liner within the steel pipe. To account for all the potential loads, whether their origin be weight, overburden, or seismic, and to use an intensified stress that includes the effects of discontinuities and concentration effects, it will be assumed that the steel pipe is at the yield stress Sy value of 30,000 PSI and calculate the resulting strain:

C" 30000 0 C = = 6

=0.011 ,

ET - 30x40 -inch C The CIPP is then subjected to the same localized strain value, with the resulting stress:

(77 = Er (e)= 300,000(0.o01o) = 3DoPSJ This tensile stress value will be used to account for all imposed loads from the steel pipe 0 to the CIPP whether due to bending or axial loads. This stress is of the type due to a strain-controlled load application, i.e., the steel pipe will be at the strain corresponding to its yield point regardless of the stress in the CIPP. A strain-controlled load has the self-o* limiting characteristic of a secondary stress, and the same value will be used for all imposed loads in the following equations, This tensile stress value will be substituted for the expression in each equation that represents the resultant stress caused by the sustained and occasional mechanical moment loading on the discharge line. The appropriate stress indices will be applied to the pressure and thermal loading terms but the above tensile stress (F.-) will be used directly in all cases for the mechanical moment loading term since it includes stress intensification effects.

pill Ri fnn~lt >_

CALCULATION SHEET CALC. # M-1031 REV. I DATE 14.MAY.2003 SHEET _ _10 OF 7_ _

The primary stress intensity is evaluated at design conditions. for pressure and bending loads as follows:

BrAP ... ),B,(2Q-21 IM.e * .5 STL Q

',2tNOM where: B, = 0.5 30 0 PSI B2(j*QMi = *0T substituting:

C.

D.5(30"*2D75 300 !9 0.5(1,333) 22-0.495 )

616 5 667PI .P.OK 0

t.7The B1 and B., stress indices in the above case are applicable to both straight pipe sections and elbows.

+- The primary plus secondary stress intensity is evaluated for the maximum range of pressure, temperature, and bending moment that can occur as the system goes from one load set to any other load set that may follow it in time. This maximum range is analyzed as follows:

• + 2 + ( 'fr

• ST EQ io where: PyAX = 9.0 PSI Max Pressure Range This is the maximum operatingpressure rangefrom the SSW hydraulic analysis fRef. 87 occurringas either a -9.0 PSIG ro zero at the dischargepipe inlet orzero to +9.0 PSIG at the dischargepipe outlet end.

I*II I P*h zlAfln

pII I P* llAflA"4 CALCULATION SHEET CALC. # M-1031 REV. 1 DATE 14.MAY.2003 SHEET 32- OF:

For this type of secondary stress range analysis, this is not an unacceptable result but requires that further analysis of the particular load case be performed as follows:

I The primary stress case (EQ 9) is satisfactory, this confirms that gross failure will not e, occur since the secondary stresses are self-limiting, i.e., the loads imposed from the steel pipe to the CIPP (second term in EQ 10) act as a strain-controlled secondary stress within the CIPP that cannot cause failure. However, distortion and thermal ratchetina must also be considered (below) when EQ 10 exceeds the allowable.

2. The thermal expansion stress alone (third term in EQ 10), as calculated below, is within an allowable stress of 2/ 3 (Su). Therefore, thermal stress ratcheting will not occur from thermal stress alone, and the bending stresses that are superimposed upon this stress (second term in EQ 10) to exceed the criteria are due to occasional loads representative of the faulted case seismic loads.

3. Any distortion that does occur from the worst case loading combination would be localized at the elbow and would be self-relieving.

4. This primary and secondary stress intensity range equation maximizes the stress intensity (i.e., twice the maximum shear stress) by combining the pressure stress in o the hoop direction, which is a either a tensile or compressive stress, with the longitudinal stresses. A Mohr's circle diagram analysis on the following pages shows the worst case stress combination where the longitudinal stresses are also in tension Cand the stress intensity is maximized.

Thermal expansion stress evaluated separately:

= C3 a(AT) :< V3 )STLE 1 substituting:

4.0(300, 0)(4.0XPIO-)(loo-3o)

_ . (Y){1,333) 840 S 839PSI .1. ox 011I 1 DnnfAC4'>,

CALCULATION SHEET CALC. # M-1 031-REV. 1 DATE 14.MAY-2003 SHEET 3 ..... OF 1?__

Evaluate Maximum Primary & Secondary Stress Intensity (Mohr's Circle Analysis):

The stress intensity equation has three components in this application as follows:

1. Pressure stress range in the hoop direction for max/min operating pressures.

2. Longitudinal bending stress range, this is taken to be the maximum stress that can be created in the CIPP due to the steel pipe stress range being equal to the yield stress due to all the combined sustained and occasional loads acting on the steel pipe, including faulted case'seismic loads.

N', 3. Longitudinal restrained thermal expansion stress range. The worst case for the CIPP is the restrained contraction that occurs where the temperature change is the design range of 1001F decreasing to 30°F. Since the CIIP is cured at greater than IO0F and is maintained in a state of conformance to the original pipe ID at IO0F prior to oreleasing the curing hydrostatic pressure and temperature, there is no case where restrained thermal expansion will create greater stress than the restrained thermal contraction load case combination.

The Mohr's circle analyses of these load cases is as shown on the following page. It is seen that the maximum possible load combination value of 1,368 PSI requires the O* longitudinal stresses to be tensile with hoop stress simultaneously compressive. For this CIPP installation, this corresponds to a thermal expansion stress due to restraint of thermal contraction (tensile stress) together with the negative pressure case.

It is concluded that the CIPP stress analysis is acceptable, based on the considerations above, and that the CIPP installation will operate within allowable stress limits.

DII I CD' ACt4'Y1,

CALCULATION SHEET CALC.# M-1031 REV. I DATE 14-MAY-2003 SHEET OF O__" :37 MOHR'S CIRCLE ANALYSIS PRIMARY + SECONDARY STRESS INTENSITY RANGE STRAIGHT PIPE CASE This analysis shows that the code stress equation is a worst case load combination that applies for the case where the maximum thermal expansion stress is in the tension direction and hoop stress - MAX STRESS is compressive as shown in Case #1 below versus the Case #2 INTENSITY CIRCLE combination with thermal compression that will not occur.

CASE #1 1190 t L r L i & I

• 1140 f

-I-- I3 C7 Gp HOOP z (-)190 PSI 0; LONG = 0 PSi GT BENDING (+)300 PSI 4=. a0 THERMAL (+)840 PSI MAX STRESS INTENSITY RANGE = 190 + 1140 = 1330 PSI C)

CASE #2 +~19D

-114C0 1 I( 190 I

I I

-, J, L , q [

Ia 1140 I 111ý2 Op HOOP= (+)190 PSI GFp LONG = (+)95 PSI OR 0 PSi 0

IT BENDING = (-)300 PSI CY THERMAL= (-)840 PSI MAX STRESS INTENSITY RANGE = 1140 + 190 = 1330 PSI DII I DfPlfAd4"A

CALCULATION SHEET CALC.# M-1031 REV. 1 DATE 14.MAY-2003 SHEET _ .5r OF J-7 mr)IJFV-ý-CIRCLE ANALYSIS Ic-finuedl PRIMARY + SECONDARY STRESS INTENSITY RANGE PIPE ELBOW CASE (C, = 1.2)

This analysz-i shows that the code stress eqution is a worst case load combination that applies or the case where the maximum thermal expansion stress is in the tension direction and hoop stress Iscompressive as shown In Case #3 below versus the Case #4 combination with thermal compression that will not occur.

IINTENSITV CIRCLE M.AMXSTRESS 228 CASE 3 7 C%.

1 I,

i i 1 I

~ I x[(28 T I l I C:

i IT ac ap HOOP = 1.2 X 190 = (-)228 PSI Up LONG = 0 PSI aT BENDING = (+)300 PSI GE THERMAL =.(+)840 PSi MAX STRESS INTENSITY RANGE 228+ 1140 = 1368 PSI

-1T C0 CASE #4 D[I/

11I4 I > 2281 I I I I I a

) I Op HOOP = 1.2 x 190 = (.t-)228 PSI a'p LONG = (+)114 PSI OR 0 PSI Or BENDING = (-)300 PSI YETHERMAL = (-)840 PSI MAX STRESS INTENSITY RANGE = 1140 + 228 = 1368 PSI DII I DnfflA9,Ir

CALCULATION SHEET CALC. # -M-1031 REV. 1 DATE 14-MAY-2003 SHEET - OF F. References

1. PNPS Specification M-624 "Specification for Cured-In-Place-Pipe (CIPP) Lining for SSW Discharge Piping" 2, Piping Isometric Drawing MIOO-7253 Buried Discharge Piping Salt Service Water "A"'Loop

3. Piping Isometric Drawing MI00-7255 Buried Discharge Piping Salt Service Water "B"Loop

4. CGI-860 "SSW Cured-In-Place-Pipe (CIPP) per Specification M-624" c 5. ASTM F1216 "Standard Practice for Rehabilitation of Existing Pipelines and Conduits by the Inversion and Curing of a Resin-Impregnated Tube"

6. ASME Boiler and Pressure Vessel Code - Section III "Rules for Construction of Nuclear Power Plant Components", 1986 Edition.

0 7. PNPS Specification M-300 "Piping" S. PNPS Calculation M-630 Rev. 3 "SSW System Hydraulic Analysis"

9. PNPS Calculation M-976 Rev. 0 "Buried Piping Evaluation Salt Service Water Discharge Piping"

10. Shell EPON Resin Systems for Pipe Rehabilitation Information (see attached) 1I. AOC Vipel L704-Series Polyester Resin Product Information (see attached)

12. Belzona 1311 Product Specification Sheet (see attached)

13. PDC 01-09 "SSW Discharge Piping Cured-In-Place-Pipe (CIPP) Lining"

14. FRN 01-09-02 "SSW CIPP Liner Epoxy Repair"

15. FRN 01.-09-04 "SSW CIPP Liner Stress Relieving Process"

16. FRN 01-09-06 "SSW Loop "A" CIPP Liner"

17. NCR 01-038 Nonconformance Report - Loop-B Liner Separated in Three Locations

18. NCR 0 1-048 Nonconformance Report - Loop-B Material Test Results

19. NCR 03-027 Nonconformance Report - Loop-A Liner Thickness Readings

20. NCR 03-039 Nonconformance Report - Loop-A Material Test Results

21. CGI-861 "Belzona 1311 Ceramic R-Metal" 1ii I I*n*'lfrI4.

CALCULAT16N SHEET CALC. # M-1031 REV. I DATE 14.MAY-2003 SHEET 3_ OF 37

22. ASTMV Standard D638 "Standard Test Method for Tensile Properties of Plastics"

23. ASTM Standard D790 "Standard Test Methods for Flexural Properties of Unreinforced and Reinforced Plastics and Electrical Insulating Materials"

24. CR-PNP-2001-02301 "Prior to installation of the: SSW Cured In Place Pipe liner, the mixed resin/curing agent prematurely reacted due to the high ambient temperature."

G. List of Attach me nts; Attachment I = Shell EPON Resin Systems for Pipe Rehabilitation Information Attachment 2 = Test Results for Loop-B CIPP Installed in RFO-13 Attachment 3 = AOC Vipel L704-Series Polyester Resin Product Information Attachment 4 = Belzona 2311 Product Specification Sheet C

Attachment 5 = Test Results for Loop-A CIWP Installed in RFO-14 Attachment 6 = Independent Verification Statement Record 0

pII I P*AAA4'l7

CALCM-1031 RSvOf

• ,* 9Attachment "

Page .'--f I' '.P._ -f SHELL EPONO RESIN SYSTEMS FOR PIPE REHABILITATIOH We recommend the use of one of the six Shell EP"N Resin/EPOH CURING AGENTO systems for the repair of pipe In place. Each aF these systems has been designed to do a specific job and provide long term -

integrity and durability. A brief guide to selecting the right system is given below, EPON' Resin @210 1 EPON CURING AGENT* 8270 This system is designed to rehabilitate pipes carrying potable water at temperatures up to about 30" C. This system provides a tough, flexible barrier to inhibit corrosion and is recommended for repairing pipe with minor leaks. The maximum operating pressure depends on the ýize of cracks and condition of the original pipe.

While the system can easily span small cracks, it tends to creep and Is not suitable as a long term 'stand alone' pipe under pressure. The use of KEVLARG reinforcement with this system greatly improves its CV. ability to withstand pressure.

-- EPOH Resin 9215 & EPON CURING AGENT 927O

'C This system is designed for general purpose use at temperatures up to about 50" C and Is very similar to the EPON 9210/9270 system.

It provides a tough, flexible barrier which inhibits corrosion and is recommend for repairing pipe with minor leaks. It is resistant to hydrocarbons and caustics. The maximum operating pressure depends on the size of cracks and condition of the original pipe. While the system can easily span small cracks, it tends to c-rep and is not suitable as a long term 'stand alone" pipe under pressure. The use of KEYLAR reinforcement with this system greatly improves its ability to o withstand pressure.

Il., EPON Resin 9215 1 EPON CURING AGENT 9264 0 The resin and curing agent mix of this system haz a long vorking life of all of 17 hours1.967593e-4 days <br />0.00472 hours <br />2.810847e-5 weeks <br />6.4685e-6 months <br />. It is recommended for repairs where a 'stand

- alone' pipe is needed with long term physical integrity, durability and resistance to chemical attack. The system exhibits low creep and can be used to repair pipe where large sections of the otld pipe are missing. Pipe prepared with this system is resistant to acids, bases and hydrocarbon solvents and can operate incontinuous service at temperatures of up to 65' C.

Pil i P1*lARd.*AR

GALC M-1 031 Rev 01 Attachment I Page 2- of S" EPON Rosin 9215 & EPON CURVIG AGENT g926 The properties of this system are very similar to that of the" EPON 9215/9264 System. The resin and curing agent mix is designed be less sensitive to water and to begin curing at a lower temperature, to thus producing better laminates in the presence of water. This is also recommendad for repairs where a 'stand alone' pipe is system needed with long term physical integrity, durability and resistance to chemical attack. The system exhibits low creep and can be used repair pipe where large sections'of the old pipe are missing. Pipe to prepared with this system is resistant to acids, bases and hydrocarbon solvents and can operate in continuous service at temperatures of up to 65" C.

EPO ResiS 9220 I EPON CURING AGENT 9264 This is the newest addition to our family of pipe repair systems, hence, not all of the data is available for this system which you will find for other systems In this brochure, This system was designed especially for making thick walled Insitupipea, i.e., Ismhn or thicker, Desirable features viscosity to speed wetout and the longest working Wife ofare low any of our systems - 19 hours2.199074e-4 days <br />0.00528 hours <br />3.141534e-5 weeks <br />7.2295e-6 months <br />. It is recommended for repairs where alone" pipe is needed with long term physical integrity, a 'stand durability and resistance to chemical attack. The system exhibits low creep can he used to repair pipe where large sections of the old pipe and are missing. Pipe prepared with this system is resistant to acids, and hydrocarbon solvents and can operate in continuous service bases at W temperatures of up to 65' C.

0 EPON Resin 9225 A-EPOI CURING AGENT 9290 Pipe prepared with this system can operate in continuous service at temperatures up to 90." C. This system produces pipe with low creep 0 giving long term physical integrity and the ability to operate stand alone pipe. This system also exhibits the as a best resistance to attack by acids, bases and solvents compared to the other EPON Resin systems.

TYPES OF CURING AGENTS .AND CROSSLINKING REACTIONS The EPON CURING AGENT 9270 is a proprietary mixtures of amines.

These amines undergo addition polymerization with epoxy resin resulting in a three dimensional, insoluble, infusible, crosslinked polymer network. The molecular structure of the polymer network formed Is composed of about 30% of the curing agents.

The EPON CURING AGENTS 9264, 9269 and 9290 are proprietary mixtures of amines which causes the epoxy resin to undergo catalytic homopolymerization resulting in a three dimensional, insoluble, infusible, crosslinked Polymer network. The molecular structure of the polymer network formed is composed of less that 10% of the curing agents.

Pll I nlflnAnInq

I n 1 o 8 0 b i~ ~i u I WIN*1 I Em YTall MING IIt 9215(9210 9201Ip269 922919264 9221J9290 CUSTI1 T"3silo Stm1xbig,?31 7,540 1,SOIt 9,080 TAa 51.7 69.10 8.425 i,009 51.1 42.1 TebsliW modulm, psi 450,110 55.2 106.9000 415.909 929,000 4*0,00 Tiaile I~a 2,798 2,661 2,999 2,96% 3,409 IT'tle aloa*uaton. 1 1!.5 3,101 11.5 3.0 4.8 4.2 plegura! at.t*th, psi 12,6m0 12.6w0 19.000 15,600 I5,4"0 86.9 1241 101.6 106.2

'ltm'al *ultz, pSI 113,000 120.1 490.800 300,05D Nh7 2161 2999 3319 3489 304?

Bemt derlectleo, 4mgC so Cl0ss transition, dog C so £9 93 lot is) 120 Ila 143

?"sIlls StcugtL, pls 5,100 5,100 5, 00 5,z00 69a0 a

ei 35.z 35.2 if.5 5,049 Tensile IvalfUSo psa 390,1a 35.9 47.6 34.5 2689

.u)0 tensi longPtig, 1 2.3 1.5 3313 3*4 >

Flexural Stregth. Psi 1o..300 IM~A 1L.0 rtekaral pdulms, psi 4VP,0O9 2.3 10,300 421.00 41192 1.5 6,000 55.2 9,39D 54.1 1.5 9,500 g4 "ia ,1900 3g1190 415.50D 532,000e 219 U196 *3005 490. Doe 3215 3311

1 0300 a 6 I*1 C 3ZLL Mims1Kin CUMIHXE RIS FOR1tSIVJ milr M71ia 920jfl uImSR52Q AMINI EMUSIN9219 mtsu nim LCDR 9215M692 9220192M "/O Patable water I Tick failed Pipe 2I Tabibit Congsloa r II I x Se.l PIbol,,e I I II I it SeL laiger Main I I pnt~wza Sy~tw I I I K I

SlaI 110M Plip I II I thnical Raistajce K

-*I. Seavice Teqerattne 30 deg. C 30 deg. c 65 4d8. C £5 Isdeg. C 90 dagc vadinq Life. Ent, viol 2.1 I?

srstm. I gkl 0 2Im 2.3 0.5 19 1.

2hr 6oC 3 et 1c 3lhr f oc 3 hr 76C I hr # "c I 3 -t 0c I hr @s c I . hrefor I br Itoc I hrelo c 2 br 0 a c

4. hr I R c C)

-U >

w io~

a..-

-  ! 0 3 00 061*6 I R DmusmI WSI alic uma cmTwmUN 92139g6 ro922Mq5 swim929 OwV. (IFIM"S1*(

11114.; CT100-5 in to Sod c 3.2 1.3 5.il 6.

10 to 75 dog C B.

s-B so to ?Ga" c 1! ,

715to 95 ft; C S2*3 M C Dis?. Vila U R I a 3 p

I 3 It 201 SI1IMC ID I 20at 1 ICJ*O 01 It U*

It 3 201 S*]*iW I*=13. R

,n IR 3 U B0 UN it 3 iU 3 I to=m fl-ICUSl 5TAt!

"iOr1npil mtII M1 R Gm VOL aI 0

- =r

'a':3

• I i'Jurz-al!

DII I Dnnra4A'l

M.

CALC M-1031 Rev 0i Attachment z-.

Page 2 of -T h"

ASubstdlfly of THE MMR GROUP. INC.

Massachusetts Materials Rescarcl, Inc. TEL 505.835.-2.2

• FAX508-835.9025 P. BOX 810

• 2AI W!S3TBOV1STMNSTREFT - WEST BULSOy N, MA OI5831 DATE: May 2,2001 P.O. NO.:

MMR NO.: F4-23 ATrENTION: .MMR ID it:

PAGE M: 2 SAMPLE rDENTrFICATION:

C Fle*urai Test Results I Test No.No1p I Sample Width D-epth in.

Span in.

[b. Leoad Stress psi jTangent sioduls 1Remark M Ii I B-OutI .57 .530 9B 113 14219 1384.000 2 1B-o-2 1.565 -570 8s 1 125 ,4087 1371,965 0P 3

_ _ B-Out 3 1,530 1 .550 8 t 113 14212 1370.909 1 M 4 1B-INI 1.560 1.575 18 T169 15469 1410,566

-I! 5 1B.IN2 1.573 .590 8 7 -175 15263 1371.9651 6 1B-IN_3 1.0 1sO

.580 8 1175 16.1.2 1439,5951 MASSACHUSErrS MATERIAlS RESEARCH, INC.

Rocbafi C.

Streeno Manger of Fatigue and Simulated Service Testing The results replned above apply only to the ten samples(s) provided. We believe the above t=s to be reliable and correct.

Inaccuradas or rars, if the oecur, will be corrected free of charge. Inno event shall Massachuseus Materials Res , Inc.

be liable for any spedga omuseu tial or odher damages. The above es-ting was conducted in eccordanc- with aMR's Qullry Control Manual, Revision #ISAdated 31 August, and your purchase order requirentaa. This enuslal Is eontrolled under She United Stats Nuclear Ragujatory Commission Rules and R-'hqAdwr Title . Chapte I, Code of Fedeml

-Energy, Parn #21.

aquItiorts mi1I D*fllAr4AA

CALC M-1031 Rav 01 Attachment ..2_

Page _j_ of_5

1. IV V D

! U U.,.A GROUP. INI.

ASubliftry of THE MMR Massachusctts MatErials Rcscachlt, Inc.

P0, BOX810 - 241 WESTSBYL.MN STREET- WESTBOYLSI.5N, MA01583 *TEL. 501.835.4282 - FAX5084354025 DATE: May 2,2001 P.O. NO.;

HJMR NO.: F4.23 ATTENTION: MNIR ID #-

PAGE #: 3 O' SAMPLE IDEN*IFICATION:

A Belzona kit was received, mixed per the enclosed instructions and spread onto a flat plat treated with a release compound. The sample was put into an enviromental ehambe: set at 85 C* degzres F. for 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> to cure. Flexural and tensile samples were then rough cut and machined from the cured BeIzona and tested per ASTM D 790 and D 638,the test results ae listed in the following tables.

Belzona 1311, cerantic P-Material Tensile Test results Test No. Sample W idth in. Depoth Area sq I Ultimate Ultimate Remarks 1 Type In. in. I Load lb. Sutss psi I l aezn 1,689 1.377 .2598 11538 1:5921 i C 2 (.0712 1.430

.3062 _ 193. 16320 I 133 1 ( 1 j -339 1.2403 1130 4702 All three specimens broke u voidsin the mattriaL Belzona 1311, ceramic R-Material Flexurol Streneh Tests Results 0

Test no. Material Width Deepth Span Load Stress Tange*nt I Rer-rk I in. in. in. lb. psi modulus I Belzona .501 .387 6 iB0 10,795 1.67 'd I - - -si 2 2 .507 1.375 6 125 l7890 psi 1.68'6 MASSACHUSEMTT MATEIIALS RESEARCIL INC, Manager of Fatigue and Sitmnuated Service Testing kteresalts reporm'e above apply only to the test unples) provided. We believe the above test to bereliable atd cient.

Ilccunracis ot eff Mtithe

, o=cwr,wM1l be coectcad free of charge. Inno event Mhall MNassacut Materiuls Research. Inc.

be liable for my spedal, consequenual or uther damages. 'To above testignwas conducited in ace:ordanee with MMR'e Quality Contrtl Manual, RePidon ItSA, dated 31 Aurast, end your parchasa order requiranenu. This matearal is controlled under the ti.hed SlatzeNuclear Regulatory Commtni.sion Rules and Retlations, Thle , C*apler 1, Code of Federal Regulotions-EaergyPW #21, oII i IfPISIAr4A

CALC-M-1031 Rev of Attachmenl 2-Page 4- ot r ASTK D III

~ns 11SH 21iPiI?11S Of PLASTICS ASTN biTl ITYi III) 1t1ttra CorpMe1OS rest tye; Tensije Series I 44toeaated Naterii*i Te~SLng Syltel IS,0 Operate: c*me: 1.PKOUANGSAVANE feat Date: 01 May 2001 Saspbe Identiiicatioa: F21-M?1 sample Type: ASTK Interface type: 42/43/4100 Series KacbiaeePa~iltL~5 of test:

asoplE late 19tolee*/1eC 0-00 Be'dity f t., 3 : 50 Chashead Speed fial/ig .2090 Teupcrature (deg. ?1-.71 pizensims; Epec, I Spec. 2 Spec. 1 S

Wio:w {ist .5010 .74400 17MO0

.46600 .4100 spe: gauge lee [ig) 2.9000 2,0000 2,0090 4.5000 115M 4.5000 Grip distance: (inl oatofI I specious, 0 excludeS.

Saephe;Cuetia; LOOF a Is feTeile Zongebies M, spec*me lOLL DI1.

... oo...... I......... ,..... ............ ........

I ]36H. 9.950 2 3663. 2.050 3 list, 12,300 3629. 11.430 Standard Devi*ctin: 51. 1.251 minicull 9.950 Ntriuus:, 3663. 12.300

- . -~ ---- a * ... flfl# ~a=~ . - ---- -- . .a ,....A AWfl mi i PnmrlA4A9

CALC M-i 031 Rev Of Attachment 2.

Page -E. 0r FZUVALU VROIwflIIU OF PA22~L Ag. 79,0 ILV, T OCPM. f' 4

ThnkrM, Crpam&1 00 P 3=,mp-Lna, kw I BI.C Toot UartG. 03 Wil 192 FU"*iOt. rko.

SlpwL rip- I I$

sa0oplo Race (pta/lecl 0.0 ljuMi~ranq C d: L CMxdhol~d Spood (lN/on I-- Moo0 71 I/L=lr:Jwl.L*,*w*

8P. t i p*c. 2 5pee. "

• 1k) (LI&.l. .5)500 .$-$sod .62.106

.64900 .49900 .41100 0 1pal. (Wn S.Ondofi .na00 4.2000 000 ot 'j spectiarns. 0 .xeu4wd.

UYhI- C.0 lom*0C LCOP 'N IV Misy1cment B;'10 W-4~ aL-sp "C~allus Ca at at 1: a2 of Clubor LUnI fi10/l W'.1 4poll jpa.)

. .29C .9200 $1.4 6311.7 2GLCGI

.2721 .023" b7.1 4iC. 31S9I0 423S3 .013) 07,3 ~ 441.2 7463Jq X.I: .2rus .0204 a3.4 61125.b J373195.

Davsr.lofl .0391 .0014 2.3 96.1 19040.

Ktillcum, .2239 .010; 01.4 6116.7 32bsou.

Komi.t".J .2721 ,0213 &1.& 5601.2 25110.

P11 I R*Af.Rl47

CALC M-1'031 Rev 1 Attachment ..

ADE, Ifobil Leiader /a Basin Technriogy YipelTML704-AAP Series Polyester Resin Product.Ifformation Vipel*" Isophthalic Based Resin for Underground Sewer Pipe Liners C,;

Nominal Test Method C Viscoaity 6 77'F/2'CRVFBwookfleld Spindle #4 ' 2DRPNI. cps. 5'a00D QI-003 ThLixnd!ex2.3O 4 Color OpiqtI Of.OO5 1.1 Non.'/olkatic bESSrnPl-ION

- GriTine@iii4'Fiwigh risc VipW L704-AAP Series Isa high~

I olocularweigh5 isophthlcleunsaturated peruxydicarbortai and O.S5Yo polycslvrrcsin. Vlpelr"~L7D4-AAr Secicý Trisonox'42S),nilnui". 12 provides the corrosion resistance, duma.

Pat Li~cCn@ 771F'2S'C billyv fnd tughsness thm. is requiredi ror 0n (I % Di.(4-tcn-butyl-cyclahcxsyI) curid in~ place pipe applications. kcfcr to peroxyslicarbonosc and '-0.5% tse AOC Ccrrosion ResistantsRcsin Trigoncx*42s).Ifours 4S Q02.6 Guide for corrohioun rcsistancc Isironns.

(ion listed usnder F70 i. A tyvpicalresins in Tri.-onox isa trademark. otAkzo Nobel Chemsieals thslsierics isVpclT"L704-AAP- 12, FEA'rsjt9!ls 0 E.'celgensswsllveed poslite Tensile Strength, PSEIMPa 13.S50"M. ASTMD-633 0 Superior mcchanical propenies Tensile; Modulus' PSIIGP4 600,OM4.1 ASTMD-639 II Excellens wei-out propenlies Tensile Elonsgation, % 3.0 ASTNID-633 Flexural Strength, ISiMPI' 23.30W1161 ASTM D-7901 II Excellent cusringproperties 5

FlexuralModlulus. PSIIQPa 630.OOOM.3 ASTM D-7J0 lieas Distortion Temperature,

'FIC4'264psi 212/IIXI ASTIvD.6-18 BEN BPTS Barcol Hardness 40 ASTMIA3*358 Ac~p?.bIlltV 5

AQC'S VipcP ' L704-AAP Series molecular archiisecture provides an cxcellcmn balance or corrosion and phy~sicanl psoponisiea PHl I RnnAA.R4-R

CALO M-1031 Rev I Attachment 3 Page 2 of 4 Zn-Warid Leader intR1,i Thw'hitttl/o ASTM F1 216 TEST RESULTS ON L704 6 mm Applied Felt ONE MONTH RESULTS AT 77°F hIflh.J U LSC.IVLC' L.704

______________________________t I ~ ~

REQU MENTS I

PASS Olt FAI LAL. STREN0TH. mi 9.544 I

) DEVIATION i IODULUS. *si # 5 u

_w r t ,,

STAIDARD DEVIATION:

-I PAS TAP WATER 10.915 432

% FLEXURALS IDo 563.496 10.993 Jd * *q*

• r STANDARD Kh*gM 9 PP V DENv - 0 - -A PASS dU k *V* ..........

j', >30 5% NITRIC ACED 10.6 .72 4 II_______ _

& 0 >SO. PASS

% FLEXUAL I-STANDARD DEVIATION

- MODULUS RETENTION F o 1

-i{

10% PHOSPHORIC ACID 1.439 C) "In rA~ -

7. rL-Auj3..pj z I IDD 552.54-98 rA~

P.L*.,x. U ,%PL*J PASS

~MA. cur ~n~vr AI'T~

10% SULFURIC ACED ~STI!FT FTW!C

%FLEXURAL S' FLEXVRAL.

STANDARD DEVI vsi RETENTION > _0 I ePASS ST70

%. FLEXtJARAL. MOE >80 - PASS

% P"*EX'UARAL, MOE I.-

0*7 127B m 5l SY 97 >80 PASS FLEXUxk- 567.331 4.-62 950 HIGHWAY 57 EAST "COLLIUEAILLE, TENNESSEE 38017 - 00118&4-2800

• 9011854.1183 FAX

• wý.woc.trealftn.C PILLRO046149

CALC M-1o0i Revi1 Attachment Page 2 of

% FL.EKURAL MOD9ULUS RETMC17O 100w PASS WCKZGTA.BLILOIL ______ _____

FLEXURAL STROWMPs 11.t09 _ _ _ _ _

-S'ANDARD DEVIATQIN 2.484 ___________________

%n&2MRA ýsThEI4flmp RETEK~mo" lo >80 PASS FLEXUWRAL MODULUS. Eg 549.S55______

STANIDARD DE"'ATMO 27-735

% 9LEXAPAZ MODULUM RE1MEMI1Q 91 8 PS 0.1% DETRGiN-T FLEXURAL STRENOH. 1 STANDARD DEVIA77ON ___-7__ ____2_

% OLXUFLSRENG-hpo REMMNION as ;g PASS 7:7 FLEXUýA MoDULtuS, O 51 12$44 STANDARD DEvIATow 15.537

% FLEXUAPLAL MOCDLUS MEENTION 91 >W WS FL EXUAL sptERGEL Pi 1175Lfu_____

STAN DARD DEVLTION 3M- _______ _______

%FLEXURAL. STMlENGV pdr~i RETEfON too ~ 'S PAWS FLEXCURL MODULUS. 54945 _______1 ________

STANDARD DEVIATION 1119 ____ ____

%FLEXURAL MODULUS RETENUON1 97 ________________

ApUl 1. 1999 C)

Mwbyswcr1 g Lbeprb&~sdmomWhorai spon t barspwaloaus twom Jtoo MyskHo bbMw 5 t ow rc.U&&ogu fh.u alb ~

4awsbddd. vjfem saiiot w r~ohSY sa lw. -fay cdow ivmwrnjmk.

PILLROO46150

ALC MI031 ReV1i.

Attachrnent*_2_

Page -+- of A-.

AOC.

Worfd Leadwr rn Resim Technoogy February 28, 2001 ASTM D696-98 mI Coefficient of Linear Thermal Expansion of L-704 Series in a clear casting.

C%,

.0O 0 The samples were scanned from 20'C to 100'C at 1OC per minute. The COE was evaluated from 25'C to 80'C.

Sample COE (250 to 8000 0: L704 Series 60.45 e-06 PC (mrnm/rn/°C) 61.11 e-06 / C (mrnr/n/m/C) 6-2.28 e-06 /1C(mmmmm]0C*

61.28 e-06 / OC (mm/mm/°C) Average PILLROO46151

CALC M-1 031 ReV :I' Attachment +-

• Page i of "2.

PRODUCT SPECIFICATION Re'* .lZ World leaders In the conservation of man-made resources end the environment . SHEET BELZONA0 1311

1. PRODUCT NAME' Sofidifier Comoonetl results In a more highly cross-linked BSELZONA0 1311 Appearance Paste polymer. For enhanced performance ti*s (Ceramic R.-MeIl) Color Gray materiel may be post-cured by heating to Repair system designed for rebuilding Gel strength 2 121F (1001C) for a period of up to 24 metals damaged by erosion-corrosion, at 77'F (25,C) 70- IS0 g/cnr OY hours. This should be carried out Density 1,63 - 1.69 glcrm fotiwolng an initial cure period of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> at ambient temperature.

2. MANUFACTURER Miled Pratenies Belzona Inc., Mixing Ratio by Weight America's Gateway Park, IM Abrasion Resistance:

(Base: Solidifter) 5:1 2000 N.W. 88th Court Mixing Ratio by Volume Taber Miami, Florida 33172 (Base: Sotldiflari 3:1 The Tabor abrasion resistance wtlh I kg Balzona Polymeorcs Ltd., Mixed Form Plate load Is lypleally, Claro Road, Peak Exotherm H110 Wilteels (Wet) 129 mm' Hatrogate. North Yorlushire Temperature 239 -20'F cS17 Wheels (Dry) 48 ran HGI- 4AY, Erglan.d. (115- 140-C) toespar 1000 cycles Time to Peak E-xotharm 25. 42 mins.

3. PRODUCT DESCRIPTION Slump Resistance , ill at O3 Adhesion.

CN A*,*o-comonent, non-machinable grade 0.5 inch Tenesle Shear ma:erial based on a atticon-sleel alloy (1.27 cm) When lasted inaccordance with ASTM blended within high molecular weight Mixed Density 2.36.Z-52 gacnr D1C02, using degreased substrates which reac'Jie polymers and oligomers. tne have usen grit blastec to a=ý14 miltprofile.

system Isdesignat for rebuilding metals 0 Shelf Life: typical values will be, an: offers protecton against the effects of MIldsitel 2,700 psi (19SOkga/cri) eroslon-corroeion. Ideally sulled to be Sepauate base and ealidlfier comnponems shall have a 5 yea*rshelt ilaewhen mored Brass 2,270 psI (15O kgslcrr) vvercoated withl Batzonag 1321 (Ca. Copper 2.200 PSl (155 kglcfrr) mmic S-Meta4, between 32F (01C) and B69F (30`C).

Stainless steel 2,800 pil (196 kgslcm')

I Working Life: Alurninium 2,000 PsI (140 kgslc'rr]

C Centrifugal and turbine pumps. Will vary according to ,emperature.

Heat exchan;ers. water box enoc, At 77-F (25-} tire usable life Of mixed O Chemical Rasistance:

di.ision bars and tube sheets. material is 15 minzes. Once fully cured, the material will demon.

Butterfly and gate valves, strata excellent resistance to the following Propellers. C3 Volume Capacity: chemicals; C Kor nozzJes. carbonic aold The volume capacity of a 1 kg. unit of Bow Ihrusters. mixed tSlzonal 1311 Ia25,2 in.' 10". hydrobromle acid Pike elbows. (413 =j'. 10% hydrochloric acid T-pleces. 10% nitrtc acid 20% nitroeu acid 0 Cure Time: 5% phosphoric acld

4. TECHNICAL DATA Allow to solidity for the times shown Inthe 10% eulfuric acid Base Commone chart below before uub-ecting It to the 20% ammonia solution Appearance Paste cndllhonrs Indicated, time water Color Very dark gray 20% potassium hydroxide Get strangih S. PHYSICAL / MECHANICAL 20% sodium hydroxide at 77"F (25'C 150 - 350 g/kr HF Density 2. - 2.8 gl/rim PROPERTIES propanof Determined after 7 days cure at 7"F butanol (25'C). Post cuting the material with heat ethylene glycol dlsthanolamane Co~nnuead...

CURETIMES TEMPERATURE 41IF (5VC) 50F (150' V J 51 15'0) 68'r (20MC) 7"'F (2S'C) Bb'F (30IW)

Movement or uee Involving; no loading or immersion 4 hrs 3 htS 2114 hrs 1314hrs 1 hr 3/4 hr Machlningand/or lightloeding 6 his 4 hrs 3 hrs 2 hrs 1112hrs I It Full electrical, mechanical or thermal loading 4 deye 2 days t1/2 day 1day 20 hrs 16 hm Immersuon in chemicals 5 days 4 days 3 days 2 days 1112days 1 day PILLRO046152

CALO M-1 031'Rev 1.

Attachment._..

Page .9L of .2 methylamlne (25% In water) Q Hardness~: 8. WARRANTY hydrocarbons Theahardnests of themateriatl wehen toned Balzons guararleas t&s product wllf mineral ol1s to ASTM 0785 is typically Roch',,ll Pit04. meal tMeperformance olalms astiled Inorgenio salts herein when material lIstored ard used For a more detailed deSdripflon of as ins'tucted In ths Betzonae Instructlons chemical reMsIfenoe propeftles, rn/ar O Heat Distortion Temperature: for Use lealet. Betzonne further guarsn.

to Producl Dale M501. Tested to AZTM 0648 (264 psi fiber stress), typical values obtained will be toes that all its products are carefully Manuftacturad to ensure the highest 136'F (58'C).

0 Compressive Strength: quatiy possible and tested strictly in When tested in accordance with ASTM accordance with universally recognised 069S, typical values obtained iltlbe u Heat Resistance: stardards (ASTM, ANSI, 1S. DIN, etc.).

13,000 psi (914 kgs/cm),.

For many typical applications, the product Since Bnazrona has no control avar the is thermally stable to 450tF (20(GC) dry use of the prowuct described heroin, no and 1401F(G0'C) wet. warranty tar any application can be given, U Corrosion Resistance:

Once fully cured, will Show no visible 0 Impact Strength: 9. TECHNICAL SERVICES signs of corrosion aher 5,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> Reverse no.c.led impact Slrengtn is C=rnplete technical assistance is available exposure Inthe ASTM E117-73 salt spray typically 0.93 fr.lo.ton. of 50 JIM. and includes fully trained Technical cabinet. Consultants, technical service personnel 2112fully staffed research. development O ElectricalProperties: o Shrinkage; ard quality control laboratories.

N" Dielectrl Constant 0,09,; mrniurum Tasted to ASTM D150 is typically 0.005% maximum thermal espanrl s typinll 10. HEALTH AND SAFETY 3.29 at I520Hz Prior to using this material, please consult the Material Safety Doiw Shele provided CV Dielectric Strength Tested to ASTM E22B ttee tOldfftlier Of thermal axnanslon is typicnly vNthteach packaged product.

Testaed to AS.*7 D0149 is typically 1::.s p pmr/'C .

32 volts/lml 41280 volts/mm). 11. APPROVALS/

6. SURFACE PREPARATION ACCEPTANCES Dissipation Factor Tested toASTM D150 is typically US.D.A AND APPLICATION 4 0.0005 at I MHz PROCEDURES BUREAU VERITAS For proper technique, rofer to the Oaelzona CATERPILLAR Surface Resistivity Instructions for Use leafetwhich is NATO C3 Tested to ASTM 0257 Is typcially enclosed with each packaged producl. GENERAL MOTORS 6.76 x10" ohm. Areas rebuilt mJdBautznato 131,1 may be TOYOTA overcomeld with Belzona 1321 (Ce- YORK INTERNATIONAL Volume Reslitlvity rarmic S-Me:alj FORD Tested to ASTM D257 is typrially RUSSIAN REGISTER OF SHIPPING 1.03 x 100 ohm cm.

0 7. AVAILABILITY AND COST Belizornt 1311 Is available fraea network of Balconre Distributors throughout the world for prompt delivery W ~xrlSrnfs to the application site. Fot Information, consult the Selzona Dlstributor In your area.

Praws a=nCna~el-Frlti~ s Onry DELZONS Wanea flasse;Ine sneuiea svmn lae.aran siini selnsaiant..

2000NA. BescC.

Man'i. Mft~a 33172, U.SA..

Tat:%1(305)5044W' F=a +1 W3) Ms t1140 aesariep5"Moviemltd cias 2211i, 01m,% eENMOSM a109435 HIarroS5IHotI&AY.

Do!=re Belzonn1311-Product Specification Sheet (Page 2)

Wh: +"o44t2l43t7&&1 F= . ~~(0) IZ23DO5MY Iwoe PILLROO46153

CALO 031 RevT Afttahmefit 5' Page .. +/-.. of 7u.

THE MIP Iris IIIe help you see Ilia whjole pictstre."

net: ~www'heroandp-lab.eoni naiui ifoIe-rld-b!rn 221O7fedrna~ogy Drive P0 Box 24 Schenect~ady, NY 12301 phone: 519-392.000Z fax: 518-382-1182 1~ m~& 401 Gasllgton R"., Sute L Greenville, SC 29615 Page I of 4 phone: 614-297-4417 tax: &64-297-4517 REEORT LAB NO.: NR-0559 DATE RECEIVED: April 16, 2003 PZUZSTED BY: Phi!lip Hacizi COMANY: Entergy Nuclear Generation Co.

Pilcg,7 Nuclear Power Station

'a; STREET ADDRESS: 600 Rocky Hill Road CITY: Plymouth, MA 02360 PHN:(502) 830-7126 COPIES: N.V. Gja~a

?UC!AS'OPRDEA NO.: PS30-10276 CUJSTOMER~ REQUEST NO.: NA 0 D=EScP.IyTIoN OF MATERIAL AND W'ORK REQUESTED:

Received materials as deszribed in the document 'Testing Requirements for PNPS SSW Discharge Piping Cured-In-Paace-P!pe 0 (CIPP) Lining and Belzona 1311 Ceramic R-Metal Samples for PDC 01-09, Specification Number M-624, CG! Evaluation No. 860, and CGI Evaluation No. 861", Rev. 1, dated 02-MAY-2003.

WORK, BY: James F. Getman, Robert F. Kraus RESULTS SOURCE NO.: N.A. DATE REP.: May 9, 2003 The two material samples were identified as (1)

Selzona 1311, and (2) CIPP lining material. Flexural Modulus of Elasticity, Flexural Strength and Tensile Strength tests were requested.

(Copý,rinued. On page 2)

Reviewed by: */pae d D17. Purvis Robert F. Kraus IHEREFYCERTIFY THATTHE OATACON'TAINED INTHISREPORT RAVEBEEN GENE1vE INACCORDANCE WITH AN~D M2EMTHIERPOUIREMENrS OFTHE ARO0V PURCHASE OROER, 0.

PILLROO46154

PILLROO461 55 CALC M-1031 Rev I Attachmen t 5"Z Page . of _.4-THE MOP LmB Page 3 of 4 NR-0559 Philip Ha=izi TABLE I ROOM TEMPERATUR.E TEST RESULTS FOR PNPS SSW DISCHARGE PIPING CIPP LINING AND BELZONA 1311 CERAMIC R-METAL FOR PDC 01-09, SPEC M-624, CGI EVALUATION 860 & CGI EVALUATION 861 Feuralra Tensile Sample Specimen Modulus Strength Strengse Acceptance Label Label of Elastici (.psi) (psi)

Psi) Criteria (psi) .

BeIzona I 1 1.10 xl0D 1 8570 4096 1311 2 1.21 x10' 1 9020 4586 Flexural Lot 1 3 1 1.20 x101 L 7470 5432 Modulus of I i ___ _Elasticity:--

Belzona 1 tT_!xTW- 9890 5401 300,000 psi C 1311 2 1.22 x10' 1 9880 5304 Lot2 1 3 1 1.36x1O0 I 7530 4250 Flexural i I I A Strength ?

CIpp . 1 - 467 x 10 1 4410 2368 4,000 psi 2 3850 2848 C , 3 1T 479x10 2 450 2958 2 Tens~ie crPI I 392 x00j1 5510 3918 1 Stength__.

OUT OUT 1 2

3 425 xlo' 1415 x10' I

1 5610 5790 [ 4026 3927 Notes: I. The CIPP INmaterial specimen #2 did not meet the acceptance criteria for flexural 4,000 psi 1

0 strength.

2. None of the three CIPP IN specimens met the acceptance criteria for tensile strength.

3. The CIPP OUT specimens #1 end #3did not meet the acceptance crieria for tensile strength.

4. The acceptance criteria were documented in "Testing Requirements for PNPS SSW Discharge Piping Cured. In-Place-Pipe (CIPP) Lining and Belzona 1311 Ceramic R-Metal Samples for PDC 01-09, Specification Number M-624, CO1 Evaluation No. 860, and CGI Evaluation No. 861", Rev. 1,dated 02-,AY-2003.

The CZP? material was cured by the alien:, A total of six specimens (three labeled !N and three labeled OUT) , each of a nominal size of 0.7 in.. by 0.3 in. by 7 in., were fabricated for the measurement of Flexural Strength and Modulus. . Flexural Strength and Modulus were measured at room temperature in 3-Foint bending in accordance wich ASTY D790-02. The specimen preparation was performed az The M&P Lab.

'210 TcWJQ, Nivc. POBoX714. Sct"nUdy, NY 12301 491 OGaIrijwon R,,d.Suitu L. GOwvl1e.5C Z9615 PILLROO46156

CALC M-1 031 RaV 1 Attachment'_9 Page .- of._.

THE MIP LhO Page 4 of 4 Philip Harizi 1R-0559 Flexurel Modulus was calculated from the cross-sectional dimensions and the slope of the steepest tangent line to a rest specimen plot of stress as a function of strain. A result was expressed in psi (pounds per square inch),

Flexural Strength was calculated from the cross-sectional dimensions and the maximuom sustained test load. Each result was expressed in psi units.

Tensile Strenoth The Belzona 1311 material was cured at The M&_P Lab. A total cf six specimens (three from Lot I and three from. Lot 2),

each with the nominal shape of ASTM D636-02 Type 1 s~eri=rmes,

- were fahricatec! for the measurement 0o Tensile Strength.

Tensile Strength was measured at room temperature in accordance with ASTM D63e-02. The specimen preparation was performed at

.The N&P Lab.

The CZ?? material was cured by the client. A tot.al of six specimens (three labeled IN and three labeled OUT), each with the nominal shape of AST. D636-02 Type 7 specimens, Were fabricated for the measurement of Tensile Strength. Tensile Strength was measured at room temperature in accordance with C'D ASTM D635-02. The specimens were removed from the pipe wall along the longqzudinal direction by personnel at: The M&P Lab.

All sides of each specimen were machined to remove effects from external membranes or the host pipe.

CD Prior to each test, the actual cross-sectional dimensions were measured, and a specimen's initial area was S-calculated. This area was used as the denominator in a fraction with the corresponding specimen maximum sustained load in the numerator to calcula-e the Tensile Strength in psi.

Testing applicable to supplied ize..s was performed in accordance with !OCFR50 Appendix B, 1OCE'P Par: 21 and revision 4 of The M&P Lab's quality program manual, dated 30 November 1999, Material Disoosition The specimens will be retained at The M&? Lab for six months and then discarded.

2.iT.=hnaloy Dri,. PD Box71z, SchaoneetyNY 12301 "481 CuIl noc Rxe, Suite L, Grc=nville. SC28615 PILLROO46157

CALC.M-1031 Ray i Attachment-j.;.

Page ..L of .. (P.

ENN-DOC-134 REV. 0 ATTActimENT 9.1 DESION VERImcA'tON COVER PAGE DESIGN VERIFICATION COVER PAGE D IP.2 0 IP-3 C JAF XPNPS Document No, M-1031 Revision Page 1 of_&

L-Jl*/*cH z.., sT.

Title:

SSW Discharge Piping CIPP Liner Design l

Quality Related 0 Non Quality Related DV Method: ,*Design Review 0 Alternate Calculation E Qualification Testing

.C%

VERIFICATION DISCIPLINE VERIFICATION COMPLETE AND COMMENTS REQUIRED RESOLVED (DV print, sign. and date)

Electrical Mechanical 0 Instrument and Control t~e~

CivillStructural C

Print/Sign After Comments Have Been Resolved PILLROO46158

CALC M-1031 Rev 1 Attachment 6

'Pagq,_I of 6 ENN.DC-134 REV 0 ATTAOHMENr9.7 CALCULATION DJESIGN VERI1FICATION ICHECILIBT ENN-DC-134 REV 0 ATTACHME 9.7 IDENTIFICATION: DISCIPLINE:

Document

Title:

SSW Discharae.Piping CIPP Liner Design 0 Civil/Structural

[] Electrical Dc No: M 3 Rev.__ QA Cat. 0] 1& C Verifier. Print S_____________ Sign bale Mechanical Mnerger authorization"" Other for supervisor performing veritcaltion, NIA Print Sign Date 1101 METHOD OF VERIFICATION:

Design Review X Alternate Calculations 0 Qualification Test C Design Inputs - Were the inputs correctly selected and Reference incorporated into the design? Page No.

Design Inputs Includedesign bases, pIant operational condlions, performance OR requirements, regulatory requirements and commitments. codes, standards, field data, ate. Aliinformation used as design Inputs should have been Paragraph No.

reviewed and aopproved by the responsible design organization, as applicable.

Allinputs need to beretrievable or excerpts of documents used should be Completion of the Reference Boxes Is attached. optional fo: aenquestions.

0.' See site specific design Input procedures for guidance In Identifying Inputs.

Yes.[ No El N/A Verifier Comments: .,,,,6" Resolution: "_._

PILLROO46159

I:

CALC M-1031"Rev 1 Attachment._

Page -!-of ._

2. Assumptions - Are assumptions necessary to perform the Reference design activity adequately described and reasonable? Where Page No.

necessary, are assumptions Identified for subsequent re. OR verification when the detailed activities are completed? Pargraph No.

Yes .R NoD N/A1 WA_[I Verifier Comments: _ ,"

Resolution: __._

3. Quality Assurance - Are the appropriate quality and quality Reference assurance requirements specified? Page No.

Yes N N/AOR Yes [*] No 0] .NJAL- Paragraph No.

Verifier Comments:

Resolution: IA C)

4. Codes, Standards and Regulatory Requirements - Are the Reference applicable codes, standards and regulatory requirements, Page No.

including issue end addenda properly Identified and are their OR requirements for design met? Paragraph No.

• I -

Yes ; No El NIAD Verifier Comments: A Resolution:

PILLROO46160

PILLROO46161 CALO M.1031 Rev 1 Attachment Pae of

8. Design Oulputs - Is the output reasonable compared to the Reference inputs? Page No, OR Yes *. No C N/A [ Pamrgraph No. 6 Verifier Comments: M*gN' Resolution: -'3

'-a 9. Acceptance Criteria - Are the acceptance crtera Reference incorporated In the calculation sufficient to allow verilication Page No.

that design requirements have been satisfaclorily OR accomplished? Paragraph No. 5,-. c e' ...

C Yes*& No N/AD Verifier Comments: 40./.

Go CD Resolution: )_14_

C

10. Records and Documentation - Are requirements for record Reference preparation, review, approval, retention, etc., adequately Page No.

specified? OR Ala all documents prepared In a clear legible manner suitable ior mnbofilming and/or Paragraph No.

other-documentallon storage method? Have all Impacted documania beeon Ideentied torupdale?

YeasR No N/AD Verifier Comments: _oJV6 Resolution: k&/

PILLROO4SI12

CALC M-1031 Rev I AttachmenL Page -ý6 of__

Software Quality Asuranoe- For a calculation that utilized Reference 11.

soitware applications (e.g., GOTHIC, SYMCORD), was It Page No.

properly verified and validated In accordance with ENN IT- OR 104 or previous site SQA Program? Paragraph No.

Yes D NoD N/A9-Verifier Comments: 4A Resolution: *.*

OTHER COMMENTS ,4.1f,^ -I Y^,, -4*

[%1 RESOLUTIONS C

C All comments for "NO" answers have been resolved satisfactorily.

Pll I RMfASRIR1

Attachment B Safety-Related E Nc:m-Safety-Related S "Q"-Lfat Item M Non.-"Q" FRTYPE 85.21 PILGRIM NUCLEAR POWER STATION SPECIFICATION FOR '

CURED-IN-PLAOE-PIPE (CIPP) LINING FOR SSW DISCHARGE PIPING SPECIFICATION NUMBER -M-624

,N. EBID Addendiurn No, _ ZPURCHASE DATE, 12-MAR-2003 Ln ASME B&PV CODE CERTIFICATION. [I REQ'D 0' NOT REQ'D N

gm El I

RMOV4Z 0707/09o. - j/J -9/,3t4aJ 1JOA33dII J&A4ý2 9A/d2

.7 k I I EO P.D, Harizi 04/02/01 SP. Woods D4102/01 04t02101- AA~aca b4'02/01 R.P Mu75ri'l PREPARED VERIFIED SCM " APPROVED .

REV BY DATE [ BY DATE [ REVIEW DATE 8Y DATE ENTERGY NUCLEAR GENERATING COMPANY PILGRIM NUCLEAR POWER STATION 600 ROCKY HILL ROAD PLYMOUTH, MA 02360 SpeoIfloatlon M-624 NE3,08 Rev, 18 Page I of 12 Attaohment 1 PIlt._ROtl S040

110 SCOPE (1j This specification provides Ihe requirements for the design, materials, Instailelion, Inspections, and lesting of a Cured.ln-Pli).-Pipe (IP11) lining for the Salt Service Water (SSW) discharge piping at Pltgrim Nuclear Power Statlion (PNPS), T'he purpose of [he OIPP Is to provide a new protective linIng lot the exstllng steel pipe that maintains the structural Integrity of the disoharge pipe for soil, overburden, seismic, and live loads,

[21 The SSW piping to receive the CIPP Is the discharge piping for Loop "A"and Loop "B" from the last flange oonnection In the Auxiliary Building piping vault to the end of the discharge pipe at the Seal Well openlng,

13) The SSW discharge piping is 22" nominal diameter standard weight carbon steel pipe (0,375" wail thickness) with a 3/116" natural rubber lining thickness, Flange connections are rubber-lined Pressure Class 150 flat-laced slip-on flanges, Exrsllng rubber lining and coatings that are Intact will remain In piece for the CIPP Installation, (41 The Loop "A"discharge piping Is approximately 240 ft (total length to be lined) wllh 1hree(3) 45-degree elbows and one(l) 90-degree long radius elbow, 0 (5) The Loop "B"discharge piping is approximately 225 ft (total length to be lined) with four(4) 45-degree elbows end one(l) 90-degree long radius elbow,

[5) As a result of pipe spool replacements performed In 199D, there is a 40'-0" spool In Loop "A"and a 40'-.3" spool in Loop "B"that are 22" nominal diameter standard weight carbon steel pipe (0,375" wall thickness) coated with Duromar EAG-FE epoxy with a minimum 1/32" (0,031") thickness, and include "WEKO" elastomeric expansion seats on both end flange )oInts of the replacement spool, which are to be removed before the CiPP M', Installation, T7) This specification provides the requirements for the CIPP design, materials, installation, CV inspections, testing, and Supplier documentation.

[8) The SSW discharge piping is pad of a "U", Safety-Related, PNPS Class I system, The CIPP design, materials, Installalion, Inspections, testing, and documentation are to be performed and/or accepted under the PNPS Nuclear QualIty Assurance program In accordance with Appendix B to Part 60 of Title 10 of the Code of Fadersi Regulations (10CFRSO Appendix B),

Specification M0-624 Rev, El Page 2 of 12 PILLROO46041

2,0 EQUIPMENT OR SERVICES QUIR-E.-

[1) The Supplier shall perform the lon1 and s-neodod coalinglning eleanlnn,-eXamlna

.... preparations for the existing steel pipe prior to installing the olPP liner, t2) The Supplier shall provide sufficient number of workers and resources to perform work on a continuous 24 hour/day basis Inaccordance with the Owner's schedule,

[33 The Supplier shall provide all CiPP liner materials and end seals,

[4] The Supplier shall be responsible for Installing the GIPP liner and for the curing process,

[5) The Supplier shall provide the necessary equipment and shall perform the monitoring and controlling of ali CIPP liner curing parameters.

[61 The Owner shall provide all necessary access to the SSW discharge piping Including the opening of the Auxiliary Building piping vaults, removal of piplng spools, and Installation of outlet cofferdams,

[71 The Owner shall be responsible for the required Inspections and tests and performing examinations or verifying that all examinations have been performed and that the applicable criteria have been met,

[8] The Owner shall perform any necessary weld repairs of the existing steel pipe, C;,

[9) The Owner shall provide all necessary staging and work platforms, 110) The Owner shall provide the necessary ventilation, air quality monitoring, and confined-space safety training for all workers,

[11) The Owner shall provide all olean water required and shall dispose of waste water from curing the GIPP liner,

[12] The Owner shall provide all necessary security personnel and radiological monitoring during the work, 310 APPLICABLE DOCUMENTS 011 ASTM F121 6 "Practice for Rehabilitation of Existing Plpeilnes and Conduits by the Inversion and Curing oi Resin-lmpregnated Tube' (21 ASTM D638 "Standard Test Methods for Tensile Properties of Piastios' (3) ASTM 0790 "Standard Test Methods for Flexural Properties of Unrelnioroed and Reinforced Plastics and Electrical Insulation Materials" Specification M-624 Rev, El Page 3 of 12 pILLR00 4 G

4.0 ,**SGN REQUIREENTIS

[1] The preparation, verlfloation, and Independent roview of a safaiy-reJaIed design oalculallon for the CI.P Instalalion will he lhe rouponaebltlly of the Owner.

[2] The CIPP minimum required thickness (tIAUI) shell be the larger of that required by either Ilhe external load or Internal pressure analysis, The finel CIPP nominal design thickness (hiom) shall be based on the minimum required thickness Increased by 10% to account for thickness variations In the actual Installation, The actual thickness used shall be rounded to the next standard millimeter thickness greater than the nominal design thickness,

[3) The maximum allowable stress for the external load and Internal pressure analyses shall be equal to one-half the long-term (tIme-temperature corrected) flexural and tensile strengths, that Is,a Factor al Safety (N) equal to 2 shall be used Inthe design equations,

[4] For the external load analysis, the design shall be based on the Partially Deteriorated Gravity Pipe Condition, For the negative pressure (vacuum) design condition, the OPP shall be designed as a gravity pipe with the external hydrostatic pressure Increased by an amount equal to the negative pressure, The long-term (time-temperature corrected)

Flexural Modulus of Elasticity (EL) shall be equal to one-hall the short-term value, An Enhancement Factor (K) value of 7,0 shall be used, An Ovallty Reduction Factor (C) of o.90 shall be used, based on a 0,250 Inch maximum to mean Inside diameter differenlial,

[5) For the Internal pressure analysis, the design shall be based on the Fully Deteriorated Pressure Pipe Oondition, The design shall use long-term flexural strength (UL) and tensile strength (o0L) equal to one-third the rated short-term strength values listed below.

[6] The short-term design values to be used, and verified by testing In Section 7,0 below, shall be as follows:

Rated Physical Property Short-Term Value Flexural Modulus 300,000 PSI Flexural Strength 4,000 PSI Tensile Strength 4,000 PSI Specification M-624 Rev, El Page 4 o 12 PII I IRflld.An4.

[7] The design loadings sha(l be as lollowa:

Design Parameter Design Value Maximum Internal Pressure/Temperature 30 PSIG@ l00°F Minimum Operating Temperature = 30oF Maximum External Dilferential Pressure (Minimum Internal Pressure) 25 Iltwg. (-II PSIG Internal)

Portions of the SSW discharge piping are normally operating at negative pressure, Tile Maximum External Differential Pressure of 25 ft W~g, Is based on the highest negative operating pressure for the discharge piping plus an accounting for groundwater pressure acting externally, External soIl, overburden, seismic, and live loads do not act upon the G)PP liner because the steel pipe will remain the structural component.

0'1 5.0 MATERIALS Lfl

[1] The CIPP liner material shall consist of a felt tube composed of woven or non-woven 0 material capable of carrying resin and withstanding the Installation pressures, and curing temperatures, and shall be compatible with the resin system used, Either an epoxy resin and hardener (curing agent) system, or a polyester resin using polymerization Initiators (catalysts) system shall be used.

[2] The OIPP system shall achieve the physical strength propertles in accordanee with this specification. To confirm the actual short-term strength properties, test samples o1 the CIPP shall be taken at the final Installation after the curing is completed, The samples shall be out from a section of CIPP that has been cured within the SSW pipe or within a like diameter pIpe provided for this purpose at the entrance and termination point as described In Section 6,0 below,

13) The cured specimens taken at the time of final Installation shall meet or exceed the following minimum values, which correspond to the shor-term values described In Section 4.0:

Minimum Physical Property Measured Value Flexural Modulus = 300,000 PSI Flexural Strength 4,000 PSI Tensile Strength = 4,000 PSI Specification M-624 Rev, El Page 6 of 12 PILLROO46044

[4) The liner fell lube shall have a unilorm thlokness- hat. when compressed at Installation pressures will equal or exceed the specliled nominal design thickness as measured at the test sample locations.

[5] The liner shall be fabricated using afiber base material capable of expanding to the size that when Installed will cure while Incontact wlih the existing pipe, lining, or coating, (61 The average Inside diameter of the existing rubber-lined pipe Is20,876" except for the 40 foot epoxy-coaled spool section Ineach line that is21,188" Inside diameter,

[7] The outside surface of the liner tube (before watout) shall be encapsulated within a translucent flexible membrane that allows observation of the resin Impregnation (wetout) procedure, (8] The wall color of the Interior pipe surlace of the OIPP after Installation shall be a light reflective color that enhances final visual examination,

[e) Any lubricant used In the Inversion water shall be a nontoxic biodegradable oil of vegetable origin,

[10] The end seals to be used at the entrance and termination point ol the CIPP shall be expanding type seals with an EPDM elastomer element and AL6XN alloy retainIng bands, Alternative materials may be used Ifapproved by the Owner,

[11] Material Safety Date Sheets (MSDS) shall be submitted to the Owner prior to delivery of any chemical materials to PNPS.

Specification M-624 Rev. El .P.gs 6 01, P1l I Ifnn.ArldI..

6.0 FABRICATION AND INSTA&LATION REQUIREMENTS (1) OiPl Installatlon shall be by the liner Inverslion proeeae wilh the following specific requirements, t2l The SSW discharge lines shall be cleaned of all debris, foreign material, and biological matter and Inspected as described in Section 7,0 prior to the CIPP Installation,

[3) The existing "WEKO" seals Installed at flangea oints in the piping shall be removed,

[4) The existing rubber lining and other urethane and epoxy compound coatings and previous lining repairs shall be visually examined, Loose or damaged lining or coatings shall be removed and the underlying steel pipe examined as described InSection 7,0 below, It Is not necessary to repair the rubber lining or coatings,

[(5 The CIPP Installation shall not begin unili the Owner has Inspected and reviewed the final examination results end any measurements, preparations, or repairs performed on the existing pipe, lining, or coatings, f6] The fell liner tube weloul process shall be oonduoted so as to produce a uniform distribution ci the epoxy or polyester resin mixture throughout the tube, (7] The wetout process shall not begin until the Owner has inspected and reviewed the Ln processing equipment to be used for the wetout, inversion, and curing process.

[t8 The CIPP Installation shall be performed by the Inversion process, The Inversion pressure shall be sufficient to cause the Impregnated tube to Invert from the point of Inversion to the point of termination and hold the tube tight to the pipe wail during the curing process.

M t9 Apull tape may be used to augment the Inversion process and shall be kept under tension throughout the Inversion process to prevent Itfrom getting trapped under the liner.

[10] Provision shall be made to produce test samples of the OIPP at the entrance and termination point for each Inversion length of tubing Installed. The sample material shell C be out from a section of CIPP that has been cured within Ihe SSW pipe or within a like diameter pipe provided at the entrance and termination of the SSW pipe for this purpose, Additional plate lest samples may be made using a clamped mold for a section of saturated felt, The axial length required for [he sample material and the handling of the samples Isdescribed InSection 7,0 below,

[11) Curing shall be accomplished using circulated heated water, steam, or pressurized heated air, The heated alirwater should be circulated the length ci pipe to uniformly raise the temperature to elffet a cure of the resin, The temperature of the hot supply and return water, steam, or air shall be monitored during the actual curing conditions, The Supplier shall determine the appropriate curing times and temperatures and Is responsible for providing all monitoring and control of the curing parameters, Specification M-624 Rev, El Page 7 of 12 PILLROO46046

[12] The required pressure to hold the flexible tube tight agalnst the existing pipe shall be maintained until the cure has been substanllally complolod-.The Supplier shall determine the appropriate preesurn to be mainlainod during lhe curing process and Is responsible for providing all monitoring and control el te curing peramolnrs.

(13] The CIPP shall be cooled [o a temperature below 1OO°F before relieving pressure used during curing,

[14) End seals shall be Installed at the entrance and termination point of the OIPP of the type described InSection 5,0, 7,0 !NSPEOTION, EXAMINATION, AND TEST REQUIREMENTS t1) The existing rubber lining and other coatings and previous lining repairs shall be visually examined, Loose or damaged lining or coatings shall be removed and the underlying steal pipe examined, Any sIgnitlcant corrosion shall be removed and the sleet pipe thickness confirmed to be greater than the minimum required thickness to be provided by the Owner. Steel pipe wall thickness shall be determined either by direct measurement of the depth of wall loss due to corrosion (measured as a gap between the lowest point of the pit and a prolongation of the original contour ol the pipe) or by ultrasonic measurement of the remaining wall thickness.

(2] The Owner shall provide an Inspection and review of the Initial examination results and approve the method and materials to be used for any repairs or preparations performed on the existing pipe, lining, or coatings,

[3] The CIPP Installation shall not begin until the Owner has inspected and reviewed the final examination results end any measurements, preparations, or repairs performed on the existing pipe, lining, or coatings,

[41 Prior to beginning the watout processing of each tube, the Owner representative(s) shall verily that the equipment setup is capable of ensuring a thorough and uniform welout and Impregnation of the felt tube with the epoxy or polyester resin mixture, The Supplier shall demonstrate the handling and processing of the liner from the wetout through the complete Inversion and curing process, The wetout process shall not begin before the successful completion of this Owner verification, The Supplier shell demonstrate the methods of operation for the equipment to the satisfaction of the Owner representative(s),

After acceptance of the setup, the Owner representative(s) shall witness the wetoul, inversion, and curing process, Specification M-624 Rev. El Page 8 of 12 PILLROO46047

(6) The liner felt tube material shall have a reasonably uniform thickness with varlations not greater than +i-10% of the average flattened tube total thickness with the exception of localized areas that may have a lesser or greater thickneasaover a Widlh at the surff ae that Is less than the nominal tube thickness and for anTliongth. The felt tube shall be visually examined with thickness measurements required only for areas that are Identified visually or by tactile means as varying significantly from the average thickness, Unliormity of thickness for the liner felt tube material Isa critical characteristic that, together with the physical property tests described below, provides the basis for acceptance of the OiPP Installation, (6] The following physical propertles defined InSection 5.0, as measured for the test specimens described below, are critical characteristics that provide the basis for acceptance of the CIPP Installatlon; Average Thickness Flaxural Modulus of Elasliolty Flexural strength Tensile Strength (7) Test samples of the CIPP shall be taken at both the entrance and termination point after the ouring Is completed for each Inversion length of tubing Installed as described In Section 6,0, An amount of sample material suitable for the preparation of a minimum of six specimens with a minimum axiallength of 10" as described below shall be collected at both the entrance and termlnation point sample locations,

[B) Additional plate test samples may be Included using a clamped mold for a section of saturated felt, The plate specimens will be tested Inaddition to the samples described above,

19) Test sample material shall be Immediately marked with Identificatlon for traceability and prepared for shipment to a testing laboraltry previously agreed to by the Owner,

[101 The thickness of the cured samples shall be measured with a caliper or similar device prior to shipment, Thickness measuremenls are only required for the cured test samples taken from the entrance and termination points, The average thickness of the cured samples shall be equal to or greater than the nominal design thickness (NoUM) determined Inthe Section 4,0 analysis,

[11] Test specimens shall be prepared from axially oriented sample material with a minimum length of 10' and an Individual specimen width of 1-1/2" each unless otherwise agreed to by the Owner,

[12) Flexural testing shall be performed on at least three specimens taken at both the entrance and termination point (total six specimens) to determine the Flexural Modulus of Elasticity and the Flexural Strength Inaccordance with ASTM Standard D790. Testing Is required only for the llatwise orientation of the specimens.

Specilication M-624 Rev, El Page 2 of 12 PILLROO46048

[13) Tensile testing shall be performed on at-least-three specimens taken at both the entranoe and termination point (total six specimens) to determine the Tensile Strength In accordance with ASTM Standard D638,

[143 Test specimens may be prepared by machining [he samples, il Isnot required that the original Inside or outside surfaces be retained Inthe teat specimens Ifmachining is performed.

[15) The finished CIPP shall be Inspected by visual oxamInalion over the entire length and shall be free of significant voids (air bubbles), dry spots, pita, and craoks,

[16) Any significanl Impedections found shall be reported to the Owner to be disposationed,

[17) Voids (air bubbles), dry spots, and pits shall preferably be repaired with Beizona jisI Ceramic R-Metal epoxy compound, The Inside surface uanibrane may be removed as needed to make repairs, As an alternative, other epoxy Or urethane repair compounds may be used Ifapproved by the Owner, Repairs shall be nilowed to cure sufficiently long at ambient temperature or curing may be accelerated by heating, (18] Cracks are not permitted and any affected areas of 0IPP shall be removed by cutting or excavating to completely remove the crack, The area shall preferably be repaired with Belzona 1311 Ceramic R-Metal epoxy compound, Alternative repairs may be approved C by the Owner' (19) The 0FPP Inversion around bends may result In wrInk(es or fins due to malaeria bunching of the tube along the Inner radius of the bend and thinning of the tube around the outer radius of the bend, The wrinkles, fins, or thinning are not considered to be Imperfections M, or defects and are accounted for by the design analysis.

810 HANDLINGJO CL9ANINn. SHIPPING, AND STORAGE RE~QUIREMENTS The Supplier shall be responsible for ali shipping and handling of the OIPP materials and supplies, The Owner will provide E suitable area at or In close proximity to the Installation work site for the Supplier to set up the work vehicles or lemporary structures necessary for the storage, handling, and watou. process for the CIPP materials, The work area wilI be available to the Supplier for the duration of the Installation project, Specification M-624 Rev. El Page 10 of 12 PILLRO046049

9.0 QUALITY ASSURANCE RBQUIfWMENTS

[1) The SSW discharge pipIng Isparl of a "Q7, Safety.Related, PNPS Olaas I system, The CIPF design, malerilial, Inalaltiot, inspeoctions, lfoing, and documentation are to be performed and/or acoepted under the PNPS Nuclear Quality Assurance (QA) program In accordance with Appendix Bto Part 50 oi Title 10 of the Code of Federal Regulations (100FR6O Appendix B),

(2J Defects or nonoonformanoes found Inthe existing discharge piping or the CIPP Installation shall be documented via the PNPS Nonconformance Report (NOR) process for disposition by the Owner prior to any repair work being performed.

[3) PNPS Quality Assurance/Quality Control (QA/QC) personnel shall perform the Inspeotlon lunctlon and shall perform, review, and/or'bonflrm examinations without restriition to ensure that the Inspection objectives have been achieved, PNPS Quality Control personnel shall perform examinations direotly and/or Integrate Supplier examinations and/or use remote means Iocomplete the inspection function,

[4) The CIPP materials end Inelallatlon will be controlled as a"Oornmeroial Grade itemn' (OGI) under the PNPS Quality Assurance program, This specification Identifies oritlcal characteristics that will require confirmation by the Owner to oamplete the acceptance of 0' the CIPP Installation, Any parameler, variable, or characteristic not Identified Inthis specification as a "critical characteristic" shall be monitored and controlled solely by the

.Suppller, (5] Final acceptance of the OIFP Installation will require the completion of the physical property testing described InSection 7,0 The Installed CIPP may be released for SSW system operation Immediately following the satisfactory completion of the post-installation Inspection, and prior to final acceptance, for station operation Inthe cold condition only, 10,0 GUARANTEE II) Completion of CIPP Q installation for which the test samples adequately meet the critical characteristics defined Inthis Specification and for which any defects or nonconformances have been successfully dlsposiltloned will fulfill the performance requirements for this work.

Specification M-624 Rev, El Page 11 of 12 PILLROO46050

11.0 CONTROL OF INTERFACE BETWEEN.SUPPL[ER AND PURCHABgR

[1) All correspondence tI aend from the Supplier shall 'reforonce the iPiu.lase Order number, (2] Supplier technical information shall be submitted to the Owner upon request, The final preparation, verification, and Independent review of a Batety-related design calculation for the CIPP Installation will be the responsibility of (he Owner.

120 METHOD OF ACCEPTANCE (1) The CIPP Installation will be controlled as a 'Commercial Grade Item" (OCa) under the PNPS Quality Assurance program,

[2) The Inspection and testing described In Section 7,0 shall be the method of acceptance for the CIPP Installation, Inspections and testing shall be performed by PNPS Quality Control or an approved PNPS supplier, DEFINITION OF `011 Cl] Quality Assurance (OA) designator that, when utilized with Items or services/activities, Identifies that QA Program elements are applicable In order to meal 10CFRBO Appendix B requirements, 14,0 APPLICABILITY OF IOCFR21 t1] The Owner shall be responsible for any notifications pursuant to Part 21 of Title 10 tothe Code of Federal Regulations (100FR21) "Reporting of Defects and Noncompliance" during the CIPP Installation process and at any time In the future, This does not preclude the Supplier from reporting to the NRC any known or suspected defect or failure to comply with applicable requirements for this or any other CIPP Installation, Specification M-624 Rev, El Page 12 of 12 PILLROO46051

Speoifloaticn-M-624 Desijn Verlfloatlon Co~er Page'P ~ag e1 of 1 ENN.DC.1 34 REV, 0 ArrAoHMENT D.1 DESIOVERIFICATMol COVER PAae DESIGN VERIFICATION CoVEri PAGE 0 iP-2 0 IP-3 0 JAF PýPNPS Document No, *]*SccI'iun1Ian -vM-624 Revision Page 1 ot 6

Title:

CURID.iN-PLACE-PIPE (CIPP) LINING FOR SSW DISCHARGE PIPING Qualily Meited 0 Non Quality Related C,

DV Method: gDesign Review MAlternate Calculaison 3 Qualification Testing 011 VERIFICATION DISCIPLINE VERIFICATION COMPLETE AND COMMENTS REOUIRED RESOLVED (DV prnt, sign, and date)

Electrical Mechanical 2 rJ.. ,7 3//

Instrument and Control C ClvMI/Struclural PuinilUSgn Alter Comments Have Been Resolved Originator Date, 7

~, ~-Iqd r PILLRO046052

Sp~oioftaion M-624 Desfgn Ver~floatioll ChIeolkiast page 1 of 7 ENN-DC-134 2ReV. ATTAOHM~ENT 9,r DESIGN VERWIPIATION CHEtOKLIST IDENTIFICATION: DISCIPLINE.,

bocumeni

Title:

CURED-IN-PLAGE-PiPE (CIPP) LINING 0 CIiviustLWCIura FOR SSW DISCHARGE PIP~ING 0I Eldectica Doc, No,i Specificationi M-624 ReV, El QA Gat, Q &

Veri~er ~ ~ ~ ~'~" ~ IMechanical VatiIer B {ai el, Manager authorization DJOther icc supervisot pedormnlrg vorcitcallon,

~\fAPrint Sigh Date METHOD OF VERIFICATION:

Design Review Qualification Test

'I Design Inputs - Were the inputs correctly selected and Reference Incorporated Into the design? Page No.

Design Inputs Iniude design bases, plant operational conditions, perlormanee OR -- ,/,W* ,3 requiremenls, regulatory requirements and cotnilrnlmnies codes, standards, field dais, sic. AliInformation used as design Inputs sho*id have been Paragraph No.

reviewed end approved by the responsible design organlmltion, as applicable, Allinputs need to be retrievable or excerpts ohdocuments used should be Dompletlln of the Ratlrance attached. Boxes Is optional for oll See sile specific design Input procedures (or guidance in Identitying Inputs. questions, Yes X No [3 N/A 0]

Verifier Comments:

Aeeclutloril -

pit I RpOO4SO2

Speciflonflton fi-624 Design Vetiflcatin Chec0klist PE19a 2 of 7 2,, Assumptions- Are assumptions necessary to pedorm lhe Reference design autlvlty adequately described and reasonable? Where Page No, necessary, are assumplions Identified for subsequent to.

verification when the detailed acllvitles are completed? Paragrnph No.

Yes El No EI NfA 9ý VerifIer Comments.- -

eSaolutiofli IV__

C B,. Quality Assurance - Are the appropriate quality and quality Reference assurance requiremenls specified? Page No.

C OR 9 YesM4 No [I N/A El Paragraph No.

Verifier oommentat 1110 Resolutiont _____

4, Oodes1 Standards and Regulatory Requirements - Are the Reference applicable codes, standards and regulatory requirements, Page No.

Including Issue and addenda properly Identified and are their requirements for design met? Paragraph No,_

Yes,. No El N/A El Verifier Commental -

ResolutIont ____

P11 .I..-panRIns

Srpeolfloatioln M-624 Desi~gn Verlflcatkoh Ohecki~st Page 3 ol 7 S, Construction and Operating Exporleeo - Have appiloabla Reference construction and operatlng experience bean aonaIderad? Page No, YesA No U N/A [I Paragraph No,

_ _OR_

Verlifr Commen*ta Resolutlohi ,VI Interfaces Have the design Inteilace requirerneflia been Reference S, Interfaces - Have the design Interface requlremonla been satisfied and documented? Page No.

OR Yes F NoE N/A [] Paragraph No. - //

Verifier Commentat Resolution:m /

7, Methods - Was an appropriate design method used? i Relerenoe Page No, _

Yes a No [I N/A C OR, Paragraph No. "'

Verifier Comments,.

Resolutioni P il P* nAF'ns.R"

Soeoifio2tionM-624 Design~ Verificaition 0heokl~st Page 4of 7 resoablICIJMDrIItoUI th otpu utpts-Deegn i Rafternas Inputs? Page No,___________

OR ~

Yes~, No5 NtA E Pariagraph No,:ýJ-Verifier conmmefltBat Flesolut)rnr'NI Reference Equipment and Prooeeses - Are the specified parts, equipment and processes suitable for the required Page No.

application?

OR Yea* NIA ED Paragraph No._________

Verifier Commental -

Resolution:

Materials Compatibility - Are the specified materials Reference compallble with each other and the design environmental Pegs No.,__________

conditions to which the material wllt be exposed? OR Paragraph No, -- 's' S Yes No D N/A 0 Verifier Comments : -

ReoUtiot011 ____

Pll I IlnnARFnlA

Sipeolflonflon-M-624 Design VerI-fIcatlOn Cheookilat Pa~ge 5of 7 11 Maintenance - Have adequate malnienanoe features and Referenco requirements been npoollied? Page No.

OR.

Yes 0, No D N/A L] Paragraph No, ,'-_ ,. *. -

Verifier ComIllentel Resolutioni W1__4

.N.

I 12, Maintenance and Repair-Are rccessiblilly and other Referenoe design provisions adequate lor prfdormance oi needed Page No, maintenance and repair? OR C Paragraph No,__________

Yes 0 No [ N/A Verifier Commentel - e~+/-I~Th4 A,¶ Resolutiont _____

13, AccesElblllty for Inspeatotll- Has adequate accessibility Reference been provided to perform the In-servioe inspeotion expeoted Page No, to be required during the plart life? OR No D N/A 9 Paragraph No.

Yes El Verifier Commental Resolutioni _1___

PII I P1nArts;I",!7

I'.

Speolaiootion M-624 Design VerificatIon Ohecklist Page 6 of 7 I4. Radiation Exposure - Has the design propiory oonsidered Reference radiation exposure to the public and planl porsonnOt? Page No, Oar Yes D No M N/A 1 Paragraph No,__________

Verifier Oommetatt ____ ,

Resolutlont 1i, Acceptance Criteria - Are the acapiance orltaria Reteranaoe C Incorporated inthe design documents suffioent to allow Pago No.

verification that design requirements have been aatisfaotorily OR accomplished?

Paragraph j,~',

Y8S89 No rl N/A ED Verifier Commentai Resolution: A C"-

16, Testing - Have adequate pre-operatlonal and subsequent . leteranae periodic test requirements been appropriately specified? Page No, OR Paaograph No t_.u'*.," 5,

-* ¢*__

Yes 9 No ED N/A DJ Verifier Oommentsi Resolution:

PILLRO046058

Spasgl~pioilon M-624 Design Verificatlor Chacklst Page 7 of 7

17. Hnhdllng and Siorage- Are adequate handling, alorage, Reference cleaning and shipping requirements specified? Page No.

OR Yes 10I No N/A IE Paragraph No, __ ____

VerIfler Conimentat Resolutlon _ ____

18, Identification - Are adequate component Identllifoaion (e.,,, Reference C equipment labeling) requirements speollied? Page No.

OR yesaK No M N/A M Paragraph No,.

C Verifier Commentat Resolutlon: "/'

M 19, Records and Documenrtatlon - Are requirements for record Rotoeronse preparation, ravlaw,'approval, retention, etc,, adequately Page No.

specliied? oR Ate all documents prepared Ina cloarlegiblo manner suttable for nllcroftlming and/or Paragraph No.

other dooumentaton etorage method? Have ell Impn,.ted documants been Identified for updals as necuesuy Yes ,.* No 17 N/A [I Verifier Commentst Resolution:

PILLRO046059

ExhibitIT RTYPE A2,20 NUCLEAR ORGANIZATION CONTROLLED L....

DOCUMENT O CHANGE NOTIOE+ ODON)

CDCN Lo No, n3LaO' MANUAL TITLE:. g9P6(=iF*A-rhW~ T~O~3 DOCUMENT TITLE: vRc>rzhP-L.As-PPic (GIP1rýLWG4lP4 bio£)CýC6~IJ~

• rYiL.;

'*n*, i iibii I r *

• P I "' " j NEW DOCUMENT El REVISION , RETIRE L REVISION NO.: ' OTHER KNOWN DOCUMENTS AFFECTED NO, OF PAGES ATTACHED; 8-9-.'via SECTION(S) AFFECTED:

Nfl GENERAL REASON FOR CHANGE

[ Change In Work Prooess Change InRelaled Document C

[ Error In Previous Revision gOther: f7R$, OL-07?-09 CK&M -tý T'cQý SPECIFIC PURPOSE AND

SUMMARY

OF OHANGES (attach addltlonal.pages Ifnecessary) s_ c1nf*ncT I, kt-u24 eV, aL' A1rrAC n9j'Dexy3T P.Svfr F ( psm LS AITrACR ED 7bcZCpe Wrp- y Ai' Aw P,\,e c~; .rPF 7DocL' 6~j%

Signature of Initiator: wL Owner: j?. mP'u -4..

Date Initiated: 03 / ý6 Date Issued by Document Services '--

NOP83A7 Rev 15 PILLROO46060