ML091871223

From kanterella
Jump to navigation Jump to search
License Amendment Request No. 2009-05, License Amendment Request to Incorporate Use of Fiber-Reinforced Polymer System to Strengthen Existing Auxiliary Building Masonry Brick Walls for Tornado Loadings
ML091871223
Person / Time
Site: Oconee  
Issue date: 06/29/2009
From: Baxter D
Duke Energy Carolinas
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
LAR 09-005
Download: ML091871223 (37)
v • d • e


Text

DA VE BAXTER Ener Vice President Oconee Nuclear Station Duke Energy ON01 VP / 7800 Rochester Highway Seneca, SC 29672 June 29, 2009 864-873-4460 864-873-4208 fax dabaxter@dukeenergy.com U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D. C. 20555-0001

Subject:

Duke Energy Carolinas, LLC Oconee Nuclear Station, Units 1, 2, and 3 Docket Numbers 50-269, 50-270, and 50-287 "License Amendment Request to Incorporate Use of Fiber-Reinforced Polymer System to Strengthen Existing Auxiliary Building Masonry Brick Walls for Tornado Loadings" - License Amendment Request No. 2009-05

References:

1. Letter from Leonard N. Olshan, Project Manager, Plant Licensing Branch II-1, Division of Operating Reactor Licensing, Office of Nuclear Reactor Regulation, to Bruce H.

Hamilton, Vice President, Oconee Site, "Correction to Amendment Nos. 360, 362, and 361 for Oconee Nuclear Station, Units 1, 2 and 3 (TAC Nos. MD2129, MD2130, and MD213 1)," dated March 26, 2008.

2. Letter to Mr. James Dyer, Director, Office of Nuclear Reactor Regulation, from Henry B.

Barron, Group Vice President and Chief Nuclear Officer, Nuclear Generation, Duke Energy Corporation, "Tornado/HELB Mitigation Strategies and Regulatory Commitments," dated November 30, 2006.

In accordance with 10CFR 50.90, Duke Energy Carolinas, LLC (Duke) proposes to amend Renewed Facility Operating Licenses Nos. DPR-38, DPR-47, and DPR-55. If granted, this amendment request will revise the Updated Final Safety Analysis Report (UFSAR) to incorporate the use of a Fiber Reinforced Polymer (FRP) system to strengthen existing masonry brick walls for uniform pressure loads resulting from a tornado event. The masonry walls to be strengthened are located within the Units 1, 2, and 3 Auxiliary Buildings (ABs).

The AB masonry walls to be strengthened are passive, non-structural and constructed on a structural support system consisting of rigid reinforced concrete columns and beams. The walls are double-wythe in-fill panels constructed of solid concrete bricks. The-walls are exterior, seismic, pressure boundary (ventilation only), non-committed fire boundary, non-radiation, non-flood, and QA Condition 1. The FRP system will be used on the exterior side of the walls for flexural strengthening. The typical FRP application will consist of a matrix of glass fibers bonded directly to existing masonry construction with a two-part epoxy polymer. To remediate potentially limiting conditions of construction, mechanical shear restraints will be installed along the brick masonry wall perimeter (top and side edges only).

Enclosures 3 and 4, and Enclosure 6 contain security sensitive and company confidential information, respectively.

Withhold from public disclosure under 10 CFR 2.390.

Upon removal of these enclosures, the letter is uncontrolled.

www. duke-energy: corn

Nuclear Regulatory Commission License Amendment Request No. 2009-05 June 29, 2009 Page 2 Duke has concluded that the use of an FRP system on existing AB double-wythe solid concrete brick walls is safe and is necessary to support the design and implementation of Duke's Natural Phenomenon Barrier System modifications. A similar application of the FRP system for AB block masonry walls was submitted to the Nuclear Regulatory Commission (NRC) in a License Amendment Request (LAR) dated June 1, 2006, and was subsequently approved by the NRC in Safety Evaluations dated February 21, 2008, and March 26, 2008. The use of FRP, as proposed, is predicated on the satisfactory completion of qualification testing and commercial grade dedication of the selected FRP system and the incorporation of subsequent periodic surveillance requirements into existing plant programs. Regulatory commitments associated with this LAR are given in Attachment 2.2.

In accordance with Duke administrative procedures that implement the Quality Assurance Program Topical Report, these proposed changes have been reviewed and approved by the Plant Operations Review Committee and Nuclear Safety Review Board. Additionally, a copy of this LAR is being sent to the State of South Carolina in accordance with 10 CFR 50.91 requirements.

Duke respectfully requests that the amendment be issued by June 30, 2010, with a 180-day implementation period to coincide with the completion schedule of other NPBS modifications.

If you have any questions in regard to this letter, please contact Stephen C. Newman, Regulatory Compliance Lead Engineer, Oconee Nuclear Station, at (864) 873-4388.

I declare under penalty of perjury that the foregoing is true and correct. Executed on June 29, 2009.

Sincerely, Dave axter, Vice President Oconee Nuclear Station Enclosures 3 and 4, and Enclosure 6 contain security sensitive and company confidential information, respectively.

Withhold from public disclosure under 10 CFR 2.390.

Upon removal of these enclosures, the letter is uncontrolled.

Nuclear Regulatory Commission License Amendment Request No. 2009-05 June 29, 2009 Page 3

Enclosures:

1. Evaluation of Proposed Change
2. Fiber-Reinforced Polymer System: Application and Technical Discussion
3. Units 1, 2, and 3 Auxiliary Building Double-Wythe Solid Concrete Brick Walls to be Strengthened Using FRP [Security Sensitive]
4. Description of Analytical Method for Evaluating Double-Wythe Solid Concrete Brick Walls and Designing FRP Reinforcement [Security Sensitive]
5. Affidavit of Dave Baxter
6. Company Confidential Information [Confidential]

Attachments:

1.1 List of Acronyms 2.1 UFSAR-Mark Ups 2.2 List of Regulatory Commitments 4.1 Flowchart of Analytical Method for Evaluating Double-Wythe Solid Concrete Brick Masonry Walls and Designing FRP Reinforcement [Security Sensitive]

4.2 Application of Performance Testing Program to Oconee Analysis and Design

[Security Sensitive]

4.3 Example of Analytical Method Using Performance Testing Program Specimens

[Security Sensitive]

Enclosures 3 and 4, and Enclosure 6 contain security sensitive and company confidential information, respectively.

Withhold from public disclosure under 10 CFR 2.390.

Upon removal of these enclosures, the letter is uncontrolled.

Nuclear Regulatory Commission License Amendment Request No. 2009-05 June 29, 2009 Page 4 bc w/enclosures and attachments:

Mr. Luis Reyes, Regional Administrator U.S. Nuclear Regulatory Commission -'Region II Sam Nunn Atlanta Federal Center, Suite 23 T85 61 Forsyth St., SW, Atlanta, GA 30303-8931 Mr. John Stang, Project Manager Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Mail Stop 0-14 H25 Washington, DC 20555-0001 Mr. Eric Riggs U.S. Nuclear Regulatory Commission Senior Resident Inspector (Acting)

Oconee Nuclear Station Susan E. Jenkins, Manager, Infectious and Radioactive Waste Management, Bureau of Land and Waste Management Department of Health & Environmental Control 2600 Bull Street, Columbia, SC 29201 Enclosures 3 and 4, and Enclosure 6 contain security sensitive and company confidential information, respectively.

Withhold from public disclosure under 10 CFR 2.390.

Upon removal of these enclosures, the letter is uncontrolled.

ENCLOSURE I EVALUATION OF PROPOSED CHANGE

- Evaluation of Proposed Change License Amendment Request No. 2009-05 June 29, 2009 Page 1

Subject:

License Amendment Request to Incorporate Use of Fiber-Reinforced Polymer System to Strengthen Existing Auxiliary Building Masonry Brick Walls for Tornado Loadings

1. DESCRIPTION
2. PROPOSED CHANGE
3. BACKGROUND
4. TECHNICAL ANALYSIS
5. REGULATORY SAFETY ANALYSIS 5.1 No Significant Hazards Consideration 5.2 Applicable Regulatory Requirements/Criteria
6. ENVIRONMENTAL CONSIDERATION.1 List of Acronyms

- Evaluation of Proposed Change License Amendment Request No. 2009-05 June 29, 2009 Page 2

1.0 DESCRIPTION

The proposed license amendment request (LAR) will revise the Updated Final Safety Analysis Report (UFSAR) to incorporate the use of a fiber-reinforced polymer (FRP) system to strengthen existing double-wythe solid concrete brick walls for uniform pressure loads resulting from a postulated tornado event. For the purpose of this request, the acronym "DWSCB" will be used herein to reference these Double-Wythe Solid Concrete Brick masonry walls. The DWSCB walls to be strengthened using an FRP system are located within the Units 1, 2, and 3 Auxiliary Buildings West Penetration Rooms (WPR) and are non-structural in-fill panels. The locations of these walls are shown in Figure No. 2.1 of Enclosure 2 and are listed and further described in Enclosure 3.

2.0 PROPOSED CHANGE

Duke proposes to revise UFSAR Section 3.8.4.7, "Concrete Masonry Walls," to document:

" the evaluation of certain masonry walls that are part of the Units 1, 2, and 3 Auxiliary Buildings for tornado-induced differential pressure and tornado wind loadings; the use of an FRP system to strengthen the masonry walls to meet the tornado-induced differential pressure load; and,

  • the applicable codes, standards, loads, and load combinations.

The proposed UFSAR changes are included in Attachment 2.1 (markups).

3.0 BACKGROUND

As previously stated in Reference 1 of Enclosure 2, the Natural Phenomenon Barrier System (NPBS) modifications will enhance Oconee's tornado design. These modifications will employ a fiber-reinforced polymer (FRP) system to strengthen existing brick masonry walls for uniform pressure loads resulting from a tornado event.

Similar modifications utilizing FRP reinforcement of the block masonry walls of Oconee's Units 1, 2, and 3 Auxiliary Buildings were approved in 2008 by the NRC as described in References 27 and 28 of Enclosure 2.

The brick masonry walls to be strengthened using an FRP system are located within the Units 1, 2, and 3 Auxiliary Buildings. The design function of the Auxiliary

- Evaluation of Proposed Change License Amendment Request No. 2009-05 June 29, 2009 Page 3 Building structures is to enclose, support, and protect the electrical and mechanical equipment necessary for the safe operation of the Nuclear Steam Supply System (NSSS). The Auxiliary Building structures provide environmental protection and biological shielding for this equipment.

The Auxiliary Building DWSCB walls to be strengthened using an FRP system are passive elements. The walls are double-wythe in-fill panels constructed of solid concrete bricks. All masonry walls are non-structural and constructed on a rigid structural support system of reinforced concrete columns and beams. The walls to be strengthened using an FRP system enclose the Units 1, 2, and 3 WPRs.

The FRP system will be used for flexural strengthening of the DWSCB walls. Glass fibers when combined with epoxies (i.e., an FRP system) create a high-strength, lightweight structural laminate designed to work in conjunction with the existing structure to achieve the desired final performance. An independent study sponsored by the Licensee indicates that the proposed FRP system can effectively and predictably improve the low flexural capacity and brittle failure mode of unreinforced brick masonry walls subjected to extreme out-of-plane loads [Reference Enclosures 6A and 6B]. The wall loading condition would be uniform pressure resulting from tornado-induced differential pressure. The loading condition will produce tensile stresses in the FRP system. The typical FRP application Will consist of a matrix of fibers bonded directly to existing masonry construction with a polymer and overlapped to provide both horizontal and vertical tensile reinforcement. Structural steel shear restraints will be installed at the top and sides of the wall perimeters to improve the shear resistance of the masonry walls at their interface with the structural support system members.

The use of structural steel shear restraints is necessary to improve the shear resistance of the masonry walls due to potentially limiting conditions of construction of the Auxiliary Building masonry walls. The potential exists for either shrinkage cracks along the sides or settlement cracks along the tops of the masonry walls. These boundary conditions could reduce the resistance to shear sliding of the walls under tornado loading; therefore, shear restraints will be installed on the brick masonry walls discussed in this License Amendment Request.

4.0 TECHNICAL ANALYSIS

Design Existing DWSCB walls will be analyzed for tornado-induced differential pressure in accordance with Standard Review Plan (SRP) Section 3.8.4 [Reference 2 of Enclosure 2], ACI 531-79 [Reference 3 of Enclosure 2], and Chapter 3 of the Oconee UFSAR

[Reference 4 of Enclosure 2]. Design of the FRP system will be based upon the

Enclosure I - Evaluation of Proposed Change License Amendment Request No. 2009-05 June 29, 2009 Page 4 results of this analysis and ICC AC125 [Reference 5 of Enclosure 2], and will comply with the general design considerations contained in ACI 440.2R-02 [Reference 6 of ] for FRP systems used for flexural strengthening.

Installation of the FRP system will not adversely affect the current structural qualification of the DWSCB walls (e.g., seismic) by significantly increasing mass or stiffness nor will it have any immediate or long-term deleterious effect on the DWSCB wall materials of construction.

Elevated temperatures during a fire can cause epoxy resins to soften or burn, potentially compromising the structural strength provided by the FRP materials.

Unless simultaneously subjected to a fire and to uniform pressure loads resulting from a tornado event, the FRP system will remain in a near-zero state of stress; therefore, fire-induced degradation of the FRP system is not an immediate structural concern.

Qualification Tests and Commercial Grade Dedication Qualification testing and reporting will be performed in accordance with ICC AC125

[Reference 5 of Enclosure 2] for the selected FRP System.

Installation of the FRP system will result in use of a commercially available item in a QA Condition 1 application. Duke will perform and document a technical evaluation of the FRP system (fibers and polymeric resins) in accordance with Reference 7 of, to demonstrate that:

1. The item qualifies as a commercial grade item.
2. The supplier is capable of supplying a quality product.
3. The quality of the item can be reasonably assured.

Inspection and Verification Duke will utilize technical procedures to control testing of concrete substrate and installation and inspection of the FRP system in accordance with ICC AC 125

[Reference 5 of Enclosure 2], ACI 440.2R-02 [Reference 6 of Enclosure 2], and ICC AC178 [Reference 8 of Enclosure 2]. The installer will be required to have personnel certified and trained by the FRP system manufacturer to install the specified system.

Certified installers and an accredited quality control inspector will be present during installation of the FRP system.

Hazards The specific FRP system that Duke will use, Tyfo Fibrwrap Advanced Composite System by Fyfe Company LLC,,exhibits good low and high temperature properties, long working time, and high elongation (i.e., ductility). Full cure of the epoxy ranges

- Evaluation of Proposed Change License Amendment Request No. 2009-05 June 29, 2009 Page 5 from 3 to 5 days depending upon ambient temperatures and field conditions. The composite is expected to "cure to the touch" within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. The composite system is an NSF/ANSI Standard 61 listed product for drinking water systems. The Tyfo SEH-51A reinforcing fabric is a custom weave uni-directional glass fabric with a high tensile modulus. The Tyfo Type-S epoxies are 100% solvent-free, emitting no toxic fumes or volatile organic compounds (VOCs). [Reference 18 of Enclosure 2]

The Tyfo Fibrwrap Advanced Composite System installed on both masonry block and brick walls will meet Oconee Station fire protection requirements. Fire protection considerations are evaluated as part of the station modification process and will be addressed for each installation of the FRP system.

Durability / Service Life The post-exposure durability of the Tyfo Fibrwrap subjected to gamma radiation, loss of coolant accident conditions, sustained and cyclic high temperatures, cyclic low temperature, alkali solutions, water, and outdoor environments has been evaluated

[Reference 22 of Enclosure 2]. The results of the durability tests showed that FRP materials had good resistance to all of the exposures studied; however, FRP-FRP bonds and FRP-concrete bonds are unable to maintain their load carrying capacity if they are subjected simultaneously to stress and temperatures close to the glass-transition temperature of epoxy. (The glass-transition temperature is unique to each FRP system and is 180 degrees F (82 degrees C) for the SEH-5 1 A composite system installed [Reference 18 of Enclosure 2].) It was also observed that moisture had the most deleterious effects on FRP and its bonds.

The FRP system will not be exposed to temperatures nearing the glass-transition temperature of epoxy nor will it be exposed to appreciable moisture. The FRP system will be subjected to ambient temperature and humidity conditions associated with the local climate. Although applied to exterior surfaces of masonry walls, the FRP system will be shielded from sunlight and adverse weather conditions (e.g., rain, snow, ice, etc.) by structural siding supported by a structural steel support system attached to the Auxiliary Building reinforced concrete frame. The FRP system will not be exposed to high temperature gas and/or liquid or significant radiation levels when applied to the exterior (nor interior) surfaces of masonry walls. As previously stated, unless simultaneously subjected to a fire and to uniform pressure loads resulting from a tornado event, the FRP system will remain in a near-zero state of stress.

As part of Duke's "Inspection Program for Civil Engineering Structures and Components", generally described in Section 18.3.13 of the UFSAR [Reference 4 of ] and detailed in Engineering Directives Manual (EDM-410) [Reference 11 of Enclosure 2], periodic long-term inspection of the FRP system will be performed on a nominal 5 year interval to monitor long-term durability. In the future, this

Enclosure I - Evaluation of Proposed Change License Amendment Request No. 2009-05 June 29, 2009 Page 6 inspection frequency may be reduced to a nominal 10-year interval with appropriate justification based on the structure, environment, and previous long-term inspection results. Inspections will follow the guidance provided in ICC AC125 and ACI 440.2R-02 [References 5 and 6].

Long-term inspection will consist of both visual inspection and physical testing of the FRP system and substrate (i.e., masonry and grout). Inspections of the installed FRP system will include:

" visual inspections for changes in color, debonding, peeling, blistering, cracking, crazing, deflections and other anomalies; and,

" tension adhesion testing of cored samples using methods specified in ASTM D4541 [Reference 9 of Enclosure 2] or ACI 530R-02 [Reference 16 of Enclosure 2].

To avoid testing damage to the FRP-strengthened masonry walls, the FRP system will also be applied to adjacent masonry test walls of similar construction, one for each Unit. These test walls will be exposed to virtually identical environmental conditions as the FRP-strengthened walls, but will be more accessible for tension adhesion testing. In addition, the test wall sample areas may be restored using conventional concrete repair procedures without concern for the design FRP system. Visual inspections will also be performed on both selected portions of the FRP-strengthened masonry walls via removable sections of siding and on the test walls.

5.0 REGULATORY SAFETY ANALYSIS 5.1 No Significant Hazards Consideration Duke has evaluated whether or not a significant hazards consideration is involved with the proposed amendment by adhering to standards set forth in 10CFR 50.92, "Issuance of Amendment." This ensures that operation of the facility in accordance with the proposed amendment would not:

1) Involve a significant increase in the probability or consequences of an accident previously evaluated.

Response: Physical protection from a tornado event is a design basis criterion rather than a requirement of a previously analyzed UFSAR accident analysis. The current licensing basis (CLB) for Oconee states that systems, structures, and components (SSC's) required to shut down and maintain the units in a shutdown condition will not fail as a result of damage caused by natural phenomena.

Enclosure I - Evaluation of Proposed Change License Amendment Request No. 2009-05 June 29, 2009 Page 7 The in-fill masonry walls to be strengthened using an FRP system are passive, non-structural elements. The use of an FRP system on existing Auxiliary Building masonry walls will allow them to resist uniform pressure loads resulting from a tornado and will not adversely affect the structure's ability to withstand other design basis events such as earthquakes or fires. Therefore, the proposed use of FRP on existing masonry walls will not significantly increase the probability or consequences of an accident previously evaluated.

2) Create the possibility of a new or different kind of accident from any accident previously evaluated.

Response: The final state of the FRP system is passive in nature and will not initiate or cause an accident. More generally, this understanding supports the conclusion that the potential for new or different kinds of accidents is not created.

3) Involve a significant reduction in a margin of safety.

Response: The application of an FRP system to existing Auxiliary Building masonry walls will act to enhance the margin of safety, e.g., the West Penetration Room walls, by increasing the walls' ability to resist tornado-induced differential pressure. Consequently, this change does not involve a significant reduction in a margin of safety.

In summary, based upon the above evaluation, Duke has concluded that the proposed amendment involves no significant hazards consideration.

5.2 Applicable Regulatory Requirements/Criteria Tornado loadings for specific areas of the Units 1, 2, and 3 Auxiliary Buildings are described in Table 3-23 of the Oconee UFSAR [Reference 4 of Enclosure 2]. The CLB for the Auxiliary Building masonry walls to be strengthened using an FRP system is described in UFSAR Section 3.8.4.7. UFSAR Section 3.8.4.7 primarily discusses masonry walls in the context of Oconee's response to I. E.Bulletin 80-11 [Reference 17 of Enclosure 2]. UFSAR Section 3.8.4.7 requires revision to address the use of an FRP system to strengthen certain masonry walls for uniform pressure loads resulting from a tornado event.

5.3 Precedence A similar application of the FRP system for Auxiliary Building block masonry walls was submitted to the Nuclear Regulatory Commission in a License

- Evaluation of Proposed Change License Amendment Request No. 2009-05 June 29, 2009 Page 8 Amendment Request dated June 1, 2006, and was subsequently approved by the NRC in a Safety Evaluation dated February 21, 2008 and March 26, 2008.

6.0 ENVIRONMENTAL CONSIDERATION

Duke has evaluated this license amendment request against the criteria for identification of licensing and regulatory actions requiring environmental assessment in accordance with 1 OCFR 51.21. Duke has determined that this license amendment request meets the criteria for a categorical exclusion as set forth in I OCFR 51.22(c)(9).

This determination is based on the fact that this change is being proposed as an amendment to a license issued pursuant to 1 OCFR 50 that changes a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 1 OCFR 20, or that changes an inspection or a surveillance requirement, and the amendment meets the following specific criteria:

(i)

The amendment involves no significant hazards consideration.

As demonstrated in Section 5.1, this proposed amendment does not involve a significant hazards consideration.

(ii)

There is no significant change in the types or significant increase in the amounts of any effluent that may be released offsite.

The current licensing basis (CLB) for Oconee states that systems, structures, and components (SSC's) required to shut down and maintain the units in a shutdown condition will not fail as a result of damage caused by natural phenomena. Use of an FRP system on masonry walls located in tornado-vulnerable areas of the Units 1, 2, and 3 Auxiliary Buildings will better ensure that this design requirement is maintained. Since the principle barriers to the release of radioactive materials are not modified or affected by this change, no significant increases in the amounts of any effluent that could be released offsite will occur as a result of this proposed change.

(iii) There is no significant increase in individual or cumulative occupational radiation exposure.

By using an FRP system, the reduction in the probability of masonry wall failure resulting from a tornado event will better ensure that radioactive effluents, which could potentially be released to the environment in the event of a design basis tornado, are contained within the Auxiliary Building structure. Because the principle barriers to the release of radioactive materials are not modified or affected by this change, there will be no significant increase in individual or cumulative occupational radiation exposure resulting from this change.

ENCLOSURE I ATTACHMENT 1.1:

LIST OF ACRONYMS

Attachment 1.1 - List of Acronyms License Amendment Request No. 2009-05 June 29, 2009 Page 1 Acronym Meaning ACI American Concrete Institute ASTM American Society for Testing and Materials CDTR Cask Decontamination Tank Room CFL Constructed Facilities Laboratory (N. C. State University)

CFR Code of Federal Regulations CLB Current Licensing Basis DWSCB Double-Wythe Solid Concrete Brick EDM Engineering Directives Manual FRP Fiber Reinforced Polymer ICC International Code Council LAR License Amendment Request NFPA National Fire Protection Association NPBS Natural Phenomenon Barrier System NRC Nuclear Regulatory Commission NSSS Nuclear Steam Supply System ONS Oconee Nuclear Station SSC's Systems, Structures, and Components UFSAR Updated Final Safety Analysis Report WPR West Penetration Room

ENCLOSURE 2 FIBER-REINFORCED POLYMER SYSTEM:

APPLICATION AND TECHNICAL DISCUSSION

- Evaluation of Proposed Change License Amendment Request No. 2009-05 June 29, 2009 Page 1 Application of Fiber-Reinforced Polymer System The Natural Phenomenon Barrier System (NPBS) modifications [Reference 1] will employ a fiber-reinforced polymer (FRP) system to strengthen existing masonry walls for uniform pressure loads resulting from a tornado event.

The masonry walls to be strengthened using an FRP system are located within the Units 1, 2, and 3 Auxiliary Buildings. The walls are double-wythe in-fill panels constructed of solid concrete bricks. All masonry walls are non-structural and constructed on a rigid structural support system of reinforced concrete beams and columns. For example, typical columns are 2 ft. x 2 ft. at 16 ft. on center, and typical beams are 2 ft. wide x 3 ft. deep at 13.0 -ft. to 15.5 ft.

on center. Masonry walls extend from the top of the supporting structural beam to the bottom of the next structural beam. All walls to be strengthened are plane and terminate either at a structural wall or column. Wall edges consist of mortar joints around the perimeter. The walls are reinforced horizontally with truss reinforcing (Dur-O-Wal joint reinforcing, 9 gauge 2 wires) every sixth course. Walls to be strengthened using an FRP system enclose the Units 1, 2, and 3 West Penetration Rooms (WPRs). The locations of these walls are shown in Figure No. 2.1 and are further described in Enclosure 3.

The FRP system will be used in a bond-critical application for flexural strengthening of the masonry walls. The wall loading condition will be uniform pressure resulting from tornado-induced differential pressure. The loading condition will produce tensile stresses in the FRP system. The typical FRP application will consist of a matrix of fibers bonded directly to existing masonry construction with a polymer and overlapped to provide both horizontal and vertical tensile reinforcement. The FRP system will not be relied upon as a compressive reinforcement.

The FRP system will be subjected to a benign environment: ambient temperature and humidity conditions associated with the local climate. Although applied to exterior surfaces of masonry walls, the FRP system will be shielded from sunlight (i.e., ultraviolet radiation),

adverse weather conditions (e.g., rain, snow, ice, etc.), and tornado wind loads by structural siding supported by a structural steel girt system attached to the Auxiliary Building frame.

The Updated Final Safety Analysis Report (UFSAR) has been updated to reflect the installation of the FRP system to WPR walls. See Attachment 2.1 showing marked-up changes.

Structural Design of FR]P System Existing masonry walls will be analyzed for tornado-induced differential pressure in accordance with SRP Section 3.8.4 [Reference 2], ACI 531-79 [Reference 3], and Chapter 3 of the Oconee UFSAR [Reference 4]. Design of the FRP system will be based upon the results of this analysis and ICC AC 125 [Reference 5] and will comply with the general design considerations contained in ACI 440.2R-02 [Reference 6] for FRP systems used for flexural strengthening. Details of the design methodology are described in Enclosure 4.

- Evaluation of Proposed Change License Amendment Request No. 2009-05 June 29, 2009 Page 2 Installation of the FRP system will not adversely affect the current structural qualification of the masonry walls by significantly increasing mass, nor will it have any immediate or long-term deleterious effect on the masonry wall materials of construction. Moreover, the masonry walls to be strengthened using an FRP system were seismically qualified (pursuant to IEB 80-11, Reference 17) based on the extremely limiting condition of allowable tensile stress for unreinforced masonry construction. Application of the FRP system increases design margin for a seismic loading condition that produces tensile stresses in the FRP system while having no effect as a compressive reinforcement.

Fire can be a significant issue when using an FRP system for structural strengthening.

Elevated temperatures during a fire can cause epoxy resins to soften or burn, compromising the structural strength provided by the FRP materials. Unless simultaneously subjected to fire and uniform pressure loads resulting from a tornado event, the FRP system will remain in a near-zero state of stress; therefore, fire-induced degradation of the FRP system is not an immediate structural concern.

Duke concludes that the methodology used to determine the flexural capacity of the FRP-strengthened WPR walls subjected to the design-basis tornado differential pressure is appropriate because 1) the design reasonably predicts the behavior and out-of-plane structural capacities of FRP-strengthened walls, 2) the design provides for sufficient margin as evidenced by the evaluation of the performance test data derived from the testing program performed by an independent testing laboratory, and 3) the test data validates the design assumptions.

The design margin provides reasonable assurance that, in the event of a design basis tornado, the structural integrity of the FRP-strengthened WPR walls will not be impaired due to the tornado differential pressure effects and, in consequence, safety-related systems and components located within these rooms will be adequately protected and may be expected to perform necessary safety functions as required.

Qualification Tests for Selected FRP System Qualification testing and reporting will be performed in accordance with ICC AC 125

[Reference 5] for the selected FRP System. Qualification testing will be conducted as part of the Commercial Grade Dedication process further described below. Constituent materials (such as polymeric resins and glass fabric) and the composite material will be tested. This Licensee commitment is outlined in Attachment 2.2.

Commercial Grade Dedication of Selected FRP System Installation of the FRP system will result in use of a commercially available item in a QA Condition 1 application. Duke will perform and document a technical evaluation of the FRP

- Evaluation of Proposed Change License Amendment Request No. 2009-05 June 29, 2009 Page 3 system (fibers and polymeric resin) in accordance with Reference 7 to demonstrate that:

1. The item qualifies as a commercial grade item.
2. The supplier is capable of supplying a quality product.
3. The quality of the item can be reasonably assured.

This Licensee commitment is outlined in Attachment 2.2.

Inspection and Verification of FRP System Installation Duke will utilize technical procedures to control testing of concrete substrate and installation and inspection of the FRP system in accordance with ICC AC125 [Reference 5], ACI 440.2R-02 [Reference 6], and ICC AC178 [Reference 8]. The installer will be required to have personnel certified and trained by the FRP system manufacturer to install the specified system. Certified installers and an accredited quality control inspector will be present during installation of the FRP system.

The accredited quality control inspector will be on site to:

  • Document that all materials conform to the evaluation report, design drawings, and installation procedure.
  • Verify completed surface preparation by:

o checking surface amplitude; o performing adhesion tests; and, o

checking for surface primer.

0 Verify proper installation of FRP system by:

o checking ambient temperature and masonry temperature and surface dryness; o verifying polymer mixing is correct; o verifying proper application (i.e., fiber orientation, fiber overlaps and splices, number of layers and absence of air pockets); and, o verifying test samples are prepared, labeled, and stored in accordance with the installation procedure.

As a minimum, field testing during installation will include:

0 adhesion pull tests prior to system installation on masonry as per ASTM D4541

[Reference 9]; and,

  • testing of sample sets by an accredited laboratory as per ASTM D3039 [Reference 10].

o A minimum of 15% of all sample sets will be tested.

- Evaluation of Proposed Change License Amendment Request No. 2009-05 June 29, 2009 Page 4 o

Tensile properties will be required to meet, or exceed, FRP composite system properties as defined in the installation procedure.

This Licensee commitment is outlined in Attachment 2.2.

Long-term Surveillance Program for FRP System Duke's "Inspection Program for Civil Engineering Structures and Components", generally described in Section 18.3.13 of the UFSAR [Reference 4] and, as detailed in Engineering Directives Manual (EDM-410) [Reference 11], provides guidance for monitoring and assessing civil engineering structures and their. condition in order to provide assurance that they are capable of performing their intended functions. This program is applicable in meeting the regulatory requirements of the Maintenance Rule [References 12 and 13] and the License Renewal Rule [References 14 and 15] and includes the Units 1, 2, and 3 Auxiliary Building walls to which the FRP system will be applied. Inspections will follow the guidance provided in ICC AC125 and ACI 440.2R-02 [References 5 and 6].

Long-term inspection of the FRP system will be performed on a nominal 5 year interval. This inspection frequency may be reduced to a nominal 10 year interval with appropriate justification based on the structure, environment, and previous long-term inspection results.

Inspections of the installed FRP system will include:

  • visual inspections for changes in color, debonding, peeling, blistering, cracking, crazing, deflections and other anomalies; and,

" tension adhesion testing of cored samples of actual walls (not coupons) using methods specified in ASTM D4541 [Reference 9] or ACI 530R-02 [Reference 16].

To avoid testing damage to the FRP-strengthened masonry walls, the FRP system will also be applied to an adjacent masonry test walls of similar construction, one for each Unit. These test walls will be exposed to virtually identical environmental conditions as the FRP-strengthened walls, but will be more accessible for tension adhesion testing. In addition, the test wall sample areas may be restored using conventional concrete repair procedures without concern for the design FRP system. Visual inspections will also be performed on both selected portions of the FRP-strengthened masonry walls via removable sections of siding and on the test walls.

Records of long-term inspection reports will be considered 10CFR 50, Appendix B, Quality Assurance Records. All inspection reports will be maintained for the life of the plant.

This Licensee commitment is outlined in Attachment 2.2.

Relevant Performance Testing of FRP Systems The Licensee sponsored a study by an independent testing laboratory to investigate the

- Evaluation of Proposed Change License Amendment Request No. 2009-05 June 29, 2009 Page 5 effectiveness of using FRP systems to strengthen existing unreinforced concrete masonry walls to resist extreme out-of-plane loads. Details of this study are presented in Enclosure 6.

Static loading conditions were evaluated. This study showed that flexural strength and ductility of masonry walls can be increased if shear failure is controlled. Furthermore, this study demonstrated good agreement between experimental results and analytical models. In summary, the study indicated that FRP systems can effectively and predictably improve the low flexural capacity and brittle failure mode of unreinforced masonry walls subjected to extreme out-of-plane loads.

The specific FRP system that Duke plans to use, Tyfo Fibrwrap Advanced Composite System by Fyfe Company LLC, exhibits good low and high temperature properties, long working time, and high elongation (i.e., ductility). Full cure of the epoxy ranges from 3 to 5 days depending upon ambient temperatures and field conditions. The composite is expected to "cure to the touch" within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. The composite system is an NSF/ANSI Standard 61 listed product for drinking water systems. The Tyfo SEH-5 1 A reinforcing fabric is a custom weave uni-directional glass fabric with a high tensile modulus. The Tyfo Type-S epoxies are 100% solvent-free, emitting no toxic fumes or volatile organic compounds (VOCs). [Reference 18]

Homam and Sheikh [Reference 22] evaluated the durability of the Tyfo Fibrwrap. The research report discusses durability of the Tyfo Fibrwrap subjected to various types of loads and environmental exposures in civil structures. Durability evaluation of materials involved testing the post-exposure performance of the specimens subjected to gamma radiation, loss of coolant accident conditions, sustained and cyclic high temperatures, cyclic low temperature, alkali solutions, water, and outdoor environments. The results of the durability tests showed that FRP materials had good resistance to all of the exposures studied; however, FRP-FRP bonds and FRP-concrete bonds are unable to maintain their load carrying capacity if they are subjected simultaneously to stress and temperatures close to the glass-transition temperature of epoxy. (The glass-transition temperature is unique to each FRP system and is 180 degrees F (82 degrees C) for the SEH-5 IA composite system. [Reference 18]) It was also observed that moisture had the most deleterious effects on FRP and its bonds.

The FRP system will not be exposed to temperatures nearing the glass-transition temperature of epoxy nor will it be exposed to appreciable moisture. As previously stated, the FRP system used to strengthen existing masonry walls for the NPBS modifications will be subjected to ambient temperature and humidity conditions associated with the local climate. Although applied to exterior surfaces of masonry walls, the FRP system will be shielded from sunlight, adverse weather conditions (e.g., rain, snow, ice, etc.), and tornado wind loads by structural siding. The FRP system will not be exposed to high temperature gas and/or liquid or significant radiation levels when applied to exterior surfaces of masonry walls. Finally, unless subjected to uniform pressure loads resulting from a tornado event, the FRP system will remain in a near-zero state of stress.

The Tyfo Fibrwrap Advanced Composite System installed on both masonry block and brick walls will meet Oconee Station fire protection requirements. Fire protection

- Evaluation of Proposed Change License Amendment Request No. 2009-05 June 29, 2009 Page 6 considerations are evaluated as part of the station modification process and will be addressed for each installation of the FRP system.

Structural steel shear restraints will be installed at the top and sides of the wall perimeters to improve the shear resistance of the masonry walls at their interface with the structural support system members. The use of structural steel shear restraints is necessary to improve the shear resistance of the masonry walls due to potentially limiting conditions of construction of the Auxiliary Building masonry walls. The potential exists for either shrinkage cracks along the sides or settlement cracks along the tops of the masonry walls. These boundary conditions could reduce the resistance to shear sliding of the walls under tornado loading; therefore, shear restraints will be installed on the brick masonry walls discussed in this License Amendment Request.

- Evaluation of Proposed Change License Amendment Request No. 2009-05 June 29, 2009 Page 7 References

1. January 31, 2006, letter from Mr. Henry B. Barron (Duke Energy) to Mr. James E.

Dyer (USNRC), Re: Oconee Nuclear Station Units 1, 2 and 3; Docket Nos. 50-269, 270 and 287; Project Plans for Tornado and High Energy Line Break Events Outside Containment.

2.

NUREG-0800, Standard Review Plan, Section 3.8.4, "Other Seismic Category I Structures," Rev. 1 - July 1981.

3.

Building Code Requirements for Concrete Masonry Structures, American Concrete Institute (ACI) 531-79 and Commentary ACI-53 1 R-79.

4.

Updated Final Safety Analysis Report, Duke Energy Company, Oconee Nuclear Station, December 31, 2007.

5. Interim Criteria for Concrete and Reinforced and Unreinforced Masonry Strengthening Using Fiber-Reinforced Polymer (FRP) Composite Systems, International Code Council (ICC) AC125, June 2003.
6.

Guide for the Design and Construction of Externally Bonded FRP Systems for Strengthening Concrete Structures, ACI 440.2R-02.

7.

Commercial Grade Items, Duke Energy Company, Nuclear Supply Chain Directive, SCD230.

8. Interim Criteria for Inspection and Verification of Concrete and Reinforced and Unreinforced Masonry Strengthening Using Fiber-Reinforced Polymer (FRP)

Composite Systems, ICC AC178, July 2003.

9.

Standard Test Method for Pull-Off Strength of Coatings Using Portable Adhesion Testers, American Society for Testing and Materials (ASTM) D4541.

10. Standard Test Method for Tensile Properties of Polymer Matrix Composite Materials, ASTM D3039.
11. Inspection Program for Civil Engineering Structures and Components, Duke Energy Company, Nuclear Generation Department, Engineering Directives Manual (EDM) 410.
12. The Maintenance Rule, 10CFR Part 50.65.
13. Industry Guideline for Monitoring Structures, Nuclear Energy Institute (NEI) 96-03.
14. The License Renewal Rule, 10CFR Part 54.
15. Industry Guideline for Implementing the Requirements of 10CFR Part 54 - The License Renewal Rule, NEI 95-10.
16. Building Code Requirements for Masonry Structures, ACI 530R-02.

- Evaluation of Proposed Change License Amendment Request No. 2009-05 June 29, 2009 Page 8

17. I. E.Bulletin 80-11, "Masonry Wall Design," U. S. Nuclear Regulatory Commission, May 8, 1980.
18. Fyfe Company LLC, Tyfo SEH-51A Composite (using Tyfo S Epoxy) System Product Data Sheet, Dec. 2005.
19. OSC-4019-series Calculations, Duke Energy Carolinas LLC, Oconee Nuclear Station.
20. Not Used.
21. Not Used.
22. Homan, Sayed Mukhtar and Shamim A. Sheikh. 2005. "Fibre Reinforced Polymers (FRP) and FRP-Concrete Composites Subjected to Various Loads and Environmental Exposures." University of Toronto, Department of Civil Engineering, Research Report HS-01-05 (Sep.).
23. Letter from Duke Power Company LLC d/b/a Duke Energy Carolinas, LLC to U. S.

Nuclear Regulatory Commission, "Oconee Nuclear Docket Numbers 50-269, 50-270, and 50-287 - License Amendment Request to Incorporate Use of Fiber-Reinforced Polymer System to Strengthen Existing Auxiliary Building Masonry Walls for Tornado Loadings - License Amendment Request No. 2006-006," dated June 1, 2006.

24. Letter from Duke Power Company, LLC, d/b/a Duke Energy Carolinas, LLC, to U. S.

Nuclear Regulatory Commission, "Oconee Nuclear Docket Numbers 50-269, 50-270, and 50-287 - Duke Response to NRC Request for Additional Information in regard to License Amendment Request to Incorporate Use of Fiber-Reinforced Polymer System to Strengthen Existing Auxiliary Building Masonry Walls for Tornado Loadings - License Amendment Request No. 2006-006," dated March 14, 2007.

25. Letter from Duke Power Company, LLC, d/b/a Duke Energy Carolinas, LLC, to U. S.

Nuclear Regulatory Commission, "Oconee Nuclear Site, Units 1, 2, and 3, Docket Numbers 50-269, 50-270, and 50-287, Duke Response to NRC Request for Additional Information in regard to License Amendment Request to Incorporate Use of Fiber-Reinforced Polymer System to Strengthen Existing Auxiliary Building Masonry Walls for Tornado Loadings, License Amendment Request No. 2006-006,"

dated October 8, 2007.

26. Letter from Duke Power Company, LLC, d/b/a Duke Energy Carolinas, LLC, to U. S.

Nuclear Regulatory Commission, "Oconee Nuclear Site, Units 1, 2, and 3, Docket Numbers 50-269, 50-270, and 50-287, Duke Response to NRC Request for Additional Information in regard to License Amendment Request to Incorporate Use of Fiber-Reinforced Polymer System to Strengthen Existing Auxiliary Building Masonry Walls for Tornado Loadings, License Amendment Request No. 2006-006,"

dated October 30, 2007.

27. Letter from U. S. Nuclear Regulatory Commission to Duke Power Company, LLC,

- Evaluation of Proposed Change License Amendment Request No. 2009-05 June 29, 2009 Page 9 "Oconee Nuclear Station, Units 1, 2, and 3, Issuance of Amendments Regarding Use of Fiber-Reinforced Polymer (FRP) (TAC Nos. MD2129, MD2130, and MD213 1),"

dated February 21, 2008.

28. Letter from U. S. Nuclear Regulatory Commission to Duke Power Company, LLC, "Correction to Amendment Nos. 360, 362, and 361 for Oconee Nuclear Station, Units 1, 2, and 3, (TAC Nos. MD2129, MD2130, and MD213 1)," dated March 26, 2008.
License Amendment Request No. 2009-05 NPBS for Masonry Walls to be Strengthened using Fiber-Reinforced Polymer for Tornado Pressure Drop Note 1: FRP to be added to Aux. Bldg.

Wing Walls 2 Note 1 I

Indicates Walls Requiring FRP Strengthening FIGURE No. 2-1 BAVSTs not shown for clarity

ENCLOSURE 2 ATTACHMENT 2.1:

UFSAR MARK-UPS

Attachment 2.1 - UFSAR Mark-Ups License Amendment Request No. 2009-05 June 29, 2009 Page 1 UFSAR Chapter 3 Oconee Nuclear Station (31 Dec 2007) 3.8.4.7 Concrete Masonry Walls The masonry walls are in-fill panels serving as partitions with some walls having pressure, fire and radiation barrier applications. The walls are single or mnultiwythe, multiple wythe and constructed of hollow or grouted concrete blocks or solid concrete blocks or bricks. All masonry walls are non-structural and constructed on a structural support system.

Existing text restated as stand-alone paragraph:

Pursuant to I.E.Bulletin 80-11, a safety re-evaluation of all masonry walls was undertaken by Duke Power Company. As a result of this reevaluation effort, certain masonry walls were modified to meet minimum factors of safety.

Certain masonry walls that are part of the Units 1, 2, and 3 Auxiliary Buildings were evaluated for tornado-induced differential pressure loading. The walls were subsequently strengthened to meet these loads using a fiber-reinforced polymer (FRP) system. Walls strengthened with FRP are not to be credited for resisting tornado loading until the Safety Evaluation is issued by the NRC.

3.8.4.7.1 Applicable Codes and Standards The criteria used for the re-evaluation of masonry walls pursuant to I.E.Bulletin 80-11 is are contained in Attachment 4 of Reference 14. These T-his criteria identify uses the American Concrete Institute "Building Code Requirements for Concrete Masonry Structures," ACI 531-79, as the governing code with supplemental allowables specified for cases not directly addressed in the code.

The criteria used for the re-evaluation of masonry walls to resist tornado-induced loadings are contained in References 35, 36, 37, 38, 40 and 41. These criteria specify ACI 531-79 as the governing code for this evaluation with supplemental working stress allowables specified for the fiber-reinforced polymer (FRP) system.

3.8.4.7.2 Loads and Load Combinations The design loadings for the masonry walls at Oconee are those specified in portions of Section 3.8.4. The only thermal effects which a masonry wall experiences are those pertinent to normal operation, and these are not considered a significant design consideration.

In addition, the design differential pressure for masonry walls evaluated for tornado-induced loadings is contained in Reference 39. The load combinations for tornado-induced loadings are contained in NUREG-0800, Standard Review Plan, Section 3.8.4, "Other Seismic Category I Structures," Rev.1 -July 1981.

3.8.4.7.3 Upgrade and Modification of Masonry Walls A program of repairs was performed on selected masonry walls pursuant to I.E.Bulletin 80-11.

The walls included in this program were not found to be unsafe in their original configuration; however, an added margin of safety was desired for these walls. The repairs provide increased

Attachment 2.1 - UFSAR Mark-Ups License Amendment Request No. 2009-05 June 29, 2009 Page 2 factors of safety by either upgrading the walls to meet the allowable stresses set forth in the re-evaluation criteria or by shielding the safety related equipment located in proximity of the walls from damage, assuming the masonry walls were to collapse. References 12 through 24 pertain to I.E.Bulletin 80-11.

Certain masonry walls that are part of the Units 1, 2, and 3 Auxiliary Buildings were modified to resist tornado-induced differential pressure loading. These walls were strengthened using a fiber-reinforced polymer (FRP) system. Walls strengthened with FRP are not to be credited for resisting tornado loading until the Safety Evaluation is issued by the NRC.

3.8.7 References

1. Eringen, A. C., and Naghdi, A. K., "State of Stress in a Circular Cylindrical Shell with a Circular Hole."
2. Levy, Samuel, McPherson, A. E., and Smith, F. C., "Reinforcement of a Small Circular Hole in a Plane Sheet Under Tension," Journal of Applied Mechanics," June 1948.
3. Wichman, K. R., Hopper, A. G., and Mershon, J. L., "Local Stress in Spherical and Cylindrical Shells Due to External Loadings," Welding Research Council Bulletin No. 107, August 1965.
4. HTGR and Laboratory Staff, Prestressed Concrete Reactor Vessel, Model 1, GA7097.
5. Advance HTGR Staff, Prestressed Concrete Reactor Vessel, Model 2, GA7150.
6. Hardingham, R. P., Parker, J. V., and Spruce, T. W., Liner Design and Development for the Oldbury Vessels, London Conference on Prestressed Concrete Pressure Vessels, Group J, Paper 56.
7. Amirikian, A., Design of Protective Structures, Bureau of Yards and Docks, Department of the Navy, NAVDOCKS P-51, 1950.
8. AEC Publication TID-7024, Nuclear Reactors and Earthquakes.
9. Housner, G. W., Design of Nuclear Power Reactors Against Earthquakes, Proceedings of the Second World Conference on Earthquake Engineering, Volume 1, Japan 1960, Page 133.
10. Housner, G. W., Behavior of Structures During Earthquakes, Journal of the Engineering Mechanics Division, Proceedings of the American Society of Civil Engineers, October 1959, Page 109.
11. Task Committee on Wind Forces, Wind Forces on Structures, ASCE Paper No 3269.
12. IE Bulletin 80-11, "Masonry Wall Design," NRC, May 8, 1980.
13. W. 0. Parker, Jr. (Duke Power Company), Letter with attachment to J. P. O'Reilly (NRC),

July 7, 1980.

Attachment 2.1 - UFSAR Mark-Ups License Amendment Request No. 2009-05 June 29, 2009 Page 3
14. W. 0. Parker, Jr. (Duke Power Company), Letter with attachment to J. P. O'Reilly (NRC),

November 4, 1980.

15. A. C. Thies (Duke Power Company), Letter with attachment to J. P. O'Reilly (NRC), May 22, 1981.
16. W. 0. Parker, Jr. (Duke Power Company), Letter with attachment to H. R., Denton (NRC),

July 13, 1981.

17. W. 0. Parker, Jr. (Duke Power Company), Letter with attachment to J. P. O'Reilly (NRC)

September 30, 1981.

18. W. 0. Parker, Jr. (Duke Power Company) Letter with attachment to J. F. Stolz (NRC),

December 29, 1981.

19. W. 0. Parker, Jr. (Duke Power Company), Letter with attachments to H. R. Denton (NRC),

May 18, 1982.

20. W. 0. Parker, Jr. (Duke Power Company), Letter with attachments to H. R. Denton (NRC),

June 15, 1982.

21. Standard Review Plan, Section 3.8.4, Appendix A, "Interim Criteria for Safety-Related Masonry Wall Evaluation," NRC, July 1981.
22. Uniform Building Code, International Conference of Building Officials, 1979.
23. ACI 531-79 and Commentary ACI 531 R-79, "Building Code Requirements for Concrete Masonry Structures," American Concrete Institute, 1979.
24. Letter with attachment from John F. Stolz (NRC) to H. B. Tucker (Duke) dated March 14, 1985.

Subject:

Safety Evaluation Report on Masonry Wall Design

25. NCIG-01, Visual Weld Acceptance Criteria
26. PSAR, Supplement No. 4, Answer to Question 11.2, May 25, 1967.
27. PSAR, Supplement No. 4, Answer to Question 11.4, May 25, 1967.
28. PSAR, Supplement No. 4, Answer to Question 12.2, May 25, 1967.
29. PSAR, Supplement No. 5-11, June 16, 1967.
30. PSAR, Supplement No. 6-1, March 26, 1969.
31. M. S. Tuckman (Duke) letter dated November 11, 1998 to Document Control Desk (NRC),

"Response to Generic Letter 98-04: Potential Degradation of the Emergency Core Cooling System and the Containment Spray System After a Loss-of-Coolant Accident Because of Construction and Protective Coating Deficiencies and Foreign Material in Containment,"

Attachment 2.1 - UFSAR Mark-Ups License Amendment Request No. 2009-05 June 29, 2009 Page 4 Oconee Nuclear Station, Units 1, 2, and 3, Docket Nos. 50-269, -270, and -287.
32. Application for Renewed Operating Licenses for Oconee Nuclear Station, Units 1, 2, and 3, submitted by M. S. Tuckman (Duke) letter dated July 6, 1998 to Document Control Desk (NRC), Docket Nos. 50-269, -270, and -287.
33. NUREG-1 723, Safety Evaluation Report Related to the License Renewal of Oconee Nuclear Station, Units 1, 2, and 3, Docket Nos. 50-269, 50-270, and 50-287.
34. License Amendment No. 338, 339, and 339 (date of issuance - June 1, 2004); Adoption of Alternate Source Term.
35. Letter from Duke Power Company LLC d/bla Duke Energy Carolinas, LLC to U. S. Nuclear Regulatory Commission, "Oconee Nuclear Docket Numbers 50-269, 50-270, and 50-287 -

License Amendment Request to Incorporate Use of Fiber-Reinforced Polymer System to Strengthen Existing Auxiliary Building Masonry Walls for Tornado Loadings - License Amendment Request No. 2006-006," dated June 1, 2006.

36. Letter from Duke Power Company, LLC, d/b/a Duke Energy Carolinas, LLC, to U. S. Nuclear Regulatory Commission, "Oconee Nuclear Docket Numbers 50-269, 50-270, and 50-287 -

Duke Response to NRC Request for Additional Information in regard to License Amendment Request to Incorporate Use of Fiber-Reinforced Polymer System to Strengthen Existing Auxiliary Building Masonry Walls for Tornado Loadings - License Amendment Request No.

2006-006," dated March 14, 2007.

37. Letter from Duke Power Company, LLC, d/b/a Duke Energy Carolinas, LLC, to U. S. Nuclear Regulatory Commission, "Oconee Nuclear Site, Units 1, 2, and 3, Docket Numbers 50-269, 50-270, and 50-287, Duke Response to NRC Request for Additional Information in regard to License Amendment Request to Incorporate Use of Fiber-Reinforced Polymer System to Strengthen Existing Auxiliary Building Masonry Walls for Tornado Loadings, License Amendment Request No. 2006-006," dated October 8, 2007.
38. Letter from Duke Power Company, LLC, d/b/a Duke Energy Carolinas, LLC, to U. S. Nuclear Regulatory Commission, "Oconee Nuclear Site, Units 1, 2, and 3, Docket Numbers 50-269, 50-270, and 50-287, Duke Response to NRC Request for Additional Information in regard to License Amendment Request to Incorporate Use of Fiber-Reinforced Polymer System to Strengthen Existing Auxiliary Building Masonry Walls for Tornado Loadings, License Amendment Request No. 2006-006," dated October 30, 2007.
39. Regulatory Guide 1.76, Design-Basis Tornado and Tornado Missiles for Nuclear Power Plants, Revision 1.
40. Letter from U. S. Nuclear Regulatory Commission to Duke Power Company, LLC, "Oconee Nuclear Station, Units 1, 2, and 3, Issuance of Amendments Regarding Use of Fiber-Reinforced Polymer (FRP) (TAC Nos. MD2129, MD2130, and MD2131)" dated February 21, 2008.
41. Letter from U. S. Nuclear Regulatory Commission to Duke Power Company, LLC, "Correction to Amendment Nos. 360, 362, and 361 for Oconee Nuclear Station, Units 1, 2, and 3, (TAC Nos. MD2129, MD2130, and MD2131)" dated March 26, 2008.

ENCLOSURE 2 ATTACHMENT 2.2:

LIST OF REGULATORY COMMITMENTS

Attachment 2.2 - List of Regulatory Commitments License Amendment Request No. 2009-05 June 29, 2009 Page 1 The following commitment table identifies those actions committed to by Duke Energy Carolinas, LLC (Duke) in this submittal. Other actions discussed in the submittal represent intended or planned actions by Duke. They are described to the Nuclear Regulatory Commission (NRC) for the NRC's information and are not regulatory commitments.

Commitment' Completion Date Duke will perform qualification testing and reporting in accordance with Prior to initial ICC AC125 [Reference5 of Enclosure 2] for the selected FRP System.

installation of FRP system.

Duke will perform and document a technical evaluation of the FRP Prior to initial system (fibers and polymeric resin) in accordance with Duke's Supply installation of FRP Chain Directive SCD230 [Reference 7 of Enclosure 2] to demonstrate system.

that:

1. The item qualifies as a commercial grade item.

2: The supplier is capable of supplying a quality product.

3. The quality of the item can be reasonably assured.

Duke will utilize technical procedures to control testing of concrete Prior to initial substrate and installation and inspection of the FRP system in installation of FRP accordance with ICC AC 125 [Reference 5 of Enclosure 2], ACI 440.2R-system.

02 [Reference 6 of Enclosure 2], and ICC AC178 [Reference 8 of ].

Duke will perform long-term inspection of the FRP system as described Within 5 years of in UFSAR Section 18.3.13 and EDM-410, and in accordance with ICC completion of 1st AC125 [Reference 5 of Enclosure 2], ACI 440.2R-02 [Reference 6 of FRP-related station ], and ICC AC178 [Reference 8 of Enclosure 2], on a modification.

nominal 5 year interval. This inspection frequency may be reduced to a nominal 10 year interval with appropriate justification based on the structure, environment, and previous long-term inspection results.

Inspections of the installed FRP system will include:

  • visual inspections of test walls and selected portions of WPR walls for changes in color, debonding, peeling, blistering, cracking, crazing, deflections and other anomalies; and,

" tension adhesion testing of cored samples taken from test walls using methods specified in ASTM D4541 [Reference 9 of ] or ACI 530R-02 [Reference 16 of Enclosure 2].

ENCLOSURE 5 AFFIDAVIT OF DAVE BAXTER.

ENCLOSURE 5 AFFIDAVIT OF DAVE BAXTER

Affidavit of Dave Baxter License Amendment Request No. 2009-05 June 29, 2009 Page 1 AFFIDAVIT OF DAVE BAXTER
1. I am Vice President, Oconee Nuclear Station, Duke Energy Carolinas, LLC (Duke), and as such, have the responsibility of reviewing the confidential information sought to be withheld from public disclosure in connection with nuclear plant licensing and am authorized to apply for its withholding on behalf of Duke.
2. I am making this affidavit in conformance with the provisions of 10 CFR 2.390 of the regulations of the Nuclear Regulatory Commission (NRC) and in conjunction with Duke's application for withholding which accompanies this affidavit.
3. I have knowledge of the criteria used by Duke in designating information as confidential.
4. The Duke proprietary information sought to be withheld include the following two (2) technical documents that comprise Enclosure 6:

a) Technical Report No. IS-09-03, "Testing of Strengthening Brick Walls with FRP Sheets," prepared by the North Carolina State University Constructed Facilities Laboratory, Department of Civil, Construction, and Environmental Engineering, January 2009.

b) Independent Review Report, "Design of FRP Retrofit for Unreinforced Masonry Infill Panels - Oconee Nuclear Station - Comments on Design Specification and NCSU Panel Tests," prepared by Nigel Priestley, Principal, Priestley Structural Engineering.

5. Pursuant to the provisions of paragraph (b) (4) of 10 CFR 2.390, the following is furnished for consideration by the NRC in determining whether the information sought to be withheld from public disclosure should be withheld:
i. The information sought to be withheld from public disclosure is owned by Duke and has been held in confidence by Duke and its consultant, Fyfe Company, LLC.

ii. The information is of a type that would customarily be held in confidence by Duke and its consultant, Fyfe Company, LLC.

iii. The information was transmitted to the NRC in confidence and under the provisions of 10 CFR 2.390; it is to be received in confidence by the NRC.

iv. The information sought to be protected is not available in public to the best of our knowledge and belief.

Affidavit of Dave Baxter License Amendment Request No. 2009-05 June 29, 2009 Page 2
v. The proprietary information sought to be withheld from public disclosure is required for the NRC to completely and adequately conduct its review of Duke's License Amendment Request to incorporate use of a Fiber Reinforced Polymer (FRP) system to strengthen existing Auxiliary Building masonry brick walls for tornado loadings.

vi. Public disclosure of this information is likely to cause substantial harm to the competitive position of Duke's consultant, Fyfe Company, LLC, i.e., the information consists of detailed descriptions of portions of the design of Fyfe Company's FRP system the application of which provides a competitive economic advantage. The availability of such information to competitors would enable them to modify their product to better compete with Fyfe Company, LLC, take marketing or other actions to improve their product's position or impair the position of Fyfe Company's product.

Dave Baxter affirms that he is the person who subscribed his name to the foregoing statement, and that all the matters and facts set forth herein are true and correct to the best of his knowledge.

Dave xter, Vice President Oconee Nuclear Station Subscribed and sworn to before me this

  • day of 2009 tNotai'y Public..

My Commission Expires:

(a-lI2-2 -o)

Date

Retrieved from "https://kanterella.com/w/index.php?title=ML091871223&oldid=5313618"