ML102720912

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Williams Q&A - Request #3 Info-Pugh-PART 3
ML102720912
Person / Time
Site: Crystal River Duke Energy icon.png
Issue date: 10/29/2009
From:
Progress Energy Co, Progress Energy Florida
To:
Office of Information Services
References
FOIA/PA-2010-0116
Download: ML102720912 (97)


Text

PCHG-DESG E#Jginaering cQiange 0 006063016RO H.7 Review Comments (70% Design Challenge)

SProgress Energy Imemo Date: April 29, 2008 To:

Oates, Harry (Design Engr.)" Jones, David (Operations)

Burchett, Jon (Task MGR) Rothrock, David (Plant Licensing)

Siapno, Mike (ALARA) Young, Kenny (RP)

Mayes, David (Welding Engr.) Mueller, John (Coatings)

Powell, Sid (Reg. Affairs) Curham, Jack (Fire Protection)

Thompson, Rocky (Chemistry) Johnson, Ron (E&RC)

Finnell, Jeff (Materials) -Optional Rick Portmann (IWE/IWL)

Gartner, Bob (Safety) Harmon, Andy (Procurement)

Dyer, John (Move in/Move out) Mills, Doug (Safety)

Koralewski, Al (Security) Sam Franks (Bechtel)

Whetzel, Jim (Scheduling) Bill Nielsen (QA/QC)

Howell, Chris (maintenance) Stephenson, John D (Emerg. Plan.)

Kujak, Scott (MX sys. Engr.) - Optional

  • Harry to determine if anyone else in Design Engineering needs to attend this meeting.

Subject:

70% Design Challenge - EC 63016 The Steam Generator Replacement Project will be holding a 70% Design Challenge Tuesday, May 20, 2008 at 3.00pm in the SGR War Room (Northeast corner of the 2 nd floor SAB). This meeting will present EC 63016 "Containment Opening" at its 70%

completion stage. Short presentations will be given by the Hydrodemolition vendor (Mac & Mac) and the Tendon vendor (Precision Surveillance Corporation). This file can be found at:

\\Nt000104\nqlshare\Passport Workinq\CR3\EC\0000060K\0000063016R000 Prior to this meeting, attendees are expected to review the EC through Passport and provide any input / comments deemed applicable to the development of the EC Design Package and the successful installation of the modification.

Any significant input / comments should be provided to me by 5/15/08 (2 work days prior to the meeting) so that they can be addressed in the meeting.

If you are an addressee, your group's participation in the Design Challenge is considered to be necessary in order to assure the various aspects of this EC are fully considered and are addressed.

Progress Energy Florida, Inc.

H03 Reviews Page 1 of 31 0(91

PCHG-DESG Engineering Change 0000063016R0

~ Progress Energy memo Page 2 Date: April 29, 2008 Please plan on attending or have you representative attend in your place. However, after a review of the package, you conclude your sub-group will not significantly contribute to the Challenge, inform Magdy Bishara via e-mail to request a waiver.

If you are CC'd, this invitation is for information only and attendance is at your discretion. Please feel free to contact me-with any questions.

John Holliday, Ext. 1526 EC 63016 Responsible Engineer Steam Generator Replacement Project CC:

Terry, Jim Bishara, Magdy Jopling, Dan Swenson, Scott Larramore, Loyd Lese, Joe Allen, Parks R Howard, Tim Akins, Bryant Bracewell, Mary Santonastaso, Lou Kujak, Scott Hughes, Lee Brewer, Bill Foster, Berry Whisler, jeff Keeney, Neil Salton, Jim H03 Reviews Page 2 of 31

PCHG-DESG Engineering Change 0000063016RO From: CR-SGR To: Oates, Harry B.; Burchett, Jon; Siapno, Michael M.; Mayes, David; Powell, Sid; Thompson, Rocky H; Finnell, Jeffrey L.; Gartner Jr, Robert H; Dyer, John; Koralewski, Alvin; Whetzel, James L; Howell, Chris; Jones, David; Rothrock, David; Young, Kenneth G; Mueller, John; Curham, John J.; Johnson, Ron; Portmann, Rick; Harmon, Andy; Mills, Douglas F; Franks, Sam; Nielsen, William J.;

Stephenson, John D. - (CR3); Kujak, Scott; cc: Terry Jr, James H.; Bishara, Magdy M.; Jopling, Daniel L.; Swenson, Scott; Larramore, Loyd; Lese, Joseph A.; Allen, Parks R; Howard, Timothy R; Akins Jr, Leon B.; Bracewell, Mary; Santonastaso, Louis J; Hughes, Lee; Brewer, William I.; Foster, Berry J; Whisler, Jeff; Keeney, Neil; Salton, James;

Subject:

Containment Opening 70% design challenge (EC63016)

Start: Tuesday, May 20, 2008 3:00:00 PM End: Tuesday, May 20, 2008 5:00:00 PM Location: SGR War Room Attachments: 70% Challenge LE[TER.doc Gentlemen, The 70% design challenge for EC63016 "Containment Opening" will be in the SGR War Room Tuesday, 5-20-08, 2nd Floor SAB and will start @ 3:00pm.

Please provide any constructive comments or bring to the meeting for discussion.

Thank you, John Holliday x1526

<<7</0% Challenge LETTER.doc>>

H03 Reviews Page 3 of 31

PCHG-DESG Engineering Change 0000063016R0 Page 1 of 3 Design Challenge EC 63016 Title Containment Opening Date May 20, 2008 Critical Attendees Name Organization Signature Phone Oates, Harry (or designee) Supt-Design Engineering Curham, Jack Fire Protection Waiver appro ed b" .B.*

Harmon, Andy Nuc Eng & Services Howell, Chris Maintenance A-1 Maj. Proj. Environ.

Johnson, Ron Specialist Jones, Dave Maj. Proj Operations ' -. 7 Jopling, Dan Eng Supv, Civil Lead-, / -7/

U Kenny Young Rad Waste Koralewski, Al Maj. Proj Sec. Spec. *-'

Scott System Engineer-Kujak, SMisc. Struct.

Mayes, David Welding Engineer Mike Siapno Maj. Proj - ALARA 1040 Powell, Sid Maj. Proj. Lien.

Whetzel, Jim SGR Scheduling Byers, John Proj. Task Mgr DyerJohnTM - Health &

Safety 1&g Finnell, Jeff Materials Engr.

Thompson, Rocky Chemistry Burchett, Jon Task Manager Gartner, Bob Safety 2 1 Rothrock, David Plant Licensing . 3J' Portmann, Rick IWE/IWL Engr. I

  • Magdy Bishara

~~1 UAMy Documents\SGR\EC 63016 Containment opening\70% design challenge\70%

Design Challenge Attendence.doc H03 Reviews Page 4 of 31

PCHG-DESG Engineering Change 0000063016R0 Page 2 of 3 Design Challenge EC 63016 Title Containment Opening Date May 20,2008 Critical Attendees Name Organization Signature Phone Mills, Doug Safety Franks, SamEnr_____ Bechtel Proj. Field, ,

Engr. fa**t, ,,

Nielson, Bill QA/QC Stephenson, John Supv. Emergency Waiver approved by M.B.*

Stephenson, __JohnPreparedness Mueller, John Coatings Engr.

1. A. "
3. 5,t13)uppwý C-'~_ _

vuWa5Oji -SIreve - u+-TEL _ _

Design '

hallenge Atd

- X4Z11

  • Magdy Bishara.

U:\My Documents\SGR\EC 63016 Containment opening\70% design challenge\70%

Design Challenge Attendence.doc H03 Reviews Page 5 of 31

PCHG-DESG Engineering Change 0000063016RO Page 3 of 3 Design Challenge EC 63016 Title Containment Opening Date May 20, 2008 Optional Attendees U:\My Documents\SGR\EC 63016 Containment opening\70% design challenge\70%

Design Challenge Attendence.doc H03 Reviews Page 6 of 31

PCHG-DESG Engineering Change 0000063016RO 70% Design Challenge Meeting Minutes Note: For 30% Challenge Reviewer Comments See H02R0 Attendance sheet (See Sheets 4 & 5)

Safety and Human Performance messages will be given by Scott Swenson o Core Design Team and Task Manager introduction John Holliday - (RE) Structural Design Engineer 1526 Jon Burchett - Containment Opening Task Manager 1036 Rick Portman - Tendon System Engineer 3440 Dave Mayes - Welding Engineer 1508 Mike Siapno - ALARA 1040 Andy Harmon - Procurement 4361 Sid Powell - Licensing 1506 Dave Jones - Operations 1507 Sam Franks - Installer 1027 Jim Whetzel - Scheduling 4184 Also introduce core vendors:

Mac and Mac Hydrodemolition: Dave McNeil, Jerry McNeil and Brent Waldie PSC (Tendons): Paul Smith and Christopher Cox Task Manager: Jon Burchett Dan Jopling will be recording notes/Action Items.

o Include some type of visual aid (handout or overhead)

Conference room computer overhead projector.

Slide show presented by John Holliday Slide show presented by Mac and Mac Slide show presented by PSC o Scope

  • Create a temporary access opening in the post tensioned containment wall and steel liner plate directly above the 22'-7 !/2" diameter equipment hatch, located at the 150 degree azimuth.

" Restoration of the temporary access Opening so that the containment shell is returned to a condition that meets or exceeds its original design basis acceptance criteria.

o Basic Design Considerations:

H03 Reviews Page 7 of 31

PCHG-DESG Engineering Change 0000063016RO To return the containment to a condition that meets or exceeds its original design basis acceptance criteria.

  • Use materials that are compatible with the existing materials.
  • Account for the difference in material properties between the old and new concrete, specifically the creep differential.

o Significant open items.

  • AREVA has been contracted to investigate containment closure requirements during a LODHR accident. Specifically, this may result in (i) the ability to cut the liner plate while still defueling and (ii) start refueling before the liner plate has been welded in place, tested and inspected.
  • Engineering is investigating eliminating radiographic testing of the liner plate welds.

" Engineering is investigating the alternatives to performing an ILRT (substitute leak chase channels).

o Previous meeting results/action items and how each was addressed.

See H02 for 30% Design Challenge comments and resolution o Open discussion.

Various comments were discussed and resolved to the satisfaction of attendees.

Unresolved comments were added to Action Item List.

Individuals were asked and no further comments were obtained.

o Action Item List and Reviewer Comments follow:

70% Design Challenge Meeting Action Items 5/20/08 N I H03 Reviews Page 8 of 31

PCHG-DESG Engineering Change 0000063016RO I Ite 1

Comn Evaluate the possibilities for a saw cut Resolution Added requirements for a saw cut to scribe at the opening outline. Provide Section B.6.10 technical justification if applicable 2 Insure the tendon testing program Reviewed plan with Rick Portmann. The engineer is in agreement with plans to work platforms are designed for seismic and hurricane loads while stationary and install the test rigs pre outage. Address when moving on the rail system and placing the equipment (or not) over the therefore pose no danger to the BWST.

BWST Additionally, the BWST tank is almost 25' away from the outside edge of Buttress #4, so even if the platform fell it cannot hit the top of the tank. The sodium hydroxide storage tanks, just north of the BWST are enclosed by 2'-2" thick reinforced concrete wall and roof enclosure that is a Class I structure, therefore missile protected. The northernmost edge of this structure is 9'-1 5/8" south of the outside edge of buttress

  1. 4. Safe load paths have been developed for the Manitowoc 2250 crane that will be lifting the platforms into position on top of the RB roof (Ref. 63016 SK-SO01).

3 Evaluate the need for an air flow Liner plate will not be cut until defueling restriction at the opening while moving is complete.

fuel. This assumes AREVA will be able to validate the ability to cut the line plate prior to defueling.

4 If the channel pressure test is used the EC Channels will not be used. An ILRT in needs to address the unpainted steel under conjunction with 100% visual, vacuum the channel. box and MT will be employed in verifying the liner plate weld and containment leak tightness.

5 Make sure the hurricane protection plan Reviewed the violent weather protection and the hurricane limits and precautions plan and the EC is in agreement.

in the EC are in agreement.

6 The EC needs to specify the acceptable Maximum form tie spacing is has been form tie spacing. addressed in Section B.6.10 7 Discuss the joint efficiency and Discussed with David Mayes (welding approaches for eliminating RT with the engr) & Rick Portmann. The RT of the ISI lead. liner plate welds is being eliminated based on ECED 70586 (Cont. Opng Liner Plate Reconciliation doc.)

H03 Reviews Page 9 of 31

PCHG-DESG Engineering Change 0000063016RO Disiln/rga Reie Scp of Review.

Multi-Discipline 70% Design Challenge EC63016 R. Pinner/R. Thompson Multi-Discipline 5/20/08 Section A.5.1.4 page 10 of 33: 1st Grease has a high viscosity and will not paragraph: What are the spillprevention flow if spilled. Plastic sheeting will be measures that will be taken? taped to the tendons gallery floor and side walls.

2 Section A.5.1.12 page 17 of 33: Water The containment opening task plan is Requirements: Where is the "Task located at (\\nt000190\NGGData\iajor Opening Plan"? Who is responsiblefor Projects\CR3 eLibrxary SGR\! SGR ensuring the water supply is available? Documents\SGR Detailed Task Plans.

The Containment Opening Task Manager is responsible for water supply and disposal.

3 Section A.5.1.13 page 17 of 33. Sentence Per Mike Siapno all testing for radioacti ve which reads: "Discharge of the water and contamination will be done at the rubble may continue uninterrupted while collection tanks, prior to diverting the samples are being tested and analyzed": water to the water treatment plant.

The collected water must be sampled and Discharge of the water and rubble may analyzed before the first release of water continue uninterrupted while samples are to the settlingpond. The tritium and being tested and analyzed.

gamma analyses can be done in parallel, but will take -1 hour to perform. Oil and Per agreement between Carolyn Johnson, grease analysis, if this is required,will Ron Johnson and Corporate EHSS take up to 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> to perform. Ron specialist (Doug Yowell) the following Johnson to get with CarolynJohnson to testing is required:

see why she thinks oil & grease analysis Only pH sampling will need to be is necessary. performed as a pre-requisite for discharge.

Contractor should strive to keep the pH between 6.0 and 9.0 (added in installation instructions). Periodic sampling of pH will be needed. A "stop job" limit will be established at pH less than or equal to 2, or pH greater than or equal to 12.5.

Recommend that laboratory samples for pH, TSS, and Oil & Grease be collected at about 3 times during project (start, middle, end), and results placed in project file and plant file. These samples are for documentation only, and would not H03 Reviews Page 10 of 31

PCHG-DESG Engineering Change 0000063016RO require batch processing of the wastewater, or delay transfer. Grease and oil will be captured in Tank #3 thru absorbent booms.

4 Section A.5.1.13 page 17 of 33. Who will Radiation protection will be responsible do the radiologicaltesting of the rubble for radiological testing of the rubble.

mentioned in the 2 nd paragraphfrom the bottom of the page. Radiation Protection?

5 Section A.5.1.13 page 17 of 33. Last Refer to Item #3 above.

sentence of the page: "Water will be tested before discharge to the settling Only pH sampling will need to be ponds..."Chemistry will collect a sample performed as a pre-requisite for discharge.

before the first releasefrom the last Contractor should strive to keep the pH collection tank to the settlingpond. between 6.0 and 9.0. Periodic sampling of Tritium andgamma analysis of the water pH will be needed. A "stop job" limit will sample will be peformed BEFORE the be established at pH less than or equal to first releasefrom the last collection tank 2, or pH greater than or equal to 12.5.

is made to the settlingpond. The last tank Recommend that laboratory samples for will be sampled once per shift after the pH, TSS, and Oil & Grease be collected at first release is made, but subsequent about 3 times during project (start, releases to the settlingpond will not have middle, end), and results placed in project to waitfor the analysis of these samples. file and plant file. These samples are for Carolyn Johnson will also requirepH, documentation only, and would not total supspended solids, and oil and require batch processing of the greaseanalyses of the last collection tank wastewater, or delay transfer.

to be performedBEFORE the first release is made to the settlingpond, and once per shift after the first release is made. Ron Johnson to get with Carolyn to find out hwy TSS and 0 & G are necessary.

6 Section A.5.1.13 page 18 of 33: Have Ron Yes.

Johnson's two comments at the top of the page been resolved?

7 Section A.5.1.15 page 19 of 33: Paragraph The floor drains in the tendon gallery at the top of the page. What happens to must be blocked. Water draining from the the water that has draineddown the tendon sheaths will drain to the tendon tendon sheaths and is collected in the 55 gallery sump from where it will be gal. drums in the tendon gallery? It pumped by Bechtel out of the tendon CANNOTgo to our normalfloordrains, gallery to Mac and Macs water treatment plant before discharge to the settlement ponds. Sump pumps SDP-3A and SDP-3B must be turned off/disabled immediately prior to the start of hydrodemolition. According to PSC, the primary purpose of the 55 gallon drums H03 Reviews Page 11 of 31

PCHG-DESG Engineering Change 0000063016RO placed in the gallery is to collect any large concrete fragments and dissolved solids.

Typically, in other SGRs these drums overflow with water which is collected in

+ 4 the gallery sump and pumped out.

8 Section B.4.6 Environmental Conditions: Instructions for water delivery, storage Can the settlingponds handle the 700K to and the means of piping it to and from the 2000K waste water that will be produced containment will be addressed in the over a three day period? Can the drain relevant work orders. The containment line from CR-3, which is old, be reliably opening Task Manager is responsible for usedfor this application?Who is investigating and verifying that the coordinatingwith MPW, the water settling ponds have adequate storage for providing vendorfor CR-3, to provide the the expected 2 million gallons of waste 2 million gal. of water neededfor this water.

project?

9, Section B.4.12 Chemistry Requirements: Refer to Item #3 and #5 above.

Chemistry will collect a sample before the Waste grease is managed by PSC in first releasefrom the last collection tank accordance with the "Waste Vendor to the settlingpond. Tritium and gamma Program" corporate policy (EVC-SUBS-analysis of the water sample will be 00107). PSC has contracted Heritage performed BEFORE the first releasefrom Disposal to collect the grease and to the last collection tank is made to the dispose of it by burning. Heritage is in the settlingpond. The last tank will be process of becoming an approved PE sampled once per shift after the first vendor. All documentation generated as release is made, but subsequent releases part of the disposal, e.g., manifests, to the settlingpond will not have to wait disposal certificates, etc, will be provided for the analysis of these samples. Carolyn to the CR3 waste coordinator (Brian Johnson and Ron Johnson to decide ifpH, Wood, currently).

total supspendedsolids, and oil and grease analyses of the last collection tank is requiredto be performed BEFORE the first release is made to the settlingpond, and once per shift after the first release is made. Tritium + gamma must be < 1 ECL before first release can be made.

Where does the greasego from the tendons being cut?

How is the water handled that goes down the tendon sleeves into the tendon gallery?

10 B.6.6 Environmental Conditions: What is The portable waste water treatment the water treatmentperformed by the facility consists of three 20,000 gallon water treatment skid provided by Mac and tanks that can treat up to 360 gallons of Mac? Can the treated water be sampled? water per minute. These tanks will be Is there a volume integratorthat tracks sampled by RP for radioactive material the total water volume being treated? prior to their use to establish that they are H03 Reviews Page 12 of 31

PCHG-DESG Engineering Change 0000063016RO clean. Treatment basically consists of a four step process of settling, flocculation, pH measurement and adjustment, and the capture of grease (if present) in grease traps before discharge. Grease and oil will be captured in Tank #3 thru absorbent booms. Disposal of the grease is PSCs responsibility.

Water in each of the tanks can be sampled.

11 B.6.12 Chemistry Requirements: Ist RP Laboratory changed to Chemistry paragraphtop ofpage 60, reword Laboratory.

sentence "Samplesfor radiological Refer to Item #3.

testing and analysis will be ... tested at the Ron Johnson has discussed discharge on-site Chemistry", not RP, "laboratory". requirements with Carolyn Johnson and With regardto the sentence "Discharge Brian Wood and the corporate EHSS of water and rubble may continue specialist Doug Yowell.

uninterruptedwhile samples are being tested and analyzed", it should be noted that the release of thefirst batch from the last tank will be not be permitted until it has been sampled and analyzed to ensure that it is OK to release.R. Pinnerwould like to see the "Containment Opening RP Task Plan" referenced in this section.

Who in the Environmental Group has confirmed that dischargingthe hydrodemolition waste water after treatment by Mac and Mac is allowed by the Industrial Waste Water Permit?

Multi-Discipline 7 770%Design Challenge EC63016 J. Whisler D. Fletcher Multi-Discipline 5/20/08 H03 Reviews Page 13 of 31

PCHG-DESG Engineering Change 0000063016RO SFFranksIIII I Need installation instruction in section Provided.

D.2 "Installation Instructions" 2 How do we protect the sheathing opening, Refer to Section A.5.1.15 for a discussion FME concern. Section A.5 concerning when and how to protect the sheaths. Also refer to Item #10.

4 What about partial degreasing of Hoop tendons cannot be partially horizontal tendons A.5.1 task 1 item 4 degreased. Only about 60 gallons out of a total of approximately 150 gallons is expected to drain from the vertical tendons with the aid of gravity. When the end caps are removed from the hoops, a negligible amount of grease is expected to drain. Grease must be removed from the hoops during and after hoop tendon removal.

5 Full size mock up will not be required. Per John Byers a full size mock-up of the Need to address. Latest from Task containment opening is required.

Manager. A.5.1.1 6 Need Field & Quality inspection PSC will provide.

procedures from PSC. A.5.1.1 7 Need storage requirements specified for This EC will not specify storage concrete constituent materials. requirements. Materials will be delivered A.5.1.3 to the site prior to EC issue.

8 VT-Is and VT-1Cs need to be addressed Addressed in the installation instructions in installation instructions. Verify IWL (Section D.2.2.1-2b) and PSC Manual not required on vertical and hoop tendons. "Post Tensioning System Field and A.5.1.5 Quality Control Procedure Manual" contained in Attachment Z24 (Ref. AR

  1. 00285173) 9 Recommend witnessing platform load This is a recommendation from Bechtel capacity tests at PSC A.5.1.9 and will be discussed with Project management.

10 Review the need to protect the horizontal PSC has recommended not plugging the and vertical sheathing openings during vertical tendon sheaths during hydro demolition A.5.1.13 hydrodemolition. PSC has recommended that plywood covers be bolted to the hoop bearing plates to mitigate water extrusion.

11 Leave fit-up devices on liner partially Section B.6.9 addresses temporary fit-up installed. Cut-off approximately V2" devices and the installation instructions above the liner plate. A.5.2.2 have been updated to include installation and removal instructions.

12 Make sure rebar can touch the steel liner After a discussion with Jeff Whisler

- -plate. A.5.2.5 (originator of this comment) it was H03 Reviews Page 14 of 31

PCHG-DESG Engineering Change 0000063016RO decided that the additional #11 rebars that are being added adjacent to the liner plate will not physically touch the liner plate.

13 Require installation instructions for These Sections were not completed when A,5.2.9 - A.5.2.12 reviewed. Refer to Item #1.

I DicpiePoganRve Sco. of Reie I Rad Control/ALARA 170% I Ite Raden Contoo/AAtAio70 H03 Reviews Page 15 of 31

PCHG-DESG Engineering Change 0000063016RO I How will the tendon grease be Tendon grease is captured in 55 gallon captured, stored and disposed? We drums. The grease has a high viscosity and need to ensure all grease in tendon will not flow if spilled. Plastic sheeting will gallery does not go to floor drains. be taped to the tendons gallery floor and side walls (installation instructions have been revised - Section D.2.1.1 - to include adding plastic sheeting in the gallery). Waste grease is managed by PSC in accordance with the "Waste Vendor Program" corporate policy (EVC-SUBS-00107). PSC has contracted Heritage Disposal to collect the grease and to dispose of it by burning. Heritage is in the process of becoming an approved PE vendor.

All documentation generated as part of the disposal, e.g., manifests, disposal certificates, etc, will be provided to the CR3 waste coordinator (Brian Wood, currently).PSC manages waste grease disposal The floor drains in the tendon gallery must be blocked. Water draining from the tendon sheaths will drain to the tendon gallery sump from where it will be pumped by Bechtel out of the tendon gallery to Mac and Macs water treatment plant before discharge to the settlement ponds. Sump pumps SDP-3A and SDP-3B must be turned off/disabled immediately prior to the start of hydrodemolition. According to PSC, the primary purpose of the 55 gallon drums placed in the gallery is to collect any large concrete fragments and dissolved solids.

Typically, in other SGRs these drums overflow with water which is collected in the gallery sump and pumped out.

2 Comment from 30% review states liner Refer to RP Task Plan and associated work plate will be taken to storage facility orders.

for contaminated repair. Provisions must be provided to wrap or contain the liner plates during the, I transportation process.

H03 Reviews Page 16 of 31

PCHG-DESG Engineering Change 0000063016RO 3 Concrete wall debris should be non- A safety net will be erected to contain any contaminated but must be collected in debris resulting from hydrodemolition such a manner to not allow debris activities (Refer to installation activities pieces to be strewn on the berm. Section D.2.1.3). Refer to Section B.6.6 and Concrete will be analyzed prior to B.6.12 an evaluation of the requirements for release from RCA. testing the concrete debris and waste water.

4 How is negative pressure on the Liner plate remains intact during building maintained during hydro- hydrodemolition activities, therefore no demolition? impact on containment pressure.

Need to ensure main RB purge is Operations is responsible for the operation of running once liner is cut. the RB Purge fans, both before and after the liner is cut (ref. David Jones - Operations) 5 Operations & HP must be notified Refer to Section B.6.7 prior to start of hydro-demolition.

H03 Reviews Page 17 of 31

PCHG-DESG Engineering Change 0000063016RO 6 How will the project ensure operations Breaching of the RB liner should be handled does not vent in containment during in. a manner similar to other large RB the liner breach? If a vent were to breaches (i.e. Personnel and Equipment occur, the release needs to be Hatch opened). The CR-3 Offsite Dose contained (system piped). Calculation Manual (ODCM) currently contains the plants radioactive effluent controls and radiological monitoring program and specifically ODCM Representative Sampling Method No. 3.1-5 already addresses radiological controls when large openings to outside atmosphere are created in the Reactor Building. The ODCM list requirements such as:

  • The. Reactor Building purge exhaust fans are operational
  • The Reactor Building supply fans are shut down
  • If the purge exhaust must be shut down then either the personnel hatch or equipment hatch openings must be closed
  • Monitor the Reactor Building recirculation system by using RM-A6 or by taking general area air samples.

Other considerations to be considered when the liner is breached are:

" Run the main purge long enough to assure cleanup of the RB atmosphere

A precaution has been added in the installation instructions (Section D.2.1.3) that Operations must be aware that any venting of radioactive material in the RB must with the containment breached must be handled in accordance with the CR3 Offsite Dose Calculation Manual (ODCM).

7 HP needs to take air samples during Refer to Section A.5.1.16.

the containment breach process. Prior to cutting the liner plate the following is required:

Appropriate radiological postings installed outside the access Opening Personnel monitoring and air monitoring equipment (radiological) installed and operational outside access Opening.

H03 Reviews Page 18 of 31

PCHG-DESG Engineering Change 0000063016RO 8 HP needs to verify air flow from Not applicable to this EC. However, RP will outside to inside during containment continuously monitor and sample the air at breach. the Opening. Refer to the RP Task Plan for specific information regarding this subject.

9 Understanding that most SGRs start Not applicable to this EC. Refer to the RP the RCA at the dome penetration, CR3 Task Plan.

will have most of the area between the MSB and OSB (to be removed) posted as a RCA. Currently, Station HP does not see this as a time restraint for releasing the large equipment planned in this area. The equipment will be evaluated and surveyed as necessary. I 10 Until concrete analysis indicates Radiation protection will be responsible for concrete is free of radioactivity, radiological testing of the rubble. Samples control of equipment and water is for radiological testing and analysis will be necessary. Water must be collected taken at the collection bins and tested at the and analyzed prior to its release. on-site RP laboratory. Discharge of the water Further discussions are necessary and rubble may continue uninterrupted while between NPC and the Station HP to samples are being tested and analyzed. Refer talk about sampling methodology, to the Containment Opening RP Task Plan location of tank(s) and release of for specific details on handling and testing of water. Chemistry plans to sample the waste generated during hydrodemolition.

water prior to release to settling ponds The large concrete fragments and fine for radioactivity and NPDES particles that accumulate in the collection parameters and will periodically tanks are periodically sucked out by a sample thereafter. What is to be done vacuum truck and hauled off-site to a landfill with the concrete slurry/sludge? or may be used for beneficial on-site construction purposes, such as road building or for drainage ditches.

Only pH sampling will need to be performed as a pre-requisite for discharge. Contractor should strive to keep the pH between 6.0 and 9.0. Periodic sampling of pH will be needed.

A "stop job" limit will be established at pH less than or equal to 2, or pH greater than or equal to 12.5.

Recommend that laboratory samples for pH, TSS, and Oil & Grease be collected at about 3 times during project (start, middle, end),

and results placed in project file and plant file. These samples are for documentation only, and would not require batch processing of the wastewater, or delay transfer.

H03 Reviews Page 19 of 31

PCHG-DESG Engineering Change 0000063016RO I aicpie/ a Rev iew Scop of Reie Environmental, Chemical 70% Design Challenge EC63016 Control, Waste Reiewe I Dicpln Dat Tunoe Required?

Carolyn Johnson Multi-Discipline 5/19/08M Ite Comn Resolution 1 The Environmental Specialist for NPC is Per agreement between Carolyn Johnson, Ron Johnson. We have both discussed Ron Johnson and Corporate EHSS this project with Corporate EHSS and specialist (Doug Yowell) the following Ron will be taking the lead so all testing is required:

questions should be addressed to him. If Only pH sampling will need to be he has questions concerning the plant, he performed as a pre-requisite for discharge.

will contact Carolyn Johnson, the CR3 Contractor should strive to keep the pH Plant Environmental Specialist. between 6.0 and 9.0. Periodic sampling of However, pH, TSS, oil/grease need to be pH will be needed. A "stop job" limit will performed due to operational and sludge be established at pH less than or equal to concerns in the pond. Oil/grease are 2, or pH greater than or equal to 12.5.

major concerns due to the tendons-must Recommend that laboratory samples for keep this out of the water. pH must be pH, TSS, and Oil & Grease be collected at measured to ensure this is not hazardous about 3 times during project (start, waste. TSS is a concerns for equipment. middle, end), and results placed in project file and plant file. These samples are for documentation only, and would not require batch processing of the wastewater, or delay transfer.

Mac and Macs water treatment plant consists of three 20,000 gallon tanks. Per discussion with Rudy Pinner and Mike Siapno, samples can be taken from the first tank if the tanks are sampled by RP for radioactive material prior to use to establish that they are clean. Grease and oil will be captured in Tank #3 thru absorbent booms.

2 What size containers will be used to hold Mac and Mac may provide either a the water from the hydrodemolition containment area or an individual process? How many will be available? container that they will size based on the expected volume of waste water and concrete.

4 It does not appear that this meets the Total amount of water is 2,000,000 Water Management conservation gallons (conservatively). Cannot recycle requirements for water SWFWMD. What water due to excessive treatment costs, is the accurate quantity of wastewater that possibly employing new technology and is expected from this process? Why are processes and resulting risk to project we not implementing conservation for this schedule.

H03 Reviews Page 20 of 31

PCHG-DESG Engineering Change 0000063016RO process? Is there a way to recycle or conserve? This appears to be irresponsible environmental conservation.

5 I don't see chemical control addressed in Done.

this. Refer to CHE-NGGC-0045.

6 What is the quantity of new grease that There will be 9000 gallons of new grease will be purchased and what is the quantity delivered to the site in a road tanker.

of grease waste that is expected from the There will be approximately 150 drums of tendons? What is the plan for disposal? waste grease. Waste grease is managed by PSC in accordance with the "Waste Vendor Program" corporate policy (EVC-SUBS-00107). PSC has contracted Heritage Disposal to collect the grease and to dispose of it by burning. Heritage is in the process of becoming an approved PE vendor. All documentation generated as part of the disposal, e.g., manifests, disposal certificates, etc, will be provided to the CR3 waste coordinator (Brian Woods, currently).

7 Coatings on support components supplied The coating in question is applied by PSC by vendors must be removed and to the tendons prior to shipping. This replaced-how will this be done? What is coating does not have to be removed. The the process? This is unnecessary waste. coating "1601 Amber" is the same coating What are the coatings comprised of? used in original construction and is 100%

compatible with the tendon grease.

8 Storm drains near this project must be Refer to Section A.5.1.6 covered 9 Will there be spillage onto the berm? The 55 gallon drums of waste grease are How will this be handled? sealed and loaded onto pallets (usually 4 to a pallet) where they are banded and then loaded onto a trailer and hauled off site. The hauler will secure the pallets and tie a tarp over them for added security.

Hence no grease spills should occur on the berm. Waste water is piped by Mac and Mac from the containment opening to their waste treatment facility located west of the plant.

10 Concrete Batch Plant-I received a call on The batch plant is outside the scope of 5-14-2008-chemicals not approved and this EC. Refer to the Containment being ordered. Has this operation and Opening Task plan and associated work process been thoroughly reviewed-many orders for details.

gaps are identified. Where will this be?

How will these chemicals or supplies be stored? What waste will be created?

H03 Reviews Page 21 of 31

PCHG-DESG Engineering Change 0000063016RO How will the personnel be protected?

Chemical approval permits need to be submitted to ensure this is controlled properly.

11 Before wastewater from the Refer to Item #1.

hydrodemolition is pumped to any pond, it must pass all analytical testing that is established by Ron Johnson and Chemistry 12 All diesel used on site and equipment Include in the work orders.

brought on site must be reviewed by the NPC Environmental Specialist to ensure compliance with Air Permits. If necessary per the permit, this data will be provided to the CR3 Environmental Specialist 13 Section 12. Is this correct? Discharge of Yes.

the water and rubble may continue Per Mike Siapno radiation protection will uninterrupted while samples are being be responsible for radiological testing of tested and analyzed. the rubble. Samples for radiological testing and analysis will be taken at the collection bin/containment area and tested at the on-site RP/chemistry laboratory.

Discharge of the water and rubble may continue uninterrupted while samples are being tested and analyzed. The large concrete fragments and fine particles that accumulate in the collection tank/containment area are periodically sucked out by a vacuum truck before final disposal. Debris will be hauled off-site to a landfill or may be used for beneficial -

on-site construction purposes, such as road building or for drainage ditches.

14 The plan from the contractor needs to be Treatment of the waste water is planned identified in this document. per the discussion contained in Item #1 and 13 15 The sludge orslurry that is vacuumed, RP will take samples for testing before where is it going to be disposed and is it releasing to the Vacuum truck. Debris will going to be analyzed? be hauled off-site to a landfill or may be used for beneficial on-site construction purposes, such as road building or for drainage ditches.

16 No grease or oily water from the tendons Tendon grease is captured in 55 gallon H03 Reviews Page 22 of 31

C, PCHG-DESG Engineering Change 0000063016RO to floor drains in the plant. This will drums. The grease has a high viscosity cause exceedances for the NPDES permit. and will not flow if spilled. Plastic sheeting will be taped to the tendons gallery floor and side walls. Waste grease is managed by PSC in accordance with the "Waste Vendor Program" corporate policy (EVC-SUBS-00107). PSC has contracted Heritage Disposal to collect the grease and to dispose of it by burning.

Heritage is in the process of becoming an approved PE vendor. All documentation generated as part of the disposal, e.g.,

manifests, disposal certificates, etc, will be provided to the CR3 waste coordinator (Brian Wood, currently).PSC manages waste grease disposal The floor drains in the tendon gallery must be blocked. Water draining from the tendon sheaths will drain to the tendon gallery sump from where it will be pumped by Bechtel out of the tendon gallery to Mac and Macs water treatment plant before discharge to the settlement ponds. Sump pumps SDP-3A and SDP-3B must be turned off/disabled immediately prior to the start of hydrodemolition. According to PSC, the primary purpose of the 55 gallon drums placed in the gallery is to collect any large concrete fragments and dissolved solids.

Typically, in other SGRs these drums overflow with water which is collected in the gallerv sump and pumped out.

H03 Reviews Page 23 of 31

PCHG-DESG Engineering Change 0000063016RO Dicpi ne/PrograraR.view Maintenance 70% Design Challenge EC63016 I I Reiee Dicpln a

  • I.

Dat Tunoe S

  • I Chris Howell Multi-Discipline 1 5/20/08 1 I Item Comn Resouion*

I Does the EC identify SP affected due to SP- 182, RB Structural Integrity Tendon new tendons installed and tensioned. B. 15 Surveillance, has been added to the ADL.

The procedure will be affected due to the new tendons and revised predicted tendon losses.

2 EC should give specific plans for water The appropriate work orders will detail source, storage and delivery the requirements for water delivery, storage and the means of piping it to and from the containment. The containment opening Task Manager is responsible for determining if the settling ponds have adequate storage for the expected 2 million gallons of waste water. ECED 59400 identified the possible source of this water as the well fields located to the east of CR3, operated and maintained by the fossil group at Crystal River South (CRS). Well water would be diverted through existing CRS plant piping or temporary piping to one of the existing abandoned oil storage tanks (Cap.

8,000,000 gallons) which have been successfully used in the past by CRS to satisfy requirements for bulk water storage for other high water demand projects. Water from this storage tank will then be pumped either via temporary piping or existing available plant piping to the hydrodemolition equipment located at the containment access Opening.

3 B.7 Mechanical Maintenance review is Corrected sentence accordingly.

for any impact to Plant Maintenance, not for the installer.

4 Should the EC specifically identify the Section A.5.1.10, B.6.10 and the tendons being detensioned and removed installation instructions identify which during Mode 1 thru 4. three vertical tendons can be removed during modes 1 thru 4.

Sorry I'm sending you comments this Spoke to Jeff Finnell (Materials Engineer)

H03 Reviews Page 24 of 31

PCHG-DESG Engineering Change 0000063016RO way, but I couldn't get the review file to about the requirements for design work in Passport. The design spec reconciliation. Section B.6.8-c contains an mentioned the substitution of A514 Grade explanation about the substitution of Q for Grade E or SSS-100, and later ASTM A524 Grade Q material for SSS-mentions substituting A615 Grade 60 for 100, ASTM A514 Grade E material.

Grade 40. Just wanted to ask if a material Attachment Z01RO contains an evaluation design reconciliation had been done for by Jeff Finnell as to the acceptability of these substitutions. Thanks. this substitution. Section B.6.8-h contains Received 5/21/08 from Jim Derrico an evaluation of the acceptability of using Grade 60 material versus Grade 40 material for the concrete reinforcement steel. Jeff Finnell believes that these evaluations are adequate to justify the material substitution and no further reconciliation is required (except at the conclusion of the project when the NIS2s will have to be prepared in accordance with ASTM Section XI).

Section I Statement JJC Comment B.4, Design Inputs

24. Fire. No permanent flammable materials are I believe you mean to say there is no impact to Appendix R of Protection or installed per this EC; There is no adverse 10CFR50, correct? YES.

Resistance impact with Station compliance with Requirements: "Appendix B"to 10CFR50. All work activities Your characterization of the CR3 FP Program is too narrow.

will comply with Station Fire Protection You should review the Fire Protection Plan (FPP) for what Procedures as applicable, constitutes the "Fire Protection Program". The definition of the program in the FPP includes:

Basis:

FIR-NGGC-0003 (Ref. 6.10) The components, procedures and personnel utilized in FIR-NGGC-0004 (Ref. 6.11) carrying out all activities of fire protection, including such AI-2200 (Ref. 7.9) things as fire prevention, detection, annunciation, control, confinement, suppression, extinguishment, administrative procedures, Fire Brigade organization, inspection and maintenance, training, quality assurance, testing, control of combustibles and housekeeping.

RE Comment:

Revised Section B.4 accordingly. Spoke to Jack Curham and got his input.

B.6, Evaluation

24. Fire This EC does not install any permanent This first statement needs clarification. I'm not sure what you Protection or flammable material. However, during the are actually saying.

Resistance implementation of this EC, fire watches, Requirements: placement of fire extinguishers and/or other I assume by the station you mean someone from the FP Staff, appropriate measures, as approved by the as that staff is defined in the Site Fire Protection Plan (FPP)?

Station will be implemented in accordance with applicable plant procedures to ensure We need to be concerned with interaction with the fire brigade.

adequate fire prevention and mitigation Refer to A12205E pre-fire plan for the RB (and any other area measures are in place. you may be working in or potentially affecting).

All welding, cutting, or burning shall be per Why isn't A12210 a reference when we discuss use of fire FIR-NGGC-0003, "Hot Work Permit'. watches?

H03 Reviews Page 25 of 31

PCHG-DESG Engineering Change 0000063016RO Determination of fire loading shall be per FIR-NGGC-0004, "Determination of Combustible Loading and Equivalent Fire RE Comment:

Severity'. Revised Section B.6 accordingly. Spoke to Jack Curham and got his input.

All transient combustibles shall be controlled per AI-2200, "Guidelines for Handling, Use and Control of Transient Combustibles".

B.7, Interfaces Fire Protection: Fire Protection will review this EC. There is Other than compliance with our CR3 FP Program during and no modification planned that could impact after implementation, nothing in this EC appears to impact the any fire protection equipment. Coatings site FP Program and therefore this statement is not necessary.

need to comply with FIR-NGGC-0004 This implies to me we need a FP review form in accordance with EGR-NGGC-0102, but that is not a reference in the reference section, and I do not believe needs to be.

Coatings are installed per CPL-XXXX-W-005, Nuclear Power Plant Protective Coating and purchased per CPL-XXXX-W-006, Nuclear Power Plant Protective Coatings Procurement. These document acceptable protective coating systems for nuclear plants and provide requirements for flame spread rating and dry film thickness in order to meet requirements of FIR-NGGC-0004.

RE Comment:

Revised Section B.7 accordingly. Spoke to Jack Curham and got his input.

Di scilie/r a Reie Scop of Reie 70% Design Challenge EC63016 I Multi-Discipline I Reiewe Disciln Date Tunoe Reuied I Ron Johnson IEnvironmental I 5/15/08 I I ItemCommnt esoltio 1 Pg 5, Section A.5, 3Yu paragraph, and Have updated the EC accordingly elsewhere, regarding any discussion (Section A.5 and A.5.1.13.

related to the discharge of waste water.

Add language: "Water will be The appropriate work orders will detail discharged to the settling ponds in the requirements for water delivery, accordance with the site Industrial storage and the means of piping it to and Waste Water Permit." (Note: from the containment. The containment parameters and limits listed in the EC do opening Task Manager is responsible for not correlate to the site IWW permit, determining if the settling ponds have therefore recommend a more generic adequate storage for the expected 2 statement.) A specific plan for getting million gallons of waste water. ECED the waste water from the work area to 59400 identified the possible source of the settling ponds is needed. CR3 has a this water as the well fields located to the H03 Reviews Page 26 "of31

PCHG-DESG Engineering Change 0000063016RO pipeline to the ponds, project needs to east of CR3, operated and maintained by determine how to access this pipe line. the fossil group at Crystal River South (CRS). Well water would be diverted through existing CRS plant piping or temporary piping to one of the existing abandoned oil storage tanks (Cap.

8,000,000 gallons) which have been successfully used in the past by CRS to satisfy requirements for bulk water storage for other high water demand projects. Water from this storage tank will then be pumped either via temporary piping or existing available plant piping to the hydrodemolition equipment located at the containment access Opening.

+

2 EC discusses the creation of used grease PSC estimates that there will be 150 waste, and that the disposal of that waste drums of used grease that will be sent for shall be the responsibility of PSC. 1) disposal.

Need a better estimate of the amount of used grease that will be generated. 2) Refer to Section A.5.1.6 for details of Need to verify that Brian Wood (CR3 grease disposal. Ron Johnson, Brian waste coordinator) is in agreement with Wood and Carolyn Johnson are in allowing PSC to handle disposal, and 3) agreement that PSC can manage grease If PSC is allowed to handle disposal, disposal through their sub-contractor corporate policy requires that they Heritage Environmental.

utilize a Progress Energy approved waste disposal vendor, and that all disposal documentation is provided to Brian Wood for record retention. (If PSC wants to use a vendor not on the approved list, project will need to initiate a request to add that vendor to the approved list in accordance with corporate procedure EVC-SUBS-0107.)

3 Water requirements. EC says that a total Approximately 2,000,000 gallons of water of 612,000 gallons of water (300 gpm) is required. This amount willprovide will be needed. This differs from amply margin.

previous information given to me that 5 days @ 365,000 (i.e., 1.75 million) Refer to Item #1 above for discussion gallons would be needed. In other concerning water supply and storage.

places the EC says 700,000 gallons.

Need a worse case estimate for planning purposes. A specific plan for water source and storage needs to be identified H03 Reviews Page 27 of 31

PCHG-DESG Engineering Change 0000063016RO and agreed upon with Fossil plant operations. Existing plant water systems do not have the excess production capacity to operate the plants and a high-volume project simultaneously. If the spare water storage tank is used, project will need to plan on cleaning the tank and flushing the lines before storing up water. +

I - -

4 Section A.5.1.13. 2 n paragraph states Added comment to Section A.5.1.13.

that "The large concrete fragments and fine particles that accumulate in the collection tanks are periodically sucked out by a vacuum truck and temporarily stored in a holding tank where radiological testing of the rubble is completed before final disposal to an on-site designated waste disposal area."

There are no authorized "on-site" disposal areas. If concrete passes rad testing it needs to go to a permitted C&D landfill off site.

5 Pg. 18 continuing to Pg 19; Section Added sentence to Section A.5.1.6 stating A.5.1.15 comment, if there is a risk of that plastic sheeting will be taped t floor petroleum contaminated water draining and walls of tendon gallery and that floor down a vertical tendon sheath, AND drains must be protected from spills. Note there is a storm drain in the vicinity that grease has a high viscosity and will where the water will be captured, then basically drop out of the tendon sheaths in the storm drain must be protected with a "clumps".

plug or rubber map cover to prevent oily water from entering the storm drain.

6 Pg. 28, Section A.5.2.10, 2 nd paragraph. Added as requested.

Add "Also, the batch plant will be permitted in accordance with Florida Department of Environmental Protection regulatory requirements."

7 Pg. 7, Section B.6 Add to Nuclear Done..

Generating Group Procedures: CHE-NGGCO045. All chemicals used for this activity will need to be reviewed pursuant to the nuclear chemical control program.

8 Pg. 48, Section B.6.7:

Reference:

Added sentence in B.6.6 on Page 48 to "Diesel fuel that will be stored in mobile address diesel fuel containment.

tanks" Add text to specify that mobile H03 Reviews Page 28 of 31

PCHG-DESG Engineering Change 0000063016RO diesel tanks and mobile diesel equipment shall have integral secondary containment or be placed within a secondary containment.

Disciln/rga Review*6 Multi-Discipline I 100% Design Challenge EC63016 Reiewe Disciln Dat Tunoe Reuied I Rick Portmann IISI Review 15/20/08 1 I I

Item I Comn I R'esoltio I I A.5.1 - Task#l: Item# 17 - Need to add a AQQde note as requestea.

note that the detensioning of the additional 20 vertical and 18 hoop tendon outside the opening in defuel mode only will take place after the SG's have been removed and replaced.

2 A.5.1.1 (the last mock-up on the list): Note added as requested. Also added to Visual inspections per IWE/IWL for the installation instructions.

tendons and concrete needs to state that the training will need to meet IWL-2300 requirements.

4 A.5.1.5: Should a caution be added for Discussion added. Also added to work in the steam exclusion area while at installation instructions.

power since it discusses work on the RB as much as 60 days prior to the start of R16?

5 A.5.1.5: Discusses Missile Shields. Referenced EC-ED 68398. Since we are Missile Shields were permanently moving the 8'x10' platform to Buttress #

removed in R15. Need to add a 5, it must pass the fuel pools, however, discussion that the equipment, rigging and per the EC-ED evaluation it is acceptable procedures for R16 will not affect or are to move the 8'x 10' platform past the fuel still bounded by EC/ED 68398 and will pools and stage it at Buttress #5.

H03 Reviews Page 29 of 31

PCHG-DESG Engineering Change 0000063016RO meet NUREG-0612 requirements.

6 A.5.1.5: Reference to SP-182, Revision Done.

14 - Delete the revision level and section reference.

7 A.5.1.6: Disposal of the used grease is Done.

the responsibility of PSC, should say non-contaminated grease.

8 A.5.1.7: Reference to SP-182 - Delete the Done.

section reference.

9 A.5.1.8: Discussion on EC 63022 for the The chipping platform is installed by EC Chipping platform, I don't see the 63022 (Re. Section B.2.h of EC 63022).

platform as part of the scope of 63022.

Could this be in the scope of EC 63020?

10 A.5.1.10: Reference to SP-182, Rev 14 - Done.

Delete the revision level & section refs.

11 A.5.1.11: Delete "XXXX hours after the Done.

reactor has shut down".

12 A.5.1.12: A discussion of the Hydro vs. No discussion found in EC 61170. Left Chipping demolition is not needed in the section as is.

EC, I believe this was discussed in EC 61170.

13 A.5.1.12: A caution statement needs to be Caution statement added.

put in about damaging the liner when using mechanical chipping means. (Note:

Ft. Calhoun OE can be used as an example here) 14 A.5.1.16: The two paragraphs in boxes Changes incorporated.

which discuss the liner thickness need switched.( i.e. have the as-found information prior to the hydrodemolition paragraph). Also the discussion of a 1/16" reduction allowance needs to be deleted and changed to "not to exceed a minimum of 5/16" in thickness" 15 A.5.1.16: Change "form" to "from" [third Done.

to last word in section]

16 B.3

References:

Change 1.13 to the 2001 Done Edition through the 2003 Addenda as amended by 10CFR50.55a. Delete references 1.15 and 1.16.

17 B.4: Item# 21, delete reference to ASME Done.

VIII. Item# 25, add Concrete 18 B.6: Item#5-d(i) needs to address 60 year This EC addresses current licensing basis, life not extended life. However, the SGR I__Iproject will address the impact on H03 Reviews Page 30 of 31

PCHG-DESG Engineering Change 0000063016RO containment at 60 years from the creation and restoration of the opening and predicted tendon forces to 60 years.

19 B.6: Item#9, delete "clear" (clear plastic Done.

is not allowed in containment) 20 B.6: Item#15, last item in Table -

Containment pressure test could be changed to" ILRT (or Alternative NRC approved pressure test).

21 B.6: Item#21, Paragraph needs re-written Section has been updated to reflect and updated to a more current current understanding of the Section XI understanding. code, i.e. one year testing of the new tendons and then revert to 5 year.

22 General Note: Thru-out the EC is A follow-up discussion with Rick references to VT-I or VT-IC Portmann established that using VT-1 and examinations, these have been replaced in VT-1 C terminology is acceptable.

the new code by "General Visual" or Detailed Visual" examinations.

H03 Reviews Page 31 of 31

PCHG-DESG Engineering Change 0000063016RO Dicpie/r a Re

- ie -- -- Scp of Review I I Third Party I EC 63016 RO (draft 7/15/08) I Reiee Dicpln Dat Turove Required?

D. Pandya Icivil 1 (Process) EC Module - Attributes not Updated Attributes section completed 2 (Process) FO0 - Turnover summary not Turnover section completed.

completed. Any caveats?

3 (Process) EC Module - ADL/AEL not Updated ADL. AEL not affected. Section complete C05 update.

4 (Process) ADL and COO Mark-up section ADL and COO now match do not match related to document updates 5 (Technical) HOO - Risk assessment does Added risk assessments as requested.

not address key risks such as required skill sets not in-house, use of contractors, complex design techniques, infrequently used installation techniques (hydro-demolition), personnel safety, etc.

6 (Admin) BOO - B.3 - Large number of All revision levels updated.

references have been revised since EC initiated. Need to update revision levels of references to current levels and assess impact to EC as a result of revisions to references prior to issue for site reviews 7 (Admin) BOO - B.3 - Ref 1.2 reference 8 t' Deleted reference to the 8 th and 6 th or gth edition of AISC Manual. Ref. 1.1 edition. Design of the upper support references 6 th edition. Which was used frames by PSC and liner plate lift frame is when and why the difference? per AISC 9th edition.

8 (Process) Calc S06-0002, Rev 1 does not Owners Review signature was have a documented owner review (Rev 0 inadvertently omitted when Rev. 1 was does). Does the SGR project not perform issued. AR #288675 was initiated to owner review of revisions performed by rectify this omission. Per document the vendor? control, the calculation did not require a new revision to add signatures on cover page.

9 (Process) Calc S06-0003 uses GTSTRUDL added to document indexing GTSTRUDL. This is not included on the table in Calc S06-0002 thru S06-0006.

document indexing table. Other calcs Per document control this can be done may have same trend. without revising the calculations.

10 (Admin) AOO, pg 7 - Elaborate on S&ME is the name of the company, it is acronyms first time (e.g., SM&E, PSC). It not an acronym. A listing of the vendors may also be helpful to list all the involved in this EC, acronyms and full contractors/vendors being discussed in company names has been added to the EC in one place with a brief Section B.6.7 (Interface Requirements).

explanation of their task (include under H07 Reviews Page 1 of 8

PCHG-DESG Engineering Change 0000063016RO Interfaces).

11 (Admin) All referenced documents Have added difficult to find documents as throughout all sections should be listed in Attachments, i.e. the SGR Design Letters BOO, B.3 (e.g., AOO, pg 10 uses #EVC- are now located in Attachment Z16.

SUBS-001 07, ASTM A421 (see BOO)). Certain e-mail and fax correspondence Also, how are these documents has been put into Attachment ZO1, Z03, retrievable in Progress Energy records? If Z04 and Z05. Third party reviews are in not in RMS or PassPort, need to provide Attachments H04 and H05.

some mechanism to retrieve them.

12 (Recommendation) AO0, pg 10 - Have removed individual names.

recommend that you do not reference names of individuals in EC for activities to be performed - use title only.

13 (Admin) AOO, pg 10 - when tendon Have added reference drawing numbers.

numbers are referenced, reference drawing or source document.

14 (Process) AO0, pg 25 - EC Team should Have added environmental and safety; have had FP, safety and environmental they should have been on the list as team members. originally. Did not add FP because their input was minimal. This EC does not affect FP.

15 (Process) BOO, B.3 - Software used Have added GTSTRUDL Version 27 as (including version) should be added to reference #10.12.

references (e.g., GTSTRUDL) 16 (Admin) BOO, pg 14- flexible tendon Revised as noted and added to sheathing - reference A513-69 instead of references (Ref. 1.19)

A513. Add to references 17 (Admin) BOO, pg 14 - tendons - DBD Revised as noted and added to references A421-65 and not A421-98a references (Ref. 1.17) 18 (Admin) BOO, B.5 - items listed are not These ARs track vendor calculations, assumptions but requirements. drawings and manuals that are required before EC is issued. They will be deleted from Assumptions before EC is issued.

19 (Admin) BOO, pg. 23 - power level Removed reference to power level.

references FSAR 3.6 - not correct reference.

20 (Admin) BOO, pg 25 - throughout the EC, Removed all references to page numbers reference made to page numbers of DBD of DBD.

- page numbers not correct.

21 (Admin) BOO, pg 28, reference 50 lb/cu. NCR 289428 written to address problem.

Ft. - DBD states psf (incorrect - need to correct) 22 (Process) BOO, pg 37 m - states aux Added reference (S06-0005).

crane acceptable but no reference to supporting calc.

23 (Admin) BOO, pg 50 - reference to Att. 3 Should have been Calc S06-0002. Have of Calc S06-0003 not correct. revised accordingly.

24 (Process) BOO, pg 52, crane evaluation Revised accordingly. Have removed not referenced correctly in interface sentence referencing crane evaluations requirements. as all information concerning the crane is H07 Reviews Page 2 of 8

PCHG-DESG Engineering Change 0000063016RO addressed in the referenced EC 63020.

25 (Process) A number of vendor Documents have been owner reviewed.

documents/reports (excluding calcs) are Owner review cover sheets per EGR-included as attachments (e.g., Z013). NGGC-0003 have been completed and Have these been owner reviewed and added to each attachment as applicable.

documented?

26 (Technical) BOO, pg 55 - there is an The Reviewer, D. Pandya spoke to the equivalency evaluation performed by CR3 materials engineer (Jeff Finnell) procurement in an e-mail (not verified or about the need for a more formal formally documented) in attachment Z01 evaluation and it was concluded that the that is used in the EC. This should be e-mail was sufficient and met current CR3 documented in a formal Material requirements.

Evaluation.

27 (Technical) BOO, pg 59 - repair of liner to Revised to repair to a minimum of 3/8".

5/16" thickness (less than nominal 3/8")

has no basis provided.

28 (Process) BOO, pg 69 - chemistry Added requirement that suspended solids requirements not specified in installation (of water for hydrodemolition) must be section, as stated. less than 45ppm to Section D.2.1-3. Also added chemical requirements for the discharged water to Section D.2.1-3.

29 (Technical) BOO, pg 70 - operational Added a statement that there is no impact requirements section has no evaluation on the operational requirements of the provided (only a table of activities), plant and that the Table is added for clarification only and will aid in preparation of the installation instructions.

30 (Process) BOO, pg 71 - security Added requirement to notify security requirements not specified in installation before breaching containment to section, as stated. installation instructions Section D.2.1-3 31 (Technical) BOO, pg 72 - maintenance Added discussion about acceptance risk assessment for earthquakes lists limits.

probabilities. However, no acceptance limits are specified.

32 (Technical) BOO, pg 72 - probability for Value of 2.12E-08 is for tornado earthquake of 2.12E-08 referenced per probability not earthquake. Have revised AR 284485284485 AR lists this value for tornado EC accordingly.

loading. Also, AR investigation is not approved yet and it is used as input to EC.

33 (Process) BOO, B.7 - this section Added identified reviews to Section B.7 identifies required reviews. ISI (IWE/IWL, and ensured that they have been noted in Pressure Testing, Repair and the Milestone panel of the EC.

Replacement), installer, reg affairs, environmental, FP, license renewal, Appendix J, Security reviews should be considered/added.

34 (Process) BOO, B.8 - Quality class should Quality class added. Also added a be stated as safety related. Also discuss description of what components and what aspects are treated as non-safety activities are safety related and which are related. non-safety related.

H07 Reviews ý Page 3 of 8

PCHG-DESG Engineering Change 0000063016RO 35 (Process) DOO - has incomplete Statements completed. Added additional statements, references. Also, all installation instructions to match BOO.

installation requirements from BOO have Instructions per B.6.17 and B.6.24.

not been added.

36 (Process) DOO, D.4 - Parts List - several Have completed all required Q status items does not have "Q status" field fields.

completed.

37 (Process) EOO - concrete testing per Added testing requirements for both pre-Z013 not included, outage, during restoration of the access opening and post modification.

38 (Process) EOO - For some tests, it is not Have added requirements for turnover.

specified if they are required prior to turnover.

39 (Process) EOO - If there are any Per the Task Manager the only spare part anticipated requirements for spare parts will be the liner plate contingency (e.g., PSC supplied grease, gaskets), material.

specify in EOO.

40 (Process) HOO - Validation Plan - This The Validation Plan has been revised was approved in July 08, however, it several times and the present date shown appears that the'EC was initiated in 2006. in Passport reflects the latest revision.

Does not meet requirements of EGR-NGGC-001 1.

41 (Process) HOO, Validation Plan - For "Checked" post job critique and AR such a large scope/complex EC 289302 initiated to track it.

(including use of multiple vendors), post job critique should be specified.

42 (Process) DOO - Did not see where QC Discussed this item with Bill Nielsen Hold Points (not in existing procedures) (SGR QA/QC Lead), Jeff Whisler are clearly identified. (Bechtel) and Dan Jopling (SGR Design Supervisor) and the consensus is that the QC hold points will be addressed in the work instructions/package. Therefore, no QC hold points have been identified in the EC (DOO).

43 (Process) HOO - pre-job brief should have Have "checked" appropriate boxes.

addressed use of checklists, expectations for EC teams and DRB, OE, etc.

44 (Process) Z15 - Contains a specification Added new specifications CR3-C-0002 that is not included in COO or ADL. Need and -0003 to both COO and the ADL.

to follow requirements of EGR-NGGC- Revised spec CR3-C-0002 to reflect 0020 for processing the specification formatting requirements of EGR-NGGC-approval. The spec also does not meet 0020.

the formatting requirements of the procedure.

45 (Recommendation) Z1 3 - contains a We decided not to make this a vendor report on testing requirements for specification.

concrete. Should this not be a Progress Energy specification for testing?

46 (Recommendation) EGR-NGGC-0015 The IWE/IWL R/R Plans address P67 includes inspection requirements for inspection requirements for all phases of H07 Reviews Page 4 of 8

PCHG-DESG Engineering Change 0000063016RO containment per IWL/IWE requirements. the project, including exposed concrete For inaccessible areas that will now be and rebar inspections. Section EOO has accessible, is there a requirement or is it been revised to include a VT-3 prudent to document the inspections? examination of the exposed liner plate Also, this procedure should be reviewed (concrete side) prior to pouring concrete in the EC for possible impact to the to ensure that no damage occurred project since repair/replacement activities during reinstallation of the rebar and are beinq performed. tendon sheaths.

47 (Recommendation) OE/Lessons Learned OE observations were made at Davis-

- Did the project benchmark any other Besse and TMI and documented as AIMS plants that have undergone a similar items. These items and the responses evolution? If so, refer to the benchmark have been reproduced in Section A.6 report and discuss OE.

48 (Admin) The EC and drawings (e.g., 421- Drawing has been updated and all 326) refers to SSE as 2xOBE reference to 2xOBE has been replaced interchangeably. Use one term or explain with SSE why both are the same.

49 (Technical) How are GTSTRUDL error The following explanation is from S&Ls notices reviewed for potential impact to Javad Moslemian (Manager Civil Engr):

the computer analyses supporting the We have procured the "GTSTRUDL" EC? No documentation found to discuss program under GTSTRUDL's QA their impact. program. Anytime, an error is detected by the GTSTRUDL company, GTSTRUDL notifies us of the error. Once the error notification is received by S&L, it is forwarded to the process owner responsible for the GTSTRUDL program.

The process owner then reviews the error with the project teams that have utilized the GTSTRUDL program in their work. If it is determined that the noted error affected a given project, the affected utility will be notified of the error and depending upon the nature/effect of the error, additional actions may be taken.

The following information is from Chris Sward (S&L Project Manager for PE plants):

Our procedure for software control is attached (SOP0204 - proprietary). This procedure outlines all of our requirements for handling vendor software. With regard to error notification, Article 3.5.2 includes the process that Javad described.

49 (Admin) BOO, B.6.4 - calc S-00-0006 Corrected to SOO-0006.

appears to be incorrect reference.

50 (Technical) BOO, B.6.5-p - Calc S06-0002 An expanded discussion regarding why H07 Reviews Page 5 of 8

PCHG-DESG Engineering Change 0000063016RO states benchmarking acceptance criteria the new FEM models are acceptable has based on 5% max difference. In some been added to Section B.6-p for cases, differences are large, sometimes > Calculation S06-0003 (Benchmarking 100%, (e.g., new meridional moment < calculation).

design basis moment, new meridional force and shear > design basis force) in calc S06-0003. The description for calc S06-0003 in the EC discusses where results are close, but does not explain why such large differences in results for moment can be ignored in demonstrating that the new model is reasonable for use for design purposes. Need to strengthen discussion for why new model is acceptable for use (e.g., state of the art modeling, use of as-built info, manual cross-check, third party reviews, etc.)

51 (Technical) S06-0003, purpose - States This model was used to benchmark dead that benchmarking of new model was load + 1.15 accident pressure + prestress limited to load combination for change in because that was the only load case for pre-stress. A caution should be added to which existing design basis results are the calculation that if this model is used available. Additional benchmarking for other load cases, additional (against existing design basis calculations benchmarking may be required. is not possible because there are no additional results for other load cases available. Refer to Section B.6-p for an evaluation as to why the FEM models are acceptable. Based on these conclusions the stated purpose of calc S06-0003 is correct.

52 (Process) BOO, B.7, B.4 - Need to add At the time of issuing this EC it is EC 63021 under interfaces (man-lift used unknown as to whether EC 63021 will by this EC) ever be issued. The whole issue of using a man lift is under review.

53 (Process) BOO, B.7, B.4 - Need to add Added to Interfaces.

EC (ED) 70586 under interfaces (liner plate reconciliation). Shows up on x-ref panel.

54 (Process) NTM ARs 285173 and 285181 Assignments and due dates created in do not have assignments with due dates passport.

to track due dates.

55 (Process) REG AR 282349282349(50.59 Screen and 50.59 evaluations are screen/eval) not completed. The screen complete and assignments created for should actually be ready at the 70% review and approval.

design challenge stage.

56 (Process) Ensure that "Caveat Outst" field Caveat Oust has been checked. Refer to is checked if caveats or exclusions (future Section B.5 Assumptions for a listing of details, missing documentation, vendor outstanding items.

output, etc.) are identified. Per B.7. It appears that there will be a few open H07 Reviews Page 6 of 8

PCHG-DESG Engineering Change 0000063016RO items.

57 (Process) EC X-ref Panel - No NTM AR NTM AR 00289302 has been assigned to found to track post-job briefing (per EGR- John Holliday (RE).

NGGC-001 1).

58 (Process) COO - Identify any impact to the No PMs are affected by this EC. The Preventive Maintenance (PM) activities, tendon surveillance procedure (SP-182) will be affected and has been addressed in Section B.6.21.

59 (Process) E00 - Testing of carbon A new welding procedure specification content will require a new spec if value must be developed for welding rebar above 0.64. How is this item tracked? applicable to the containment opening.

Should this be a Caveat or open item? NTM AR 289322289322has been assigned to David Mayes the SGR welding engineer.

60 (Process) EO0 - Plant mode restrictions Plant mode restrictions added as for testing are not specified. applicable.

61 (Technical) BOO - EGR-NGGC-0005, An evaluation of the applicable design 9.3.1.5 requires evaluation and margins and the impact on these margins documentation of design margins. (None) has been added to Section B.6.3 Document margins after mod and B.6.10.

implementation clearly.

62 (Technical) BOO, B.3 - ACI 349-01 used. Only calculation S06-0006 references FSAR, 5.7 references 349-85 and 349- ACI 349-01 when calculating the modulus

97. Also, AWSD1.1 -1992 used in EC, -84 of rupture for concrete. The value shown referenced in FSAR. Document in ACI 349-01 is the same as that shown acceptability to use a later version. in ACI 349-85 and 87 (Ref. Section 9.5.2.3), i.e. Fr=7.5(f'c)11 2 .

References to AWS have been deleted.

There are no references in the EC to AWS D1.1 orAWS D1.4 63 (Process) COO - FSAR should be listed FSAR has been added to the ADL. FSAR on the ADL. I would expect a summary 2008-0017 has been created per CP-216 description of the analysis performed to (Preparation of an FSAR Change be added to the FSAR. Package) that will document all changes to the FSAR resulting from this EC.

64 (Technical) BOO, B.6.8-b needs to include Evaluation has been added for evaluation for using different ASTM year addressing the acceptability of using for replacement tendons. ASTM A421-98a versus ASTM A421-65.

65 (Technical) B.6.8-d - Original tendon Reference to NO-OX has been deleted.

grease stated as NO-OX-ID. Design input Per the Containment DBD (Section, section lists different grease as original Tendon Grease), Visconorust 2090P and grease. Also, replacement grease in 2090P-2 was used to field coat the inside design input listed differs from that in of the tendon conduit and used as bulk evaluation section (2090-P4). Evaluate filler after tendon insertion. The new basis for replacement. grease will be Visconorust 2090-P4 manufactured by the Viscosity Oil Company as specified in SP-1 82, RB Structural Integrity Tendon Surveillance Program.

The P-4 is an improved version of the P-2 grease previously used at CR3. Note that H07 Reviews Page 7 of 8

PCHG-DESG Engineering Change 0000063016RO the P-2 grease is no longer available and was superseded by the P-4 grease approximately 25 years ago.

66 (Process) B.4.10 - requires Bechtel to Added requirement for Bechtel to confirm confirm operation/discharge volume of operation and discharge volume of the temporary sump pumps prior to hydro- temporary sump pumps prior to demolition. This is not included in the hydrodemolition in Sections D.2.2.2gand installation requirements (DOO). D.2.1.3 67 (Process) - B.4 should contain design Have moved to Section B.6 input, B.6 has evaluation of design inputs.

In B.4.10, evaluation in Calc S06-0007 included. Move to B.6.

68 (Process) BOO and EO0 - Testing Have aligned the testing requirements in requirements specified in BOO, B.6.20 and B.6.20 and EOO.

EOO should be the same.

69 (Admin) B.6.23 states that safe load Sentence re-worded. The paragraph paths have been evaluated. No reference following the list of lifts/loads identifies the provided, calculation that evaluates effects of a load drop.

70 (Process) B.6.24 states that installation Identified relevant procedures in DOO instructions will reference the fire Section D.2.1 protection procedures. None referenced in D00.

71 (Technical) The 50.59 evaluation TEMCO was never used in the evaluates use of GTSTRUDL but not evaluations.

TEMCO/PC that is used for evaluating reduction of thermally induced loads. This appears to be a different methodology than that described in the FSAR.

8/13/08 - D. Pandya review of resolutions provided.

Mechanical/Civil Design Action Group 72 Item 1 - Attributes still not completed Completed (e.g., turnover, 50.59) 73 Item 2 - resolution not provided Completed 74 Items 3/4 - ADL still does not match Updated.

Section C (e.g., 2 VTMAs in C not on ADL, drawing 421-032 on ADL not in C, no sheet number for 1 drawing in C). No items on AEL - any required?

75 Item 6 - still open Updated revision levels 76 Item 38 - Turnover section specifices no Turnover and closeout summaries added turnover. Should have turnover since Pri 0 documents. POMs impacted, 77 Item.41 - was NTM initiated to track? If AR 289302289302was initiated and added to x-

_ yes, add to x-ref panel. ref panel.

78 Item 47 - response incomplete Updated.

79 Item 57 - add NTM to x-ref panel, Updated.

H07 Reviews Page 8 of 8

f PCHG-DESG ENGINEERING CHANGE 0000063016RO Regulator Programs EC63016 Final Review Reiee Dicpln Dat Tunoe

  • S Required?

S. Powell Regulatory rograms 8/14/08 1 B.2 - the abbreviation CTMT is not Replaced abbreviation CTMT with defined and is not used consistently containment.

2 B.4.1 - You incorrectly refer to Improved Correction made.

Tech Spec Bases. The Bases give the background information on where the requirements in the LCO's and Required Actions come from. Drop the word Bases and remove the 'Bs' in the next three bulleted items.

3 B.4.28 - The abbreviation PSC has not Defined.

been defined.

4 B.5.1 - It is not our plan to close the risk Revised to "EC Closure" assessment ARs prior to EC issue. The ARs and individual assignments need to remain open to incorporate changes due to Plant reviews.

5 B.6.1 - The liner thicknesses do not Should read "liner plate thickness is 3/8" for agree with page 17 the cylinder and dome and 1/4" for the base".

6 B.6.5a - should STRUDL be Yes.

GTSTRUDL?

7 B.6.5d(iii) - re: discussion on vertical and Revised to Kip/ft horizontal tendon forces - force is given in kips/ft while a similar discussion on the previous page used kips/tendon. Why was it changed here?

8 B.6.5f - probability of a tornado strike is "R" removed.

given as2.12ER-08. Why is there an 'R'?

Occurs in several places.

9 Page 47 - inconsistent use of Corrected to GTSTRUDL GTSTRUDL vs GT Strudl 10 Page 49- 'E' is not defined. Is it Young's Yes. Defined "E".

Modulus?

11 Page 52 -'Young's Modulus (E)' should Done have been defined earlier in the document 12 Page 59 - High slump or low slump? Reference to high slum has been removed.

Numerous places to consider which is correct.

13 Page 60 - pour rate of 4 ft/hr - Is this a Yes. Concrete pour rates are typically stated vertical measurement within the space of in units of ft/hr.

the opening?

14 Page 74 - No more than 60 days - This Left at 60 days since.

could be 90 since we cannot startup until the containment is fully qualified H05 Final Review Page 1 of 23

PCHG-DESG ENGINEERING CHANGE 0000063016RO 15 Page 76 -'Up to 90 days prior' is Changed accordingly.

confusing and could be interpreted as this must be done more that 90 days prior. I suggest 'When there are less than 90 days until' 16 Page 87 - In Table re: 'Install new tendon Changed accordingly.

sheaths, new and existing rebar' - this must be done before we load enough fuel to pressurize the building. It should be

'Defueled or Mode 6 fully flooded Fuel Transfer Canal.' Applies to the next three items also.

17 Page 89 - problematic risk assessment Revised spelling should be probabilistic 18 Page 89 - In the sentence containing the Done.

probabilities for OBE and SSE - After

'occurring' insert 'that leads to fuel damage' 19 Page 89 - Remove first 'CCDP' and Done insert 'conditional fuel damage probability (CFDP)'. Substitute CFDP for CCDP elsewhere.

20 Page 91 - re: Mechanical splices - if this Discussed with Sid and have added an test program does not agree with the expanded description of the testing FSAR then this should be evaluated in requirements to Section B.6.20. The EC the 50.59 Screen requirements for testing are more conservative than those of ASME Section III, Division 2. No change to the FSAR required.

21 Page 95 - '2017 - All tendons' - you Revised.

don't really mean 100% of tendons Requlato Programs EC63016 Final Review S. Powell Regulatory Programs 8/14/08 1 Page 1 & 2 - Items 17 thru 21 - Theses Revised must be done in No Mode or Mode 6 fully flooded Fuel Transfer Canal 2 Page 3 - Partial degreasing may be started Left as 60 days after discussion with Sid.

at less than 90 days before the outage.

3 Page 8 - Mode 5 & 6 Activities - The saw Revised accordingly cut may be done pre-outage 4 Page 11 - If the reinforcing steel testing Discussed with Sid and have added an program is not consistent with the FSAR expanded description of the testing this needs to be addressed in the 50.59 requirements to Section B.6.20. The EC Screen requirements for testing are more conservative than those of ASME Section III, Division 2. No change to the FSAR required.

H05 Final Review Page 2 of 23

PCHG-DESG ENGINEERING CHANGE 0000063016RO 5 1Page 11 - BPI-Grip or Bar-Grip? -- C-orrect as stated "BPI-GRIP" Disciplie/Prgra Re ie Scop ofRve Electrical!/ I&C Design 1EC63016 Final Revie-w Reviewer Discpine Dat Turove Required?

Vincent LeNoir Electrical / I&C 8/13/08 N Itm Comen Reouto 1 Installation Instructions, D. 1.2 -Change Done.

EC 63044 to EC 70377 for Temporary

___Power Interface.____________________

Discilin/Prgra Reie Scop 0f Revie I I EC63016 Final Review Reiewer Dicpln Dat Turove Req-uired?

I R. Pinner IChemistry 1 8/14/081 no I Item I nF,,,

D.0 Comen Is it appropriate to defer piping Resolutio I The details for water supply and disposal for connections for the required water supply concrete removal will be included and and waste water discharge piping to the approved per Work Order Task 1165094-settling ponds to be handled by work Task-03. The EC identifies and evaluates orders? the critical characteristics for water supply and disposal in Section B.6.6 and B.6.12, Who will be responsible for handling this? i.e.

" require 2,000,000 gallons of water Who is the containment opening task with TSS of less than 45ppm manager and how will he address delivered at 360 gpm obtaining the required water volume for " disposal of maximum. 2,000,000 the hydrodemolition, i.e. what process will gallons of water, with samples (for be used to insure that this happens? RP and chemical testing) being taken at the collection 'tank prior to It should be noted that during plant cool delivery to Mac and Macs water down, CR-3 will begin a condensate treatment plant release to the settling ponds. As soon as

  • Final testing for Ph only, prior to we get to mode 5, we will be releasing discharge.

condensate as fast as permitted (300

  • Supply and discharge piping will use gpm max) in order to drain the secondary either existing piping or will be field system to allow work to commence. This run. The present plan is for Mac and could add approximately 500,000 gallons Mac to supply and field route the of condensate to the settling ponds. This discharge piping.

needs to be taken into consideration when assessing the available volume in We have identified in the installation the ponds. instructions (D.2.1.3) and Sections B.6.6 and B.6.12 that approximately 500,000 gallons of condensate may be added to the settlinq ponds durinq plant cool down.

H05 Final Review Page 3 of 23

PCHG-DESG ENGINEERING CHANGE 0000063016RO Jon Burchett is the Task Manager and has overall responsibility for ensuring adequate water supply and disposal facilities.

B. 12 No where does this section discuss Revised Section B.6.12 to include radiological analyses that are required for discussion concerning radiological testing.

discharging to the settling ponds. We Discussed with Neil Keeney and Mike have to evaluate this waste water for Siapno. Requirements for radiological gamma emitting radionuclides and tritium. testing will be written into the Containment The concentrations must be < 1 ECL Opening RP Task Plan. Have initiated AR (effluent concentration limit) to allow 292005 and assigned to RP group, thereby discharge. Also who is responsible for tracking issue of RP Plan by 1/30/09 and insuring that the water obtained from committing the RP group to include the Crystal River South (CRS) for requirements for testing in the appropriate hydrodemolition meets the < 45 ppm TSS work orders.

criteria? Joh Burchett (Containment Opening Task Manager) is responsible for ensuring water delivered to hydrodemolition contractor has a TSS of less than 45ppm.

EC-63016 Containment Opening, Steel Liner Plate, Concrete, Rebar and Tendons -WORK ORDER# 's 1165090,1165055, 1165094 Ralph Medley, Dick Fletcher Civil / Mechanical 08/19/08

& Jeff Whisler TYPO's 1 InFile AOO, page 23 of 30, the last Revised.

sentence of the second paragraph under A.5.2.10 the word "address" should read

_ "addressed".

2 In File DOO, page 11 of 19, item D.2.2.5 Revised.

this should be Item #2 not Item #7.

3 In File DOO, page 12 of 19, item D.2.3 Revised.

Item #4a should show the concrete specification CR3-C-0003. (same as stated in item #2 above) 4 In File DOO, page 5 of 19, under Revised.

paragraph D.2.2.4 the first item should be 1 not i. The second item should be 2 not 6 and sub items should be a thru f instead of e thru j. _

H05 Final Review Page 4 of 23

PCHG-DESG ENGINEERING CHANGE 0000063016RO F 4 CLARIFICATIONS 1 In File AOO, page 10 of 30, indicates that Progress Energy is responsible for 30 vertical tendons are to be degreased, supplying the drums.

therefore this will require a large number of barrels to collect the grease. Who is responsible to supply / buy these? This will be a big cost / ticket item.

2 In File AOO, page 17 of 30, in paragraph The EC is correct. This is PSCs A.5.1.15 indicates to not plug the vertical recommendation based on previous tendon sheaths. Is this correct or experience.

shouldn't these be plugged to keep the debris and water out of the gallery?

3 In File BOO, page 21 of 91, do you need Done.

to add the grease cap gaskets to the second bullet?

4 In File BOO, page 21 of 91, do you need Done and added to BOM.

to add a bullet for 55 gallon drums?

5 In File DOO, page 5 of 19, Item 1 does not Drawings will be included in Attachment address how the platforms are to be Z23. These drawings and associated installed?Bolted?Welded? calculations will be issued to PE 8/29/08 and included in the EC prior to PGM review. Revised section accordingly.

I* 0icpie/rga Reie Scp of Review

  • I I EC63016 Final Review I IReiewer isciple IDat T e Re.qir IRon Johnson I Environmental S8/19/08 I Item Comn Resouion 1 Section B.3.10.11, (Page 10); insert Done permit number after the words "Industrial Waste Water Permit"; (FLAO1 696o).

2 The corporate waste vendor program is Done.

referenced in a few locations, but should probably also be specifically listed at Section B.3.10 (Other References):

"Progress Energy Procedure, EVO-

___SU BS-001 07, Waste Vendor Program" ____________________

H05 Final Review Page 5 of 23

PCHG-DESG ENGINEERING CHANGE 0000063016RO FConfi . M mnt. CM L.S. McGowan CM210 Cm 1 Att. Z06R0 is incomplete Title is now clearly included.

2 Att. Z06R0 thru Z12R0 do not have the Added as requested.

EC or Attachment number on the document. I did not review other attachments for this requirement.

Procurement EC63016 Final Review Rick Curry 8/21/08 1 Item no. 1 and 2 - Each item specified Done.

needs to be a separate line item. So, there should be six line items for this rebar.

2 Item no. 4 - Each item specified needs to Done.

be a separate line item. So, there should be two line items for this tendon sheathing. The quantity for each item needs.to be specified in the Qty/Units column.

3 Item no. 6, Screw - McMaster Carr p/n Done.

needs to included in the description not the Catalog ID column.

4 Item no. 9, Angle - Detail no. 3 of Revised to show 85 of each required.

drawing no. 421-350 shows the angle to be 1' - 3" long (cut to suit). This appears to be a conflict. I need to know what length you want for procurement. Is ten pieces at 10 feet long acceptable or do you want a quantity of 80 at 1'-3"?

5 Item no. 12, Vertical Tendon - Each item Revised.

specified needs to be a separate line item. So, there should be eleven line items for the vertical tendons.

6 Item no. 13, Horizontal Tendon - Each Revised.

item specified needs to be a separate line item. So, there should be eighteen line H05 Final Review Page 6 of 23

PCHG-DESG ENGINEERING CHANGE 0000063016RO items for the horizontal tendons.

7 Item no. 14, 2090-P4 grease - Catalog ID This item is grease. It is referenced in the 0001430382 calls this item oil not grease. tendon surveillance program (SP-182) as If oil is the correct term, change the grease and is referred to in the industry as description to match the catalog ID which grease. A review of the Viscosity Oil is OIL, VISCONORUST 2090-P4, Companies web site is not much help. They TENDON CABLE FILLER COMPOUND. refer to it as a lubricant or casing filler. Note that its melting point (when it becomes a flowable liquid is 145 degrees F. I think the Cat ID description needs to be revised.

8 Item no. 15, Grease Cap Gasket - Need Supplied by PSC. Added Prescon drawing more information to order such as numbers.

dimensions and material.

9 Item no. 16, Tendon Anchor Head - Add Done.

PSC drawing no. CR-N 1009-502 (163 Wire Stressing Washer) to the description.

10 Item no. 17 thru 23, Shims - The catalog Done.

IDs specify MIL-S-16216K not MIL-S-16216 in the description panel (TIMD202 panel).

11 Item no. 32, Fly ash - Add catalog ID no. Done.

9220174532.

12 Item no. 33, Silica Fume - Add catalog ID Done no. 9220174536.

13 Item no. 34, Water Reducing Admixture - Done Change UCON WR 91 to EUCON WR 91.

14 Item no. 37, Rebar - Clarify the Done description 4 x 23 x19'-6".

15 Item no. 38, Rebar - Clarify the Done description 2 x 21 x19'-6".

16 Item no. 39, PVC Pipe - Clarify the length Done.

for each of the PVC pipe.

ISI Containment (IWE/IWL) EC63016 Final Review Program RikPortmannirContainment (IWE/IWL) Program 8/21/08-Rick PrtmannOwner8/60

    • Note: EC Copy from 8/18/08 was **-Bold & underlined comments changed reviewed for comment. since 8/25/08 version 1 EC Review/Approval - Per IWE the Initiated AR 292796292796Responsible Individual (Ref. IWE-2320) &

IWL the Responsible Engineer (Ref. IWL-2320 & IWL-4000) needs to approve this H05 Final Review Page 7 of 23

PCHG-DESG ENGINEERING CHANGE 0000063016RO document. Should be tracked by an AR.

2 A.4, 1st para. - Change "(FRO16)" to Done

"(RF16)"

3 A.5, 2 nd para. - Change "up to two Done months" to "no more than 60 days" 4 A.5.1.1, last bullet- Reword to: "Visual Done examinations and QC inspections for the tendons, rebar, liner plate and concrete.

Note: Visual examination training must meet IWL-2300 requirements."

5 A.5.1.6, 3 rTdpara. - Should we also refer No longer a vendor manual. Added as an to the Vendor Manual number listed in the Attachment to the EC.

AR (VTMA 02580-001) ?

5 th para., Delete "is the responsibility of Did not change per discussion with Magdy Precision Surveillance Corporation Bishara and Dhiran Pandya (Chiefs Group)

(PSC)" and "PSCs waste disposal vendor who believe reference to the main vendors must be a PE approved vendor." is helpful.

7 th para., Delete "Per recommendation from Precision Surveillance Corporation" Done.

and move "(Refer to Attachment Z14RO)"

to the end of the sentence.

6 A.5.1.7, 1 st para. - Should we also refer Refer to item 5 to the Vendor Manual number listed in the AR (VTMA 02580-001) ?

7 A.5.1.7, 2 nd para. - Add "The new Done.

replaced anchorage components will also require a pre-service visual examination following replacement.

8 A.5.1.7, 3 rd para. - Delete "SP-182 states Done that" Just start the sentence with "During..."

9 A.5.1.9, 1 st para. - Delete "AREVA" [2 Revised to "construction".

places] and Bechtel Field Engineers and re-word these two sentences.

10 A.5. 1.11, 1st para. - Should we also refer Refer to item 5 to the Vendor Manual number listed in the AR (VTMA 02580-001) ?

H05 Final Review Page 8 of 23

PCHG-DESG ENGINEERING CHANGE 0000063016RO 11 A.5.1.11, 2n5 para. - Re-word the Done sentence as follows "Ifgross damage is identified, removal shall stop and Engineering contacted to determine any potential corrective actions and continuation approval." Delete "Tendon removal can continue."

12 A.5.1.15, - Delete "PSC", PSC Did not change per discussion with Magdy recommends" [2], "Bechtel", "(supplied Bishara and Dhiran Pandya (Chiefs Group) and operated by Bechtel)". Re-word who believe reference to the main vendors sentences as needed. is helpful.

Revised "Bechtel" to "construction" 13 A.5.1.16, 2 nd para. - Unless CBI is Done performing work under their Q.A.

Program with site approved procedures, Delete "Chicago Bridge and Iron (CBI) is responsible for cutting, rigging and removal of the liner plate" and replace it with "the liner plate will be cut, rigged and removed" Last sentence delete "CBI will be responsible for any repair and or preparation of the liner plate for reinstallation." And replace it with "the liner plate will be prepared reinstallation."

14 A.5.1.17, 2 nd para. - Should we also refer Refer to item 5 to the Vendor Manual number listed in the AR (VTMA 02580-001) ?

15 A.5.2.1 - Delete "CBI" in the 3 bullets and Done.

re-word as needed.

16 A.5.2.4 - Add to the last sentence "and Done EGR-NGGC-0015."

17 A.5.2.8, 1 st para. - Should we also refer Refer to item 5 to the Vendor Manual number listed in the AR (VTMA 02580-001) ?

18 A.5.2.8, 2 nd para. - 1 st sentence states Added to Section E0O.

that the sheaths need to be inspected and approved by QC. Is this a real requirement? If so it needs to be added to E0O.

H05 Final Review Page 9 of 23

PCHG-DESG ENGINEERING CHANGE 0000063016RO 19 A.5.2.8, 2 nd para. - Delete the last Done sentence, it is a repeat of the prior sentence.

20 A.5.2.9, next to last sentence - States Created AR 293932293932that the formwork supplier will engineer and provide the calculations and installation instructions. This is an outstanding action that needs a tracking AR documented here and contained as an attachment to the EC upon review and acceptance. [Same Item & comment as for B.6, para 10, and D.2.2.5.1.c]

(Similar to the E-Mail on the DRB meeting about the missing PSC Manual(s), these calculations and instructions should be identified as being needed prior to PGM approval and a placeholder put into the EC attachments.)

21 A.5.2.1 1, 1 st para. - Should we also refer Refer to item 5 to the Vendor Manual number listed in the AR (VTMA 02580-001) ?

22 A.5.2.11, 2 nd para. - Delete "per the Done requirements of PSC Manual Post Tensioning System Field and Quality Control Procedure Manual" [2 locations].

Also delete" provided by PSC" and replace it with "installed" 23 A.5.2.13 - Delete "concurrently with the Done IWL-5000 pressure test."

24 A.6, 2 nd para. of OE14720 [Causes] -fix Done the spacing (an extra return exists) 3 rd pa'ra. - How the issue is to be address Added to Installation Instructions (Section states that a note will be added to the D.2.1-3 precautions and limitations section, ?

section of what ?

25 A.7 - Correct Rick Portmann (2 n's in last Done name) also change "Tendon System Engineer" to "Containment (IWE/IWL)

Program Engineer" 26 B.3, Para. 1.7-Change "...2001edition Done with 2003 Addenda..." to "...2001 Edition through the 2003 Addenda..."

H05 Final Review Page 10 of 23

PCHG-DESG ENGINEERING CHANGE 0000063016RO 27 B.3, Para. 1.8 - States "Spare", yet it is Reference was added later. Para 1.8 is referenced within BOORO for ASME correct referencing ASME ......

Section III, Division 2 (see pg. 87 under Rebar Splice Quality Control Requirements - 2 locations) 28 B.3, Para. 4.29 thru 4.33 - Each of these If I remove the sheet number then the titles drawings reference a specific page only will be identical and may confuse someone.

of the drawing (i.e. 2 of 3, 3 of 3 etc.). I have therefore left the sheet numbers.

Suggest removing the specific page refererence.

29 B.4, Para.. 8 - Tendon Split shims says This statement is straight out of the FSAR.

"modified Armco VNT (Proposed ASTM Without considerable investigation I cannot A633-E)" is this correct terms state that "modified Armco VNT" was indeed (Proposed)? Or should it be "ARMCO incorporated into ASTM A633-E.

VNT (ASTM A633, Grade E)" Should we also add the PEERE 987 equivalents that The PEERE is discussed in Section B.6.8-c have been used since original construction? (Armor Plate HY-80?)

30 B.4, Para. 8 - Tendon Grease - Add the Discussed in Section B.6.8-d.

equivalents that have been used since original construction (2090-P4 ?). Note: The intended purpose of Section B.4, para 8 is to identify only the original materials used in construction.

31 B.4, Para. 10, 1 st para. - We state that Added a sentence that references other each of the unique structural Sections of the EC for a description of the configurations must be evaluated, configurations and associated calculations.

Should we list the evaluations (calcs, etc) here? The remaining paragraphs in this section reference to other sections or calculations in support.

32 B.4, para. 14 - Delete "Areva" Done 33 B.4, para. 20 - Add Containment Done components (concrete, rebar, tendons, tendon anchorage assemblies).

34 B.4, para. 21 - Delete the last sentence Done as it does not apply ("ISI Requirements for the liner plate weld must also be determined).

35 B.4, para. 23 - Should reference be Added made to Nureg-0612 be added to the basis?.

36 B.4, para. 28 - References to Bechtel Removed reference to Bechtel. Have Safety and Bechtel Safety Department reworded sentence concerning PSCs should be removed. Reference to all procedures.

work activities being performed in accordance with PSC procedures needs removed (we will be working to CR3 work orders and procedures)

H05 Final Review Page 11 of 23

PCHG-DESG ENGINEERING CHANGE 0000063016RO 37 B.5, para. 4 - Suggest deleting the due Done date and stating the new welding procedures will be completed prior to work order implementation. Para.'s 5, 6, 8-10 also have due dates that you may want to change to some project milestone etc. to eliminate EC changes for due dates. Also delete "David Mays" 38 B.5, para. 12 - Discusses a new AR 293703293703initiated (Para. 14). This item is calculation to document the containment now listed as a Caveat Out-Standing (#3) shell with 3 tendons detensioned (post mod), needs an action tracking mechanism added to complete calc S08-xxxx.

39 B.5, last para. - Should this be para. 13? This scope of this EC is per current licensing Also states that calc. S07-0003 has requirements, i.e. to 40 years. The 60 year evaluated the tendon forces to end of evaluation will be a separate calculation and plant life. Has the calculation revision to independent of this EC.

60 years been completed or should we add the tracking mechanism to track this outstanding item?

40 B.6, para 1. - 6th paragraph starts with Refer to item 12 "S&L has created several..." Deleted Did not change.

S&L has created" and start the sentence with "Several" 41 B.6, para 5a & 5-b - In the first sentence Refer to item 12 of each para. delete "generated by S&L" Left reference to S&L Also change the para reference from "5a" Changed to 5-a to "5-a" 42 B.6, para 5-b - 3 rTdpara,. Delete the 4 th Done sentence "The containment shell ....... pages 35 through 44."

Sentence is not telling us anything and EC will need revised if the specification page numbers change.

43 B.6, para 5-d (i) - 1 st sentence delete Done "page 17 of' Also the end of plant life forces discussed Refer to Item 39.

are at 40 years. Does this need updated to discuss the 60 year EOL? If so an action tracking mechanism needs added.

44 B.6, para 5-d (ii) - 2nd para delete "Per Changed to "Section 4.2.1" pages 32 and 33 of' H05 Final Review Page 12 of 23

PCHG-DESG ENGINEERING CHANGE 0000063016RO 45 B.6, para 5-d (iii) - 2 nd para delete "Per Changed pages 32 and 33 to "Section pages 4 and 6 of' and change "pages 32 4.2.1", however, left page reference in S80-and 33" to "and". 0002 as this calculation will not be changed.

Also the end of plant life forces discussed Refer to item 39 are at 40 years. Does this need updated to discuss the 60 year EOL? If so an action tracking mechanism needs added.

46 B.6, para 5-h - 3 rd para delete "from page Done 13" 47 B.6, para 5-i - 5 th ? para delete "page 4 Done of' and "page 5 of'.

8 th para. delete "page 5 of' 48 B.5, para 5-k - 2n, para change "on page Done 1 of Gilbert Associates, Inc." to "within" 49 B.6, para 5 2nd para delete "prepared Left reference to Mammoet (Did not change by Mammoet" and change "(Ref. page 5 per discussion with Magdy Bishara and of 10 of Calc S06-0009)" to "referenced in Dhiran Pandya (Chiefs Group) who believe Calc S06-0009." reference to the main vendors is helpful.

50 B.6, para 5-1.2 - Delete ", Revision 1" Done 51 B.6, para 5-1.3 - Delete ", Revision 2" Done 52 B.6, para 5-o - 1 st para, Reword "The Done vendor supplying.....AR#00285181)" to something like "Calculations are currently being prepared, reference AR#00285181" 3 rd para? change "DBD 011" to "Tab 1/1" or just reference 2.1 53 B.6, para 5-p - Delete "by S&L" Refer to Item 12 - left S&L as-is 54 B.6, para 5-p - Calculation #S06-0003, Refer to Item 12 - left S&L as-is 1 st para. Delete "by S&L". 2 nd para. Delete "page 18" Removed page #

55 B.6, para 5-p - Calculation #S06-0004,  ?? Already reworded.

1 st para. Delete "by Sargent and Lundy".

4 th para. Delete "by S&L and Progress Left as is - Refer to item 12 Energy", Change "Gilbert Commonwealth used in their" to "was used in the" Delete "Page 15" 56 B.6, para 5-p - Calculation #S06-0004, Added "i.e., lock-off prestress" 3 rd para states the prestress at end of life includes the prestress from retensioning the replaced/detensioned hoop and vertical tendons to 70% of GUTS. Was this prestress discussed meant to be the Lock-Off prestress? (The initial prestress is 80% of GUTS) Should probably state which prestress this is.

H05 Final Review Page 13 of 23

PCHG-DESG ENGINEERING CHANGE 0000063016RO 57 B.6, para 5-p - Calculation #S06-0004, Added "i.e., lock-off prestress" Model #1, 1 st para. states "original prestress, i.e. 70% GUTS. Should probably state that this is Lock-Off as the initial prestress is 80% GUTS.

Also discussed is 40 year end of life. Is New calculation will be provided outside the this Calc being revised or will a new calc scope of this EC.

be provided for the 60 year end of life?

58 B.6, para 5-p - Calculation #S06-0003, Done 4 th ? para. states to "retension to the initial pre-stress level of 70% Fu" What is "Fu" ? Shouldn't this be Lock-off level of 70% GUTS or initial pre-stress of 80%?

59 B.6, para 5-p - Calculation #S06-0003, Revised accordingly.

Conclusion. Discusses a new formula for the 9th and 1 0 th Surveillance. Shouldn't it also have been created for the 1 year Surveillance on the new & retensioned tendons?

60 B.6, para 5-p - Calculation #S06-0007, Required for historical clarity-no change.

Simplified Elastic and Rigorous Plastic Analysis of Liner for postulated LODHR accident, 2 nd para. Delete "Revision 0 of' and "stated that S&L" 61 B.6, para 5-p - Calculation #S06-0007, Done add a space above "Calculation S06-0007 Conclusion". 3 rd para. suggest The intent is to restore the liner plate to the deleting "However, the liner plate is to be minimum of 3/8".

restored to the originally specified 3/8" thickness" This will preclude an EC revision if we evaluate minor thickness reductions as acceptable.

62 B.6, para 6 - 2nd para. Reword "he This paragraph has been rewritten and develops all these activities and adds additional information added. It is important them" to " these activities are developed to make it very clear that the containment and added". opening task manager is responsible for these tasks.

63 B.6, para 6 - 3 rd para. Reword" Refer to Item 12 - left as-is According to MAC & Mac it will take their equipment" to "It will take" 64 B.6, para 6 - 7 th para. Delete "provided Refer to Item 12 - left as-is by MAC & Mac" 65 B.6, para 6 - 1 2t" para.? Tendon Grease Done Disposal. Delete "by PSC (tendon vendor)"

H05 Final Review Page 14 of 23

PCHG-DESG ENGINEERING CHANGE 0000063016RO 66 B.6, para 7 - Interface Requirements: This section was added based on a Vendor /Contractor section. Suggest recommendation from Dhiren Pandya deleting in its entirety, too many (Chiefs Group). Have reworded to better statement in it are not 100% accurate (i.e. reflect vendor responsibilities. Have not PSC is responsible for all activities removed.

related to inspection of the affected tendons [CR3 qualified and certified personnel will be performing these CBI personnel are responsible-for cutting, activities lAW CR3 approved work orders rigging and welding of the liner plate.

or procedurs], CBI is responsible for weld Welding will be per CR3 welding repair of damaged ares of the liner [CR3 procedures.

is responsible as this work will be done by PE Welding procedures using personnel aualified to PE oroceduresl. etc.)

67 +

B.6, para 8-a - 3rV sentence. Delete Have not deleted any company names -

"S&Ls". Refer to Item 12.

2nd para. Delete (as identified by S&L and their consultant), change "S&ME" to "Concrete Testing Laboratory" 3 rd. para. Delete "is the responsibility of Deleted all reference to consultant.

Sargent and Lundy and their consultant working in conjunction with a concrete testing laboratory (S&ME) and" Phase 1: Change "S&ME" to "the Concrete Testing Laboratory" and delete the last sentence.

Phase 2: Change "S&ME" to "the Concrete Testing Laboratory" and delete the last sentence.

Phase 3: Delete the first sentence. Only Phase 1 and 3 are done under S&MEs 10CFR50 Appendix B Program. This

[Same Comment as A.5.1.21 sentence therefore has t ostav.

68 B.6, para 8-b - 3 r"? para. Delete "by PSC Did not remove "by PSC (Precision (Precision Surveillance Corporation). Surveillance Corporation)" - Refer to Item Also delete, "PSC Transmittal #2 (N 1009- 12.

503) contained in". Change "fabricated at.

PSC's manufacturing facility" to Removed "PSC Transmittal #2 (N 1009-503)

"fabrication". Last sentence delete "and contained in" and PSC.

are supplied by PSC" 69 B.6, para 8-c c is used to identify Done.

Tendon Anchor Heads and the same paragraph identifier 8-c is used in the next para. to identify Tendon Split Shims.

Need to correct the para. identifiers for the 2 nd 8-c and the subsequent paragraphs through 8-j are verify that these are not referenced elsewhere in the EC.

H05 Final Review Page 15 of 23

PCHG-DESG ENGINEERING CHANGE 0000063016RO 70 B.6, para 8-c - (Tendon Anchor Heads) Done.

2 nd sentence delete "CR3 and PSC procurement departments identified" and change "as" to "is". Refer to Item 12.

4 th sentence delete "a term that both I think leaving this information in the EC procurement departments have problems helps clarify and document the historical identifying". background to identifying this material.

Last sentence delete "and are supplied by PSC" 71 B.6, para 8-c - (Tendon Split Shims), Done Last sentence delete "and are supplied by Progress Energy" 72 B.6, para 8-d - Last sentence delete "and Done is supplied by PSC" 73 B.6, para 8-e - Last sentence delete "and Done are supplied by PSC" 74 B.6, para 8-f - Last sentence delete "and Done are supplied by PSC" 75 B.6, para 8-g - Last sentence delete "and Done are purchased by Progress Energy" 76 B.6, para 8-h - Last sentence delete "and Done is purchased by Progress Energy" 77 B.6, para 8-i - 2nd para. Delete "as Left as-is. This is the only cold swaged spice manufactured by BarSplice Products, Inc. allowed by the NRC.

Dayton OH."

1 st bullet - Delete "and are purchased by Done.

Progress Energy" 78 B.6, para 8-j - 1st sentence, last word, Done uncapitalize "Opening" 1 st bullet - Delete "and is purchased by Progress Energy" 2 nd bullet - Delete "and purchased by Progress Energy" H05 Final Review Page 16 of 23

PCHG-DESG ENGINEERING CHANGE 0000063016RO 79 B.6, para 9 - 4h para? (Boxed info) Done Change the last sentence to "Damaged areas must be evaluated for potential repair and/or replacement actions." [Not all damage may need repair]

1 st bullet - delete "in this EC" Done 2 nd bullet - delete "Rev. 82" 4 th bullet, 2nd sub-para. If these welds are left as permanent welds then the EC and Drawings will have to be revised to These welds are made at the front end of show these welds, work and welding the outage and the welds are safety related instructions will have to be done as if the and will require NDE examinations. Per Jim weld may become a permanent weld, Terry the attachments on the inside face of applicable Inspections and NDE the liner plate will be removed. Attachments Examinations will have to be performed. on the concrete side of the liner will be cut-We may not want this option, suggest off approximately Y2" above the liner plate deleting not enough control or adding and left in-place. These welds will be more information?. examined as necessary to ensure that the 7 th bullet - This paragraph appears to be underlying liner material is intact. Section in a wrong location, this is not a design or updated.

code item, suggest deleting or shorten the information and refer to the RP Task Plan.

8 th bullet - 2 nd sentence change "his" to "this" 80 B.6, para 9 - Evaluation of Sump Pump Done requirements in the Tendon Gallery.

Change "MAC and MAC [2 locations] to "the".

Reword "Bechtel must confirm.... Pump they supply" to "steps must be taken to verify that the temporary sump pump is correct for the operation and the discharge volume is sufficient for this application."

81 B.6, para 10-General Done overview/evaluation of the methodology used in structural calculations: 1 st bullet, 2nd para., 1 st sentence Delete Per SP-182 (Ref. 7.2)". 2 nd sentence Delete "SP-182 also states that" and capitalize "During".

Last sentence un-capitalize "opening"

[Note: The capitalization of the word opening appears to be through-out the EC]

H05 Final Review Page 17 of 23

PCHG-DESG ENGINEERING CHANGE 0000063016RO 82 B.6, para 10 - Evaluation of the Done replacement concrete/concrete mix: 2 nd para., 2 nd sentence, Delete :prepared by S&L and located in" 4 th sentence change "by S&ME based on initial constituent material selection made by S&L and will be" to "and" 83 B.6, para 10 - Evaluation of concrete Done. Initiated AR 293932293932 Have reserved formwork for outside face of the calculation S08-0021 thru which to issue containment wall: 4 th sentence needs formwork calculations.

reworded to something like "The design of the formwork will be contained in

[attachment # xxx or calculation S08-xxxx]. AR# is generated to track the completion of this [attachment / calc] by xx/xx/xx." [Same Item & comment as for A.5.2.9 and D.2.2.5.1.c]

84 B.6, para 10 - Evaluation of the desiqn Reference to PSC has not been changed.

and use of the tendon work Dlatforms and Refer to Item 12.

upper support frames: Delete "supplied by Precision Surveillance Corporation (PSC). Reword "PSC has qualified all four USF's...." to "All four USF's are Revised. Referenced attachment Z34 qualified.. .them on the rail (Ref.

Attachment xxx (or Calc S08-xxx)" [Note:

For the time being this is assumed as the calculations have not yet been received per AR# 00285181, we need to identify what mechanism will capture the PSC calc (Attachment or Calculation?)]

Reword "Additionally, as previously noted, PSC calculation (AR#00285181) has qualified all platforms ....... on the rail system" to "As previously noted, all platforms have been qualified.....on the Revised. Referenced attachment Z34 rail system (Ref. Attachment xxx [or Calc S08-xxxx])"

Delete "SP-182 (Ref. 72) states that" and capitalize "During" Delete "However, Precision Surveillance Corporation (PSC) has stated that" and Done capitalize "All"

Conclusion:

Pre-construction Qualification Have not changed. Refer to Item 12 Testingq of Mechanical Splices: Should the tests listed here be captured in Section E0ORO ?

H05 Final Review Page 18 of 23

PCHG-DESG ENGINEERING CHANGE 0000063016RO Added test requirements to E00.

85 B.6, para 12 - 1s para. Delete (MAC and Left reference to Mac and Mac as-is-refer to MAC). 4 th para, Setence between the 1 st item 12.

and second bullet, and the 2 nd -4th bullet:

This should contain our site requirements Done.

for discharge waste water to meet our chemistry and environmental requirements? Not a "should meet" statement by MAC & MAC. Need to rewrite to state the discharge waste water will meet the requirements of the IWWP.

Tendon Grease Disposal: Delete "by PSC Done (tendon vendor)"

86 B.6, para 14 - Delete "Areva" [2 places] Done and reference the work instructions that did the layout. Reference to the work instructions may come in handy if a problem is detected.

87 B.6, para 15 - Operational Requirements The table was previously changed to 60 under various Conditions: (Table) This days.

table needs to be re-looked at for applicable modes and dates etc. The first 2 activities state that the work can be done 90 days prior to Mode 5, yet the elsewhere in the EC this is stated as no more than 60 days prior.

88 B.6, para 20 - Test Requirements: Added testing requirements for Qualification Should the Rebar testing of A.5.1.1.4 and of the Mechanical Splicing System BOORO pg 74 & 74 (AC1318-05, ACI-349-01, ASME III need added?

Concrete tests needs added? Concrete testing added.

6 th bullet - Delete "by MAC and MACs water treatment plant" 7 th bullet - states that PE will supply the Added test weight material to BOM test weights. Does the BOM for this EC identify and procure the material and make the test weights?

89 B.6, para 23 - 3 rd para., Delete Done

"(Manitowoc M2250)" [Not in the scope of this EC and could get changed due to unavailability]

90 B.7 - Add an Interface review for the Done designated Responsible Person/Engineer per IWE/IWL. (also list the tracking AR as this review will not be performed until H05 Final Review Page 19 of 23

PCHG-DESG ENGINEERING CHANGE 0000063016RO later) 91 B.8 - Delete "Revision 4" Done 92 D.1 - Pre-Outage: Move task #4 to after Done existing task #7 and duplicate task as a new task #10 in Modes 5 and 6.

93 D.1.23 -Add IWE inspections "IWE and Done IWL" 94 D.2.1.2 - 5 th bullet, change "be taped to" Done to "line".

9 th bullet, Change "of by PSC" to in accordance with EVC-SUBS-00107" 1 0 th bullet, Delete "is the responsibility of Precision Surveillance Corporation (PSC) and" also delete "PSCs waste disposal vendor must be a Progress Energy approved vendor" 95 D.2.1.3 - 2 nd bullet, states that the water Done "will be" stored, Was this a "may be" stored in other sections of the EC? We may not want to make it mandatory.

4 th bullet, Delete "Mac and Mac" 6 th bullet, This needs re-wored in its entirety, I believe what we want to state here is that communication with the Added Control Room is vital to ensure that radiological releases are not performed while personnel are working in elevated areas around on on the containment building. The current statement is a Federal Requirement and realy has nothing to do with what we are doing here.

7 th bullet, Why do we only think we will This water is from the condenser. Have have only 500,000 gallons added to the added sentence to clarify.

settling ponds when we say we will be using as much as 2,000,000 gallons of water? (Also we say "Condensate" in this para. and I don't think we are using condensate, we say elsewhere we are using well water) 1 2 th bullet, Reword "Steps must be taken Done to verify that the temporary sump pump installed in the tendon gallery is correct for the operation and the discharge volume is sufficient for this application prior to the start of hydrodemolition." Done 1 4 th bullet, Delete "Mac and Mac" 96 D.2.1.4- Add a 3 r" bullet to notify Done Security prior to removal of the liner plate.

H05 Final Review Page 20 of 23

a PCHG-DESG ENGINEERING CHANGE 0000063016R0 97 D.2.2.1.1.a - Delete. "supplied by Left as-is Precision Surveillance Corporation(PSC)" Refer to Item 12 98 D.2.2.1.2.b - Delete the last sentence Done "Refer to PSC Manual ........

99 D.2.2.1.3.b - Delete in its entirety, we are References PSC procedures which is OK.

detensioning in step a.

100 D.2.2.1.3.b - Delete "as noted in PSC Done Manual ........

101 D.2.2.2 - Boxed area, Delete "Mac and Left as-is Mac" Refer to Item 12 102 D.2.2.2.1 .i - Delete "Mac and Mac". Done.

Reword last sentence similar to comment B.6 para. 9 and D.2.1.3. "Steps must be taken to verify that the temporary sump pump installed in the tendon gallery is correct for the operation and the discharge volume is sufficient for this application prior to the start of hydrodemolition."

103 D.2.2.2.2.c -Delete "Mac and Mac" Done.

104 D.2.2.2.2.d - Change "Mac and Mac" to Done.

Hydrodemolition Contractor'.'

105 D.2.2.3.1.d - Delete "provided by CB&r" Left as-is Refer to Item 12 106 D.2.2.3.2.a - Delete "provided by CB&I" Left as-is Refer to Item 12 107 D.2.2.3.2.d - 2nd sub-para. If these welds Welds will be left on outside face only (per are left as permanent welds then the EC Jim Terry). Have added that they must be and Drawings will have to be revised to examined as necessary t ensure underlying show these welds, work and welding liner material is intact.

instructions will have to be done as if the weld may become a permanent weld, applicable Inspections and NDE Examinations will have to be performed.

We may not want this option, suggest deleting not enough control or adding more information?.

108 D.2.2.5.1.c- sentence needs reworded to Done. Initiated AR 293932293932 Have reserved something like "The design of the calculation S08-0021 thru which to issue formwork will be contained in [attachment formwork calculations.

  1. xxx or calculation S08-xxxx]. AR# is generated to track the completion of this

[attachment / calc] by xx/xx/xx." [Same Item & comment as for A.5.2.9 and B.6 para. 10]

109 D.2.3.1.a - Need to add inspections for Done.

the new replacement anchorage components.

H05 Final Review Page 21 of 23

a PCHG-DESG ENGINEERING CHANGE 0000063016R0 110 D.2.3.3.a - Suggest deleting "of ASME Done.

Section VIII and"Section XI and other areas take you back to the construction codes and we call it out better in section EOORO.

111 D.2.3.6.a - Delete "Pressure Test and" or Reworded. Note that one test satisfies IWE "and ILRT" The ILRT is a pressure test, and the other IWL.

delete one or the other terms.

112 EC Parts Listing Pages 14 Need to Added a note that PSC will provide tendon add materials for the Test Weights (ref. components for the mock-up.

E0ORO and B.6 para. 20). Also are there more Mock-Up components we need? Added material for test weights.

(such as tendon material and button heads to practice assembly and inspection techniques, tendons to plasma cut etc.)

113 E0ORO - Are there additional re-bar Added additional testing requirements for testing that should be added, such as that mechanical splice detail.

discussed in BOORO for ACI-340-01, ASME Sect III etc?

Missing items:

Detailed visual inspection of exposed re- Added.

bar ref. A.5.1.14.

Coating inspections ref. A.5.2.4 Added.

Detailed visual inspection of used re-bar per IWL-4220, ref. A.5.2.7 and A.5.2.10 114 FOORO - last sentence in 3 r' para. Done Reword "This has been discussed with Rick ........ " Just need to reference the AR assigned to revise the Surveillance Procedure.

115 GOORO - Sketches, Should the Added as G05 Hydrodemolition Frame Sketch included in the EC Attachments be added here?

116 Z22 - This Attachment is blank, CBI drawings have been added to Z22 something temporary should be added in the folder explaining what it is for.

117 Z26 - There is no record of review Review added. It has not been made into a included in the folder, Should it also be vendor manual. One time use only.

added to the vendor manual system?

118 A.5.1, Task #1 - Move item #7 to end Done.

(#10) and duplicate it as a new task #12 for Mode 5 and 6 as this will be done in both pre-outage and following shutdown.

[Review tasks listed in DOORO, section Done D.1 that may also need to be added here and likewise see if there are task items listed here that should be listed in D.1]

H05 Final Review Page 22 of 23

a PCHG-DESG ENGINEERING CHANGE 0000063016R0 119 A.5.1.2- 2na para., 2n, sentence. Delete Refer to item 12.

"prepared by Sargent and Lundy (S&L)". Deleted reference to "their consultant" 3 rd para. Delete (as identified by S&L and their consultant), change "S&ME" to "Concrete Testing Laboratory" 4 th para., Change "S&ME" to "Concrete Testing Laboratory" Phase 1: Change "S&ME" to "the Concrete Testing Laboratory" and delete the last sentence.

Phase 2: Change "S&ME" to "the Concrete Testing Laboratory" and delete Last sentence is correct.

the last sentence.

Phase 3: Delete the first sentence. First sentence is correct

[Similar Comments as in B.6, para 8-a]

120 A.5.1.5 - 1st para. Delete "supplied by Refer to item 12.

Precision Surveillance Corporation (PSC).

2nd para., Change "PSC" to "the vendor" 121 A.5.1.12 - 3 rd para., Delete "Mac and Mac Refer to item 12.

Hydrodemolition Services Inc. was awarded the contract for all hydrodemolition activities associated with creating the opening in the 42" thick concrete containment wall."

Box below 4 th para., Change "Mac and Mac" to "The hydrodemolition contractor" Dis cilistgr Rev.ew

-Sicope of Review Structural EC63016 Final Review for technical adequacy and procedural

______________________ compliance.

Joe A. Lese Civil/Structural 8/26/08 N 1 A list of minor typographical/editorial; Incorporated as requested.

comments was provided to the originator for incorporation.

2 Add a sketch depicting the buttress layout Incorporated as requested.

scheme to assist those unfamiliar with the CR3 nomenclature who might be using this package.

3 To the Closeout Summary of Section "F", Incorporated as requested.

add that all Work Orders will be CLOSED or COMPLETED and all AR's will COMPLETE prior to closeout.

H05 Final Review Page 23 of 23

PCHG-DESG Engineering Change 0000063016RO 1.1 Design Verification ie we' eiw EC 63016, Rev.0 IUasaba Hanganath CIvil/btructural 8/15/08 Ite Comn Resolutio 1 Section A.4 : Option #2- 160' concrete Revised to Elevation 160' slab, should this be slab at Elev 160'-0" instead of 160' slab.

The primary activities/scope should go under Scope section.

2 Section A.5: In the first paragraph explain Explanation added.

why it is required to detension and retension additional tendons adjacent to the opening.

Reword the second line second Done.

paragraph "Any of three adjacent...."

In the third paragraph last sentence will the treated water be tested for any Previous sentence discusses radiological contamination before discharging the testing.

water to the settling ponds.

In the last paragraph on page 4 the opening in the concrete is indicated as Revised to read "approximately 12" approximately 18" larger than the liner. larger".

However, drawings 421-349 and 421-350 indicate that the opening in concrete is about 12" in the bottom, 6" on the top and 1'-3" on either side larger than liner plate on the inside face of Containment.

Need to clarify this.

Reword the first sentence first paragraph "As soon as the concrete demolition is Done.

complete and the reactor defueled.

to be consistent with the sequence of activities.

In the second paragraph Page 5 explain why it is required to detension additional Done.

tendons adjacent to the opening.

Tendon sleeves, conduit and sheathing has been used in this EC Changed to sheathing.

interchangeably, suggest using one name sheathing throughout the document or clarify that sleeves and conduits are 100 DV Page 1 of 32

PCHG-DESG Engineering Change 0000063016RO same as sheathina.

3 Section A.5.1 Task #1: These tendons have to be detensioned.

Under Item 6, why is it required to In order to detension them the grease has degrease the vertical tendons that are not to be drained out or else it would leak out required to be removed, after the end caps are removed.

The Pre-Outage, Modes 5 and 6, and Defueled activities identified in Page 6 Done.

are not consistent with the title of the activities shown in subsequent pages in this section to describe these activities and vice versa. Make this consistent.

4 Section A.5.1.1: add under mock-ups and Done.

training category "Mechanical splicing of tendon sheaths".

In the last bullet under mock-ups and Done.

training add liner plate and rebar and IWE

-2300.

5 Section A 5.1.2: In the second paragraph Done.

first sentence add after strains "and controlling concrete placement temperature."

6 Section A 5.1.4: Identify which EC will At this time we do not know if it is going to provide the mast climber material hoist. be an EC.

7 Section A 5.1.7: The last sentence before Revised to state "20 vertical detensioned the bullets indicates that following 20 (only) tendon anchorages (including the vertical tendons require IWL inspections, surrounding concrete) .........

Are we inspecting the tendons or just the button heads, end caps and the anchorage assembly. In order to inspect Repeated for the hoops.

the tendons, it will have to be removed and inspected. Clarify. Also identify these are de-tensioned tendons. Same comment for the 18 hoop tendons identified in Page 11.

8 Section A 5.1.8: add at the end "This EC Done.

will cover Hydrodemolition Support Frame, design and installation of the chipping platform accessible ladder, waste chute, and the protective screen."

9 Section A 5.1.14: Delete 100% VT-1 Done.

examination and indicate as "Detailed visual" since ASME Section XI IWL does not have VT-1 or any VT examination requirements. Reference 2.10 in this section should be 2.1.

10 Section A 5.1.16: Indicate in this section Done.

the bottom part of the cut liner plate will have two cut out sections as shown in Drawing 421-349. This cut out section is to provide clearance for the HTS 100 DV Page 2 of 32

PCHG-DESG Engineering Change 0000063016RO runways.

11 Section A.5.1.17: This section has a The PSC manual will not be issued to reference to Attachment Z23 for PSC CR3 until 8/22/08.

manual. This attachment is presently F&Q 8.1 is the section in PSCs manual empty. Also AR#00285173 referenced in that addresses Ram Tendon this section presently has no information Detensioning. I have added the PSC in the AR and what is F&Q 8.1 mentioned manuals List of Contents section to Z23 here. for the reviewers clarification. This will be replaced with the manual before issuing the EC.

AR 285173285173Assignment 1 was initated to track that PSCs manual is in fact issued to CR3 before 9/05/08.

12 Section A5.2.7: Replace "100% VT-I" Done.

with "Detailed visual."

13 Section A 5.2.8: Same comment as Item Refer to Item 11 above.

11 above on Attachment Z 23. In addition Reason added. Tendon sheathing could provide a reason why the tendon insertion displace during insertion and disturb the should be stopped at the commencement newly placed concrete.

of concrete placement and not start till the concrete attains minimum 3000 psi concrete and what is the basis for starting after reaching 3000 psi concrete strength.

The 3000 psi concrete strength is not Section D.2.2.1 Item 4 has been revised consistent with Section D. 2.2.1, Item 4, to 3000 psi.

Step I, Page 7 that mentions 2000 psi.

14 Section A.5.2.10: Replace "VT-I" with Done.

"Detailed" 15 Section A.5.2.11: See comment on Refer to resolution for Item 11.

AR#00285713 provided under Iteml1.

Change Reference Drawing 431-352 to Done.

421-352.

16 Section A.6: Page 27 AIMS ID #574: Done.

Conclusion Statement: In the last line after EC add "in the installation

.instructions" and under Update to above conclusions statement, in the second sentence change Drawing to Drawings and add Drawing 421-349.

17 Section B.2: Suggest rewording the OK as-is.

second paragraph to be close to the work activity sequence as follows "Creation and restoration of the access opening will require removal of the concrete, rebar, tendons, tendon sheaths, and liner plate within the boundaries of the Opening and splicing of existing rebars. In addition requires installation of a new reinforcing cage comprising of 2 layers of #11 rebars at 11" center to center spacing, in both 100 DV Page 3 of 32

PCHG-DESG Engineering Change 0000063016RO the hoop and vertical directions in the opening and reinstallation of liner plate and concrete before detensioning of additional vertical and hoop tendons adjacent to the concrete opening. These new rebars will not be spliced to any existing rebars that may be protruding from the sides of the Opening."

18 Section B.4.4: The operating temperature The temperatures identified in B.4.4 are inside containment is shown as 90 to 110 the ambient air temperatures. The design degrees and operating temperature basis operating and accident temperature outside containment is shown as 25 to profiles through the containment wall are 100 degrees. These temperatures are shown in the Containment DBD in the also identified in DBD. Calculation S06- section for "Containment-General" under 0006 (Page 35) that evaluates the heading "Thermal". The Table of containment wall after restoration of design temperatures shown in that containment opening till end of life uses section of the DBD are for the winter inside wall temperature of 99 degree and condition because this will yield the worst outside wall temperature of 37 degrees, case temperature differential between the which are winter temperatures as per inside of containment and the outside.

DBD. Need to verify if the thermal gradient used in Calculation S06-0006 for the thermal range is acceptable based on the operating temperatures identified in Section B.4.4.

19 Section B.4.6: Tendon Grease disposal: Added PSC Provide a basis for 200 drums (11,000 gallons) of waste tendon grease estimation.

20 Section B.4.8: Mechanical requirements: As stated in B.4.8 "AP-404, Loss of The containment closure is required as Decay Heat Removal (LODHR), requires per ITS during Mode 6 only, why then the containment closure capable of containment closure should be capable of withstanding an 8 psi (5.14 psi per withstanding internal pressure due to Ref.10.3) internal pressure should Decay LODHR during Mode 5. Heat Removal be lost in Modes 5 or 6".

Licensing and Operations has therefore conservatively interpreted this requirement of AP-404 as requiring containment closure capable of withstanding internal pressure due to LODHR during Mode 5.

21 Section B.4.12: Waste Water Hydrodemolition contractor. Also note requirements: What is the basis for the that Section B.6.6 evaluates the water 2,000,000 gallons of clean water requirements.

requirement for hydrodemolition at the rate of 360gpm.

22 Section B.4.15: Same comment as Refer to Item #20 above.

Section B.4.8 above.

23 Section B.4.24: Provide any document Station Fire Protection Plan (FPP, number or location to find the Station Fire Revision 25), added.

100 DV Page 4 of 32

PCHG-DESG Engineering Change 0000063016RO Protection Plan identified under Basis.

24 Section B.6.3: Under Design Margins it The existing area around the equipment mentions about thickened area around hatch is thickened since this is a large equipment hatch. Is this area that is penetration thru containment. The already existing, since this EC did not analyses investigated this area because it modify the equipment hatch area, clarify, is directly below the SGR access Also the reference to Ref.1 at the end of opening.

Design Margins is not correct, it should be Ref. 5.7. Revised Ref. number.

25 Section B.6.4: See comment regarding Refer to Item 18 resolution.

containment wall inside and outside temperature in Item 18 Section B.4.4. In addition the calculation reference SOO-0006 is not correct, it should be S06-0006 Calc SOO-0006 is correct.

26 Section B.6.5a: Should the reference 5.12 identified here be 5.11, verify.

27 Section B.6.5-b: Page 27 second RS are from Ref. 3.1 as stated in B.6.5-b.

paragraph mentions about use of The ZPA at each floor is used in the applicable acceleration from the response analysis.

spectrum, to simulate equivalent static Have added to this section a reference to load at each segment. How are these the "ZPA" acceleration values developed. Is it the ZPA at each segment, clarify.

28 Section B.6.5-c: The page number Eliminated page numbers referenced in last bullet for wind pressure should be 11. The page numbers associated with Reference 2.1 identified Rev. 5 is latest revision as shown in throughout this EC seems to be not Section B.3.

correct, verify. Also Reference 2.1 (DBD) is not the latest version identified in this EC. Need to verify the impact of the new version of DBD on EC.

29 Section B. 6.5-d: ii) Reduced Prestress Friction losses are accounted for as a During SGR: In the last line of first result of retensioning the tendon to 0.8 paragraph it is indicated that the effective GUTS and then locking off at 0.7 GUTS.

prestress in the tendon were calculated It is recognized that the tension in the taking into account losses due to friction tendon varies along its length due to in addition to other sources identified friction. By tensioning to 80% and then here. However, review of Calculation backing off to 70%, the tension in the S06-0006 indicates that the loss due to tendon at the buttress will be at 70% but friction was not considered. ACI 318-63 between buttress's it may be at 75%,

Section 1607 also requires to consider therefore the average is around 70%.

friction loss and loss due anchorage This is industry wide normal practice. If slippage in addition to other sources that any additional information is required, have been identified in this section of EC. suggest contacting Dr. Howard Hill.

In addition review of original Calculation 1.01.7 and 1.01.16 indicates that friction losses had been considered in accordance with ACI 318-63. Clarify why these losses were not considered.

100 DV Page 5 of 32

PCHG-DESG Engineering Change -0000063016RO 30 Section B. 6-5-f: Tornado Wind While TLD added.

Defueled: In the title after HTS add "ITLD" and revise Item (i) as follows Removed reference to TLD in sentence.

"rigging the SGs into and out of containment using TLD on the HTS and".

Also the weight of Auxiliary Crane is shown as 527 kips, as per Mammoet Also refer to Attachment Z33 Calculation 001004168-C40 Appendix C Page 1, the total weight of the crane including counter weights and the cart is 322.347 kips. Need to revise this and Load removed. Added sentence to mention that the load used is higher and Section B.6.5-m hence the design is conservative. Also the AR identified here presently does not

+

have any information in the Dassport. I 31 Section B.6-5-g: Tornado Covers period from start of retensioning Depressurization While Defueled thru to completion of retensioning, therefore Refuel (Page 32): The first paragraph last conservative.

line mentions that this activity includes re-tensioning of tendons. However, at Stage 2 Prestress as per definition in Page 28 the tendons will be detensioned, needs As noted, we are only reviewing for Il/I clarification. Also the tangential wind concerns and have used the latest velocity in Reg Guide 1.76 is shown as editions of Reg. Guide 1.76 (Revision 1) 230 mph for Region 1 and CR3 is in to determine pressure drop and the Region 1 compared to 212 mph identified Enhanced Fujita Scale as approved for here, need verification. use by the NRC in NUREG/CR-4461. The load combinations are per NUREG-0800 SRP 3.3.2. Note that during this time period there is no fuel in the reactor.

Additionally, tornado is not a design basis accident load (Refer to Table 5.3 in the FSAR).

32 Section B.6.5-i: Thermal Loads: Page 34 It's there.

shows that the design temperatures are as per Ref 2.1 under the parameter "Thermal". Could not locate this section in Ref 2.1. Design temperatures are shown Refer to Item 18 resolution.

in design input section of this EC Section B.4.4. Why are these design temperatures not used in the containment wall analysis in Calc S06-0006.

33 Section B.6.5-i: Temperature from full Should have been reference 2.1.

restoration of access Opening until end of plant life (Page 35): It is mentioned that Table 6-3 of Ref. 2.1 provides design basis temperature for the containment shell for various conditions. Table 6-3 Refer to Item 18 resolution.

only provides winter temperature condition and Page 35 of Ref. 2.1 provides the operating temperature, 100 DV Page 6 of 32

PCHG-DESG Engineering Change 0000063016RO which is also mentioned in Design Input Section B.4.4. Why is this temperature not used in the analysis. Also provide a basis for the statement that says that the noted temperatures for the winter Refer to discussion in Section 5-i accident condition will not be concurrent concerning peak temperature and with the maximum peak pressure within pressure.

containment building.

34 Section B.6.5-j: Pressure Loads: In the Done. Also added letter to Attachment second paragraph in the first sentence Z16.

after building add "(

Reference:

Progress Energy Letter No.SGR 06-0054 from D.

L. Jopling and R. Lemberger to Chris Sward,

Subject:

RB Pressure and Temperature, dated August 9,2006.)"

35 Section B.6.5-k: What is the reference for Refer to Attachment Z33 auxiliary crane load of 527 kips shown in second controlling load. See comment provided in Item 30. The auxiliary crane load is also shown as 160 tons in EC 63020 File D 020R0.

36 Section B.6.5-m: same comment as Item Refer to Attachment Z16 35 for auxiliary crane load. PE letter SGR 07-026 37 Section B.6.5-0: This review cannot be Calculations provided to verifier.

completed as the calculations are not available yet.

38 Section B.6.5-p: Calculation S06-0004 Definition is on page 6 of S06-0004.

Page 30 table of concrete properties lists Existing and Original concrete properties separately. What is the difference between the existing and original concrete. Does the existing concrete include the proposed concrete opening, need clarification.

39 Section B.6.5-p: Calculation S06-0004 Section 4.2 Page 44: In FEM Model B the first bullet mentions Model #1, should this Changed to Model A be Model A. Also in the last bullet under this FEM Model B should 1-2 be A-B. No. Should be B1-B2 40 Section B.6.5-p: Calculation S06-0004 Different E values will have no affect on

Conclusion:

In the conclusion it is membrane results, so long as the same E mentioned that after Calculation S06- is used. The prestress levels are 0004 was completed for all future calculated in calculation S06-0005 and analysis a reduced E value =2500ksi compared.

would be used, however it did not indicate the effect of this reduced E value on the prestress levels in and around the opening after re-tensioning will they be at levels similar to those before the SGR outage as concluded earlier in this 100 DV Page 7 of 32

PCHG-DESG Engineering Change 0000063016RO section. Could not locate this conclusion in the calculation S06-0004. Is the concrete material used is compatible with Concrete is compatible. Higher strength the original constituent concrete material. but with low creep properties. Existing In addition Becthel in their review of concrete is "creeped-out" due to age.

Creep Effects on Behavior of Restored Containment Structures provided in Attachment H04 recommend evaluation of wall at the opening and in the in the Varying the properties by +/-20% is not vicinity by using a variation of +/- 20% realistic; would have resulted in a huge variation in the resulting concrete number of results; which one would be stiffness compared to the "ideal" values. acceptable? The code allowable's that we Could not verify if the calculation has use for design have built in factors of considered this aspect. safety, any structural analysis is just our best estimate of the structures resionse.

41 Section B.6.5-p: Calculation S06-0005: Calculation evaluates containment for Page 13 of calculation mentions about both modes 5 and 6 and defueled. Calc is defueled mode as mode 6. Defueled correct.

mode is supposed to be no mode. Need to correct this and verify if this has any effect on the calculation.

42 Section B.6.5-p: Calculation S06-0005, This calculation has to evaluate the Page 47. The last Stage 2 Prestress containment with the opening, full of wet while Refueling is not part of this concrete and conservatively stage 2 calculation and it is covered under prestress. During restoration, which can Calculation S07-0007 as indicated in occur while defueled or in mode 6, we Page 46. It is not clear from Calculation have to assume stage 2 prestress. Page S06-0005 Page 1 whether it covers the 1 of the calc is correct.

time period between the installation of the liner plate and the placement of concrete.

43 Section B.6.5-p: Calculation S06-0006, Refer to item 29.

Page 49. Model #1 - Why the tendon prestress losses do not include loss due to friction and anchorage slippage as required by AC 318-63 Section 2607.

44 Section B.6.5-p: Calculation S07-0003, Done Page 50. Add a sentence after first paragraph "Steam Generator Replacement will not impact the dome tendons, hence the prediction of end anchor forces for these tendons shall be per the existing methodology.

45 Calculation S07-0003 : Same comment Refer to item 29.

as Item 43 regarding the losses in tendon prestress due to friction and anchorage slippage.

46 Calculation S07-0003: Page 51- Will the They are already installed, cannot affect creation of new sequencing for the 30 their original sequence.

verticals and 35 hoop tendons in and around the opening affect the original 100 DV Page 8 of 32

PCHG-DESG Engineering Change 0000063016RO sequencinq.

47 Calculation S07-0003

Conclusions:

Same Refer to item 29.

comment as Item 43 regarding the losses in tendon prestress due to friction and anchorage slippage.

48 Calculation S06-0007: Page 52: Done.

Simplified Elastic and Rigorous Plastic Analysis of liner for postulated LODHR accident: Add after first sentence the following: "ASME Section III Div.2 Paragraph CC-31 10 (e) provides that the design of the metal containment portion not backed by concrete for load carrying purposes, such as access opening liner plate carrying the LODHR accident pressure load, shall meet the requirements of ASME Section III Division 1, Subsection NE.

49 Calculation S06-0007: Page 54, Removed reference temperature. As Conclusion states that the liner thickness noted in'the discussion for S06-0007, per is 3/16" at 5.14 psi. It should be identified Table NE-3221-1 thermal load evaluation here that the design temperature for this is not required for Service Level D, condition is 173 degrees as per Page 40 therefore, the liner plate in the access of Calculation S06-0007. opening is evaluated for LODHR internal pressure only.

50 Section B.6.6 : Environmental Conditions: Added reference Z24 Water requirements: Provide reference to the total requirements and the number of hours required for hydro-demolition mentioned in first paragraph.

51 Section B.6.6: Water requirements: As noted in B.6.6, the delivery and ECED 59400 mentions about diverting disposal of water is outside the scope of the water from treatment plant to oil tanks this EC.

well in advance prior to usage. May need to include this requirement in installation.

52 Section B.6.6 : Waste water disposal: In This is not really true. The waste water is the first sentence in' the second continually pumped from the collections paragraph add after water "that has been bins to the treatment plant. There will be found acceptable through test" no waiting for radiological results.

53 Section B.6.8: Material Requirements: 8-a Done Concrete: Phase 3: Page 58, Add after ASTM C 512" to confirm the acceptability of the concrete mix for intended application."

54 Section B.6.8: Material Requirements: 8- Tendons are not a hazardous material.

b: Tendons: Page 59, after disposal add a sentence "The disposal shall be in accordance with the requirements of corporate procedure EVC-SUBS-00016 (Hazards Waste Management)."

100 DV Page 9 of 32

PCHG-DESG Engineering Change 0000063016RO 55 Section B.6.8: 8-c: Tendon Split Shims: PEERE = Plant Equipment Equivalency What is PEERE 987 and it should also be Replacement Evaluation and is a Quality identified in Reference Section. Record in document control. Added to Reference section.

56 Section 8-d and 8-e: Grease cap, Grease Revised to "Caps" Cans, and End Caps have been used interchangeably. We may want to use End Caps as specified in SP-1 82 and Drawing 5EX-003 or mention that Grease cans, Grease caps, and end caps all refer to same item.

57 Section B.6.9: Page 64, Last paragraph Done.

third sentence mentions that water will probably evaporate. Delete probably to make a positive statement. Also in same paragraph it is mentioned that it is assumed that oxygen behind the liner plate to be very limited. Delete assumed and state that the oxygen will be very limited.

58 Section B.6.10: Structural Requirements: Done.

Page 66 at the end it is mentioned about the possibility of corrosion of liner plate due to wet concrete is not a problem. Is there any OE that can confirm this or if no OE is available state that there are no OEs to indicate this as a problem.

59 Section B.6.10: Evaluation of the design Added Attachment Z34 and use of the tendon work platforms and upper support frame: are there any drawings for these structures.

Page 70: Provide reference to PSC This is a statement by PSC and it is statement that all work associated with stated in the work instructions that no moving and staging the platforms at work can be done in these areas pre-buttress numbers 2,3 and 5 can be outage.

achieved by personnel working and staying within the boundaries of the RB Outside edge of the roof. There is roof and define what is RB boundary roof. handrail around the outside edge of the roof.

60 Section B.6.10; Page 70- Provide Added.

reference to 85 psf stored platform loads on IB roof.

Is there a document to ensure that USF's Work instructions contain direction for and associated equipment will be stored storing the platforms on the IB roof. Note securely on the containment roof both that the area where they will be stored, on before and during SGR outage for the north side of the RB is shielded on adverse weather conditions. three sides by the TB and RB and the fourth side is partially shielded.

61 Section B.6.12 : Water requirements TSS= Total Suspended Solids, have Page 75: What is TSS and is there any added to EC. 100 DV Page 10 of 32

PCHG-DESG Engineering Change 0000063016RO reference to 45 ppm requirement. Requirement is per Mac and Mac Waste Water: Page 75: Why is the need to check the pH value only before As stated in this section the only discharge. It conflicts with the requirement for testing the water prior to requirements for waste water discharge discharge to the ponds is pH testing. This identified by Mac and Mac in this section. is what the site's Industrial Waste Water Why not use the APHA, Standard Permit (IWWP) requires.

methods for examination of water and waste water as specified in SP-182. There are no conflicts. Mac and Mac have identified what limits their equipment is capable of filtering. These limits meet out requirements as previously stated, i.e., pH of between 6 and 9.

The IWWP controls CR3s industrial releases.

62 Section B.6.19: Page 78: Failure effects The two probabilities given are the CFDP.

Item (ii): An estimate of CCDP is not Reference 9.7 added.

provided here as stated. The estimate provided is for the probability of OBE or SSE occurring for the stated time interval and also the reference 9.1 mentioned here for CDF is not correct. Need to provide estimate of CCDP and the reference for SPRA and add this reference to the Reference section of this EC.

63 Section B.6.19: Page 79: Failure effects Clarified.

Item (ii): The probability of tornado occurring is shown as 2.12E-08. This probability should it be probability of tornado striking CR-3 containment in less than 90 days. Verify.

64 Section B.6.19: Page 79: Failure effects Revised.

Item (iii): This section mentions load combinations per Table 6 of FSAR.

There is no Table 6 in FSAR Chapter 5, verify if it should be Table 5-3.

65 Section B.6.19: The failure effects on the They are in Section iv.

structural requirements for the RB after restoration of the opening and before retensoining of the tendons (Stage 2 prestress) should be addressed.

66 Section B.6.20: Containment pressure Discussed with Casaba and revised test: After IWL 5000 add IWE 5000. accordingly.

Revise the next sentence as follows: "All examinations shall be in accordance with IWL-5250 and IWE -5220, which requires detailed examinations of the restored concrete surface and liner plate in accordance with IWL-231 0 (b) and IWE-100 DV Page 11 of 32

PCHG-DESG Engineering Change 0000063016RO 2310 prior to the start of the pressurization, during test pressure and following the completion of the pressurization." Also add SP-1 78 identified here to the Reference section of this EC.

67 Section B.6.20: Liner Plate: Delete Done.

reference to IWL, since liner plate is not part of IWL scope.

68 Section B.6.20: Hydrodemolition water The only requirement for testing the water effluent testing prior to discharge: What prior to discharge to the ponds is pH is the reason for pH sampling of water testing. This is what the site's Industrial before discharge. Also the water should Waste Water Permit (IWWP) requires.

be discharged in accordance with the The IWWP controls requirements for requirements of station procedure EVC- water discharge.

SUBS-0016.

69 Section B.6.20: Functional testing of the Added "1/2" thick".

hydro-demolition equipment: What thickness steel sheets will be required.

70 Section B.6.21: ISI Requirements for the Revised accordingly.

Liner Plate Welds: Delete VT-3 visual inspection and replace with Detailed Visual Inspection or VT-lfor liner plate.

71 Section B.6.23: Page 84: Why only the Plant will be in No Mode during these lifts.

load drops associated with coilers, tendons and tendon ram will be addressed in AR#00284485 and not the rebar and liner plate.

Also want to add in the last paragraph to Added.

state that "The actual weights and radii will not be significantly different from the weights and radii shown on the safe load path drawings" 72 Section B.6.28: What are the PSC work Added "Attachment Z23"

_ procedures.

73 Section B.8 : Under Safety Classification Done.

of activities: Add installation of work platform and USF and chipping platform chute and safety curtain as non safety related activities.

Tensioning of tendons and addition of This section is for components and grease in the tendon sheath are safety materials.

related activities and should be included.

74 Section C.2: ARs They were previously added.

277358,289322,289302, and 290111 are in Other References in the Reference section of this EC, however, they are not in passport Xref.

75 Section C.2 VTMA 02580-0001 and They have been removed. These two 100 DV Page 12 of 32

PCHG-DESG Engineering Change 0000063016RO VTMA 02584-001 are in Section C.2 but VTMAs are not being used in this EC are not in ADL of passport.

76 Dwg: 421-346. In the defueled Stage 1 Revised accordingly.

Prestress the sketch indicates detensioning of tendons adjacent to opening, which is not correct and should be deleted.

Also in Load combination 35a for Changed to 1.45.

defueled Stage 1 prestress, it shows 1.45 DL and in load case Defueled Stage 2 prestress excluding SGs in Load combination 35c, it shows 1+/- 1.45 DL.

Does not seem consistent, verify.

See additional comments marked on the drawing.

77 Section D.2.1: Item 2 Page 3. Drawing Has been added to drawing.

63016-SK-SO01 does not mention about lifting the USF. Should this be identified in the drawing.

Also it is mentioned that the work platform No drawings have been prepared. Added will be lowered to the ground or on top of reference to site procedure EM-220, Intermediate Building and secured in Violent Weather.

case of severe weather. Is there any procedure or drawing, which shows how the platform will be secured.

78 Section D.2.1:Consider adding following additional Prerequisites / Precautions:

1) Project Task Manager shall Done.

ensure that all applicable environmental permits are obtained and in place before implementation of activities associated with this EC.

2) Work planning shall ensure that Done.

activities associated with this EC are in compliance with the applicable portions of EVC-CRNF-00003, "Use Crystal River Nuclear Plant Site-Specific Environmental Compliance Manual".

3) Work planning shall coordinate RP is responsible for identifying this with the Radiation Protection as to training, not this EC any special training requirements for personnel necessary to efficiently implement this EC.
4) All painted surfaces of any SSC to' NA be removed per this EC shall be tested for the presence of lead in accordance with Procedure SAF-SUBS-00013 and Al-1 831 and any other plant or corporate 100 DV Page 13 of 32

PCHG-DESG Engineering Change 0000063016RO procedure or process.

5) Any hazardous waste that is produced by activities Done.

implemented per this EC shall be handled and shipped in accordance with Procedures EVC-SUBS-00016, EVC-SUBS-00008, Al-1 820, and any other applicable plant or corporate procedure or process.

6) Any non-hazardous waste that is Done.

produced by activities implemented per this EC shall be handled and shipped in accordance with Procedure Al-1820 and any other applicable plant or corporate procedure or process.

7) All chemicals and other Done.

consumables shall be approved and properly labeled per CHE-NGGC-0045 and any other applicable plant and / or corporate procedure or process.

8) All lifting and rigging shall be Done.

performed in accordance with Al-650, "Rigging, Lifting, and Material Handling Program", or any other applicable plant and / or corporate procedure or process.

9) All welding shall be performed per Done.

NGGM-PM-0003, Corporate Welding Manual.

10) Work to be performed inside the RP will specify reactor Building and in the yard inside Radiological Controlled Area (RCA) will require RWP. An ALARA pre-job brief may also be required for specific tasks.
11) Standard inspection criteria for Done.

structural steel, welding, and bolting apply, per NUA-NGGC-1530 unless noted otherwise.

12) Special care shall be taken to minimize damage to existing Done applied protective coatings. Care shall taken during rigging, handling, unloading, and erecting structural steel and components.

Any damage done to protective coatinq should be repaired in Page 14 of 32 100 DV 100 DV Page 14 of 32

PCHG-DESG Engineering Change 0000063016RO accordance with site procedure.

Note: If any of above requirements are Done.

added, need to ensure that the procedures identified in these requirements are included in the Reference section of this EC, if they are not already identified.

79 Section D. 2.1: Item 2 Page 3: Identify Done two other violent weather warnings, Tropical storm and Hurricane as mentioned in Section B.6.10 Evaluation of tendon work platforms and USF.

80 Section D.2.1: Item 3 Page 4: identify two Only pH is required.

other requirements for waste water discharge as mentioned Section B.6.12 81 Section D.2.1 Item 4 Page 5: Identify two Done.

other requirements for liner removal as mentioned in Section A.5.1.16 82 Section D.2.2.1 Item 1: Tendon Service Changed to G01 Platform Installation: Step b. references safe load path drawing as Attachment Z12. Attachment Z12 drawing is for tendon retensioning sequence, Z12 does not appear to be the right reference.

83 Attachment Z13 RO -Concrete testing The final water/cement ratio will be does not mention about water/cement identified after the completion of the ration requirements for concrete. Is this concrete mix testing.

not an important factor in getting a proper concrete mix.

84 Section D.1 : Pre-outage: Done.

Step 8: Add another line "Test the temporary pumps to ensure that they are operable and have sufficient capacity" Add a note at the end of pre outage to This information is included in the indicate that the activities identified during installation requirements. Note that the pre-outage with the exception of Survey time is different for certain activities.

and Layout of basic geometry of the opening cannot start more than 90 days before Mode 5.

85 Section D.1: Defueld - After Removal and Done.

Reinstallation of the OTSG.... : Add another step after step 15 "IWL inspection of tendon anchorage of the detensioned tendons" 86 Section D.1 : We are installing three layers.

During Refueling activities but Prior to Mode 4: Change "three" to "Two" in Step 100 DV Page 15 of 32

PCHG-DESG Engineering Change 0000063016RO 17 and add another step after Step 18" Install one layer of reinforcing steel" Step 21: Suggest reword as follows "Re-tension detensioned tendons and re- OK as-is.

grease detensioned vertical and replaced vertical and hoop tendons" Add after Step 22 another step "Retension replaced vertical and hoop tendons" 87 Section D.2.1: 2 Limitations on Tendon OK as-is.

activities: Under Bullet 4 add at the end "and the USF shall be secured safely on top of RB floor."

3 Prerequisites / Precautions to Hydrodemolition activities: In Bullet 3 The NPC Environmental specialist is expand NPC and add after air permits responsible for verifying compliance with another sentence to mention that the air permits.

compliance shall be in accordance with "Crystal River Fossil Plant Site-Secific Environmental policies, Permits, Registrations, Certificates and Plans" currently located at :

http://Proqressnet/C3/C 17/Crystal River Energy Complex/Site Specific Manuals /

Crystal River Fossil Site-Specific Manual pdf. Also need to add this reference to the Reference Section of this EC.

Bullet under Sump Pumps SDP-3A and 3B, suggest adding a hold point in the work package to ensure that the pumps We do not specify Hold points. The are disabled prior to start of demolition. planners will do this.

In the bullet under safety net add a line at the end "Safety net to be provided and installed by Mac and Mac Hydro-demolition contractor."

88 Under bullet that mentions about reducing Will not know water pressure affects on water pressure, need to determine the containment concrete until actual workable water pressure to ensure that implementation. No existing OE for Mac this pressure will not buckle the liner plate and Mac; this is the first nuclear job they through prior testing or based on OE. have done. What a workable minimum water pressure is, is unknown at this time, we will have t determine during actual hydrodemolition.

89 Section D.2.2.1 : 1. Tendon Service Sequence added.

Platform Installation: Step f: Identify the sequence in which platforms 2,3 and 5 will be rolled clockwise around the roof from their initial position at AZ 150 degrees.

100 DV Page 16 of 32

PCHG-DESG Engineering Change 0000063016RO I

90 Section D.2.2.2 Hydro-demolition: 2. Revised accordingly by adding e-mail Mode 5 & 6 activities: In Step e it is message to Attachment Z24 from Mac mentioned that operation of the hydro- and Mac. Frame is not attached to demolition equipment is in accordance containment wall.

with Mac & Mac work instructions (Attachment Z24). Review of this work instructions shows that the hydro-demolition work track frame will be mounted on CTMT wall, however, as per Sketch G05RO the track is mounted on steel frame supported on Chipping Platform. In addition the work instruction also mentions that-the concrete work height will be 24', which is less than 27' required as per Drawing 421-347. Need to correct this in Mac & Mac work instructions.

Note: The Lead Reviewer signature on the EC DV milestone panel signifies that a lead review has been performed in accordance with EGR-NGGC-0003 and that errors/deficiencies (for all reviews performed) have been resolved and included in the EC package.

100 DV Page 17 of 32

PCHG-DESG Engineering Change 0000063016RO Engneei 'hIvhIwlIIIOwner's Revi0ew' Mechanical DV I Charlie Kar I IVltUL; IdIl.;dI Ite Comn Resoutio 1 A.3 Revision Summary RESOLVED ADDED Original revision.

Section/Pages affected by this revision:

ADD "ALL" 2 B.2 Scope Description RESOLVED (LAST PARAGRAPH) HIGHLIGHTING REMOVED IWHY IS THIS HIGHLIGHTED??

During the SGR outage the creation and restoration...

3 B.3 RESOLVED Specifications: SPECS ADDED ADD...

G/C Inc. Specifications SP-5569 and SP-5618 4 RESOLVED B.3 SAF-ESGX-00002 ELIMINATED Plant Procedures: ADDED AI-2210 ,AI-2205E 7.1 SAF-ESGX-00002, Fall Protection REV. LEVEL??

fIS THIS A "PLANT" PROCEDURE?

ADD...

AI-221 0 AI-2205E 5 B.3 RESOLVED FOR CONSISTANCY WE SHOULD CONSISTANT W/ EC XXXXXRX PROBIBLY USE EITHER EC XXXXXRX IOR EC XXXXX, REVISION X 8.0 Plant Change Documents:

... ALSO...

EC 61170, Methodology Study - SG Transport Through Containment REV.

LEVEL??

100 DV Page 18 of 32

PCHG-DESG Engineering Change 0000063016RO EC 63021, Temporary Man-lift Outside RB to the Roof. REV.

LEVEL??

EC 64487R - ???

8.1 EC-ED 0068398R0 ADD...

EC 63020 6 B.3 RESOLVED Regulatory Documents: REV LEVELS CORRECTED, ADDED FSAR, Revision 29 THE CURRENT REVISION IS 31cc 4SPACE NUREG/CR-4461, Revision2 "Tornado Climatology of the Contiguous USA".

Improved Technical Specifications REV.

LEVEL??

TECHNICAL SPECIFICATION BASES REV. LEVEL??

7 B.3 RESOLVED Other References (NO INTERFACE AR'S)

INTERFACE EC AR #'S??

POST-JOB BRIEF NTM??

THE FOLLOWING REFERENCES ARE LISTED IN SECTION 100 DV Page 19 of 32

.PCHG-DESG Engineering Change 0000063016RO B.4-6, BASIS ADD...

Offsite Dose Calculation Manual, Industrial Waste Water Permit (IWW)

Mac and Mac (hydrodemolition contractor) documents.

WE PROBIBLY NEED A DOCUMENT SEE AR 292151292151TO TASK MANAGER OF SOME SORT THAT WE CAN AND WO 1165094-03 REFERENCE FOR WATER SUPPLY I DISCHARGE INFRASTRUCTURE /

+

ACTIVITIES.

8 B.4 RESOLVED REV LEVELS CONFINED TO SECTION Basic Functions of Each Structure, B.3 System and Component: AI-504 ADDED GENERALLY SPEAKING, IT IS NOT A GOOD IDEA TO INCLUDE THE REVISION LEVEL WHEN REFERENCING A DOCUMENT, EXCEPT IN SECTION B.3. (ERROR TRAP ADDITIONAL WORK IF YOU NEED TO CHANGE A REFERENCED DOCUMENT REV. LEVEL.)

4 Basis: Design Basis Document for the Containment, Revision 4 (Tab 1/1),

G/C Inc. Specifications SP-5569 and SP-5618, Improved Technical Specifications Section 3.6 and 3.9.

ADD...

AI-504 9 B.4 RESOLVED Loads such as Seismic, Wind, Thermal, and Dynamic: BASIS REWRITTEN Basis: Design Basis Document for the Containment, Revision 4 (Tab 1/1), ACI 318-63, Parts IV-B and Part V References 5.18 thru 5.23. -- FOR CONSISTANCY, SHOULD WE LIST THESE REFERENCES BY NAME AS WE HAVE IN THE CASE OF THE 100 DV Page 20 of 32

PCHG-DESG Engineering Change 0000063016RO DBD ABOVE??

10 B.4 Waste water disposal requirements: RESOLVED The current plan is to discharge this water into the Crystal River South SECTION B.4,6 & B.6.6 REWRITTEN percolating ponds (Refer to Section B.6.12 for chemical testing requirements).

THERE IS NO DISCUSSION OF THE TASK MANAGERS ROLE IN SECTION B.6-6. 1 The containment opening task manager is responsible for water delivery, storage and the means of piping it to and from the containment ADD...

AND IS OUTSIDE THE SCOPE OF THIS I.

EC. 4 11 B.4 RESOLVED Interface Requirements:

SEE AR 292151292151TO TASK MANAGER AND WO 1165094-03 WE PROBIBLY NEED A DOCUMENT OF SOME SORT THAT WE CAN REFERENCE FOR WATER SUPPLY /

DISCHARGE INFRASTRUCTURE /

ACTIVITIES.

12 B.4 RESOLVED REFERENCE ADDED, Mechanical Requirements: TYPOs CORRECTED The inside surface of the reactor building REWORDED is lined with a carbon steel liner to ensure a high degree of leak tightness during operating and accident conditions.

PER..... the nominal liner plate ...

.... the temporary access ILOWER CASE?

100 DV Page 21 of 32

PCHG-DESG Engineering Change 0000063016RO Opening GeGU* WILL result in a new pathway....

THE FOLLOWING SOUNDS MORE LIKE EVALUATION THAN DESIGN INPUT4, During hydrodemolition of the concrete containment wall, water will drain down the exposed vertical tendon sheaths into the tendons gallery where it is collected in 55 qallon drums. However,....

13 B.4 RESOLVED Hydraulic Requirements: DISCUSSION OF PUMPS ADDED None.???... THE PUMPS AND ASSOCIATED PIPING SUPPLIED FOR THE HYDRODEMOLITION OPERATION MUST BE CAPABLE OF PROVIDING AND RECOVERING THE WASTE WATER NEEDED FOR THE OPERATION???

14 B.4 Chemistry Requirements:

Waste water requirements:

Waste water from the hydrodemolition process (approximately 2,000,000 gallons over a three day period) will be tested before discharge to the CR South percolating ponds - I'M NOT SURE THAT WE SHOULD SAY THIS SINCE THE DISPOSAL OF THE RESOLVED WATER IS OUTSIDE THE SCOPE REWORDED AND CONTROL OF THIS EC to ensure it meets Plant and the State of Florida permit requirements including the Industrial Waste Water Permit (IWW).

WHAT ABOUT ANY CHEMICALS USED-DURING THE MODIFICATION OR CONTAINED WITHIN EQUIPMENT RESOLVED USED BEING APPROVED FOR USE AT DISCUSSION ADDED CR3?

15 B.4 RESOLVED Access and Administrative Control REWORDED for Plant Security:

RECOMMENDED REWORD...

... containment building which will require that Plant Security implement compensatory measures THAT THEY DEEM APPROPRIATE s... "as tationing s___

.. a guar-d at the Opening 100 DV Page 22 of 32

PCHG-DESG Engineering Change 0000063016RO while the containment liner is breached.

16 B.4 RESOLVED Redundancy, Diversity, & Separation REWORDED Requirements of Structures, Systems and Components:

None - Refer to Evaluation Section.- THIS STATEMENT APPEARS UNDER THIS DESIGN INPUT BUT NOT OTHERS THAT NOT APPLICABLE

(...CONSISTANCY) 17 B.4 ADD... I, RESOLVED Test / NDE / Inspection Requirements: REWORDED 17a B.4 RESOLVED Accessibility, Maintenance, Repair. DISCUSSION ADDED and ISI Requirements:

ARE THERE ANY ISI REQUIREMENTS FOR LINER PLATE WELD INSPECTION?

18 B.4 RESOLVED Fire Protection or Resistance ADDED AI-2210,AI-2205E Requirements:

Basis: ADD...

AI-221 0 AI-2205E 19 B.4 RESOLVED Handling, Storage, and Shipping ADDED FSAR Table 1-3 Requirements:

Basis:

ADD...FSAR Table 1-3 20 B.4 RESOLVED Materials, Processes, Parts, and ADDED CPL-XXXX-W-005 Equipment Suitability for Application:

Basis: ADD...

CPL-XXXX-W-005 (Ref. 3.2) 21 B.5 Assumptions:

THE ITEMS LISTED IN THIS SECTION RESOLVED DON'T APPEAR TO BE PHRASED AS ASSUMPTIONS.

ALSO...

THE ASSUMPTIONS SECTION SHOULD NO INTERFACE AR'S ADDRESS EC INTERFACE AR's AND 100 DV Page 23 of 32

PCHG-DESG Engineering Change 0000063016RO NEED FOR CAVEAT OUTST CAVEAT ADDRESSED FAILURE MODES AND EFFECTS RESOLVED EVALUATION...??? DISCUSSION ADDED 22 B.6 RESOLVED Loads such as Seismic. Wind. BULLETS STANDARDIZED Thermal, and Dynamic:

Model #3 Calculation S06-0006:

IMISMATCHED BULLETS??

  • Seismic (Refer to Section B.6.5-b for seismic design basis parameters)
  • Vertical and hoop re-tensioning forces (Refer to Section B.6.5-d)
  • Operating temperature (Refer to B.6.5-i for description of thermal loads)

(For accident temperature loads refer to "Liner Plate Model" below).

> Accident pressure of 55 psi 23 B.6 RESOLVED Loads such as Seismic, Wind, RE EXPLAINED TO DV THAT RED Thermal, and Dynamic: TEXT WAS IN PLACE AS A REMINDER Calculation S07-0003:

Vertical Tendons:

... The original 144 vertical tendons were split into 31 sequences and the 282 hoops into 60 sequences. Calculation 100 DV Page 24 of 32

PCHG-DESG Engineering Change 0000063016RO S07-003 creates 5 new vertical sequences (I thru V) with 6 vertical tendons in each sequence (total of 30 verticals) and 6 new hoop sequences (I thru VI) with 6 hoops in each sequence, except one sequence has 5 hoops (total 35 hoops).

fTHIS RED TEXT IS NOT A CJK COMMENT, DO YOU MEAN FOR IT TO BE RED?

24 B.6 RESOLVED Loads such as Seismic, Wind, WORDING ADDED RE: 3/8" Thermal, and Dynamic: THICKNESS.

Calculation S06-0007

Conclusions:

... The calculation also determined that the minimum acceptable liner thicknesses to assure structural and leak-tight integrity of the liner plate, without any vertical stiffeners, under two postulated LODHR accident scenarios were:

5.14 psi ............. 3/16" thickness 8.00 psi .............. 1/4" thickness The above thicknesses may be used during the SGR outage to qualify the "as-found" extent of condition of the liner plate for damaged areas where the thickness is < 3/8".....

ADD...

HOWEVER THE LINER PLATE IS TO BE RESTORED TO THE ORIGINALLY SPECIFIED 3/8" THICKNESS.

25 B.6 RESOLVED Environmental Conditions: REWORDED Water requirements RECOMMENDED REWORDING...

...Well water weuld could be diverted through existing CRS plant piping or temporary piping to one of the existing abandoned oil storage tanks (Cap. 8,000,000 gallons) which have 100 DV Page 25 of 32

PCHG-DESG Engineering Change 0000063016RO been successfully used in the past by CRS to satisfy requirements for bulk water storage for other high water demand projects. Water from this storage tank wil could then be pumped either via temporary piping 26 B.6 RESOLVED Environmental Conditions: REWORDED Waste water disposal:

RECOMMENDED REWORDING...

IWE ARE NOT CONTROLING THIS ACTIVITY

... Waste water will CAN be routed via existing plant piping or temporary piping and discharged to the south percolation ponds which have been determined (by CR3 and corporate environmental) to be within the current definition of wastewaters under the Plant Industrial Waste Water Permit....

MAYBE ADD A STATEMENT LIKE "THE SOURCE AND STORAGE OF SUPPLY WATER, THE USE OF EXISTING PLANT PIPING /

FACILITIES, THE ERECTION /

SUPPORT OF TEMPORARY PIPING THE DISPOSAL OF WASTE WATER IS OUTSIDE THE SCOPE OF THIS EC AND WILL BE ADDRESSED BY...."

27 B.6 RESOLVED Mechanical Requirements:

(IN BOX 4)

Any damage to the 3/8" thick liner plate that occurs during hydrodemolition, REWORDED and/or iust prior to cutting the plate is acceptable if the reduced thickness of the plate is __3/16".4- WHY NOT _"

100 DV Page 26 of 32

PCHG-DESG Engineering Change 0000063016RO REQUIRED FOR 8 PSI (BECAUSE PLATE ALONE WILL SEE ONLY NO-MODE CONDITIONS)?? Damaged areas must be repaired such that the minimum thickness is _Ž5/16" thick. WE SHOULD REQUIRE THE FULL 3/8" AS ORIGINALLY SPECIFIED SO THAT ANY INSPECTED THICKNESS DOWN TO 5/16" COULD BE ACCEPTABLE DUE TO THE +/- 1/16" TOLERANCE.

ALSO...

Refueling operations shall not commence until the liner plate has been re-installed and welded back ADD 4 CORRECTED in-place, new concrete IS in the Opening placed and the tendons around the Opening re-tensioned (at a minimum).

ALSO...

.... As noted in Section B.4.9 sump DISCUSSION ADDED pumps SDP-3A and SDP-3B must be turned off/disabled immediately prior to the start of hydrodemolition operations to ensure that effluent that drains into the tendon gallery does not contaminate the plants waste water system.

WHAT WILL PRECLUDE THE POSSIBILITY OF WATER RUNNING DOWN BETWEEN THE LINER PLATE AND THE EXISTING CONTAINMENT CONCRETE BELOW THE CONTAINMENT OPENING?

Temporarily turning these pumps off during hydrodemolition of the concrete wall has no impact on plant operations. WILL WE KNOW IF FLUIDS OTHER THAN THE WASTE DISCUSSION ADDED WATER FROM THE HYDRODEMOLITION OPERATION ARE BEING ROUTED TO THIS SUMP AND WILL THESE FLUIDS BE A CONCERN (RADIOACTIVE CONTAMINATION OR OTHER CONCERN)?

100 DV Page 27 of 32

PCHG-DESG Engineering Change 0000063016RO 28 B.6 RESOLVED Structural Requirements:

DISCUSSION ADDED

.... The calculation also determined that the liner plate within the Opening was acceptable to use as formwork during the placement of high slump concrete with form-ties attached to the vertical angle stiffeners at a spacing of 3'-0", with a maximum pour rate of 4ft/hour. The maximum tensile load at a form-tie is 6 kips per tie, anchored at a vertical angle stiffener at the liner and to the outer formwork. WILL THIS (OR ANOTHER PRECAUTIONARY ACTION)

PRECLUDE THE POSSIBILITY OF CONCRETE RUNNING DOWN BETWEEN THE LINER PLATE AND THE EXISTING CONTAINMENT CONCRETE BELOW THE CONTAINMENT OPENING?

29 B.6 RESOLVED Chemistry Requirements:

... These requirements will be specified in the installation instructions, limits and precautions.

WHAT ABOUT ANY DISCUSSION ADDED CHEMICALS USED DURING THE MODIFICATION OR CONTAINED WITHIN EQUIPMENT USED BEING APPROVED FOR USE AT CR3?

ALSO...

Water requiremeni The 2,000,000 gallons of clean potable water must be sampled by Chemistry to ensure it meets the normal requirements for potable water.

IS UNTREATED WELL WATER, REWORDED FROM POSSIBLY UNSANITARY TANKS AND PIPING CONSIDERED POTABLE? (REFERENCE REQUIREMENTS OF 42CFR PART 72 OR REQUIRMENTS OF THE 100 DV Page 28 of 32

PCHG-DESG Engineering Change 0000063016RO LOCAL AUTHORITY HAVING JURISDICTION) 30 B.6 RESOLVED Test Requirements (INCLUDING NON- WORDS ADDED DESTRUCTIVE EXAM INATIONS):

The following tests AND NDE will, at a minimum be required to support this EC:

ALSO...

SHOULD WE SPECIFY THAT A FUNCTIONAL TEST BE RUN ON DISCUSSION ADDED THE HYDRODEMOLITION WATER HANDLING EQUIPMENT TO CONFIRM THAT THE EQUIPMENT IS CAPABLE OF FUNCTIONING PROPERLY IN THE CONFIGURATION REQUIRED?

31 Section C. RESOLVED BROWN TEXT REMOVED DELETE BROWN TEXT 32 Section D. RESOLVED LOWER CASE RED TEXT BELOW ARE RE EXPLAINED TO DV THAT RED NOT CJK COMMENTS TEXT WAS IN PLACE AS A REMINDER 33 D.2.1 Prerequisites / Precautions RESOLVED

... Mock-ups and Associated Training for Complex Work Activities Required for the Creation and Restoration of the Access Opening.

... Several mock-ups that will simulate complex work activities associated with the creation and restoration of the access Opening will be required and are considered essential to the successful completion of the project. These simulations aid in training the craft in executing these activities in a safe and expeditious manner.

MOCK-UPS SHOULD INCORPORATE ANY RADIATION PROTECTION / DISCUSSION ADDED ALARA CONSIDERATIONS DEEMED APPROPRIATE BY RP.

34 D.2.1 Prerequisites I Precautions RESOLVED

... Verify the settling ponds are available AND IN A PHYSICAL CONDITION / DISCUSSION ADDED CONFIGURATION to receive the discharge from the hydrodemolition activities 100 DV Page 29 of 32

PCHG-DESG Engineering Change 0000063016RO 35 D.2.2.1 Tendon Detensioning, RESOLVED Removal, Reinstallation and HIGHLIGHTING REMOVED Retensioning 2.Tendon Degreasing and Tendon Removal

... After hoop and vertical tendons have been removed from within the opening, the tendon sheaths shall be degreased to the extent practical. f??? WHY YELLOW HIGH LIGHTING?

36 D.2.2.2 Hydrodemolition RESOLVED

2. Mode 5 & 6 activities

... Install a water collection system in the tendon gallery to collect and pump water from the vertical tendons to the Mac &

Mac water treatment equipment (DO NOT PLUG THE VERTICAL TENDONS DURING HYDRODEMOLITION).

SHOULD WE TEST DISCUSSION ADDED TO HYDRODEMOLITION EQUIPMENT "Pre-outage activities" 1.i PRIOR TO STARTING DEMOLITION OPERATION?

37 2.Liner Plate Reinstallation RESOLVED HIGHLIGHTING REMOVED

a. Reattach the lifting /

rigging frame supplied by CB&I

b. The liner plate can be reinstalled after the HTS Structure has been removed (ref EC 63016)

WHY HIGHLIGHTING  ???t 38 D.2.2.5 Formwork and Concrete RESOLVED Placement 1 Concrete Form Work Installation REWORDED TO ADDRESS DWGS

a. After the reinforcing steel has been installed and inspected formwork installation can commence
b. Insure the containment opening is clean and 100 DV Page 30 of 32

PCHG-DESG Engineering Change 0000063016RO acceptable for concrete placement

c. Install the formwork in accordance with vendor

.requirement and drawings DETAILS ON FORMS ARE DIPICTED ON ... ??

39 D.4 RESOLVED ADD ITEM #'S BELOW ITEM 22 ADDED ADD CONCRETE FORM MATERIAL 40 E.1 Testing Requirements RESOLVED BROWN TEXT DELETED Unique Prerequisites, Precautions, Limitations, Initial Conditions, and Outaqe Requirements:

Test and Acceptance Criteria:

DELETE BROWN TEXT 41 SECTION F. RESOLVED DELETE BROWN TEXT BROWN TEXT DELETED COMPLETE SECTION F SECTION F COMPLETED 42 H.1 RESOLVED H.1 Validation Plan ATTACHMENT 1 VALIDATION PLAN Sheet 1 of 2 EXPECTATION...

CROSS-REFERENCE STATEMENTS / VARIOUS STATEMENTS IN PROMISES MADE WITH AREAS OF VALIDATION PLAN HAVE BEEN THE EC WHEREIN THE STATEMENT / CROSS-REFERENCED TO SECTIONS PROMISE IS ADDRESSED. OF THE EC.

(EXAMPLE... formation of a Project Team.. .The project team members are documented in EC Section A.7...

OR ... Project kick-off meeting attendance sheet, comments and resolutions are documented in EC Section)

ALSO ONLY POST-JOB CRITIQUE WILL BE POST-JOB BRIEF, CRITIQUE? ACCOMPLISHED.

BOTH?

WE ARE MISSING MEETING ATTENDANCE SHEETS COMMENTS / RESOLUTIONS (KICK-OFF AND 0%)

WHERE IS POST-JOB BRIEF MISSING NOTES NOTED FILE H01

.REQUIREMENT CAPTURED??

100 DV Page 31 of 32

11 PCHG-DESG Engineering Change 0000063016R0 NEED NTM.

NTM # DOCUMENTED IN SECTION H.1 VALIDATION PLAN 43 ZOO RESOLVED Attachment A DELETE BROWN TEXT BROWN TEXT DELETED SUGGEST ADDING WORDS LIKE "FOR ATTACHMENTS, SEE "Z "

FILES LISTED IN THE CONTENTS SECTION OF THIS EC."

Note: The Lead Reviewer signature on the EC DV milestone panel signifies that a lead review has been performed in accordance with EGR-NGGC-0003 and that errors/deficiencies (for all reviews performed) have been resolved and included in the EC package.

100 DV Page 32 of 32

PCHG-DESG Engineering Change 000006302OR3 1.1 Design Verification X

11 EC 63016 Rev.3

a saba H-anganatr I cavil/Structural I7/27/09 Ite Comn Resluio I A. I I .. . ... . l

-I File A00: A.3 Revision Summary- I Incorporated all comments except b).

I Revision 3: The platform size is not required to be a) A.5.2.6, Page 23 should be Page changed, since 8'xl0' size is acceptable 25: A.5.2.12, Page 27 should be Page 29 b) After B.6.5-j add B.6.5.o, Page 47:

Revised Tendon work platform size at buttress #5 from 8'x1 0' to 6'X8'.

c) B.6.8-a, Page 65: Add Attachment Z25 after CR3-C-0003.

d) B.6.9, Page 75: Provided optional material for access opening curtain and add reference to Section B.6.10.

e) B.6.10: Change page 80 to 81.

f) B.6.10, Page 90 to 92, Page 92 to Page 93, Page 93 to Page 94, Page 98 to page 100, Page 101 to page 102, and Page 103 to Page 105.

g) COO C.2, page 1: add after ODCM, "AI-504, and CP-341".

h) D00: Under D.4, Page 23 add "added Item #80, HKB 3 anchor bolts".

i) Attachments Z06 to Z12 do not have the revised drawings.

j) Under Pages Added include the following: Added Attachments Z55 and Z 59.

2 File BOO: Section B.6.10, Page 82: Add Comment incorporated..

reference calculation S08-0021 for evaluation of form work for severe weather. Presently there is no attachment Z55 in EC for formwork drawing.

3 File BOO: Section B.6.10, Page 87, what V2= U2 + 2 a s is the basis for 62 mph velocity of the 101 R3 DV Page 1 of 2

PCHG-DESG Engineering Change 000006302OR3 falling object. Provide reference to Based on distributed load over a 8' x 10' allowable live load in IB roof and how area (smallest platform footprint).

does it relate to maximum 500 lbs tool load.

4 File BOO: Section B.6.10, Page 88: Based on industry experience as Provide reference for the statement that provided by PSC and Bechtel.

decrease in leakage has been seen by PSC since the use of P4 grease.

5 File BOO: Section B.6.10, Page 88: Under Clarification not required, since it is two primary methods for determining industry standard wording.

grease fill under ii) add the following at the end "The tendon net duct volume is the gross duct volume minus the volume taken by the tendon wires and components".

6 File BOO: Section, Page 92: In Pre- Comment incorporated.

Construction Qualification Testing ... title change ASTM to ASME and add after Div: "2 Subsection" 7 File DOO: D.4, Items 48A and 48B The correct reference provided.

reference to sketch in attachment Z52.

Attachment Z52 is about admixtures and does not have any sketch. Provide the correct reference.

Note: The Lead Reviewer signature on the EC DV milestone panel signifies that a lead review has been performed in accordance with EGR-NGGC-0003 and that errors/deficiencies (for all reviews performed) have been resolved and included in the EC package.

101 R3 DV Page 2 of 2

PCHG-DESG Engineering Change 0000063016RO Attachment A For Attachments see "ZO1 thru Z40" files listed in the contents section of this EC.

ZOO Attachment Page 1 of 1