ML12123A270

Inservice Inspection Program Fourth Ten-Year Interval Supplement to 10 CFR 50.55a Request No. RR-2-3

ML12123A270
Person / Time
Site:	Kewaunee
Issue date:	05/01/2012
From:	Jordan A Dominion, Dominion Energy Kewaunee
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
12-319B
Download: ML12123A270 (49)

Text

Dominion Energy Kewaunee, Inc.

"Dn N490 Hwy 42, Kewaunee, WI 54216 Dominion Web Address: www.dom.com May 1, 2012 ATTN: Document Control Desk Serial No. 12-319B U. S. Nuclear Regulatory Commission LIC/JG/R5 11555 Rockville Pike Docket No.: 50-305 Rockville, MD 20852-2738 License No.: DPR-43 DOMINION ENERGY KEWAUNEE. INC.

KEWAUNEE POWER STATION INSERVICE INSPECTION PROGRAM FOURTH TEN-YEAR INTERVAL SUPPLEMENT TO 10 CFR 50.55a REQUEST NO. RR-2-3 By application dated April 29, 2012 (Reference 1), Dominion Energy Kewaunee, Inc.

(DEK), requested approval of 10 CFR 50.55a Request RR-2-3 for the Fourth Ten-year Interval of the Inservice Inspection (ISI) Program for Kewaunee Power Station (KPS).

10 CFR 50.55a Request RR-2-3 proposed a temporary deviation from the requirements of ASME Section XI, Appendix IX, Article IX-1000, Paragraph (c)(2), which prohibits the use of clamping devices on "... portions of a piping system that forms the containment boundary"; and ASME Section XI, Appendix IX, Article IX-6000(a), which states that the area immediately adjacent to the clamping device shall be examined using a volumetric method.

Additional Information regarding this request was provided via letter dated April 30, 2012 (Reference 2). The NRC provided verbal approval of Request RR-2-3 during a telephone conference between DEK and NRC staff on April 30, 2012.

Following installation of the leak limiting strong-back device described in Request RR 3, a structural fillet weld was being added at the interface of the 3/4-inch diameter pipe and the leak sealant enclosure.

As described in Request RR-2-3, this weld was intended as an added measure of safety to prevent a catastrophic separation of the 3/4-inch line above the leaking sockolet. However, upon initiation of welding, the welder inadvertently created a very small through-wall perforation of the 3/4-inch line.

The resulting water leak (approximately 1 to 3 gallons per hour) precludes use of a fillet weld on this portion of the pipe. Therefore, DEK is no longer able to make the repair under the conditions stated in Request RR-2-3. Consequently, a revised alternative is needed (in lieu of the previously proposed fillet weld) as an added measure of safety to prevent separation of the 3/4-inch line above the leaking sockolet.

The revised alternative consists of a structural restraint on the 3/4-inch line. Additionally, relief is being requested to accept short-term operation in MODE 4 with the newly created through-wall perforation (that was created during initiation of welding) for the purpose of effecting repairs to it.

To verify that the damage caused by the welding initiation was not due to piping deficiencies (e.g., erosion or thinning), the newly created through-wall perforation in the

Serial No. 12-319B 10 CFR 50.55a Request RR-2-3 Supplement Page 2 of 4 3/4-inch line (caused by the initiation of welding) has been evaluated and found to not structurally impair the integrity of the 3/4-inch line.

The newly created through-wall perforation has been characterized using UT techniques and its growth potential has been evaluated.

This supplement to 10 CFR 50.55a Request RR-2-3 hereby requests revision to the originally proposed alternative, to substitute a structural restraint in place of the originally proposed fillet weld as an added measure of safety to prevent a catastrophic separation of the 3/4-inch line above the leaking sockolet. Additionally, the scope of Request RR-2-3 is being proposed for expansion to accept short-term operation in MODE 4 with the newly created through-wall perforation by monitoring of the newly created leak (caused during welding of the clamping device). For ease of review, the information contained in the originally submitted proposal (References 1 and 2) is retained in this Supplement.

Therefore, this supplement replaces the originally proposed request in its entirety.

KPS is currently in a refueling outage. The reactor has been refueled and the reactor vessel has been reassembled. The plant is currently in MODE 5 - Cold Shutdown with the residual heat removal system in operation. Per KPS Technical Specification (TS) 3.4.7, "RCS Loops - MODE 5, Loops Filled," one RHR loop is required to be operable and in operation; and either one additional RHR loop shall be operable, or the secondary side water level of at least one steam generator shall be greater than or equal to 5%. Both the originally discussed leak (which has since been sealed by use of the clamping device described in Reference 1) and the newly created through-wall perforation exist in a 3/4-inch line that is common to both RHR loops. Neither leak can be repaired without removing both RHR loops from service.

DEK is proposing to perform a temporary alternate repair of the RHR piping by maintaining the recently installed leak-limiting device over the previously identified socket weld leak (and adding a structural restraint in lieu of the previously proposed fillet weld); and to accept short-term operation in MODE 4 with the newly created through-wall perforation by monitoring of the newly created leak (caused during welding of the clamping device) to ensure that containment integrity and structural integrity is maintained prior to proceeding from MODE 5 to MODE 4. This temporary alternate repair will remain in place until the unit achieves MODE 4. After the unit enters MODE 4, core cooling is provided by reactor coolant pumps circulating water through the core and to the steam generators. In this condition, with core cooling being provided by the steam generators, the section of pipe containing the leaks will be isolated and repaired.

Repairs will be pursued expeditiously. Isolating the portion of the RHR system with the leak will take approximately 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after reaching Mode 4, eliminating the need for the leak-limiting device.

The alternative to conducting the proposed temporary alternative repair under ASME Section Xl, Appendix IX, is to return the plant to the refueling mode (MODE 6), remove the reactor head, remove the upper core internals, and offload the core into the spent

Serial No. 12-319B 10 CFR 50.55a Request RR-2-3 Supplement Page 3 of 4 fuel pool. This option would result in an undue hardship and unusual difficulty without a compensating increase in the level of quality and safety, and is therefore justified under 10 CFR 50.55a(a)(3)(ii).

Since the piping remains seismically qualified, system leakage will be maintained within the Current Licensing Basis, and since the clamp is structurally equivalent to the piping, there is no expected additional risk of pipe failure.

The details of this supplement to 10 CFR 50.55a Request No. RR-2-3 (which replaces References 1 and 2 in their entirety) are provided in Attachment 1 to this letter.

Changes from the initially submitted request (provided in Reference 1) are indicated by revision bars in the margin. A copy of the revised temporary modification package that will be used to perform the alternate repair is provided in Enclosure 1.

If you have questions or require additional information, please feel free to contact Mr.

Craig Sly at 804-273-2784.

Very truly yours, A. J. Jo~ra Site Vice P esident - Kewaunee Power Station

Attachment:

1. Supplement to Kewaunee Power Station Fourth Ten-year Interval Inservice Inspection Program 10 CFR 50.55a Request No. RR-2-3

Enclosure:

1. Temporary Modification Package 2012-11 (revised)

References:

1. Letter from A. J. Jordan (DEK) to Document Control Desk (NRC), "Inservice Inspection Program Fourth Ten-Year Interval, 10 CFR 50.55a Request No. RR 3", dated April 29, 2012.

2. Letter from A. J. Jordan (DEK) to Document Control Desk (NRC), "Inservice Inspection Program Fourth Ten-Year Interval, 10 CFR 50.55a Request No. RR 3, Response to Request for Additional Information", dated April 30, 2012.

Serial No. 12-319B 10 CFR 50.55a Request RR-2-3 Supplement Page 4 of 4 Commitments made by this letter:

1. Prior to making the change from MODE 5 to MODE 4, the situation will be re-evaluated if the magnitude of leakage is found to be higher than expected or if the leak rate increases rather than decreases after the sealant is applied. The System Integrity Program (SIP) allows for less than 6 gallons per hour (gph) for combined external leakage from the Safety Injection (SI) system, Internal Containment Spray (ICS) system and the Residual Heat Removal (RHR) system. A review of historical data over the previous nine refueling outages indicates the total external leak rate has not exceeded 0.07 gph. Based on this, a limit of 5.5 gph will be established for total leakage from the affected piping near RHR-600. At a leak rate above 5.5 gph, external system leakage must be evaluated for operability.

2. Following installation of the devices, a VT-2 examination will be performed and repeated a minimum of once every twelve hours, and leakage will be quantified a minimum of once every twelve hours, until a MODE change from MODE 5 to MODE 4 is made and the resulting portion of residual heat removal piping needed to facilitate repair is isolated and depressurized.

3. The sealant injection pressure and volume will be controlled by work instructions and procedures to ensure the sealant is not injected into the RHR system piping.

cc:

Regional Administrator, Region III U. S. Nuclear Regulatory Commission 2443 Warrenville Road Suite 210 Lisle, IL 60532-4352 Mr. Karl D. Feintuch Project Manager U.S. Nuclear Regulatory Commission One White Flint North, Mail Stop 08-H4A 11555 Rockville Pike Rockville, MD 20852-2738 NRC Senior Resident Inspector Kewaunee Power Station

Serial No. 12-319B ATTACHMENT 1 FOURTH TEN-YEAR INTERVAL INSERVICE INSPECTION PROGRAM SUPPLEMENT TO 10 CFR 50.55a REQUEST NO. RR-2-3 KEWAUNEE POWER STATION DOMINION ENERGY KEWAUNEE, INC.

Serial No. 12-319B 10 CFR 50.55a Request RR-2-3 Supplement Page 1 of 10 Kewaunee Power Station Fourth Ten-Year Interval Inservice Inspection Program Supplement to 10 CFR 50.55a Request No. RR-2-3 Proposed Alternative In Accordance with 10 CFR 50.55a(a)(3)(ii)

Hardship or Unusual Difficulty Without Compensating Increase in Level of Quality or Safety

1. ASME CODE COMPONENTS AFFECTED ASME Code,Section XI Code Class 2 Residual Heat Removal (RHR) system 3/4-inch Sockolet to Valve RHR-600.

Pipe is 3/4-inch schedule 40, ASTM A312, type 304.

Fitting is 0.750-inch on 10-inch Sockolet, 3000 Ib, ASTM Al 82 F 304. Code of record is USAS B31.1 - 1967.

RHR design temperature and pressure: 400 OF and 600 psig. (The estimated pressure and temperature of the RHR loops during MODE 5 is approximately 350 psig and less than 2000F.)

2. APPLICABLE CODE EDITION AND ADDENDA ASME Boiler and Pressure Vessel Code,Section XI, 1998 Edition, 2000 Addenda

3. APPLICABLE CODE REQUIREMENTS

• ASME Boiler and Pressure Vessel Code, Section X1, 1998 Edition, 2000 Addenda, IWA-4133 states that mechanical clamping devices used to replace piping pressure boundary shall meet the requirements of ASME Section XI, Appendix IX.

o ASME Section XI, Appendix IX, Article IX-1000(c)(2) states that clamping devices shall not be used on portions of a piping system that forms the containment boundary.

o ASME Section XI, Appendix IX, Article IX-6000(a) requires a plan for monitoring defect growth in the area immediately adjacent to the clamping device.

Serial No. 12-319B 10 CFR 50.55a Request RR-2-3 Supplement Page 2 of 10 NRC Inspection

Manual, Part 9900:

Technical

Guidance, "Operability Determinations & Functionality Assessments for Resolution of Degraded or Nonconforming Conditions Adverse to Quality or Safety", states (in Section C.12, "Operational Leakage from ASME Code Class 1, 2, and 3 Components") that "NRC staff does not consider through-wall conditions in components... to be in accordance with the intent of the ASME Code or construction code and, therefore, would not meet code requirements, even though the system or component may demonstrate adequate structural integrity. Thus, unless a through-wall flaw is evaluated and found acceptable using an applicable and NRC endorsed code case, in which all provisions are met..., a relief request is necessary."

4. REASON FOR REQUEST Currently, Kewaunee Power Station (KPS) is in MODE 5-Cold Shutdown, and has declared both trains of residual heat removal (RHR) inoperable due to a through-wall leak on a 3/4-inch socket weld connection of ASME Code Class 2 piping in the common RHR pump A and B discharge piping (Note: Installation of a leak limiting device on this original leak had successfully stopped leakage through this flaw). While completing installation of the leak limiting device on the original leak, a newly created through-wall perforation on a section of this 3/4-inch piping was created when attempting to create a fillet weld as an added measure of safety to prevent a catastrophic separation of the 3/4-inch line above the leaking sockolet. The RHR system is currently providing flow to the reactor coolant system (RCS) cold leg for the MODE 5 lineup.

KPS TS 3.4.7, "RCS Loops - MODE 5, Loops Filled," is applicable during MODE 5 with the RCS loops filled.

TS LCO 3.4.7 requires one RHR loop to be Operable and in operation. In addition, TS LCO 3.4.7 requires one additional RHR loop be operable (but not necessarily in operation) or the secondary side water level of at least one steam generator shall be greater than or equal to 5%.

Currently both loops of RHR are declared inoperable due to the through-wall leak at the 3/4-inch socket weld and due to the newly created through-wall perforation on a section of this 3/4-inch piping.

Both loops of RHR are available to provide decay heat removal. Additionally, if both RHR loops become unavailable, one SG is available to provide decay heat removal as well as feed and bleed with the Safety Injection system (SI).

In order to implement a permanent weld repair (ASME Code repair) for the 3/4-inch socket weld and for the newly created through-wall perforation on a section of this 3/4-

Serial No. 12-319B 10 CFR 50.55a Request RR-2-3 Supplement Page 3 of 10 inch piping, both RHR cooldown loops must be removed from service and isolated from containment.

In order to remove both RHR cooldown loops from service one of two options must be performed.

The first option is to return the plant to the refueling mode, remove the reactor head, remove the upper core internals, and offload the core into the spent fuel pool. Then, the RHR system could be isolated and drained to allow repair of the affected piping. This option would require maneuvering the plant from its current operating condition in MODE 5 with one steam generator (SG) available to provide an alternate method for decay heat removal to a "no-MODE" condition. This option would result in an undue hardship and unusual difficulty without a compensating increase in the level of quality and safety of the plant. This first option would require the following actions/conditions:

RCS cooldown from current plant conditions, thus losing the SG decay heat removal capability, and entry to MODE 6 - Refueling.

" The reactor head would have to be disassembled and detensioned.

" The RCS would have to be drained to 6-inches below the reactor vessel flange resulting in the SGs no longer being available for decay heat removal, a reduction in reactor system coolant inventory, and a shorter time-to-boil if decay heat removal were lost.

" The reactor head would have to be removed and the reactor cavity flooded to 23 feet.

" The reactor core would have to be offloaded to the spent fuel pool.

" The estimated duration of this evolution from the start of cooldown to core offload is 5 days.

" The estimated radiation dose for this overall reactor disassembly, core offload, and subsequent reload and reactor reassembly evolution is approximately 8 Rem based on actual exposure measured during the same activities conducted during the current ongoing refueling outage.

The second option is to perform a temporary alternate repair of the RHR piping by installing a leak-limiting strong-back device on the original leak to ensure structural integrity of the affected piping; and by monitoring of the newly created through-wall perforation (caused during welding of the leak limiting strong-back device) to ensure that the leak remains within System Integrity Program (SIP) limits. This activity is needed prior to making a MODE change from MODE 5 to MODE 4. This temporary alternate repair will remain in place until the unit achieves MODE 4. After the unit

Serial No. 12-319B 10 CFR 50.55a Request RR-2-3 Supplement Page 4 of 10 reaches MODE 4, core cooling is provided by the reactor coolant pumps circulating water through the core and to the steam generators. With core cooling being provided by the steam generators, both loops of RHR can be secured, the affected piping isolated, and the piping repaired.

Once in MODE 4, TS 3.6.1, "Containment Integrity," LCO 3.6.1, requires that the containment is Operable. Containment integrity will be maintained by the leak-limiting device as well. The ASME Code repair will be pursued expeditiously. Isolating the portion of the RHR system with the leak will take approximately 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after reaching Mode 4, eliminating the need for the leak-limiting device.

The original radiological dose estimate associated with installation and removal of the leak-limiting strong-back device was 350 mRem (approximately 136 mRem of this estimated amount was expended during installation of the leak limiting strong-back device). A dose of 199 mRem is estimated for installation of the newly proposed structural restraint (in lieu of the previously proposed fillet weld) and removal of all associated temporary modifications (needed to effect repairs).

The mechanical clamping device that will be used will comply with the applicable ASME Code requirements outlined in ASME Section Xl, Appendix IX, with the exception that it will be located on piping that is considered a containment boundary. ASME Section Xl, Appendix IX, Article IX-1000, Paragraph (c)(2) prohibits the use of clamping devices on

"... portions of a piping system that forms the containment boundary." Therefore, in order to use the device, DEK requires approval of an alternative to allow a temporary deviation from the requirements of Appendix IX, Article IX-1 000, Paragraph (c)(2) for the period of time that it will take to for the plant to reach MODE 4 and to complete the ASME Code repair.

Based on the discussion above, DEK requests NRC approval of an alternative to the repair requirements of ASME Boiler and Pressure Vessel Code, Section Xl, 1998 Edition, 2000 Addenda IWA-4133.

Pursuant to 10 CFR 50.55a(a)(3)(ii), DEK is requesting approval to temporarily deviate from the requirements of Appendix IX, Article IX-1000, Paragraph (c)(2) which prohibits the use of clamping devices on "... portions of a piping system that forms the containment boundary" and ASME Section Xl, Appendix IX, Article IX-6000(a) which states that the area immediately adjacent to the clamping device shall be examined using a volumetric method. Additionally, DEK is requesting approval to temporarily deviate from the intent of the ASME Code that prohibits operation with through-wall conditions in components.

This requested deviation is

Serial No. 12-319B 10 CFR 50.55a Request RR-2-3 Supplement Page 5 of 10 based on DEKs conclusion that compliance would result in hardship and unusual difficulty without a compensating increase in the level of quality and safety.

5. PROPOSED ALTERNATIVE AND BASIS FOR USE The proposed alternative would allow use of a leak-limiting strong-back device on a piping system that forms part of the containment boundary. The device accomplishes two functions; limiting the leakage from the original defect, and maintaining the structural integrity of the affected piping.

The proposed alternative for the original socket weld defect uses a leak-limiting device to ensure containment integrity, since this region of the RHR piping is a portion of the containment boundary. A sealant will be injected into a leak-limiting enclosure to provide a temporary pressure boundary for the RHR system. The sealant, X-36, has a low concentration of halogens/chlorides, therefore it is safe for use on stainless steel. The sealant injection pressure and volume will be controlled by work instructions and procedures to ensure the sealant is not injected into the RHR system piping. The leak-limiting device is mechanically fastened with clamps and bolts to the 10-inch diameter RHR pipe and the 3/4-inch diameter pipe is fastened to the leak sealant enclosure with set screws. As an added measure of safety, a structural restraint will be installed to physically restrain the 3/4-inch line. This restraint will prevent a catastrophic separation of the 3/4-inch line above the leaking sockolet. (NOTE: this restraint replaces the originally proposed structural fillet weld at the interface of the 3/4-inch diameter pipe and the leak sealant enclosure).

RHR-600 is an outside containment isolation valve for Containment Penetration 10, a Class 6 penetration. Penetration Class 6 is a system required to operate post-accident.

The design and operational criteria for penetration Class 6 isolation valves are governed by the functional requirements of the system. The isolation valves at Penetration 10 are not subject to the requirements of 10 CFR 50, Appendix J (reference 5).

The System Integrity Program (SIP) allows for less than 6 gallons per hour (gph) for combined external leakage from the Safety Injection (SI) system, Internal Containment Spray (ICS) system and the Residual Heat Removal (RHR) system.

A review of historical data over the previous nine refueling outages indicates the total external leak rate has not exceeded 0.07 gph. Based on this, a limit of 5.5 gph will be established for total leakage from the affected piping near RHR-600. At a leak rate above 5.5 gph, external system leakage must be evaluated for operability.

After installing the leak limiting strong-back device, a MODE change from MODE 5 to MODE 4 will be made, the affected piping will be depressurized and isolated, and the ASME Code repair will commence.

Serial No. 12-319B 10 CFR 50.55a Request RR-2-3 Supplement Page 6 of 10 Original Socket Weld Defect The requirements for containment isolation will be satisfied by the leak sealant enclosure. The enclosure is designed to RHR temperature and pressure requirements and ASME Section Xl, Appendix IX, Mechanical Clamping Devices for Class 2 and 3 Piping Pressure Boundary. The piping remains seismically qualified and the enclosure will prevent system leakage, or maintain leakage within the Current Licensing Basis.

ASME Section Xl, Appendix IX, Article IX-2000 states that, if the defect size cannot be directly determined, a conservative bound of the size shall be determined and documented. ASME Section Xl, Article IX-6000 states that the area immediately adjacent to the clamping device shall be examined using a volumetric method. Visual examination identifies the existing leak size as a pinhole and has placed the defect at the toe of the socket weld to the 3/4-inch branch line to valve RHR-600. There is no other visual indication of degradation to the piping wall thickness. Therefore, DEK is requesting a deviation from Article IX-6000(a) in that no volumetric inspection in the area of the clamp will be performed on the 10 inch pipe or on the 3/4-inch pipe. The installation of the leak-limiting device also precludes volumetric inspection of the defect.

Therefore, the defect can be conservatively characterized as residing within the socket weld and any growth would be limited to the weld itself, effectively limiting the impact of the defect to that of a circumferential crack. The proposed alternative, as a conservative measure to account for nondestructive examination limitations of the sockolet, includes two aspects; installation of a leak-limiting strong-back device which includes a restraint on the 3/4-inch diameter pipe, and a VT-2 examination a minimum of once every twelve hours. The device will conservatively maintain structural integrity of the affected components during the duration of the proposed alternatives.

Application of the leak-limiting strong-back device to maintain containment integrity and the structural integrity of the 3/4-inch line will ensure that the plant can transition from MODE 5 to MODE 4 and perform an ASME Code repair.

The leak limiting strong-back device has been designed to accommodate thrust loads resulting from a complete failure of the welded connection of concern. A review of the piping stress analysis has been performed to ensure that the additional mass does not adversely affect the qualification of the existing system.

Following installation of the leak limiting strong-back device, a VT-2 examination will be performed and repeated a minimum of once every twelve hours until a MODE change from MODE 5 to MODE 4 is satisfactorily completed and the resulting portion of residual

Serial No. 12-319B 10 CFR 50.55a Request RR-2-3 Supplement Page 7 of 10 heat removal piping needed to facilitate repair is isolated and depressurized. Prior to making the change from MODE 5 to MODE 4, the situation will be re-evaluated if the magnitude of leakage is found to be higher than expected or if the leak rate increases rather than decreases after the sealant is applied.

Newly Created Through-Wall Perforation During installation of the leak-limiting strong-back device discussed above, the weld (that had originally been intended as an added measure of safety to prevent a catastrophic separation of the 3/4-inch line above the leaking sockolet) was not able to be completed. Upon initiation of welding, the welder inadvertently created a very small through-wall perforation of the 3/4-inch line.

This newly created through-wall perforation requires evaluation for structural integrity.

NRC Inspection Manual, Part 9900, Technical Guidance, Section C.11, outlines the methods available to evaluate structural integrity for Class 2 High Energy Systems. The choices are ASME Section Xl, Construction Code, or an NRC approved alternative such as a code case approved in Regulatory Guide 1.147. There are no approved code cases for Class 2 piping greater than 200°F or greater than 275 psig.

Section C.12 states:

The NRC staff does not consider through-wall conditions in components, unless intentionally designed to be there such as sparger flow holes, to be in accordance with the intent of the ASME Code or construction code and, therefore, would not meet code requirements, even though the system or component may demonstrate adequate structural integrity. Thus, unless a through-wall flaw is evaluated and found acceptable using an applicable and NRC endorsed code case, in which all provisions are met including any additional requirements or limitations imposed by the RG endorsing the code case, a relief request is necessary.

As there is no current NRC endorsed code case for Class 2 piping greater than 200°F or greater than 275 psig, a relief request is necessary per the guidance in Section C.12 of NRC Inspection Manual Part 9900. This supplement seeks approval to deviate from the intent of the construction code for structural integrity of the 3/4" RHR piping.

The newly created through-wall perforation was evaluated in both the axial and circumferential directions and concluded to be stable and the 3/4-inch pipe will maintain its structural integrity with the presence of the flaw.

The newly created through-wall perforation has been characterized using UT techniques and its growth potential has been evaluated. A straight beam ultrasonic

Serial No. 12-319B 10 CFR 50.55a Request RR-2-3 Supplement Page 8 of 10 inspection of the 3/4 inch piping above the leak sealant enclosure to the bottom of valve RHR-600 was performed and has verified that the wall thickness is consistent with the specified nominal piping thickness of 0.113 inches. No anomalies were detected during the ultrasonic inspection. Visual inspection has characterized the newly created through-wall perforation as having an indistinguishable axial length and a circumferential length of approximately 3/64 inch. In this situation, the perforation is known to have been created during maintenance and is not due to aging during operation of the plant. The location of the perforation is on 3/4 inch piping base metal.

The estimated length of the attempted weld is 0.25 inches.

The perforation has been conservatively bounded as through-wall, with an axial and circumferential length of 0.25 inches (corresponding to the area of weld in contact with 3/4 inch pipe).

There are two (2) possible degradation mechanisms that could cause the perforation to grow in size, both of which are related to service time. The first mechanism is fatigue.

The second mechanism is stress corrosion cracking. Perforation growth caused by erosion due to leaking water is considered negligible because the pressure is low and stainless steel is resistant to flow accelerated corrosion wastage mechanisms.

Isolating the portion of the RHR system with the leak will take approximately 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after reaching MODE 4. During this time the size of the defect will have negligible fatigue crack growth because the number of fatigue cycles that could occur during this time period is low or nonexistent. Similarly, the short duration will be insufficient to initiate flaw growth due to stress corrosion cracking, as the environment has not changed. Additionally, there have been no cases of stress corrosion cracking on stainless steel base metal at KPS. Based on this, a limit of 5.5 gallons per hour will be established for total leakage from the affected piping near RHR-600 to ensure compliance with existing System Integrity program (SIP) leakage limits of less than 6.0 gallons per hour.

The requirements for monitoring the newly created through-wall perforation will be based on the guidance provided in ASME Section Xl, Appendix IX, Article IX-6000, but will be adjusted based on the expected short duration until an ASME Code repair can be performed. A VT-2 examination will be performed and repeated a minimum of once every twelve hours, and leakage will be quantified a minimum of once every twelve hours, until a MODE change from MODE 5 to MODE 4 is made and the resulting portion of residual heat removal piping needed to facilitate repair is isolated and depressurized.

Additionally, Temporary Modification 2012-11 has been updated to replace the previously proposed full circumferential structural fillet weld, which was to have been added at the interface of the 3/4-inch diameter pipe and the leak sealant enclosure, with a structural restraint to prevent possible catastrophic separation of the 3/4-inch line above the leaking sockolet.

Serial No. 12-319B 10 CFR 50.55a Request RR-2-3 Supplement Page 9 of 10 The above described approaches will provide the safest and most expeditious method to complete an ASME Code repair of the affected piping given the current condition of the plant.

6. DURATION OF PROPOSED ALTERNATIVES This alternative would be applicable for Kewaunee Power Station during the current refueling outage while in MODE 5 and until the plant reaches MODE 4 and ASME Code repair of the affected piping is completed. Isolating the portion of the RHR system with the leak will take approximately 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after reaching Mode 4, eliminating the need for the leak-limiting device.

7. PRECEDENTS Dominion is currently aware of three (3) situations (see references 1, 2, 3 and 4) where similar alternatives have been approved to facilitate repair of ASME Section XI piping the forms that containment boundary.

8. REFERENCES

1. Letter from M. L Marchi (WPSC) to NRC, "Relief Request RR-2-1 to Allow Continued Plant Operation with Two Pin Hole Leaks in a 3/4 inch ASME Code Class 2 Chemical Injection Weldment," dated August 12, 1996.

[ADAMS Accession No. ML111810480]

2. NRC SER, "Kewaunee Power Station - Approval of a Relief Request from the requirements of 10CFR50.55a for Repair of 3/4-inch ASME Code Class 2 Chemical Injection Weldment (TAC No. M96273)," dated September 13,1996.

3. Letter from M. L. Marshall (NRC) to J. A. Stall (Florida Power and Light Co.),

"Turkey Point Nuclear Plant, Unit 4 -

Safety Evaluation for Relief Request Regarding Mechanical Clamping Device on Pressure Boundary Piping (TAC No.

MC7338)," dated August 15, 2005. [ADAMS Accession No. ML052090182]

4. Letter from R. J. Laufer (NRC) to M. Kansler (Entergy), James A. Fitzpatrick Nuclear Power Plant -

Relief Request for Temporary Non-Code Repair of a Shutdown Cooling Pipe (TAC No. MC7544)," dated August 9, 2005. [ADAMS Accession No. ML052070047]

Serial No. 12-319B 10 CFR 50.55a Request RR-2-3 Supplement Page 10 of 10

5. Letter from Darrell G. Eisenhut, NRC Director Division of Licensing, to C.W.

Giesler, Wisconsin Public Service Corporation, "Exemption to Certain 10 CFR 50 Appendix J Requirements," dated September 30, 1982.

Serial No. 12-319B ENCLOSURE 1 FOURTH TEN-YEAR INTERVAL INSERVICE INSPECTION PROGRAM SUPPLEMENT TO 10 CFR 50.55a REQUEST NO. RR-2-3 TEMPORARY MODIFICATION PACKAGE 2012-11 (REVISED)

KEWAUNEE POWER STATION DOMINION ENERGY KEWAUNEE, INC.

Temporary Modification CMAA-D20 ATAHMN 3

Pag

1. o1 dOvfDminion-Site Unit Year Temporary Modification Number Revision Number Work Order(s)

KPS 1

2012 2012-11 3

KW100894696 KW100894787 KW1 00895870 High Risk?

[ YES

• X NO Provide information as required and attach additional sheets as necessary for each Item.

Part A. TM Description (To be completed by Requestor/Originator/Engineering)

1. Title RHR-600 Leak Repair

2.

Expiration Date [Not to exceed one refuel cycle (unless approved by site VP)]

KR32 (Remove prior to entering Mode 3)

3. Affected Systems/Components/QA Class RHR (System 34)/RHR-600/SR

4. Reason (e.g., awaiting parts, testing, calibration, repairs, temporary power supply)

The %" socket weld upstream of RHR-600 has a pinhole leak. This TM performs a temporary repair of the leak by injecting leak sealant into an enclosure around the leaking fitting to stop or minimize the leak to within allowable limits. This TM will be installed in Mode 5 and removed prior to entering Mode 3. In addition, a NRC Relief Request is required before changing from Mode 5 to Mode 4 with this TM installed.

The additional flaw in the 3/4" diameter pipe caused during TM installation has been evaluated and found not to structurally impair the integrity of the 3/4" pipe. The flaw was evaluated in both the axial and circumferential directions and concluded that the 3/4" RHR pipe was stable and able to maintain its structural integrity with the flaw. Therefore, this TM does not address the presence of this additional flaw.

REV 1 revised the section regarding Monitoring Requirements (IX-6000) to be consistent with the NRC relief request requirements. Also provided clarification to the system pressure requirements.

REV 2 will change the following:

1. Clarify that during sealant injection, the RCS temperature will not exceed 195 F. This was required to eliminate confusion regarding temperature at the injection location and plant operating mode temperatures.

2. Add bolt torque values to the implementation sections. Values based on vendor installation practices.

3. Clarify allowable sealant volume.

4. Enhanced discussion regarding thermal effects and constraints due to the installation of the repair clamp.

5. Revised Ref. 12 to Revision B for change to the Bill Of Materials.

REV 3 will change the following:

The additional method of retaining the %" pipe will now be a structural restraining clamp rather than a 3/16" circumferential fillet weld between the leak sealant enclosure and the 3/4" pipe.

I FcrmfNo. 730749 (May 20U)

SDominion-Temporary Modification

. MA A l D 20 A TNe&

2

5. Description (e.g., specific details on the aspects of the modification): Work Order reference(s), and instrument index as applicable, and locations (e.g., racks, cubicles, building, area, elevation, and rooms to identify in detail the location of the modification).

Attach sketches as necessary.

See following pages

6. Documents/Drawings/Procedures to be Updated

a. Vendor procedure for sealant iniection b.

SC.

7. List any Mode Restrictions This TM can remain installed in Modes 4 and 5. It must be removed and the system restored prior to entering Mode 3.

8. Action Plan for Removal - Close-out Document (REANDCP/DCR, Work Order, Procedure changes)

Repair leaking weld and remove TM per WO # KW1 00894787

9. Installation Instructions for TM Install leak sealant enclosure and inject leak sealant per approved procedure. Torque clamp bolting to 126 ft-lbs and strong back bolting to 75 - 90 ft-lbs. [16]

Isolate (tag shut) valve RHR-600.

Disconnect downstream tubing from RHR-600.

Install structural restraining clamp per Attachment 1 As required, reconnect downstream tubing from RHR-600 Tighten all clamp fasteners wrench tight When tagout is cleared, open RHR-600 as required

10. Required System Testing Following TM Installation Verify any leakage is within acceptance criteria specified in WO 100894696

11. Removal Instructions for TM Per WO.KW100894787

12. Required System Testing Following TM Removal Permanent repair of the leaking fitting will follow removal of the TM. Therefore, there are no removal test requirements for this TM.

n

13. Requested By (Name - Please Print)

14.

eques d y (Signature)

15. Date Tim LaHann 04/30/2012 Form No. 730749 (May 2011)

P Dominion-Temporary Modification C

T I 3

P 3 of 1

(

Part B. Design Engineering ReviewslScreening Evaluations Attached 1, CM-AA-RSK-1 001, Engineering Risk Assessment, Attachments 2 and 3

2. DNES-AA-GN-1002, Document Impact Summary, Attachment I YES NO

3. DNES-AA-GN-1003, Design Effects and Considerations,

4. DNAP-3004, Dominion Program for 10 CFR 50.59 and 10 CFR 72.48 - Changes, Tests, and Experiments (KPS only - perform ONE IS REQUIRED GNP-04.04.01 for Applicability and Pre-Screening prior to DNAP-3004)

EYES

[] NO 0 50.59172.48 Screen, Attachment 4 EYES

[

NO 50.59/72.48 Evaluation, Attachment 6

5. Additional Attachments C.

d.

6. Summary: Descriptions & Conclusions Resulting from Reviews/Evaluations Performed in Step 3.1.8. and Above RSK-1001: The TM is medium risk AA-GN-1002: A procedure for leak sealant injection is required AA-GN-1003: Components within the ISI boundary are affected.

50.59: The TIM screens out of 50.59

7. Additional Reviews and/or Comments - Provide Details Below None

8. Prepared By (Prin ign)

9. Date Tim LaHann 1 1.1.2

10. Independent/Design A rReview (as applicable)

11. Date (Print & Sign)

Lori Christensen

)Ž'/

/

Additional reviews for Implementing Organization, Training, etc. as necessary in

.1 n... Qft-+ir,.

I I

I ~

"~________________________________________________________________

12. Name (Print & Sign)/Department a.

b.

C.

d.

13. Date 1.

2.

3.4.

I Form No. 730749 (May 2011)

P Dominion-Temporary Modification 2 I A T A C N

a e4

14. Engineering Supervisor

15. Engineering Supervisor

16. Date (Name - Please Print)

(Signature) u/

jAA M;1,.4e 4

c.4.j.

5nr~-LiIi Part C. Operations Review (To be completed by Shift Manager/Designee)

1. Are controlled Station drawings affected by the TM and are m YES 13 NO 0 NA they attached?

2. Necessary Station personnel are informed of the TM?

0 YES LI NO 13 NA

3. Temporary procedure changes and Temporary procedures LI YES [I NO 0 NA are implemented to support the TM?

4. Evaluated need for check valves and/or other anti-siphon El YES

[1 NO 0 NA protection, if TM utilizes piping or hoses?

5. Limiting conditions and special requirements indentified.

Note: NRC Relief Request is required before mode change (5 to 4) with TM installed.

6. TM verified not to violate Technical Specifications, not to.

create a hazard to Station safety or personnel, or conflict with 0

YES 13 NO 13 NA existing Station conditions?

Note: NRC Relief Request is required before mode change (5 to 4) with TM installed.

7. TM Tags generated in accordance with applicable Site

[0 YES [] NO Ej NA Tagging procedure and any special instructions included on the tags?

8. TM Log updated?

U YES NO E] NA

9. Engineering Post Installation Walkdown Requested?

[1 YES 0 NO 13 NA

10. Quarterly walkdown required?

[1 YES El NO

[g NA

11. PRA risk impact has been assessed and, if determined to be applicable, has been entered into the Risk Monitor and/or I

YES 13 NO 13 NA Shutdown Risk Assessment?

12. The affected Unit shall not exceed the operating mode of: 5 until NRC Relief Request is approved. Once the Relief Request is approved, the unit shall not exceed Mode 4.

13. Concurrent or Independent Verification: NA

14. Functional Check or Visual Inspection: Per WO KW1 00894696

15. The opposite Unit shall not exceed the operating mode of: NA

16. STA Concurrence (Print & Sign) for Virginia Plants Only [Commitment 5.1.4]

17. Date NA

18. Shift Manager/Desig4eR, (Print & Sign)

19. Date Ethan Treptow I/Z Form No. 730749 (MN 2011)

Temporary Modification CMAA-D-0 ATCMN 3

Pag 5 of1 Dominion-Part D. FSRC Review (as applicable, Refer to LI-AA-600)

NOTE: If the TM is used to move radioactive fluids or gases, the Manager Radiological Protection or Radiological Protection alternate must be a member of FSRC NOTE: TMs which could affect Nuclear Safety must be reviewed by FSRC

1. Is FSRC Signature Required?

Z YES E] NO

2. FSRC Authorized Duration

3. FSRC Chairman Approval (Prin &

i "7 /

4. Date Part E. TM Installation (To be completed by applicable personnel)

1. Shift Manager Approvph-r^TM Installation (Print & Sign)

2. Date Ethan TreptowP7j

/~

3. Shift Manager Comments (includes any additional requirements in accordance with Section 3.4, "Implementation") - Provide Details Below Lea¶=ha~,,.vo,.',

pA. O*

o4Tt.-

5 (--'2--.-.

4. Installation Completed By (Name -

5. Installation Completed By

6. Date Please Print)

(Signature)

7. Independently Verified By (Name -

8. Independently verified By

9. Date Please Print) (as applicable)

(Signature) (as applicable)

Notify the Shift Manager that TM is installed and the required post installation testing can be performed.

10. Instructions Used for Post Installation Testing: Per WO KWI 00894696

11. Testing Performed BI (Name - Please Print)

14. Post Installation Testing Satisfactorily?

15. Required Administrative Controls Established?

E YES LI NO

16. Is Engineering Post Installation Walkdown Required?

NOTE: Responsible Engineering signature is in accordance with 1 YES

[

NO Step 3.4.6

17. Responsible Engineer (Print & Sign) (Engineering walkdown completed)

18. Date NA

19. Shift Manager (Name - Please Print)

20. Shift Manager (Signature)

21. Date Form No. 730749 (M"y 2"11)

P Dominion" Temporary Modification CMAATC24 ATCMN 3

Pag 6 of1 Part F. TM Restoration (To be completed by applicable personnel)

1. Shift Manager Approval for TM Removal (Print & Sign)

2. Date

3. Shift Manger Comments (includes any additional requirements in accordance with Section 3.7, "TM Removal") - Provide Details Below

4. TM Restoration Completed By (Name -

5.TM Restoration Completed By

6. Date Please Print)

(Signature)

7. Independently Verified By

8. Independently verified By

9. Date (Name - Please Print)

(Signature)

Notify the Shift Manager that TM has been removed and the required restoration testing can be performed

10. Instructions Used for TM Restoration Testing 11.Testing Performed By

12. Testing Performed By

13. Date (Name - Please Print)

(Signature)

14. Shift Manager (Print & Sign)

15. Date Part G. Post Restoration Review (Completed by Shift ManagerlDesignee following restoration)

1. Post restoration testing completed satisfactorily?

[] YES El NO

2. All Documentation satisfactorily completed?

El YES El NO

3. Temporary drawings removed from Control Room/any other r] YES El NO location?

4. Procedures changed to eliminate TM? (Review Part A)

El YES El NO

5. Necessary Station Personal notified?

[] YES El NO

6. TM Tags removed?

[E YES E] NO 7.TM Log updated?

[E YES ENO

8. Shift Manager (Print & Sign)

9. Date Part H. Monthly Audit INITIAL DATE COMMENTS ON AUDIT 1.

Form No. 730749 (May 2011)

I I

Temporary Modification C

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P 7 o 12 i'Dominion-2.

3.

4.

5.

6.

Part A, DESCRIPTION RHR-600 is a /" SR sample valve located off RHR line 1 0-AC-601 R1 1. A leak repair enclosure, which incorporates a strongback design, will be installed to seal the leak. A structural clamp will also be installed to prevent the pipingNalve from separating from the 10" RHR 1A HX discharge line in event of complete weld failure.

This is a short duration TM, which allows the unit to enter Mode 4 from Mode 5 for permanent repair of the fitting leak. Upon entry into Mode 4, the A train of RHR can be removed from service and the leaking weld repaired.

To install the structural restraint clamp, RHR-600 will be closed and the downstream tubing disconnected. During clamp installation, the tubing may be reconnected as required.

Quality Classification RHR-600 and associated pipe and tubing is SR [1]. All parts used for the leak sealant enclosure and structural restraint clamp are SR, with the exception of the optional shim material, which may be non-safety related.

ASME B&PV Code RHR-600 and adjoining pipe is classified as ASME Section XI Class 2 [2]. ASME Section Xl, Appendix IX provides direction on the use of mechanical clamping devices on Class 2 and 3 piping pressure boundary. The requirements of this appendix will be used to demonstrate the acceptability of this repair on the leaking fitting.

Note that Article IX-1 000 prohibits the use of a clamping device on portions of a system that form the containment boundary. RHR-600 is credited with maintaining the containment boundary and therefore the plant cannot change modes with this temporary modification installed without an approved NRC Relief Request.

Auxiliary Cooling (AC) System Temperature and Pressure The design pressure and temperature of the piping, AC-601 R-1 1, is 600 psig and 400 OF [5].

The leak sealant enclosure will be designed to these conditions.

The TM will be installed and the leak sealant injected in Mode 5. RCS pressure will be maintained greater than 340 psig. The operating pressure will be used to determine the injection pressure for the leak compound. This will assist in preventing injection of sealant into the Form No. 710749 (May 2011)

i Temporary Modification I

awrDominion-T 44AT)-04 ATCMN 3

Pag 8 of 126 system. Sealant injection will be performed in Mode 5. During leak sealant injection, the maximum RCS temperature will not exceed 1950 F ifi. The X-36 sealant is rated for injection from a temperature of 140OF up to 400 OF [15], and is therefore suitable for this application.

Overview The leak repair will be completed using a hub clamp assembly designed and fabricated by TEAM Industrial Services, Inc. This assembly incorporates a leak sealant enclosure into a strongback clamp design. Two #10-24 set screws, tightened to 36 in-lbs, are included in the hub assembly. These set screws tighten onto the 3/4" pipe between the leaking sockolet fitting and RHR-600 and will prevent ejection of the 3/4" pipe and RHR-600 in the event of a full circumferential failure of the leaking 3/4" sockolet weld. As an added measure of safety, a structural restraint clamp will be installed above RHR-600 that will attach to the 10" diameter RHR piping to ensure structural integrity (Attachment 1).

This structural clamp, in conjunction with the set screws, is more than adequate to restrain the 520 Ibf separation thrust [12] and ensures that no catastrophic separation can occur due to a full circumferential failure of the %" socket weld.

A structural evaluation of the structural restraint clamp is attached to this temporary modification

[19].

The leak sealant enclosure is made of stainless steel and, along with the X-36 sealant, provides the pressure boundary up to the design temperature and pressure of the AC pipe, which is 600 psig and 4000F. The studs, which secure the leak sealant enclosure, are tightened to 126 ft-lbs

[12].

General Design Requirements (IX-3100)

Defect Characterization: The defect is characterized as a pinhole leak in the fillet weld of the 3/4" sockolet upstream of RHR-600. The leak is documented in CRs 472654 and 472226. The apparent failure mode of the leak will be determined by follow-up analysis. Since more accurate data on the defect size or potential for propagation is not available, this TM assumes catastrophic failure as characterized by full circumferential failure of the 3/4" sockolet weld. This failure will not result in ejection of any pipe or RHR-600 because of the restraint provided by the structural restraint clamp. The design of the structural restraint clamp is shown in Attachment 1.

In the event of a full circumferential failure of the leaking W" sockolet weld, the rupture load would be transferred through the restraint clamp and into the 10" diameter RHR line.

Material compatibility [12]: The hub clamp is constructed of SA240 Gr 304/316 material. Studs and all-thread material are SA193 Gr B8, hex nuts are SA1 94 Gr 8, and set screws are ANSI B18.3 stainless steel. All sealant enclosure materials are acceptable for use with borated water in the AC system. The pipe coupling and arms of the structural restraint clamp are constructed of stainless steel, and are also acceptable for use in the AC system.

The Grinnell Figure 295 pipe clamps that attach the structural restraint clamp to the pipe are carbon steel. Stainless steel banding, as required, will be installed between the carbon steel clamps and the stainless steel 10" RHR pipe. While there may be some leakage of borated water from the 3/4' pipe assembly, this TM will be installed for only a short time. Therefore, Fornm No. 730749 (May 20=1)

Temporary Modification

-A T D 2

A 3

P f 1

" Dominion-potential for boric acid corrosion of the carbon steel is minimal and the potential clamp degradation from corrosion will be negligible.

TEAM Industrial Services compound X-36 will be injected into the enclosure to provide temporary repair of the system pressure boundary. Sealant X-36 has a low concentration of Halogens/Chlorides and is acceptable for use on stainless steel (8].

Defect size: The defect size assumed for the design of the sealant enclosure is a full circumferential failure of the leaking W pipe socket weld. Per Reference 12, the leak sealant enclosure is adequately designed for this application. These calculations establish the enclosure size and construction, as well as maximum sealant injection pressure and volume necessary to provide the system pressure boundary. Identifying maximum sealant injection volume prevents over-injection and intrusion of the sealant into plant systems.

Additional supports: The installation of the enclosure adds a 71 lb point load [12] to line 10-AC-601 RI 1 between hangers RHR-H9 and RHR-H55 [3]. The structural restraint clamp weighs approximately 57 lbs. Installation of the clamp will add two point loads, each* approximately 28.5 ibs, to this same line. Thus a total of approximately 128 lbs will be added to the pipe line. This load increase is less than 10% of the weight of the supported pipe. The structural qualification of the nearby supports is contained in calculation S-062-RHR-34-004 [18]. These supports (RHR-H9A, RHR-H9, RHR-H55, and RHR-H29) were qualified for loads that are 10% greater than the governing load case 'to avoid future reanalysis for small load increases". Therefore, no further evaluation of this load addition is required [4].

By virtue of their relatively light weight and their being secured to the /" and 10" pipe, the leak sealant enclosure and the structural restraint clamp do not adversely affect the seismic qualification of the pipe or adjacent equipment.

Clamping Device (IX-3200)

As described above, the hub clamp is constructed of SA240 Gr 304/316 material. Studs and all-thread material are SA1 93 Gr B8, hex nuts are SA1 94 Gr 8, and set screws are ANSI B18.3 stainless steel. The leak sealant enclosure is designed to meet Table IX-3200-1 Level A stress limits as well as meet the bounding pressure and temperature requirements of the Auxiliary Cooling System [12].

Pip.ing System (IX-3300)

LeakSealant

Enclosure:

The leak sealant enclosure will be secured rigidly to the 10-inch pipe using a strongback design. The friction between the clamp and the pipe is significant compared to the seismic forces of the relatively light weight clamp and enclosure. The clamp and enclosure are fabricated from SA-204 Gr 304/316 stainless steel and are well stiffened to resist the self weight seismic forces.

Vibration: The pipe in question is at the outlet to the RHR heat exchanger and is well supported near the repair area. Vibration is not considered to be the apparent cause of the defect in the weld. Consequently, vibration was not considered in the design of the leak sealant enclosure.

Piping Evaluation/Stress: The proposed leak sealant enclosure and structural clamp introduces a relatively small load to the pipe configuration due to their total weight of approximately 128 lbs and the additional seismic forces associated with their weight multiplied by seismic Form No. 730749 (May 2021)

Temporary Modification

-A-3 Pg 10 of" 12 iW"Dominion-accelerations. Seismic forces on this configuration will be resisted by the frictional force of the pipe clamps around the 1O-inch pipe. The clamps' loads will be shared by two supports located 6 to 8 feet horizontally from the sample line's connection to this pipe. Refer to KPS Drawing M-962-2 for the piping and hanger configuration. The existing pipe stress analysis, KPS Calculation RHR-34-004, indicates the stresses for the total span between the supports are relatively small on the order of less than half of the allowable stresses. Considering that the weight of the clamps is less than 10% of the weight of this span of 10 inch diameter pipe, and that the combined pipe stresses are low, it is reasonable to conclude that installing this clamp would not have an adverse affect on the integrity of this piping system including design basis loading conditions.

Joint stiffness: There is no appreciable change in the stiffness of the RHR piping system due to the addition of the leak sealant enclosure and structural restraining clamp.

Constraining effects: The clamp holding the leak sealant enclosure is a single clamp band. The temperature increase experienced by the clamp from the point of installation until its removal will be no more than 95°F (From 150OF min to 2450F max [17]). This temperature increase will result in a radial expansion of the 10" diameter pipe by no more than 0.005". The effect of this radial expansion on the strongback bolts will be an increase in tensile stress of approximately 20%. The initial torque on the strongback bolts is approximately 40% of the material yield.

Therefore, the additional tensile stress on these bolts will remain within the yield point of the material.

There will also be a constraining effect on the 3/4" pipe due to the addition of the structural clamp. If unrestrained, the thermal expansion from the center of the 10" pipe to top of valve RHR-600 where the structural clamp is located is approximately 0.011D [19]. This thermal movement was considered in the design of the structural restraint. A relatively small force of 130 lbs [19] will be imparted to the support from this thermal expansion. This load will also be subjected to the top of the 10" pipe as a compressive force. This compressive load is considered to have a negligible impact to the stresses in the 10" pipe.

In summary, the constraining effect of the leak sealant enclosure, strongback, and structural clamp will not significantly impact the piping stresses, the strongback bolting, or the structural clamp stresses.

Defect growth: The friction resistance of the pipe clamp and the rigid connection of the leak sealant enclosure stabilizes the % inch pipe and valve, reducing stress. Therefore the defect is not expected to grow during the very short timeframe this TM will be installed.

Monitoring Requirement (IX-6000)

Compliance with the monitoring requirements of IX-6000 shall be as described in relief request No. RR-2-3 (Ref. letter to NRC dated 4/29/12, Serial No.12-319).

Sealant Iniection The sealant will be injected at a pressure based on the system operating pressure. Thus, the system pressure will prevent the sealant from entering the system piping. The allowed quantity of sealant to be injected is calculated to be 8.5 in3 [12]. This volume will be procedurally controlled via GMP-206, Leak Sealant Injection Repair of Steel Components.

Form No. 730749 (May 201)

I Temporary Modification C

AA A

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of 1

iW Dominion-Sealant will be injected to stop the leak up to maximum predetermined amount of sealant. The acceptance criteria for post-injection leakage from the joint and all other SIP (System Integrity Program) leakage is less than 6 gal/hr.

Containment Isolation The leak enclosure will be located on piping outside of containment that is between the containment and the outside isolation valve. Therefore, the leak enclosure will need to [9]:

1. Meet Safety Class 2 design requirements.

2. withstand containment design temperatures

3. withstand internal pressure from containment structural integrity test

4. meet seismic Category I design requirements

5. be protected against a high energy line break outside of containment when need for containment isolation.

6. maintain leakage within the Current Licensing Basis [13]

RHR-600 is an outside Containment isolation valve for Containment Penetration 10, a Class 6 penetration. Penetration Class 6 is a system required to operate post-accident. The design and operational criteria for penetration Class 6 isolation valves are governed by the functional requirements of the system. The isolation valves at Penetration 10 are not relied upon to prevent the escape of Containment air to the atmosphere [14].

The requirements for Containment Isolation are satisfied since the enclosure will satisfy the design requirements of the RHR system. The leak sealant enclosure will be designed in accordance with ASME Section XI, Appendix IX, Mechanical Clamping Devices for Class 2 and 3 Piping Pressure Boundary. The piping remains seismically qualified and the enclosure will remain intact during a seismic event. The leak sealant enclosure will prevent system leakage, or minimize leakage to a value that results in meeting the leakage requirements of the System Integrity Program for combined allowable leakage from the Safety Injection, RHR and Internal Containment Spray systems.

Operations The leak seal enclosure is located near RHR-600. The installed TM will not prohibit operational use of RHR-600.

References

1.

XK-100-18, Rev. BA

2.

ISIXK-100-18, Rev. AC

3.

M-962-2, Rev. A

4.

ANSI/ASME Code Reconciliation For Replacement Material, Parts, And Components, Kewaunee Power Station, Revision 3, July 6, 2010

5.

XK-100-371, Rev. 5

6.

ASME B&PV Code Form No. 730749 (May 2011)

SDominion-

7.

OP-KW-GOP-102, Rev. 13 Temporary Modification CMAATC24 ATCMN 3

Page*

Af

8.

Consumable Material Evaluation (CME) 10000005744

9.

ANSI N271-1976, Containment Isolation Provisions for Fluid Systems.

10. KPS Calculation RHR-34-004, Pipe Stress Report (Rhr-34-004) For Residual Heat Removal Piping System Analytical Part No. Rhr-34-004, Rev. 1, 19900228, CA706184

11. CEM-0049 and Addendum OOA, Rev 000, Evaluation Of Compensatory Measure Taken In Response To Identified Leakage At 3/4" Drain Line Valve 2-RH-33 Off Line 14"-RH-1 18-602

12. TEAM Industrial Services Engineering Order 91511 dated 04/29/2012, Rev B

13. System Integrity Program, Rev. 6

14. Darrell G. Eisenhut, NRC Director Division of Licensing, to C.W. Giesler, Wisconsin Public Service Corporation, Exemption to Certain 10 CFR 50 Appendix J Requirements, dated September 30, 1982.

15. TEAM email, 04/29/2012

16. TEAM email, 4/29/2012, Strong Back Torque

17. OP-KW-NOP-RHR-001, Rev. 17, Sect. 5.11 RHR Alignment-for Exceeding 245°F (Split Train Mode)

18. KPS Calculation S-062-RHR-34-004 79-14 Hanger Design Verification

19. Evaluation of Pipe Clamp Assembly Components, 05/01/2012 : Structural Restraining Clamp Fan, No. 7=~49 (May 2M1)

Tm--.2012 -11 STRUCTURAL

'STRAINING CLAMP 16' BILL OF MATERIAL ITEM OTY MATERIAL 1

2 tCLAMP, PIPE 10". GRINNELL FIG. 295 2

2

,/' STAINLESS STEEL PLATE, ASTM A240-88C TYPE 316 3

1 COUPLING, 1V/4-SOCKOLET WELD PIPE, STAINLESS STEEL ASTM A-182 F304. 6000 LB (CENTER MACHINED OUT) 4

2. PIPE. 1'. STAINLESS STEEL. ASTM A312-SBA P304 SCH. 40 SEAMLESS 5

X, SS BANDING 10 GA. 6' WIDE, LENGTH AS NEEDED SECTION A-A ValvbClonip.dgn

ýTEAM-ý Industrial Services Registration# F-003143

(

Engineering Departmenti Tel: (281) 388-5695 Fa: (281) 388-5690 ROUTING SLIP & COVER SHEET FOR NUCLEAR SAFETY RELATED JOBS Branch Work Order #: 203-04270 1 Status: Priority Caller: Chad Preston I Customer: Domion Energy I

yReview#: 91511 iEngr Order#: 91511 Name:

I Signature:

T Date:

Time:

Data Taken By:

Heather Hodges 4/28/2012 06:00 Designed By:

Heather Hodges 4oý 4/28/2012 13:08 Verified BY:

Andrew C&

4/28/2012 14:15 Shop Received By-QC Received By:

i Specifications:

Design Pressure:

600 psi Design Temperature:

1 400 OF Service:

Reactor Coolant 1 Torque Value:

1 126 ft-lb TotalWeight:

__70.8_5.,_

Void:

6.27 & BC (M)

I.Sealant Type:

[ X36 w/G-Fiber Do Not Paint I

Note:

ASME SECTION XI, APPENDIX IX _

I QC FINAL INSPECTION REQUIRED Nuclear - Safety Related MTRs and COCs Required PMI Required Bill of Materials:

[

Description:

1 Material:

Qty:

Clamp Hub SA 240 GR 304 / 316 Strongback SA240 GR 304 / 316 11 5/8"-11UNC STUDS

__SA 193 GRB8/8M 14 5/8" HEX NUTS

-SA 194 GR 8 /8M 18

1. 10-24UNC SET SCREWS 1ANSI B18.3 STAINLESS STEEL 12 SEALANT

_X-36 1 TUBE

1. ____ ___ ___ ___ ___ ___ ___

Rev. 3/3/2010

III L'veri-thin-lie

., ý, W,,

"SAFETY FIRST - OLLALITY ALWAYS" 0b3/4" 03/4"'

(2) PLACES NOTES:

1.

APPROVED TO MANUFACTURE

2.

1/4" X 0.12' TUBING GROOVES IN HUB FACE

3.

3/16" X 0.09n TUBING GROOVES IN BORE

4.

INSTALL STAINLESS TUBING

5.

DRILL & TAP (2) 1/4-NPT INJECTION PORTS IN CAVITY

6.

MAX INJECTION PRESSURE: 1000 PSI + STATIC

7.

(2) HALVES REQUIRED

8.

ALL DIMENSIONS ARE TYPICAL UNLESS NOTED 9.'

Di'I (2) #1 0-24UNC CUP TIP SET SCREWS IN 1.07" BORE, TQ: 36 IN*LBS

.**r

10.

NUCLEAR SAFTEY RELATED - DO NOT PAINT

11.

ASME SECTION XI, APPENDIX IX Sn I AKlT JAI!! I tAIrEI r% C~l "

rT JAI -I n* Trr% -ur" t1jjn

^'kl A A" -F l'l_

I TE Iv I

REGISTRATION # F-003143 D~ndustrial Services, In4 PERIMETER VOL I

BC" ENGINEERING ORDER# 91511EM DRAWING # N/A NT-71 BSývOL 5976I'NA3 BC rECO PART #

N/A WPS: N/A DRAWN BY: HH 4/28/2012 CHECKED BY: AC 4/28/2012 FLAC90" lifn rmfAAR tii IWOm"AmmL o"

UE~ayCmmi DOMINION V4!,.m HUB CLAMP SIZE A

REV 0

OF TIHE CLAMP

CALE

1:4 ISHEET I OF 2

fit b I

"SAFETY FIRST - QlUA..LITY ALWAYS" 518" i

3" 1 3/4"-I -o

-o 518"

0. 3/4" (4) PLACES F 3/8" R5 3(8" 13" NOTES:

1.

(1) REQUIRED

2.

SEND (4) 5/8-11 UNC X 24" LONG ALLTHREADS

3.

SEND (8)5/8 HEAVY HEX NUTS TEAM ID Industrial Services, I REGISTRATION # F-003143 I v-l-I PII*IKA"T'D Vti

,ka2 af ENGINEERING ORDER# 91511 EM ir*lf*

DRAWING # N/A TECO PART #

N/A WPS: N/A DRAWN BY: HH 4/28/2012 MAIO*WSWAM IWO PALCEBOL

.o WfflACIEIOM?4*Cf WT. 71 LBSfvOL".

-1NA3 BC DOMINION

1. /'*.0z.

HUB CLAMP SIZE A

IREV 0

CHECKED BY: AC 14/28/2012 SC LE 1:

ISHEET 2 OF 2 CHECKED BY: AC 4/28/2012 SCALE: 1:4 ISHEET2OF2

I I!I TEAM INDUSTRIAL SERVICES, INC.

ENGINEERING DATA COVER SHEET

. Rev. 12/16104 BranchVork Order#:

I I

I j

PRESSURE TEMPERATURE I

II Package Requirements:

(peck all that are immediately needed)

Drwlngs

• !,*calculations Price (If so 0 ballpark or jby engineering)

Dte.and Time Required: _

(Check one only)

For Irniedlate Manufacture Wait for Approval of Package I Pdce" 0 Price Only / No Calculations/Drawings Fax/EmaN Prints and Calculations:

john.p.schroeder@dbm.com ErnaT

'~t Name:/ht

&-A,*

_:4 Fax No:

T o Customer

" Notify Branch Supervisor after faxing

-Name:

Phone No: ___,____

o_

0 Immediately U Next Business Day Special Requirements:

St'ongback needed for separation I vibration U Stress Relief Required by Customer U If Lifting Lugs are required, where should they be located?

0 PE Stamp Cl Are there specific requirements I codes for this customer?

0 MTRs and COCs

[

Other D] NDE DESCRIPTION OF ITEM TO BE BUILT (HTS ONLY). STYLE OP FITTING (HTS ONLY)

D Hot Tap Fitting:

1] Split Tee Line Stop Fitting:

El Full Encirclement Reinforcing Saddle (

with Nozzle?)

(Saddle Is non-pressure retaining) 0 HI-Stop Fitting:

U Bolt-on

'Other U Weld-o-let J Saddle / Scarfed Nozzle Tap Size:

Existing Line Schedule:

Requested Nozzle Schedule:

I

TEAM

.Quality System Supplement Corporate t FORM 104.2 Rev: 5 Page I of 2 I

NUCLEAR AUTHORIZATION / CONTRACT REVIEW CHECKLIST (NACL)

TMS Division I

• PART A: Used for material only orders and in conjunction with PART B for service related work.

Limit 3jobs per Team Job # / CJ #. All threejobs must be within the same service line.

Submitted by:

Branch:

3 Date:

g'-2 I Z Utility: '

,'AM A,

Plant/Location:

Contact:

Phone #:

'Z 0- 3 91'- z3o Customer Contetr/Work Order/PO#:

Team Job #:O 3o-- ?o Personnel:

e l.

j.--

2. (.66 C,4

3. A

?

lis

,_4.

Shift: gi'

• i-Additional Personnel:

Pre-Job Check List: A new form must be comoleted each day, bv ea it w.d prior to an work bebn-oerfonmeat I.

All Pre-Job Steps rmust be initialed by the Team Industrial Services, Inc. technician who is leading activities at the work site prior to any work being performed.

2.

The Owner Representative must initial Step 8 prior to any work being performed

3.

All TISI employees on the job must sign Step #9 prior to any work being pe[ored Steps:

Yes No Initial Date Comments:

1. Has ISA been copleted?

"0

-a

_T_

2. Has Tech. Suort been contacted? (Critical Job Review) 91Z 0

V'/*s CJM: f,571

3.

Hayv Team personnel READ and do they UNDERSTAND the Owner 0 )

tC.#:

101 It

4. Have Team personnel verified procdurm(s) to bo used?

0' Procedur: 3 301

5. Have Team personnel READ and UNDERSTOOD the Owner W.O. Scope?

0

/

W-0..#-

W I06-M4

6.

Have Teamn personnel been briefed on Owner W.O. Scope and received Copy

[3 of W.O.7

7. Have Temn personnel ha a Rad. Prot/etion Bricf?

q17,9

8. Has Owner Represenative verified all Steps have been perfbrned?

0 4

1

!LRep. to Initial. O

9. Signatures of ail Team Personnel:

I 96

• PART B: Used in conjunction with PART A for all service related work. PART B is not required for material only orders.

For Technical Support Use Only Number of Jobs reviewed.

1["]

2E]

3E]

Comments:

Reviewed by:

Signature:

Date:

Job #1 Information Requirements Service Line:z P6 Leak Severity:

/

Notifications: Safety Relateck Yes

• No El Quality Assurance: Yes [

No El Line Size: j

< c/g Service: r'e.t

'i coci,'-

Health Physics:

Yes No unit:.*.

Exp. Rate:

S'60th, Procedure #:

Rev. #:

COP, Temp:

__9_

Op. Press: &5-,

Materials & Eaulpment Design Temp:

q001 Design Press:

600#:

Sealant Type: )C-,3 Y

I Lot#:

Equip.

4' 4'- 600 SealantType:

-41'bt r J&t(_ I Lot :

Comments/Description of Job:

Fabrication Data

___e_

Mill Tests: Yes No]

I Sec. M:Yesl

[

No 0 Has the Customer expressed mechanical integrity concerns for the component?

J Yes [

No []

Plant Rep. (print):*/,. /,do,,o-.e" Initials:

• Design Calcs.: Yes ý No E Engr. Dwgs.: Yes % No -l TISI Tech. (print):

Initials:

Positive Material Identification:

Yes.

No El

TEAM Quality System Supplement Corporate FORM 104.2 Rev: 5 Page 2 of 2 NUCLEAR AUTHORIZATION / CONTRACT REVIEW CHECKLIST (NACL)

.TMS Division I.

Job #2 Information Requirements

'Sowic Line:

Leak Severity:

NW~cations: Safety Related.

Yes [] No Quality Assurance: Yes El No F]

Line Service:

QeaIt Physics:

Yes E No El Ui:Exp.

Rate:

Procedure #:

Rev.#

Op. Temp:

Op. Press:

Mate' als & Equipment Design Temp:

Design Press:

Sealant Type:

Lot #:

Equip. ID #:

Sealant Type:

Lot #:

CommentsfDescription of Job:

Fabrication Da*..

.MillTests: Yes El No'El Sec. III:YN NoEl Has the Customer expressed mechanical inte concerns for the component?

Yes [. No El Plant Rep. (print):

Inktials:\\

Design Caics.: Yes [] No El 'IEngr. Dwgs.: Yes q o Ml TISI Tech. (print):

Initials:

Positive Material Identification:

Yes [E No 0l Job #3 Information Requirements ice-Line:

Leak Severity:

Ntifications: Saety Related:

Yes El No [I Quality Assurance: Yes El No El Line Si-Service:

Health Physics:

Yes [E No El Unit:.

Exp. Rate:

Procedure #: N

{ Rev. #:

Op. Temp:

Op. Press:

ftnals & Equipment Design Temp:

Design Press:

Sealant Type:

Lot #-

Equi. [1 #:Sealant Type:

Lot #:

Fabrication a a Commets/Deczipton ofJob-Mill1TessYes [l No [l Sec. III: ]

No El Has the Customer expressed mechanical integrity co ms for the component?

Yes [] No El Plant Rep. (print):

Initials:

Design Calcs.: Yes 0l No El Engr. Dwgs.: Yes No 0 TISI Tech. (print):

Initials:

'Positive Material Identification:

Yes El NooE Post Job Steps:

1. All Post-job Steps must be initialed by the Team Industrial Services, Inc. technician who Is leading activities at the work site.

2.

Port-Job must be signed by customer representative.

Steps:

Yes INo Initial Date Comments:

Compleft sign-off ofjob package.

0 3 Y191Z~/

Complete sipn-off of Team's procedure.

J~

0 (397-Complete work Recrds and have Owner sign.

X~

0 JP Plant Representative (print):

.J Signatum:

TISI Technician (print):

Signature:

Additional Comments:

(.

DS 136 TEE COUPLET AND/OR WELD-O-LET

'SCREWED/SOCKET

[-SMLS. BUTT.

WELD FITTING GIVENBY:

[, -DATE:

i-'-

'Z c?

PLANT: I I UNT:

CHKD. BY:

/

DATE:

(1-28-- rZ [SURFACE CONDMON: I C7o0,)

LINE SIZE:

0-SEVErrY OFLBAK tON10 SHTO:

LA (A

DIMBNSIONAL DATA' I LTR.

DIM.

Al n la..

.BI o*'e"%

C1 Io.7*-O D1 io. 70o Dl bO70O El

¶,q75 A2 q__,-

B2 C2 ID'.

7.-o D2 I0.7s, I E2 t.65-0 A3 S,50 B3 C3 D03 C3

/45-0 1 D3

(.05"o E3 W3.

,3zs-I p

11.25,O W4 Yvo G2

. Zs-x*

Hi 3.e6o H2 m____

il I \\ /1 32 K

/

LOCATION OF BLOW-

ýIscREEI (BPTC'-B----S1 CMTAO)-' -

AI

.OBSTRUCTIONS I "

COPYRIGHT 2000. Team Industrial Services. 10/2/00

I Designer HH Date 04M2812012 TEAM Industrial Services Sheet I of 71 Checker AC Date 04/2812012 REGISTRATION # F-003143 91511EM Split Circular Endplate Analysis

References:

Fro-, Ea9 ASME Boiler and Pressure Vessel Code,Section II, Part D, (Table for Maximum Allowable Stresses, 2010 Edition)

Formulas for Stress and Strain by Roark and Young, Fifth Edition, Table 24, Case 31 510 Data:

Design Pressure Design Temperature Split Endplate OD Cover Wall Thickness Split Endplate Thickness

-Opening Hole Diameter (Conservative)

Maximum Allowable Stress Inside Radius P:= 600.psi T - 400.deg OD := 4.0.in tJw := 0.75.in t.,,pj :- 0.625.in HD := 0Oin Sallow:= 18300.psi

= [OD - 2(t,)]

2 IR = 1.25-in Modulus of Elasticity Poisson's Ratio Maximum Allowable Deflection Joint Efficiency External Corrosion Allowance Internal Corrosion Allowance OD := OD.- 2-ExtCA tw: a - ExtCA - IntCA tendp1 := tý.dpI - ExtCA - IntCA E:

0.279-10 'PSI v':= 0.30 y :=0.05.in JE: I BxtCA:= 0-in IntCA:= 0-in OD 4.in twa]

0.75-in tendp1 = 0.625 -in Analysis:

Solving for Modulus of Rigidity G: ( E 2-(1 + v)

G = 10730769.23 1.psi Solving for variables OD - 2.ta a

22 HD a- -

2 2

a= 1.25-in b = 0.625 -in c = 0.625.in b:= a-c

TEAM Industrial Services Sheet 2 of 7 REGISTRATION # F-003143 91511EM Solving for Constants K4-(b-1 4

)3 (b _0)2-(b2-.c)

K:= 0.42.338.(ý-C

- 1.81.

+2.85046.

-3.17277.

+2.48483

ýb+c

ý+C b + c)

ýb+c)

K = 2.485 I 2b- + 4-1 62 5 -tendl G

+.t b 2 4.2

'Y2:=

F1-b-

4{ 625-tdp1)

(

+

l X-

2. +

+~)Ž t

X 12 t _Y2 + xi}Ct - Y12).,~~i~

-y= 2.496

'yj = 2.463

-Y2 = 0.406 X, = 4.231 X= 0.292 ci = 0.012 C1 7=

1 kC=2 1-~'

2 --

1 cosh[ =2 c2 = 0.409 C2.=

Stress at A (maximum) a'_: 6.P.c.b.(b

1)

(.

_ 12.cj)+2 (1_Y22j+ 2

-" Ki Idl2 kc - 31 b}

b) b]

at=7647.346.psi

ýSa11ow= 18300.psi Deflection at B (maximum) y:= 24"P'c 2.b2 (b -

!). c1 cosh(.CL + c2.cosh(2W-)

Mii.tmum 3 (Cove L

T Minimum Cover Wall Thickness C1~y = 0-in ymz, = 0.05.in P.IR trcd *= (JE.S.Uo,,) - (0.6.P) trqd.-(J~s0~

-(06.)t~rqd

=.04181 -n

'4 t,,

= 0.75.in

TEAM Industrial Services Sheet 3o7 REGISTRATION # F-003143 91511EM

/

Line Enclosure Analysis

Purpose:

This analysis will calculate the internal stresses and bolt load of a line enclosure.

References:

ASME Boiler and Pressure Vessel Code,Section II, Part D, (Table for Maximum Allowable Stresses), 2010 Edition Team Industrial Services, Teco Manufacturing, Engineering Department, ISO-9001 Quality Manual, EP8.7 UL i

I,"

I~

F l

R R

I RR Dimensioons Free BodU~ Diagraml Data:

Design Pressure Design Temperature Inside Radius R

IR - IntCA Cover Thickness t:= tw, + IntCA Cavity to Stud CL End of Sidebar to Stud CL OD Sidebar Thickness ts:= -O 2

P = 600.psi T = 400.deg R = 1.25-in t = 0.75.in A:= 0.625-in B: 0.875-in ts = 2-in ExtCA

0. 0in IntCA =0-in R =1.25.in t = 0.75-in A= 0.625 -i Length Between Centedine of Seals Sidebar Length (at Centedine)

1. of Studs per Half Hole Size Stud Tensile Area Stud Allowable Stress Enclosure Allowable Stress LS:= 3.0.in LB:= 3.0.in NS2:= I h := 0.75.in TA:= 0.226.in2 Ss := 13800-psi Saiow = 18300.psi External CorTosion Allowance Internal Corrosion Allowance R := R + IntCA t

t - ExtCA - IntCA A:= A-IntCA B := B - ExtCA LB := LB - 2.ExtCA ts := ts - ExtCA B3 = 0.875.in LB =3-in ts = 2-in

I TEAM Industrial Services Sheet4 of 71 REGISTRATION # F-003143 91511EM I Analysis:

Solving for forces and moments F := P.R-LS F,:= F F = 2250-Ibf F, = 2250.lbf Setting forces in x direction equal to 0 R2 := F, R2 = 2250.Ibf Fy:= F Fy = 2250.lbf Setting moments around centerpoint of cavity equal to 0 t

A+B-2 BL:= F.

B Allowable Bolt Load BL0 := TA.Ss.NS2 BL = 2892.857.1bf BLa,= 3118.8.1bf BL :=if (BL < F, F, BL)

BL = 2892.857.1bf Stresses in Shell (thin walled enclosure)

P.-=

P..R t

ar= 1000.psi Sidebar Stress R 1:= BL-F (at Bolt Centerline)

R1 = 642.857.1bf RI B.--

2 O'b2 :

SI-(LB - NS2.h).tS3 12 3

F 2s

=

B 2 (LB - NS2.h)-ts C~b2 =375.psi

$= 750.psi Results:

Less Than Bolt Load BL = 2892.86.1bf Stresses in Shell (thin walled enclosure) a= 1000,psi Sidebar Stresses (@ bolt centedine) 0b2 = 375.psi Shear Stresses in Sidebar T = 750-psi Allowable BLa = 3118.8.lbf Salo = 18300.psi Saow = 18300.psi 0.8"Sao0

= 14640.psi

TEAM Industrial Services Sheet 5 of 7 REGISTRATION # F-003143 9151 EM Thrust Calculation Due to Unequal Bores Seal Length #1 Seal Length # 2 Smaller Diameter Injection Pressure Number of Studs Size of Studs Tensile Area of Studs Stud Allowable Stress Allowable Load of Studs Thrust Produced Thrust:= (D1.D2 - d.2.a.IP Number of Studs Required Thrust H

Force per Stud Thrust N

Dl:= 3.5-m D2:= 3.5.in d:= 1.05in IP:= 1000.psi N:= 4 5/8-11 UNC 2

At := 0.226.mn SS 13800.psi H:= At.SS H= 3118.8,1bf Thrust = 11384.099.lbf ND = 3.65 N=4 F = 2846.025.lbf Thrust Calculation Due to Separation Diameter Design Pressure Number of Set screws Size of Set Screws Holding Power of Set Screws Thrust due to separation Ts := (d2).7'*P 4

Number of Set Screws Required Ts NDs Ts Hs Force per Set Screw Ts Fs :=

Ns d:= 1.05.in p := 600.psi Ns:= 2

1. 10 x 24 UNC (Cup 1ip)

Hs:= 262.1bf Ts = 519.541 -bf NDs = 1.983 Fs = 259.77.1bf

I TEAM Industrial Services Sheet 6 of 7 REGISTRATION # F-003143 91511 EM Thrust and Bending Calculation - Hub Thrust Produced Moment Arm Total Width Number of Studs per Half Cavity Allowable Stress Thickness Provided (After Radius)

Joint Efficiency Force per Half Thrust Fs NNS Thrust= 11384.099-lbf X:= 3.375.in B:= OD B = 4.in NS:= 2 b := (IR-IntCA).2 Sagw = 18300.psi tp := 2.375.in E:= 1.0 b = 2.5.in Fs = 5692.049.lbf Thickness Required 6.Fs.X t:=

(B-b).E.(Sao,)

tr = 2.049-in tp =2.375-in Thrust and Bending Calculation - Flat Bar Thrust Produced Moment Arm Total Width Number of Studs Cavity Allowable Stress Thickness Provided (After Radius)

Joint Efficiency Force per Half Thrust Fs :

NS Thickness Required 6-Fs-X tr:-

Thrust = 11384.099-lbf X:= 3.9-in B:= 3.in NS = 2 b:= 0-in S~alow= 18300-psi tp:= 1.625.in E:= 1 Fs = 5692.049.1bf tr = 1.558-in tr=L55-i tp= 1.625-in

TEAM Industrial Services Sheet 7 of7 REGISTRATION # F-003143 91511EM Weight and Void Void Injection Valves NWV:= 2 InjVlv:= NIV.0.19.in3 InJVlv=O0.38-in 3 Cavity = 7.707-in 3 Line= 1.815 -M' 3

2 71 Cavity:= (2.5-in) (1.57.in)AI) 4 Line:= (1.5.in) 2-.(0.75.in) + (1.05.in)2'-4(0.5650.in) 4 4

Void := Cavity - Line + InjVlv Void= 6.272.in3 B.C.

Weig.ht (Clamp & Stronqback from SolidWorks Models)

Clamp:= 17.96.lb-2 allthread := 4.0.087 lb.-24-in + 8-0.11.1lb In Studse:= 4.0.087 lb-8.inn+

8.0.11.lb in lb Sealant := Void.1.35.0.043.l

.3 m

TnjValves := NIV.0.46-lb Strongback := 20.56.lb Weight:= Clamp + allthread + Sealant + InjValves + Strongback + Studs Clamp = 35.92.1b allthread = 9.232-lb Studs = 3.664.lb Sealant = 0.364.lb InjValves = 0.92.lb St'ongback = 20.56.lb Weight= 70.66.1b

Tim J LaHann (Generation - 4)

-om:

Thompson, Josh [Josh.Thompson@Teamlnc.com]

ant:

Sunday, April 29, 2012 9:59 AM To:

Tim J LaHann (Generation - 4)

Subject:

RE: KPS Leak Sealant Injection-Engineering Order 91511 Yes that is correct-Josh Thompson Field Supervisor TEAM Industrial Services Office (815)730-1801 Fax (815)730-1864 Cell (815)685-5046

--- Original Message-From: Tim J LaHann [mailto:tim.J.lahann@dom.coml Sent: Sun 4/29/2012 9:57 AM To: Thompson, Josh

Subject:

FW: KPS Leak Sealant Injection-Engineering Order 91511 Josh:

Per our conversation, the X-36 sealant is suitable for injection into a sealant enclosure at 140 Deg F.

"this is correct, please respond indicating your concurrence with this summary of our conversation.

Tim LaHann Kewaunee Power Station (920) 388-8705 From: Lagrange, Robert rmailto:Robert.Lagrange@Teamnnc.com]

Sent: Sunday, April 29, 2012 8:45 AM To: Tim I LaHann (Generation - 4)

Subject:

RE: KPS Leak Sealant Injection-Engineering Order 91511 Temp range is up to 400 degrees F and the cure time at 200F should be approximately 30 minutes and if you go up to 200 instead of 160 it will make no difference or change in our original work scope Robert LaGrange Operations Manager TEAM Industrial Services, Inc.

3462 Mound Rd.

Joliet, IL 60436 Office (815)730-1801 Fax (815)730-1864

' e*1 (815)693-9829 Robert.Lagrange@teaminc.eom<mailto;Robert.Lagrange@teaminc.com>

Safety First and Quality Always in Everything We Do

www.team-industralservices.com<htti)://www.tearn-industrialservices.com>

Sent by Good Messaging (www.good.com<http://www.good.com>)

--- Original Message---

From: Tim J LaHann [tim.j.lahann@don.com<mailto:tirml.lahann@dom.corn>]

Sent: Sunday, April 29, 2012 08:36 AM Central Standard Time To: Lagrange, Robert

Subject:

KPS Leak Sealant Injection-Engineering Order 91511 Robert:

Per our conversation:

The X-36 sealant specified for our application has a broad temperature range for application. It is a 2 part expoxy that is mixed and can be injected into sealant enclosures up to 250 Deg F.

The cure time, and therefore the setup time for the epoxy, is nearly instantaneous once injected.

Initially we provided TEAM with an estimated operating temperature of 160 Deg F. Increasing this operating temperature to 200 Deg F will have no affect on the performance of the X36 sealant.

If this is correct, please respond indicating your concurrence with this summary of our conversation.

Thank you.

Tim Laflann ewaunee Power Station

'20) 388-8705 This message and any attachments are intended only for the use of the addressee and may contain information that is privileged and confidential. If the reader of the message is not the intended recipient or an authorized representative of the intended recipient, you are hereby notified that any dissemination of this communication is strictly prohibited. If you have received this communication in error, notify the sender immediately by return email and delete the message and any attachments from your system.

CONFIDENTIALITY NOTICE: This electronic message contains information which may be legally confidential and/or privileged and does not in any case represent a firm ENERGY COMMODITY bid or offer relating thereto which binds the sender without an additional express written confirmation to that effect. The information is intended solely for the individual or entity named above and access by anyone else is unauthorized. If you are not the intended recipient, any disclosure, copying, distribution, or use of the contents of this information is prohibited and may be unlawful. If you have received this electronic transmission in error, please reply immediately to the sender that you have received the message in error, and delete it. Thank you.

2

From:

John P Schroeder (Generation -4)

Sent:

Sunday, April 29, 2012 11:29 PM To:

Lori A Christensen (Generation - 4)

Subject:

FW:

From: Thompson, Josh rmailto:Josh.Thompson@TeamInc.coml Sent: Sunday, April 29, 2012 8:34 PM To: John P Schroeder (Generation - 4)

Subject:

Strongback studs will be torqued to 75-90 ft lbs depending on compression of tubing seals Josh Thompson Field Supervisor TEAM Industrial Services Office (815)730-1801 Fax (815)730-1864 Cell (815)685-5046 This message and any attachments are intended only for the use of the addressee and may contain information that is privileged and confidential.

If the reader of the message is not the intended recipient or an authorized representative of the intended recipient, you are hereby notbied that an.

dissemination of this communication is strictly prohibitead Ifyou have received this communication in error, notify the sender immediately by return email and delete the message and any attachments from your system.

I

SeN.

I

.D~

V PE OID V vs Tt~

r

ýermzAUIhE PrEPEF-Rc.e Page 1 of 3

~'I J.wMCAIA*sA*4

(.

Reqfe-wel>

Evaluation of Pipe Clamp Assembly Components:

Prepared by:. Christopher M. Minton Date:

LSCI)z'012-Reviewed by: Vishwa M. Bhargava Date:

A !f2b Assumptions:

The pipe clamp assembly is sufficiently rigid, such that seismic loading is negllgble.

Therefore, the only loads for consideration are those due to the design pressure (600psi) and thermal.

DO :=1.05in Dp=0.824in t:= 0.113in Pds--- 600 ib

.2 m

(D1 2 O4j 5

I I Determine force due to pressure:

Fý_totaj

• Apipe-Pdes =

l201b Determine force due to thermal growth of vent line:

I ath :=- 0.0203 0.009--m ft ft LpipAd I0 1 i The temperature increase experienced by the clamp from the point of installation until its removal will be no more than 950F (From 150°F min to 2450F max)- Thermal expansion value is that for 250°F minus 150°F.

Eplate:29000000

.2 m

1 n3

.4 Tplatr = I-(0.5in) (1.75) 0.223-in Fth.--

--130Th (30in) 3 Assume simply supported beam, maximum shear load at midspan is the following:

Ftotal:= F t

+-

= 3 1b 2

2 Pipe Clamp Evaluation:

Pipe Clamps areFigure 295. Per Anvil Catalog. for 10 inch pipe:

Rating is 3240 lbs @ 650"F. OKAY 1I

Page 2 of 3 Evaluation of Weld at Coupling:

Weld is parallel weld, length 1.75", spaced 1/2" Consider moment arm of 15 -inches.

M1 := s5in-Ftta1 = 'l%7[in.lb F3 -= Ftotal =3 %Ib Assume an eccentric load acting on the structural steel, offset I inch:

M2:= Ftotal-in=325-in.lb Required weld size is determined to be o9.L3Mn (See Attached Spreadsheet)

Allowable weld size is based on the minimum of the following:

0.707 x 0.3 x 75ksi = t.S.qo psi (Electrode.ER -3

-)

0.4xSy = 0.4 x 30 ksl = 12 ksi (Base Metal Shear, Temp considered as 100'F) 0,3.1 in <0.4 3--T" in, OK Evaluation of Stainless Steel Plate Steel: Consider 1 00°F Temperature.

Sy.= 30000 Ib Y 2 (ASME B&PVC, 2004,Section II, Part D)

M A

Check Bending Stress:

.4 L 75in

-- lat= 0 2 2 3 M c:= -

=0.875.in 2

MI"--

iab lb 19

?%U Fb -O.66SY 19800-1pIate

. 2

.2

= v,17 OKAY Fb Check Shear Stress Avlate :- 1.75in.0.Sin = 0.875-.i2 lb Tf" 1,

• foc

=Apate h2 0.267 + 0.282 =0.274.

2 Ttorsion 2---

a-(I.75in) (05in) in l b Total -- 'rorsion + Tforc=.3 o

2 M

I&

(Formula from Design of Welded Structures, Blodgett)

Fv -= O.4Sy =12 000OIb m

2t~ta OKAY

'v il

WELD CALUMATIO: (Parallel Weld) h vv=

Between SS plate and SS coupling Page 3 of 3 I..-

u*

.I LOADS FROM:

[

STRUDL r-CALC START r-

-]

OTE~R M]BBR JOINT COORDINATE SYSTM:=[-] LOCAL(

Li GLOBAL MaedalTWh.dmsofrThicmPaitloine.d 0.500 in LOADING CASE:

=]

VELOPE L

i LOADING CONDMON V. 'KtflIT7Xrr0 A 'r eVJ'T A12 1Fr n

ý-OKC ý F, =

0 lbf F2=

0 Ibf F3 =

325 lbf F (ALOw4 =

21000 psi FY(3

,g =

30000 psi WELD PROPE1RTr

(TREATED AS A LD.I A=2a =

3.50 in Z7 = (a2

=

1.02 in2 J/C = Z + Z3(b/a) =

1.27 in2 M2=

325 in -Ib M3= 0 in -lbf WE.D SIZE PROVIDED: 0.4315 in a= 1.75 in b=

0.500 in Z,=a(b)=

0.88 in2 Y/C3=Z 1(a/b)+Z 3=

4.45 in2 F=[(

F2 A

+

M Z,

+

K

)

Z3

+

(

F1 A

+

M2

)2 I/Cl

+

F3 +

M 2

)2 1i2 A

1/ C3 F*[(

0 3.50

+

4-S-76' 1.02 S+0

(

0

+

3.

)2 0.88 3.50 1.27

+

(32A

+

321

)ZJ]/ 2 3.50 4.45 FORCEON WELD:

RE~O~l*R~FlWFlDTf IZE-F"=

43l v bf /*in (Base Metal Govern) FY (Base Metal) 4-33(X)D psi wm =

F 0.4 (FY (Base Metal))

.4 (

30000 )

=.

0.399~ in

< o-4315 ia CONCLUiSION:

USE OF _

INCH WELD IS ACEPTABLE.