ML23055A284

Proposed Alternative to the Requirements for Repair/Replacement of Saltwater (SW) System Buried Piping

ML23055A284
Person / Time
Site:	Calvert Cliffs
Issue date:	02/24/2023
From:	David Helker Constellation Energy Generation
To:	Office of Nuclear Reactor Regulation, Document Control Desk
Shared Package
ML23055A283	List: ML23055A284
References
Download: ML23055A284 (112)

Text

Enclosures 1, 4, 5, 6, 7, 8, and 9 contain Proprietary Information. Withhold from public disclosure under 10 CFR 2.390. Upon separation from Enclosures 1, 4, 5, 6, 7, 8, and 9, this document is decontrolled.

200 Exelon Way Kennett Square, PA 19348 www.exeloncorp.com PROPRIETARY INFORMATION - WITHHOLD UNDER 10 CFR 2.390 10 CFR 50.55a February 24, 2023 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001 Calvert Cliffs Nuclear Power Plant, Units 1 and 2 Renewed Facility Operating License Nos. DPR-53 and DPR-69 NRC Docket Nos. 50-317 and 50-318

Subject:

Proposed Alternative to the Requirements for Repair/Replacement of Saltwater (SW) System Buried Piping

Reference:

1) "Calvert Cliffs Nuclear Power Plant, Units 1 and 2 - Summary of January 10, 2022, Closed Meeting with Exelon Generation Company, LLC RE: Proposed Relief Request for Alternative Repair of Buried Saltwater Piping with Carbon Fiber Reinforced Polymer Composite System (EPID L-2021-LRM-0122)," dated March 22, 2022 (ML22066A001)

In accordance with the provisions of 10 CFR 50.55a(z)(1), Constellation Energy Generation, LLC, (CEG) requests approval to allow the use of the V-Wrap' Carbon Fiber Reinforced Polymer (CFRP) Composite System for the internal repair of the buried Saltwater (SW)

System piping at Calvert Cliffs Nuclear Power Plant (CCNPP), Units 1 and 2.

The subject SW System piping is experiencing degradation of the piping material.

American Society of Mechanical Engineers (ASME) Boiler & Pressure Vessel Code, "Rules for Inservice Inspection of Nuclear Power Plant Components,"Section XI, Paragraph IWA-4221(b) requires repair/replacement piping to meet the original Construction Code requirements for the SW System piping. The applicable Construction Code for the SW System piping does not provide the requirements for the design, fabrication, installation, examination, and testing of a CFRP composite system.

Accordingly, attached is a proposed alternative for review and approval.

CCNPP, Units 1 and 2 are presently in the 5th 10-year Inservice Inspection (ISI) interval.

Repair/replacement of the SW System piping with the V-Wrap' CFRP Composite System will provide an overall benefit to plant safety since a CFRP composite is more resistant to fouling and corrosion, while providing the requisite pressure boundary safety function and improving long-term system reliability. The proposed alternative is described in Enclosure 1.

Additional information in support of the requested alternative is provided in Enclosures 2 through 9.

Proposed Alternative to the Requirements for Repair/Replacement of Saltwater (SW) System Buried Piping February 24, 2023 Page 2 A pre-submittal teleconference (Reference 1) was held on January 10, 2022, in which CEG presented its plan for the use of a CFRP composite system to repair/replace existing SW System piping.

Enclosures 1, 4, 5, 6, 7, 8, and 9 contain proprietary information. Structural Group, Inc.

requests that this information be withheld from public disclosure in accordance with 10 CFR 2.390. An affidavit supporting this request is contained in Enclosure 10. Non-proprietary versions are contained in Enclosure 11.

There are no regulatory commitments contained in this letter.

CEG requests review and approval of this alternative request by February 24, 2024, to support the use of the proposed alternative for plant outage planning purposes.

If you have any questions, please contact Tom Loomis at Thomas.Loomis@constellation.com.

Respectfully, David P. Helker Senior Manager - Licensing Constellation Energy Generation, LLC

Enclosures:

1 through 11 Attached cc:

Regional Administrator, NRC Region I NRC Senior Resident Inspector NRC Project Manager S. Seaman, State of Maryland - Enclosures 2, 3, 10 and 11 Only

NON-PROPRIETARY VERSION Enclosure 1 Page 1 of 22 ENCLOSURE 1 Summary Constellation Energy Generation, LLC (CEG)

Calvert Cliffs Nuclear Power Plant (CCNPP), Units 1 and 2 Relief Request No. ISI-05-021 Request for Relief for a Proposed Alternative to ASME Boiler & Pressure Vessel Code Section XI Requirements for Repair/Replacement of Saltwater System Piping in Accordance with 10 CFR 50.55a(z)(1)

NON-PROPRIETARY VERSION Enclosure 1 Page 2 of 22 WITHHOLD FROM PUBLIC DISCLOSURE UNDER 10 CFR 2.390 contains information that is being withheld from public disclosure and is requested to be withheld because:

> It reveals the distinguishing aspects of a process (or component, structure, tool, method, etc.) whose use by any of the submitters competitors, without a license from the submitter, would constitute a competitive economic disadvantage to the submitter.

> Use by a competitor of the information requested to be withheld would reduce the competitors expenditure of resources, or improve its competitive position, in the design, manufacture, shipment, installation, assurance of quality, or licensing of a similar product.

> The information requested to be withheld reveals commercial strategies of the submitter or customers or suppliers.

> It reveals aspects of privately funded development plans or programs of commercial value to the submitter or owner of the information. 0 provides additional details regarding basis for withholding this proprietary information.

NON-PROPRIETARY VERSION Enclosure 1 Page 3 of 22 Constellation Energy Generation, LLC (CEG)

Calvert Cliffs Nuclear Power Plant (CCNPP), Units 1 and 2 ENCLOSURE 1 Summary of Proposed Alternative in Accordance with 10 CFR 50.55a(z)(1)

1.

Plant Site - Units Calvert Cliffs Nuclear Power Plant (CCNPP), Units 1 and 2.

2.

ISI Interval Dates The 5th 10-year interval of the CCNPP, Units 1 and 2, ISI program began on July 1, 2019 and is currently scheduled to end on June 30, 2029.

3.

Requested Date for Approval The requested date for approval is February 24, 2024.

4.

ASME Code B&PVC Components Affected a) Piping sections to be lined with the proposed V-Wrap' CFRP Composite System are further described in Enclosure 2 and are summarized below.

i) CCNPP Unit 1, Salt Water (SW) System Approximately 1,229 linear feet (LF) of safety-related, buried 30 and 36 inch diameter, cement mortar lined, bell and spigot ductile iron piping:

Line Designation Diameter (Inches)

Approximate Length (LF)

Supply 36-LC-2-1001 36 303 Supply 36-LC-2-1002 36 303 Supply 30-LC-2-1003 30 177 Supply 30-LC-2-1004 30 146 Supply 30-LC-2-1005 30 16 Supply 30-LC-2-1006 30 13 Return 30-LC-2-1008 30 271 ii) CCNPP Unit 2, Salt Water (SW) System

NON-PROPRIETARY VERSION Enclosure 1 Page 4 of 22 (1) Approximately 987 linear feet (LF) of safety-related, buried 30 and 36 inch diameter, cement mortar lined, bell and spigot, ductile iron piping:

Line Designation Diameter (Inches)

Approximate Length (LF)

Supply 36-LC-2-2001 36 295 Supply 36-LC-2-2002 36 299 Supply 30-LC-2-2003 30 165 Supply 30-LC-2-2004 30 143 Supply 30-LC-2-2005 30 18 Supply 30-LC-2-2006 30 16 Return 30-LC-2-2008 30 51 (iii) The original "Code of Construction" of the affected components is United States of America Standards (USAS) B31.1, 1967 Edition as supplemented by the requirements of American National Standards Institute (ANSI) A21.1-1967 / American Water Works Association (AWWA) C101-67 and ANSI A21.50-1976 (AWWA C150-1976).

(iv) The applicable American Society of Mechanical Engineers (ASME) Boiler & Pressure Vessel Code (B&PVC),Section XI ISI Class for this piping is ISI Class 3.

(v) Scope of work does not include any pumps, valves, expansion joints, or threaded connections.

(vi) Piping:

(1) Is below grade, buried and has long straight runs with minimal fittings.

(2) Is primarily bell and spigot conforming to American Society for Testing and Materials (ASTM) A-377, Standard Index of Specifications for Ductile-Iron Pressure Pipe /

American National Standards Institute (ANSI) A21.51, American National Standard for Ductile-Iron Pipe, Centrifugally Cast, for Water.

(3) Is cement mortar lined per ANSI A21.4, Cement-Mortar Lining for Ductile Iron Pipe and Fittings.

(4) Has an external coating.

(5) Does not have an Impressed Current Cathodic Protection (ICCP) system installed to mitigate corrosion.

(vii) Fittings are ductile cast iron conforming to ASTM A126, Class B, Standard Specification for Gray Iron Castings for Valves, Flanges, and Pipe Fittings / ANSI A21.10, American National Standard for Ductile-Iron and Gray-Iron Fittings for Water.

(viii) Mechanical joint piping underground have thrust blocks at each direction change.

NON-PROPRIETARY VERSION Enclosure 1 Page 5 of 22 The SW System moves Chesapeake Bay saltwater from the intake structure, through the system and back to the circulating water discharge conduits. SW System piping included in this request is safety-related and consists of two subsystems in each unit. Each subsystem provides saltwater to the Service Water heat exchangers, Component Cooling water heat exchangers and the Emergency Core Cooling System pump room air cooler to transfer heat from those systems to the Chesapeake Bay. Seal water for the circulating water pumps is supplied by both subsystems. A self-cleaning strainer is installed upstream of each Service Water heat exchanger.

5. Applicable ISI ASME B&PV Code Edition and Addenda For the 5th ISI interval at CCNPP, Units 1 and 2 the applicable code is ASME B&PVC,Section XI, "Rules for lnservice Inspection of Nuclear Power Plant Components", 2013 Edition, No Addenda.

6. Applicable ASME B&PV Code Requirement The ASME B&PVC requirement applicable to repairing piping isSection XI, Rules for In-Service Inspection of Nuclear Power Plant Components, Article IWA-4000, subparagraphs:

IWA-4220 - CODE APPLICABILITY - This section in part that an item to be used for repair/replacement activities shall meet the Owners requirements and Construction Code.

Additionally, this section requires reconciliation of the technical requirement of the Construction Code and Owners requirements.

IWA-4221(b) An item to be used for repair/replacement activities shall meet the Construction Code specified in accordance with (1), (2), or (3) below.

(1) When replacing an existing item, the new item shall meet the Construction Code to which the original item was constructed.

NOTE: IWA-4221(b) items (2) and (3) are not applicable.

IWA-4412 - Defect Removal states Defect removal shall be accomplished in accordance with the requirements of IWA-4420.

IWA-4340 - MITIGATION OF DEFECT BY MODIFICATION - states in part that the defect shall be characterized using non-destructive examination and evaluated to determine its cause and projected growth for the item in accordance with IWA-4220. This section also provides the requirements for successive examination of the modification.

IWA-4611.1(a) states Defect shall be removed in accordance with IWA-4422.1 A defect is considered removed when it had been reduced to an acceptable size.

IWA-5250(a)(3) states Components requiring corrective action shall have repair/replacement activities performed in accordance with IWA-4000 or corrective measures performed where the relevant condition can be corrected without repair/replacement activity.

NON-PROPRIETARY VERSION Enclosure 1 Page 6 of 22

7. Reason for Request

CCNPP is proactively evaluating repair options to improve system reliability, reduce outage requirements, and improve resource availability by using the V-Wrap' CFRP Composite System on the interior of the SW System piping. Once fully implemented, the CFRP composite system will take the place of the host pipe and resist all design loading without reliance on the host pipe.

The CCNPP SW System piping is internally inspected on a 4-year frequency. The condition of the cement mortar lining is generally found in good condition with patch repairs to mortar lining required to ensure continued reliability of the ductile iron piping beneath.

The external surfaces of the buried SW System piping cannot be inspected without excavation.

Installation of the V-Wrap' CFRP Composite System may include partial segment lengths which would continue a sufficient distance onto a structurally sound cast iron pipe surface at the terminal ends.

8. Proposed Alternative and Basis for Use

The use of the proposed V-Wrap' CFRP Composite System for the internal repair of buried pipe is a technology improvement which was not available in the 1960s or 1970s to meet the construction code to which original piping was constructed. There is currently no USNRC endorsed ASME B&PVC,Section XI Code Case for installing a CFRP composite system as a structural liner for piping during a repair/replacement activity.

Pursuant to 10 CFR 50.55a(z)(1), an alternative is proposed for the repair of the CCNPP, Units 1 and 2 SW System piping that provides an acceptable level of quality and safety. It is proposed that the SW System piping be repaired with the V-Wrap' CFRP Composite System produced by Structural Technologies, LLC. Enclosure 2 describes the proposed scope.

The V-Wrap' CFRP Composite System has been previously approved by the USNRC and installed on the interior of concrete encased, buried carbon steel piping for safety-related applications at the Surry Power Station in 2018 with the upgrade program continuing through 2024 (Reference letter to Virginia Electric & Power Company from USNRC, dated December 20, 2017, ML17303A068).

A similar application to install the V-Wrap' CFRP Composite System in the Emergency Cooling Water System piping at South Texas Project Electric Generating Station (STPEGS), Units 1 and 2 was submitted to the USNRC (Reference letter to USNRC from South Texas Project Nuclear Operating Company, dated September 26, 2019, ML19274C393). The USNRC has concluded that the licensee adequately addressed all regulatory requirements set forth in 10 CFR 50.55a(z)(1) and the proposed alternates provide an acceptable level of safety (Reference letter to South Texas Project Units 1 and 2 [G. T. Powell, President and CEO], from the USNRC [Jennifer L. Dixon-Herrity, Chief, Plant Licensing Branch], dated September 3, 2020, ML20227A385).

A similar application to install the V-Wrap' CFRP Composite System in the safety-related Essential Cooling Pond Supply piping at Entergy Arkansas Nuclear One, Units 1 and 2 was submitted to the USNRC (Reference letter from Entergy to USNRC, dated July 15, 2020, Document No.

0CAN072001, ML20218A672). The USNRC has concluded that the licensee adequately addressed all regulatory requirements set forth in 10 CFR 50.55a(z)(1) and the proposed alternates provide an acceptable level of safety (Reference letter to Entergy Operations, Inc. [ANO Site Vice President],

NON-PROPRIETARY VERSION Enclosure 1 Page 7 of 22 from the USNRC [Jennifer L. Dixon-Herrity, Chief, Plant Licensing Branch], dated September 30, 2021, ML21188A022).

A similar application to install the V-Wrap' CRP Composite System in SW System piping has been submitted for Brunswick Electric Steam Plant, Units 1 and 2 (Reference letter from Duke Energy Progress, LLC to USNRC, dated February 24, 2021, ML21055A797). The USNRC has concluded that the licensee adequately addressed all regulatory requirements set forth in 10 CFR 50.55a(z)(1) and the proposed alternates provide an acceptable level of safety (Reference letter to Duke Energy Progress, from the USNRC [David J. Wrona, Plant Licensing Branch II-2], December 20, 2021, ML21343A200).

Any repair/replacement and/or inspections of the V-Wrap' CFRP Composite System will be conducted in accordance with the applicable edition of ASME B&PVC,Section XI or alternative thereto, at the time of the repair/replacement or inspection.

The V-Wrap' CFRP Composite System is proposed to have a minimum 50-year service life.

Design, qualification, material manufacture, installation, testing, and inspection details of the proposed V-Wrap' CFRP Composite System are discussed in subsequent sections of this document in Enclosures 2 through 9. The proposed approach allows for the installation of the V-Wrap' CFRP Composite System for up to the complete length, or partial lengths of the SW System piping as described in Enclosure 2.

9. ((

NON-PROPRIETARY VERSION Enclosure 1 Page 8 of 22

))

10. Material Manufacturing The proposed V-Wrap' CFRP Composite System has been used extensively to repair and strengthen pipe systems and is comprised of high strength carbon fiber fabrics and glass fiber fabrics, fully saturated in a two-part 100% solids epoxy matrix. These laminates are bonded to the interior surface of the pipe forming a structural lining within the pipe. This lining can be designed for the degraded portions of the SW System piping without reliance on the degraded piping for the service life of the CFRP Composite System, except at the terminal ends of the repair.

V-Wrap' CFRP Composite System material components include:

V-Wrap' C400HM Carbon Fiber Fabric.

NON-PROPRIETARY VERSION Enclosure 1 Page 9 of 22 V-Wrap' 770 Epoxy (Components A & B).

V-Wrap' EG50B Glass Fiber Fabric.

Expansion Ring Assembly.

Cab-O-Sil TS-720 Fumed Silica Powder.

V-Wrap' CFRP Composite System epoxy components and fiber materials are manufactured as

((

))

Expansion ring assembly components include an elastomeric rubber gasket, expansion rings, shims, and wedges. ((

))

Material Verification & Control a) V-Wrap' CFRP Composite System epoxy and fabric materials ((

))

b) Products that have exceeded their shelf life/use by date shall not be used and shall immediately, upon discovery, be tagged to prevent usage.

c) All materials are stored in accordance with the written recommendations of the Manufacturer.

d) V-Wrap' 770 Epoxy component materials ((

NON-PROPRIETARY VERSION Enclosure 1 Page 10 of 22

))

provides additional information on the ((

))

11. Design To ensure the pipe continues to fulfill its design function over the design life the proposed V-Wrap' CFRP Composite System is ((

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, Attachment A provides the ((

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, Attachment B provides ((

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, Attachment C provides a ((

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, Attachment D provides ((

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, Attachment E provides a ((

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12. Installation The successful installation of the proposed V-Wrap' CFRP Composite System ((

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14.

((

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The V-Wrap' CFRP Composite System ((

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NON-PROPRIETARY VERSION Enclosure 1 Page 20 of 22

15. Preservice and Inservice Examinations Preservice inspection activities shall include:

a. System flow test per the ASME B&PVC,Section XI Code to verify the functional requirements of the SW System.

b. VT2 visual examination shall be conducted of the accessible external surfaces for evidence of leakage.

c. Inaccessible portions of piping not accessible for direct observation during leakage testing shall be inspected by the observation of areas surrounding the repair location, or ground surface areas above or adjacent to repairs on buried piping where accessible; or leakage collection systems, if available, shall be monitored. Minimum holding time at pressure prior to visual examination of accessible areas shall be 10 minutes, and of inaccessible areas shall be twenty-four hours.

Inservice inspection activities for the V-Wrap' CFRP Composite System installed per the proposed alternative to ASME Code material requirements, will include a system flow test in accordance with the ASME Section XI Code, to verify the functional requirements of the SW System piping. This proposed alternative will apply inservice inspection activities in accordance with ASME Section XI Code, subparagraphs IWA-5000, System Pressure Testing. This proposed inservice inspection, which directs the system pressure test for non-isolable buried components using ASME Section XI Code, IWA-5244(b)(2), shall consist of a test to confirm that flow during operation is not impaired. This system leakage tests will be performed for the remaining life of the plant in accordance with the CCNPP System Pressure Test Plan and ASME the Section XI Code requirements listed above.

Per the CCNPP, Units 1 and 2, Updated Final Safety Analysis Report (UFSAR), Section 16.2.2, Age-Related Degradation Inspection (ARDI) Aging Management Program (AMP) requires a variety of inspections on a sampling basis for the SW System. There are adequate tests and inspections in place through the period of extended operation to manage the effects of aging on the V-Wrap' CFRP Composite System in support of safe plant operation. Based on the results of the ARDI inspections required by the AMP, components of the SW System not meeting ARDI criteria will be addressed using the Preventive Maintenance (PM) AMP (UFSAR Section 16.2.23).

16. ((

NON-PROPRIETARY VERSION Enclosure 1 Page 21 of 22

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17. Summary of Enclosures Enclosures that are attached are listed below:

• Enclosure 2 - Scope and Schedule

• - Definitions and Acronyms o Attachment A - Definition of Terms o Attachment B - Acronyms

((

NON-PROPRIETARY VERSION Enclosure 1 Page 22 of 22

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• 0 - Applications for withholding proprietary Information from Public Disclosure

• 1 - Proposed Alternative to ASME Section XI Requirements for Repair/Replacement of Salt Water (SW) System Buried Piping in accordance with 10 CFR 50.55a(z)(1) (Non-Proprietary)

18. Duration of Proposed Alternative The V-Wrap' CFRP Composite System alternative will be proactively implemented as a contingency repair depending on the extent of degradation.

The V-Wrap' CFRP Composite System alternative is to remain in service for the life of the repair and any repair/replacement and/or inspections of the repaired piping will be conducted in accordance with the applicable edition of ASME B&PV Code,Section XI, Rules for In-Service Inspection of Nuclear Power Plant Components, or alternative thereto, at the time of the repair/replacement or inspection.

19. Precedents The proposed V-Wrap' CFRP Composite System has been installed on multiple projects at multiple Nuclear facilities with the same project team (Designer, Manufacturer, and Installer) on approximately 1,000 linear feet of safety-related Essential Cooling Water, Circulating Water and Service Water System carbon steel pipe including 30-inch, 42-inch, and 96-inch diameter piping.

These installations required multiple layers of V-Wrap' CFRP composite totaling over 110,000 square-feet (See Enclosure 9, Attachment A for additional operating experience information).

20. Conclusion 10 CFR 50.55a(z) states: Alternatives to codes and standards requirements. Alternatives to the requirements of paragraphs (b) through (h) of this section or portions thereof may be used when authorized by the Director, Office of Nuclear Reactor Regulation, or Director, Office of New Reactors, as appropriate. A proposed alternative must be submitted and authorized prior to implementation. The applicant or licensee must demonstrate that:

1. Acceptable level of quality and safety. The proposed alternative would provide an acceptable level of quality and safety; or (2) Hardship without a compensating increase in quality and safety. Compliance with the specified requirements of this section would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.

Based on foregoing discussion, CEG has determined that the conditions of 10 CFR 50.55a(z)(1) are met in that use of the proposed V-Wrap' CFRP Composite System as applied to the subject SW System piping provides an acceptable level of quality and safety.

Page 1 of 8 ENCLOSURE 2 Scope and Schedule Constellation Energy Generation, LLC (CEG)

Calvert Cliffs Nuclear Power Plant (CCNPP) Units 1 and 2 Relief Request Serial No. ISI-05-021 Request for Relief for a Proposed Alternative to ASME Boiler & Pressure Vessel Code Section XI Requirements for Repair/Replacement of Saltwater System Piping in Accordance with 10 CFR 50.55a(z)(1)

Page 2 of 8 Constellation Energy Generation, LLC (CEG)

Calvert Cliffs Nuclear Power Plant (CCNPP), Units 1 and 2 ENCLOSURE 2 Scope and Schedule TABLE OF CONTENTS, Attachment A: Scope and Schedule, Attachment B: CCNPP Unit No. 1 SW System Piping Layout

, Attachment C: CCNPP Unit No. 2 SW System Piping Layout Page 3 of 8 Constellation Energy Generation, LLC (CEG)

Calvert Cliffs Nuclear Power Plant (CCNPP), Units 1 and 2 ENCLOSURE 2 Attachment A - Scope and Schedule

1) Scope Calvert Cliff Nuclear Power Plant (CCNPP) is proactively requesting approval to use the proposed V-Wrap' CFRP Composite System as an internal upgrade to the Saltwater (SW)

System piping. Additional details depicting piping sections to be lined with the proposed V-Wrap' Carbon Fiber Reinforced Polymer (CFRP) Composite System, site layout, and directional changes are provided in Attachments B and C. The SW System piping at CCNPP Unit Nos. 1 and 2 consists of 30 and 36 inch diameter, ductile iron pipe conveying saltwater from Chesapeake Bay.

The piping to be lined is buried and not subject to 10CFR50.48c, National Fire Protection Association Standard NFPA 805, "Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants, 2001 edition requirements. As depicted in Attachments B and C the CFRP Composite System will terminate onto existing piping. Access to base material at terminal ends for future inservice inspections will be considered in the 10CFR50.59, Changes, Tests and Experiments process. These terminal end areas are accessible allowing for preservice and in-service inspections of the piping to be performed per ASME Section XI requirements. Fire protection considerations required by 10CFR50.48c, National Fire Protection Association Standard NFPA 805, "Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants, 2001 edition for piping inside of the buildings will be addressed as part of the 10CFR50.59 process.

2) General Information

a.

CCNPP Unit 1, Saltwater (SW) System

i.

Approximately 1,396 linear feet (LF) of safety related, buried 30 and 36 inch diameter, cement mortar lined, bell and spigot ductile iron pipe.

Line Designation Diameter (Inches)

Approximate Length (LF)

Maximum Temperature

(°F)

Normal Operating Temperature

(°F)

Supply 36-LC-2-1001 36 303 121 32 - 95 Supply 36-LC-2-1002 36 303 121 32 - 95 Supply 30-LC-2-1003 30 177 121 32 - 95 Supply 30-LC-2-1004 30 146 121 32 - 95 Supply 30-LC-2-1005 30 16 121 32 - 95 Supply 30-LC-2-1006 30 13 121 32 - 95 Return 30-LC-2-1008 30 271 121 32 - 95 Page 4 of 8

b. CCNPP Unit 2, SW System

i. Approximately 1,266 linear feet (LF) of safety related, buried 30 and 36 inch diameter, cement mortar lined, bell and spigot ductile iron pipe:

Line Designation Diameter (Inches)

Approximate Length (LF)

Maximum Temperature

(°F)

Normal Operating Temperature

(°F)

Supply 36-LC-2-2001 36 295 121 32 - 95 Supply 36-LC-2-2002 36 299 121 32 - 95 Supply 30-LC-2-2003 30 165 121 32 - 95 Supply 30-LC-2-2004 30 143 121 32 - 95 Supply 30-LC-2-2005 30 18 121 32 - 95 Supply 30-LC-2-2006 30 16 121 32 - 95 Return 30-LC-2-2008 30 51 121 32 - 95 Access points allowing for personnel entry and/or ventilation are depicted on Attachments B and C. Additional personnel access may be installed to enhance personnel safety and improve schedule performance.

Access 1: Personnel access into the piping within the Unit 1 Intake Structure at the West Wall location. Ventilation point can be set up in this location with compressors staged near outside wall with air-lines running through blind flanges.

Access 2: Unit 2 Intake Structure approximately 20 away from Unit 1, Access Area 1.

Access 3: Primary personnel access through Rams Head in Unit 1 Turbine Building (North End). Manholes in the floor can be used for ventilation.

Access 4: Access either through Service Water (SRW) Heat Exchange room or through the Radiological Controlled Area (RCA) as an alternate. SRW Heat Exchange room access is congested and has limited time to remain open.

Access 5: Ventilation only access point through manhole near low pressure feedwater heaters. Route provides access to discharge conduit.

NOTE: Additional Ventilation only access is provided through the Component Cooling Water (CCW) Heat Exchange room.

Access 6: Ventilation access near Turbine Building personnel elevator.

Access 7: Personnel access through Rams Head near Unit 2 Turbine Building personnel elevator.

Page 5 of 8 Access 8: Access either through Salt Water (SRW) Heat Exchanger room or through the Radiological Controlled Area (RCA) as an alternate. SRW Heat Exchanger room access is congested and has limited time to remain open.

NOTE: Ventilation access is provided through the Component Cooling Water (CCW)

Heat Exchange room.

ii.

The original Construction Code for Non-Nuclear Power piping at Calvert is the USAS B31.1 Nuclear Power Piping Code, 1967 Edition with the B31.1a (1971),

B31.1b (1971), B31.1c (1972), and B31.1d (1972) Addenda.

iii.

The applicable American Society of Mechanical Engineers (ASME) Boiler &

Pressure Vessel Code (B&PVC),Section XI ISI Class for this piping is ISI Class 3.

iv.

Scope of work does not include any pumps, valves, expansion joints, or threaded connections.

v.

Piping:

(1) Is below grade, buried and has long straight runs with minimal bends and elbows.

(2) Is ductile cast iron conforming to ASTM A377, Standard Index of Specifications for Ductile-Iron Pressure Pipe / ANSI A21.51, American National Standard for Ductile-Iron Pipe, Centrifugally Cast, for Water.

(3) Is cement mortar lined per ANSI A21.4, Cement-Mortar Lining for Ductile Iron Pipe and Fittings.

(4) Has typically been coated with Carboline or approved equal.

(5) Does not have an Impressed Current Cathodic Protection system installed to mitigate corrosion.

vi. Fittings are ductile cast iron conforming to ASTM A126, Class B, Standard Specification for Gray Iron Castings for Valves, Flanges, and Pipe Fittings / ANSI A21.10, American National Standard for Ductile-Iron and Gray-Iron Fittings for Water.

vii. Mechanical joint piping underground have thrust blocks at each direction change.

3) Function The SW System moves saltwater from the intake structure, through the system and back to the circulating water discharge conduits. SW System piping included in this request is safety-related and consists of two subsystems in each unit. Each subsystem provides saltwater to Service Water (SRW) heat exchangers, Component Cooling (CC) heat exchangers and the Emergency Core Cooling System (ECCS) pump room air cooler to transfer heat from those systems to the Chesapeake Bay. Seal water for the circulating water pumps is supplied by both subsystems. A self-cleaning strainer is installed upstream of each SRW heat exchanger.

Page 6 of 8

4) Schedule a) Installation of the V-Wrap' CFRP Composite System will be accomplished, as required, to support available refueling outage work windows, inspection results and may include partial segment lengths which would continue sufficient distance onto competent piping at the terminal ends.

b) For the 5th ISI interval at CCNPP Unit 1 ends in June 2029 the applicable code is ASME B&PVC,Section XI, "Rules for lnservice Inspection of Nuclear Power Plant Components", 2013 Edition, No Addenda.

c) For the 5th ISI interval at CCNPP Unit 2 ends in June 2029 the applicable code is ASME B&PVC,Section XI, "Rules for lnservice Inspection of Nuclear Power Plant Components", 2013 Edition, No Addenda.

Page 7 of 8 Attachment A - CCNPP Unit 1 SW System Piping Layout Page 8 of 8 Attachment B - CCNPP Unit No. 2 SW System Piping Layout Page 1 of 15 ENCLOSURE 3 Definitions and Acronyms Constellation Energy Generation, LLC (CEG)

Calvert Cliffs Nuclear Power Plant (CCNPP), Units 1 and 2 Relief Request Serial No. ISI-05-021 Request for Relief for a Proposed Alternative to ASME Boiler & Pressure Vessel Code Section XI Requirements for Repair/Replacement of Saltwater System Piping in Accordance with 10 CFR 50.55a(z)(1)

Page 2 of 15 Constellation Energy Generation, LLC (CEG)

Calvert Cliffs Nuclear Power Plant (CCNPP), Units 1 and 2 ENCLOSURE 3 Definition of Terms and Acronyms TABLE OF CONTENTS

Attachment A - Definition of Terms

Attachment B - Acronyms

Page 3 of 15 Constellation Energy Generation, LLC (CEG)

Calvert Cliffs Nuclear Power Plant (CCNPP), Units 1 and 2 ENCLOSURE 3 Attachment A - Definition of Terms Acceptance Test: A test or series of tests conducted to determine whether a material system or component conforms to the specified requirements.

Adhesive: A substance capable of holding materials together by surface attachment.

Amine Blush: Surface oiliness or "sweating" that occurs when epoxy is cured in a cool or high-humidity environment.

Approved Drawings - Project specific drawings that have been prepared and approved by the Design Authority.

Batch/Lot: A quantity of material produced in a single manufacturing run. (Also see Lot)

Batch/Lot Number: An identification number assigned to a particular quantity of material from a single manufacturer.

Blister: Void between the layers of the Carbon Fiber Reinforced Polymer (CFRP) system that contains fluid.

Bond Length: The length at the repair terminations over which the CFRP system is designed to remain bonded to the host pipe to transfer longitudinal forces and maintain watertightness at the ends of the CFRP system.

Bond Strength: The direct pull-off bond strength between the CFRP system and substrate obtained in accordance with ASTM D4541, Standard Test for Pull-Off Strength of Coatings Using a Portable Adhesion Tester.

Bubble: Void between the layers of the CFRP system that contains air.

Buckling: A limit state involving a sudden change in the geometry of the structure or structural elements thereof due to compressive forces exceeding stable equilibrium.

Carbon Fiber: A solid semi-crystalline organic material consisting on the atomic level of planar two-dimensional arrays of carbon atoms. Carbon fibers are used in CFRP renewal and strengthening in the form of unidirectional fabric.

Carbon Fiber Reinforced Polymer (CFRP) Composite System: is used to repair and strengthen piping. The CFRP system is comprised of high strength carbon fiber fabrics and/or glass fiber fabrics, fully saturated in a two-part 100% solids epoxy matrix. These laminates are bonded both longitudinally and circumferentially to the interior surface of the pipe forming a structural lining within the pipe.

Page 4 of 15 Characteristic Value: Statistically based property value representing the 80% lower confidence bound on the 5th-percentiIe value of a specified population, determined in accordance with ASTM D7290, Standard Practice for Evaluating Material Property Characteristic Values for Polymeric Composites for Civil Engineering Structural Applications.

Characteristic Strength: Characteristic value of strength calculated in accordance with ASTM D7290, Standard Practice for Evaluating Material Property Characteristic Values for Polymeric Composites for Civil Engineering Structural Applications using short-term laboratory test data.

Characteristic Modulus: Characteristic value of modulus of elasticity calculated in accordance with ASTM D7290, Standard Practice for Evaluating Material Property Characteristic Values for Polymeric Composites for Civil Engineering Structural Applications using short-term laboratory test data.

Characteristic Ultimate Strain: Characteristic strength divided by the Weibull mean modulus.

Circumferential Direction: Circumferential direction of the host pipe.

Compressive Failure: Failure by reaching compressive strength without buckling.

Constructor: The party that provides the work and materials for placement or installation.

Crazing: Micro-Cracking.

Creep: Time-dependent deformation under constant load.

Creep Rupture: Failure under a sustained load that is lower than the short-term strength.

Debondinq: Separation between the CFRP system and the pipe substrate.

Delamination: Inter-Ply separation.

Demand: Strain or stress created in the structure by the design loads.

Design Authority: NRC Authorized Licensee or Organization appointed by the Owner and under contract to be responsible for a design or modification of a design.

Design Strength: Nominal resistance in end-use condition, Rn, multiplied by resistance factor, time effect factor, and material adjustment factor Design Ultimate Strain: Characteristic ultimate strain reduced by applicable resistance factor, time effect factor, and material adjustment factor.

Dry Lay-Up: The process of saturation of reinforcing fabric with epoxy after the fabric has already been placed onto the host structure. The dry lay-up method is not permitted.

Durability: The ability to resist weathering action, chemical attack, abrasion, and other conditions of service.

Edge Lift: A gap located at the edge of the fabric.

Effective Factor of Safety: Ratio of the controlling load factor divided by the product of the resistance factor, time effect factor and material adjustment factor (Required Effective Factor of

Page 5 of 15 Safety); or product of the Required Effective Factor of Safety and the controlling strength/demand ratio (Actual Effective Factor of Safety), used in Load Resistance Factor Design (LRFD) based design approach.

End-Use Conditions: The chemical and load exposure conditions to which the structure is subjected to during its service.

Engineer of Record: The licensed professional engineer who is responsible for sealing the design documents related to CFRP renewal and strengthening.

End-Use Conditions: The chemical and load exposure conditions to which the structure is subjected to during its service.

Epoxy: The polymeric material used to bind together the reinforcing fibers in CFRP.

Expansion Ring Assembly: The expansion ring, shims and associated EPDM rubber strip which is expanded out onto the installed CFRP system.

Factor of Safety: Ratio of the short-term strength and allowable stress (Required Factor of Safety), or ratio of short-term strength to unfactored demand (Actual Factor of Safety), used in ASD-based design approach.

Factored Load: Product of design load and a load factor.

Factored Strain or Factored Stress: Strain or stress created in the structure by the design loads, multiplied by the applicable load factors.

Fatigue: Progressive development of damage, such as cracking, fretting and similar effects, resulting from repeated application of loads.

Fiber Orientation: Orientation or alignment of the longitudinal axis of the fiber with respect to a stated reference axis.

Field Leader: Includes Project Manager, Construction Manager, Superintendent, Field Engineer and Project Engineer.

Fillers: Substance added in the matrix or adhesive material to alter its engineering properties, performance, and/or cost.

Finish Layer: Provides an abrasion barrier and protection against chemicals, flow, debris, etc. Is typically a thickened epoxy, either with or without a pigment added to facilitate inspection. Is compatible with appropriate exposure conditions including moisture, saltwater, elevated temperature, abrasion, and chemical exposure.

Glass Transition Temperature (T): Midpoint of the temperature range at which the polymer matrix changes from a glassy to a rubbery state.

Gravity Load: Vertical loads, including earth load, pipe and fluid weights, surcharge, and surface live loads.

Hold Point: Steps within the installation procedure which requires inspector approval prior to proceeding.

Page 6 of 15 Intake Structure: Reinforced concrete Seismic Category 1 structure on the southeast corner of the plant.

Lamina: A layer of reinforcing fabric and epoxy.

Laminate Architecture: Construction of the laminate from laminae with different types and orientations of unidirectional carbon fiber fabrics and unidirectional and woven glass fabrics.

Limit State: A condition in which a structure or component thereof is judged either to be no longer useful for its intended function (serviceability limit state) or to have reached its ultimate load-carrying capacity (strength or stability limit states).

Load Combination: Combination of the effects of design loads based on the likelihood of their simultaneous occurrence and uncertainty in each load.

Load Duration (Time Effect): The period of continuous application of a load, or the cumulative period of intermittent applications of a load.

Load Factor: A factor that accounts for unavoidable deviations of the actual load from the nominal load and for uncertainties in the analysis that transforms the load into a load effect.

Load and Resistance Factor Design (LRFD): A method of proportioning structural components (members, connectors, connecting elements, and assemblages) such that the design strength equals or exceeds the required strength for all applicable limit states.

Longitudinal Direction: Longitudinal direction of the host pipe.

Lot: A quantity of material produced in a single manufacturing run (Also see Batch).

Lot Number: An identification number assigned to a quantity of material from a single manufacturer. (Also see Batch Number).

Long-Term Strength: Strength of CFRP under sustained load with duration equal to the service life of the structure.

Manufacturer: The party that manufactures, fabricates, produces, or supplies materials or products.

Material Adjustment Factor: Factors that define the resistance-in the end use condition in terms of laboratory strength values.

Material Organization: Material manufacturer or material suppliers of CFRP repair system components.

Matrix: The continuous constituent of a CFRP system that surrounds the fibers. It consists of 100 percent solids, VOC compliant, epoxy with fillers and additives.

Measurement and Testing Equipment (MTE) - Includes all devices or systems used to certify, measure, gauge, test, or inspect for acquiring data to verify conformance to specified requirements.

Misalignment: General or local deviation in the orientation of CFRP or GFRP layers from their design orientation.

Page 7 of 15 Nominal Loads: The loads and load combinations specified for the design.

Nominal Strength or Nominal Resistance: The strength of a structure or component in the end-use conditions (without resistance factor or time-effect factors applied).

Non-Structural Layers: Dielectric Barrier is used to avoid galvanic corrosion of metallic materials in proximity to carbon fibers. A dielectric barrier layer shall be used for isolation of a metallic material from the CFRP laminate. Dielectric barrier includes a layer of glass fiber, saturating epoxy and thickened epoxy. All materials shall be compatible with the epoxy used to saturate the carbon fibers.

Ovality: Deviation of the host pipe geometry from the original circular shape, calculated as the pipe deflection divided by the original diameter.

Overlap Separation: Unacceptable separation between fabric sheets; typically resulting from insufficient overlap.

Overlap Length: The design shall provide a minimum overlap in the direction of the fibers of 12 in., but not less than the manufacturers recommended development length as established through testing in accordance with ASTM D7616.

Performance Standard: Stipulated minimum performance threshold(s), requirement(s), or expectation(s) that must be met by a manufactured structure to be appraised at a level of performance. It can be based on tests that approximate the end-use conditions.

Pot Life: Time interval, after mixing of epoxy, during which the mixture can be applied without degrading the performance of the resulting CFRP composite system beyond specified limits.

Pre-Cured Laminates: Composite materials in which the reinforcing fabric has been saturated with epoxy and cured off-site. The use of pre-cured laminates is not permitted.

Primers: Are mixed according to the recommended procedure. Primer has sufficiently low viscosity and surface tension to thoroughly wet and coat the pipe surface and provide sufficient adhesion to accommodate design loads between the host pipe and the thickened epoxy or saturating epoxy.

Purchaser: The person, company, or organization that purchases any materials or work to be performed.

Reference Strength: Strength calculated based on the characteristic material properties obtained from short-term laboratory tests.

Relaxation: Time-dependent reduction in stress under a constant strain.

Reliability: Probability that a system will perform its intended function for a specific period under a given set of conditions.

Reliability Index: A parameter in reliability analysis that is correlated to probability of failure.

Required Strength: The load effect or structural action (force, moment, or stress) acting on a structural system, member, or connection, as determined by structural analysis from the factored loads, considered in appropriate combinations.

Page 8 of 15 Resistance: Generic term describing the capacity of a structure, component, or connection to withstand the effects of load; determined from specified material strengths, stiffness, dimensions, and formulas derived from accepted principles of structural mechanics or by field or from laboratory tests of scaled models, allowing for modeling effects and differences between laboratory and field conditions.

Resistance Factor: A factor that accounts for unavoidable deviations and variability of the actual strength from the nominal end-use value and for the manner and consequences of failure.

Restraining Components (e.g., Pipe supports): Components that are not functionally safety related, but that are required to be seismically restrained, supported or anchored to prevent damage to nearby safety related equipment.

Roving: Large number of continuous parallel filaments or a group of untwisted parallel strands.

Rupture: Failure in tension through breakage of fibers.

Safety Related: Plant systems, portions of systems, structures and equipment whose failure could result in a release of radioactivity that could endanger public safety, or whose purpose is to mitigate the effect of such failure, or required for safe operation, shutdown, and removal of residual heat Shear Bond Strength: Strength of the bond in shear between the CFRP system and the host pipe as determined by laboratory testing according to ASTM D7616.

Shear Bond Failure: Shear failure of the bond between CFRP system and substrate at the repair terminations.

Shelf-Life: Indicator of the raw materials life in their unmixed, uninstalled life. Prior to mixing, the materials are in an unstable condition that limits their shelf life Service Life: Indication of the anticipated duration of the "in-service" life following mixing of epoxies, saturation of fabric and installation.

Short-Term Strength: Strength of CFRP laminate under loads applied at the loading rate equal to that specified by the relevant ASTM Standard.

Stress Range: Magnitude of change in stress due to the repeated application and removal of service loads, used in checking susceptibility to fatigue.

Page 9 of 15 Subject Matter Expert (SME) - Person who is an authority with special knowledge in an area or topic.

Surface Imperfections - Imperfections on the adhesion surface which include mill scale, rust, loose coating materials, weld with sharp edges, weld splatter/slag, plate lamination, sharp edges, manual weld irregularities, undercut, and gas cut surfaces.

Surface Preparation - To ensure that salt, oil, grease, rust, and other contaminants are removed, and the surface is ready to accept CFRP system installation and provide a mechanical bond where required.

System Pressure Boundary: The function of mechanical components (e.g., valves, piping, pumps, tanks, accumulators, ducting, dampers, etc.) used to maintain system integrity and avoid system leakage. Ensures nuclear safety functions provided by other safety systems or equipment.

Tack Free: The attainment of a sufficiently robust state to resist damage by contact or handling.

Thickening Agents: Are mixed with the epoxy according to the recommended procedure to form a thickened epoxy. Thickened epoxy can be used as a primer or over a primer to provide a smooth surface for the application of the CFRP laminate.

Time-Effect Factor: The ratio of the creep rupture strength of laminate subjected to sustained load to the strength under short-term loading.

Toughness: Toughness (area under stress-strain curve or moment rotation curve) is the ability to absorb energy and can be quantified by computing the work done per unit mass of material.

Tow: Twisted bundle of continuous carbon fibers.

Unfactored Strain or Unfactored Stress: Strain or stress created in the structure by the nominal design loads.

V-Wrap 770 Epoxy' - Two-part epoxy adhesive for high strength composite bonding.

V-Wrap C400HM': Unidirectional high strength carbon fiber fabric.

V-Wrap' Carbon Fiber Anchors: Two-part epoxy adhesive and unidirectional high strength carbon fabric.

V-Wrap' Carbon Fiber Rods: Pre-manufactured composite carbon/resin rods.

V-Wrap' CFRP Composite System: Structural strengthening system for the restoration of damaged/weakened pressure pipe.

V-Wrap EG50B': Custom bi-directional high strength glass fiber fabric.

Watertightness: Prevention of water or other fluids from one side to the other side of a barrier.

Watertightness Layer: Layer Of bidirectional glass fiber reinforced polymer embedded in the CFRP repair system.

Waviness: Deviation from the best-fit oval shape of the host pipe or the CFRP repair system, measured as the radial offset on the substrate.

Page 10 of 15 Weibull Distribution: A probability distribution function used in evaluation of strength and life data.

Wet Lay-Up: The process of on-site saturation of the reinforcement fabric with epoxy followed by application of the saturated fabric to the host structure to cure in-place.

Wet surface: A surface that depicts visible moisture on a tissue that is held to the surface of the pipe for a minimum of 30 seconds.

Wrinkle: Localized misalignment and raised surface of the primary fiber direction.

Page 11 of 15 Constellation Energy Generation, LLC (CEG)

Calvert Cliffs Nuclear Power Plant (CCNPP), Units 1 and 2 ENCLOSURE 3 Attachment B - Acronyms ANII: Authorized Nuclear In-Service Inspector ANSI: American National Standards Institute AS: Aerospace Standards ASD: Allowable Stress Design ASME: American Society of Mechanical Engineers ASTM: American Society of Testing and Materials AWWA: American Water Works Association B&PVC: Boiler and Pressure Vessel Code CAR: Corrective Action Request/Report CBT: Computer Based Training CFR: Code of Federal Regulations CFRP: Carbon Fiber Reinforced Polymer CLCI CLC2 CLC3 CLC4: Circumferential Load Combinations COC: Certification of Conformance/Compliance CPS: Centipoise CR: Condition Report CMTR: Certified Material Test Report DSC: Differential Scanning Calorimetry DSR: Demand Strength Ratio

Page 12 of 15 EPDM: Ethylene-Propylene Diene Monomer O F: Degrees Fahrenheit FFD: Fitness for Duty FRP: Fiber Reinforced Polymer FEA: Finite Element Analysis FME: Foreign Material Exclusion FMEA: Failure Mode and Effects Analysis Ft: Feet GFRP: Glass Fiber Reinforced Polymer IAS: International Accreditation Service In: Inches ISI: Inservice Inspection ISO: International Organization for Standardization JSHA: Job Safety Hazard Analysis KSI: Kips per Square Inch LLC: Limited Liability Corporation LLCI LLC2 LLC3 LLC4: Longitudinal Load Combinations LOCA: Loss of Coolant Accident LOOP: Loss of Offsite Power LRFD: Load and Resistance Factor Design LS: Limit State

Page 13 of 15 MTE: Measuring & Test Equipment NACE: National Association of Corrosion Engineers NCR: Nonconformance Report NDE: Non-Destructive Examination NEI: Nuclear Energy Institute NIST: (USA) National Institute of Standards Technology NRC: Nuclear Regulatory Commission NQA: Nuclear Quality Assurance NSF: National Science Foundation OBE: Operating Basis Earthquake QC: Quality Control OE: Operating Experience OSHA: Occupational Safety and Health Administration Oz: Ounces PCCP: Prestressed Concrete Cylinder Pipe PFD: Process Flow Diagram PQP: Project Quality Plan PWR: Pressurized Water Reactor PSI: Pounds per square inch PSF: Pounds per square foot QAP: Quality Assurance Program

Page 14 of 15 RCA: Radiologically Controlled Area REST: Components being restrained RH: Relative Humidity SAR: Safety Analysis Report SCWE: Safety Conscious Work Environment SSE: Safe Shutdown Earthquake SDR: Strength Demand Ratio SGH: Simpson Gumpertz & Heger SOP: Standard Operating Procedure S-R: Safety Related SS: Stainless Steel SSE: Safe Shutdown Earthquake STRU: Provide Structural Integrity SIF: Stress Intensification Factor SSPC: Society for Protective Coatings SW: Salt Water SWR: Service Water SYPB: System Pressure Boundary U: Unit UA: Unescorted Access UHS: Ultimate Heat Sink

Page 15 of 15 UT: Ultrasonic Testing USAS: United States of America Standards WRF: Water Research Foundation Yd: Yard

ISI-05-021 Docket Nos. 50-317/50-318 0 Page 1 of 8 ENCLOSURE 10 Withholding of Proprietary Information Affidavit Constellation Energy Generation, LLC (CEG)

Calvert Cliffs Nuclear Power Plant (CCNPP), Unit Nos. 1 and 2 Relief Request Serial No. ISI-05-021 Request for Relief for a Proposed Alternative to ASME Boiler & Pressure Vessel Code Section XI Requirements for Repair/Replacement of Saltwater System Piping in Accordance with 10 CFR 50.55a(z)(1)

ISI-05-021 Docket Nos. 50-317/50-318 0 Page 2 of 8 ENCLOSURE 10 STRUCTURAL GROUP, INC.

"APPLICATION FOR WITHHOLDING PROPRIETARY INFORMATION FROM PUBLIC DISCLOSURE"

[Document Begins on Next Page]

ISI-05-021 Docket Nos. 50-317/50-318 0 Page 3 of 8 U. S. Nuclear Regulatory Commission Document Control Desk 11555 Rockville Pike Rockville, MD 20852 RE: Application for Withholding Proprietary Information from Public Disclosure Ladies and Gentlemen:

Structural Group, Inc. (SGI), has provided certain proprietary information for Calvert Cliffs Nuclear Power Plant (CCNPP) Units 1 and 2 in connection with a request by Constellation Energy Generation, LLC (CEG) for authorization from the U. S. Nuclear Regulatory Commission (USNRC) to use an alternative to the requirements of American Society of Mechanical Engineers (ASME), Boiler & Pressure Vessel Code,Section XI, IWA-4221(b), pursuant to 10 CFR 50.55a(z)(1). This application requests that SGI proprietary information be protected from public disclosure. The proprietary information for which withholding is being requested in Reference 1 is further identified in the attached affidavit signed by the owner of the proprietary information, SGI, on behalf of itself and any wholly-owned subsidiaries or affiliated companies.

An affidavit accompanies this letter, setting forth the basis on which the information may be withheld from public disclosure by the USNRC and addressing with specificity the considerations listed in paragraph (b)(4) of 10 CFR 2.390 (Reference 5) of the USNRC regulations.

A request for withholding proprietary information has been previously approved by the USNRC for the Surry Nuclear Station (Reference 2), South Texas Project (Reference 3), Arkansas Nuclear One (Reference 4), and Brunswick Steam Electric Plant (Reference 5). Accordingly, this letter authorizes the utilization of the accompanying Affidavit by Constellation Energy Generation, LLC. Correspondence with respect to the proprietary aspects of the Application or the Affidavit should reference this letter and be addressed to Scott Greenhaus, Executive Vice President, Structural Group, Inc., 10150 Old Columbia Road, Columbia, MD 21046.

Very truly yours, Scott Greenhaus, Executive Vice President

ISI-05-021 Docket Nos. 50-317/50-318 0 Page 4 of 8

REFERENCES:

1.

Letter to the USNRC from Calvert Cliffs Nuclear Power Plant (CCNPP), Proposed Alternative to the Requirements for Repair/Replacement of Saltwater (SW) System Buried Piping, Dockets 50-317 and 50-318, ISI-05-021.

2.

Letter to Virginia Electric & Power Company (Daniel Stoddard, Senior Vice President and Chief Nuclear Officer), from USNRC (Michael T. Markley, Chief Plant Licensing Branch II-1), dated December 20, 2017, Surry Power Station, Unit Nos. 1 and 2 - Relief from the Requirements of the ASME Code (CAC Nos. MF8987 and MF8988; EPID L-2016-LLR-0019), Dockets 50-280 and 50-281, ML17303A068.

3.

Letter to STP Nuclear Operating Company (G. T. Powell, President and Chief Executive Officer) from USNRC (Jennifer L. Dixon-Herrity, Chief Plant Licensing Branch IV), South Texas Project, dated September 26, 2019, Units 1 and 2 - Proposed Alternative RR-ENG-3-24 to ASME Code Requirements for the Repair of Essential Cooling Water System Class 3 Buried Piping (EPID L-2019-LLR-0096), Dockets 50-948 and 50-499, ML20227A383 (Proprietary), ML20227A385 (Nonproprietary).

4.

Letter to Entergy Operations, Inc. (ANO Site Vice President) from USNRC (Jennifer L.

Dixon, Chief Plant Licensing Branch IV), dated September 30, 2021, "Arkansas Nuclear One, Units 1 and 2 - Approval of Request for Alternate from Certain Requirements of the American Society of Mechanical Engineers Boiler & Pressure Vessel Code (EPID L-2020-LLR-0014), Dockets 50-313 and 50-368, ML21265A255 (Proprietary),

ML21188A022 (Nonproprietary).

5.

Letter to Duke Energy Progress, LLC (John A. Krakuszeski, Site Vice President) from USNRC (David J. Wrona, Chief, Plant Licensing Branch), dated December 20, 2021, "Brunswick Steam Electric Plants, Units 1 and 2 - Authorization and Safety Evaluation for Alternate from Certain Requirements of the American Society of Mechanical Engineers Boiler & Pressure Vessel Code of Buried Service Water Piping (EPID L-2021-LLR-0014), Dockets 50-324 and 50-354, ML21343A197 (Proprietary), ML21343A200 (Nonproprietary).

6.

10 CFR 2.390, "Public Inspections, Exemptions, Requests for Withholding."

ISI-05-021 Docket Nos. 50-317/50-318 0 Page 5 of 8 Structural Group, Inc.

10150 Old Columbia Road Columbia, MD 21046

ISI-05-021 0 Page 6 of 8 I, Scott Greenhaus, am Executive Vice President of Structural Group, Inc. (SGI). In my capacity as Executive Vice President have been specifically delegated the function of reviewing the proprietary information sought to be withheld from public disclosure in conjunction with nuclear plant licensing and rulemaking proceedings and am authorized to apply for its withholding on behalf of SGI, any wholly-owned subsidiaries or affiliated companies.

I am making this Affidavit in conformance with the provisions of 10 CFR 2.390 of the U. S.

Nuclear Regulatory Commission (USNRC) regulations and in conjunction with SGIs Application for Withholding Proprietary Information from Public Disclosure accompanying this Affidavit.

I have personal knowledge of the criteria and procedures utilized by SGI in designating information as a trade secret, privileged or as confidential commercial or financial information.

Pursuant to the provisions of paragraph (b)(4) of 10 CFR 2.390 of the USNRC regulations, the following is furnished for consideration by the USNRC in determining whether the information sought to be withheld from public disclosure should be withheld.

The information sought to be withheld from public disclosure is owned by and has been held in confidence by SGI. Specific portions of the Constellation Energy Generation, LLC request which include SGI proprietary information are Enclosure 1, Sections 9, 10, 11, 12, 13, 14, 16, and 17, Enclosure 4, Enclosure 5, Enclosure 6, Enclosure 7, Enclosure 8 and Enclosure 9.

The information is of a type customarily held in confidence by SGI and not disclosed to the public. SGI has a rational basis for determining the types of information customarily held in confidence by it and utilizes a system to determine when and whether to hold certain types of information in confidence. The application of that system and the substance of that system provides a rational basis for maintaining confidentiality and justifies the USNRC withholding the information from public disclosure.

Under SGIs system information is held in confidence if it falls in one or more of several types, the release of which might result in the loss of an existing or potential competitive advantage, as follows:

1.

The information reveals the distinguishing aspects of a process (or component, structure, tool, method, etc.) where prevention of its use by a competitor of SGI without license constitutes a competitive advantage over other companies.

2.

It consists of supporting data, including test data, relative to a process (or component, structure, tool, method, etc.), the application of which data secures a competitive economic advantage, e.g., by optimization or improved marketability.

3.

Its use by a competitor would reduce their expenditure of resources or improve their competitive position in the design, manufacture, shipment, installation, assurance of quality, or licensing a similar product.

4.

It reveals cost or price information, production capacities, budget levels, or commercial strategies of SGI, their customers, or suppliers.

5.

It reveals aspects of past, present, or future development plans funded by SGI or its customer, and programs of potential commercial value to SGI.

ISI-05-021 0 Page 7 of 8

6.

lt contains patentable ideas, for which patent protection may be desirable.

There are sound policy reasons behind the SGI system which include the following:

1.

The use of such information by SGI gives it a competitive advantage over competitors. It is, therefore, withheld from disclosure to protect SGI's competitive position.

2.

It is information that is marketable in many ways. The extent to which such information is available to competitors diminishes SGIs ability to sell products and services involving the use of the information.

3.

Use by a competitor would put SGI at a competitive disadvantage by reducing the competitor's expenditure of resources and capital.

4.

Each component of proprietary information pertinent to a particular competitive advantage is potentially as valuable as the total competitive advantage. If competitors acquire components of proprietary information, any one component may be the key to the entire process, thereby depriving SGI of its competitive advantage.

5.

Unrestricted disclosure would jeopardize the position of prominence of SGI in the world marketplace, and thereby give a market advantage to competitor in those countries in which SGI operates.

6.

SGIs capacity to invest corporate assets in research and development depends upon the success in obtaining and maintaining a competitive advantage.

The information is being transmitted to the USNRC in confidence and, under the provisions of 10 CFR 2.390, it is to be received in confidence by the USNRC. The information sought to be protected is not available in public sources and, to the best of our knowledge and belief, available information has not been previously employed in the same original manner or method.

The proprietary information sought to be withheld in this submittal is that which is appropriately marked in the Document No. ISI-05-021 to the USNRC from the Calvert Cliffs Nuclear Power Plant (CCNPP), Proposed Alternative to the Requirements for Repair/Replacement of Saltwater (SW) System Buried Piping and reflected in SGI's Application for Withholding Proprietary Information from Public Disclosure addressed to the USNRC Document Control Desk. The proprietary information as submitted by SGI associated with the Proposed Alternative to the Requirements for Repair/Replacement of Saltwater (SW) System Buried Piping may be used only for that purpose.

This information is part of that which will enable Document No. ISI-05-021 to provide input and licensing support to Constellation Energy Generation, LLC. to provide to the USNRC for review of the CCNPP, Unit Nos. 1 and 2, 10CFR50.46 submittal. SGI owns or is permitted to use the proprietary information referenced in this Affidavit under agreements that include Constellation Energy Genaration, LLC maintaining the confidentiality of such information, as contemplated in this Affidavit.

Further this information has substantial commercial value as follows:

ISI-05-021 0 Page 8 of 8

1.

The SGI plan to sell the use of this information to their customers for the purpose of installing the V-Wrap' Carbon Fiber Reinforced Polymer (CFRP) Composite System in safety related piping.

2.

That SGI can self-support and defense of the technology to their customers in the licensing process.

3.

The information requested to be withheld reveals the distinguishing aspects of a methodology which was developed by SGI.

4.

Public disclosure of this proprietary information is likely to cause substantial harm to the competitive position of SGI because it would enhance the ability of competitors to provide similar licensing services for commercial power reactors without commensurate expenses.

5.

Public disclosure of the information would enable others to use the information to meet USNRC requirements for licensing documentation without purchasing the right to use the information.

6.

The development of the technology described in part by the proprietary information is the result of applying the results of many years of experience in an intensive effort by SGI and the expenditure of a considerable sum of money and resources. In order for competitors to duplicate this information, similar technical programs would have to be performed including a significant expenditure money and resources.

Further the deponent sayeth not.

NON-PROPRIETARY INFORMATION Enclosure 11 Page 1 of 57 ENCLOSURE 11 Non-Proprietary Version Constellation Energy Generation, LLC (CEG)

Calvert Cliffs Nuclear Power Plant (CCNPP), Units 1 and 2 Relief Request No. ISI-05-021 Request for Relief for a Proposed Alternative to ASME Boiler & Pressure Vessel Code Section XI Requirements for Repair/Replacement of Saltwater System Piping in Accordance with 10 CFR 50.55a(z)(1)

NON-PROPRIETARY INFORMATION Enclosure 11 Page 2 of 57 ENCLOSURE 1 Summary Constellation Energy Generation, LLC (CEG)

Calvert Cliffs Nuclear Power Plant (CCNPP), Units 1 and 2 Relief Request No. ISI-05-021 Request for Relief for a Proposed Alternative to ASME Boiler & Pressure Vessel Code Section XI Requirements for Repair/Replacement of Saltwater System Piping in Accordance with 10 CFR 50.55a(z)(1)

NON-PROPRIETARY INFORMATION Enclosure 11 Page 3 of 57 WITHHOLD FROM PUBLIC DISCLOSURE UNDER 10 CFR 2.390 contains information that is being withheld from public disclosure and is requested to be withheld because:

> It reveals the distinguishing aspects of a process (or component, structure, tool, method, etc.) whose use by any of the submitters competitors, without a license from the submitter, would constitute a competitive economic disadvantage to the submitter.

> Use by a competitor of the information requested to be withheld would reduce the competitors expenditure of resources, or improve its competitive position, in the design, manufacture, shipment, installation, assurance of quality, or licensing of a similar product.

> The information requested to be withheld reveals commercial strategies of the submitter or customers or suppliers.

> It reveals aspects of privately funded development plans or programs of commercial value to the submitter or owner of the information. 0 provides additional details regarding basis for withholding this proprietary information.

NON-PROPRIETARY INFORMATION Enclosure 11 Page 4 of 57 Constellation Energy Generation, LLC (CEG)

Calvert Cliffs Nuclear Power Plant (CCNPP), Units 1 and 2 ENCLOSURE 1 Summary of Proposed Alternative in Accordance with 10 CFR 50.55a(z)(1)

1.

Plant Site - Units Calvert Cliffs Nuclear Power Plant (CCNPP), Units 1 and 2.

2.

ISI Interval Dates The 5th 10-year interval of the CCNPP, Units 1 and 2, ISI program began on July 1, 2019 and is currently scheduled to end on June 30, 2029.

3.

Requested Date for Approval The requested date for approval is February 24, 2024.

4.

ASME Code B&PVC Components Affected a) Piping sections to be lined with the proposed V-Wrap' CFRP Composite System are further described in Enclosure 2 and are summarized below.

i) CCNPP Unit 1, Salt Water (SW) System Approximately 1,229 linear feet (LF) of safety-related, buried 30 and 36 inch diameter, cement mortar lined, bell and spigot ductile iron piping:

Line Designation Diameter (Inches)

Approximate Length (LF)

Supply 36-LC-2-1001 36 303 Supply 36-LC-2-1002 36 303 Supply 30-LC-2-1003 30 177 Supply 30-LC-2-1004 30 146 Supply 30-LC-2-1005 30 16 Supply 30-LC-2-1006 30 13 Return 30-LC-2-1008 30 271 ii) CCNPP Unit 2, Salt Water (SW) System (1) Approximately 987 linear feet (LF) of safety-related, buried 30 and 36 inch diameter, cement mortar lined, bell and spigot, ductile iron piping:

NON-PROPRIETARY INFORMATION Enclosure 11 Page 5 of 57 Line Designation Diameter (Inches)

Approximate Length (LF)

Supply 36-LC-2-2001 36 295 Supply 36-LC-2-2002 36 299 Supply 30-LC-2-2003 30 165 Supply 30-LC-2-2004 30 143 Supply 30-LC-2-2005 30 18 Supply 30-LC-2-2006 30 16 Return 30-LC-2-2008 30 51 (iii) The original "Code of Construction" of the affected components is United States of America Standards (USAS) B31.1, 1967 Edition as supplemented by the requirements of American National Standards Institute (ANSI) A21.1-1967 / American Water Works Association (AWWA) C101-67 and ANSI A21.50-1976 (AWWA C150-1976).

(iv) The applicable American Society of Mechanical Engineers (ASME) Boiler & Pressure Vessel Code (B&PVC),Section XI ISI Class for this piping is ISI Class 3.

(v) Scope of work does not include any pumps, valves, expansion joints, or threaded connections.

(vi) Piping:

(1) Is below grade, buried and has long straight runs with minimal fittings.

(2) Is primarily bell and spigot conforming to American Society for Testing and Materials (ASTM) A-377, Standard Index of Specifications for Ductile-Iron Pressure Pipe /

American National Standards Institute (ANSI) A21.51, American National Standard for Ductile-Iron Pipe, Centrifugally Cast, for Water.

(3) Is cement mortar lined per ANSI A21.4, Cement-Mortar Lining for Ductile Iron Pipe and Fittings.

(4) Has an external coating.

(5) Does not have an Impressed Current Cathodic Protection (ICCP) system installed to mitigate corrosion.

(vii) Fittings are ductile cast iron conforming to ASTM A126, Class B, Standard Specification for Gray Iron Castings for Valves, Flanges, and Pipe Fittings / ANSI A21.10, American National Standard for Ductile-Iron and Gray-Iron Fittings for Water.

(viii) Mechanical joint piping underground have thrust blocks at each direction change.

NON-PROPRIETARY INFORMATION Enclosure 11 Page 6 of 57 The SW System moves Chesapeake Bay saltwater from the intake structure, through the system and back to the circulating water discharge conduits. SW System piping included in this request is safety-related and consists of two subsystems in each unit. Each subsystem provides saltwater to the Service Water heat exchangers, Component Cooling water heat exchangers and the Emergency Core Cooling System pump room air cooler to transfer heat from those systems to the Chesapeake Bay. Seal water for the circulating water pumps is supplied by both subsystems. A self-cleaning strainer is installed upstream of each Service Water heat exchanger.

5. Applicable ISI ASME B&PV Code Edition and Addenda For the 5th ISI interval at CCNPP, Units 1 and 2 the applicable code is ASME B&PVC,Section XI, "Rules for lnservice Inspection of Nuclear Power Plant Components", 2013 Edition, No Addenda.

6. Applicable ASME B&PV Code Requirement The ASME B&PVC requirement applicable to repairing piping isSection XI, Rules for In-Service Inspection of Nuclear Power Plant Components, Article IWA-4000, subparagraphs:

IWA-4220 - CODE APPLICABILITY - This section in part that an item to be used for repair/replacement activities shall meet the Owners requirements and Construction Code.

Additionally, this section requires reconciliation of the technical requirement of the Construction Code and Owners requirements.

IWA-4221(b) An item to be used for repair/replacement activities shall meet the Construction Code specified in accordance with (1), (2), or (3) below.

(1) When replacing an existing item, the new item shall meet the Construction Code to which the original item was constructed.

NOTE: IWA-4221(b) items (2) and (3) are not applicable.

IWA-4412 - Defect Removal states Defect removal shall be accomplished in accordance with the requirements of IWA-4420.

IWA-4340 - MITIGATION OF DEFECT BY MODIFICATION - states in part that the defect shall be characterized using non-destructive examination and evaluated to determine its cause and projected growth for the item in accordance with IWA-4220. This section also provides the requirements for successive examination of the modification.

IWA-4611.1(a) states Defect shall be removed in accordance with IWA-4422.1 A defect is considered removed when it had been reduced to an acceptable size.

IWA-5250(a)(3) states Components requiring corrective action shall have repair/replacement activities performed in accordance with IWA-4000 or corrective measures performed where the relevant condition can be corrected without repair/replacement activity.

NON-PROPRIETARY INFORMATION Enclosure 11 Page 7 of 57

7. Reason for Request

CCNPP is proactively evaluating repair options to improve system reliability, reduce outage requirements, and improve resource availability by using the V-Wrap' CFRP Composite System on the interior of the SW System piping. Once fully implemented, the CFRP composite system will take the place of the host pipe and resist all design loading without reliance on the host pipe.

The CCNPP SW System piping is internally inspected on a 4-year frequency. The condition of the cement mortar lining is generally found in good condition with patch repairs to mortar lining required to ensure continued reliability of the ductile iron piping beneath.

The external surfaces of the buried SW System piping cannot be inspected without excavation.

Installation of the V-Wrap' CFRP Composite System may include partial segment lengths which would continue a sufficient distance onto a structurally sound cast iron pipe surface at the terminal ends.

8. Proposed Alternative and Basis for Use

The use of the proposed V-Wrap' CFRP Composite System for the internal repair of buried pipe is a technology improvement which was not available in the 1960s or 1970s to meet the construction code to which original piping was constructed. There is currently no USNRC endorsed ASME B&PVC,Section XI Code Case for installing a CFRP composite system as a structural liner for piping during a repair/replacement activity.

Pursuant to 10 CFR 50.55a(z)(1), an alternative is proposed for the repair of the CCNPP, Units 1 and 2 SW System piping that provides an acceptable level of quality and safety. It is proposed that the SW System piping be repaired with the V-Wrap' CFRP Composite System produced by Structural Technologies, LLC. Enclosure 2 describes the proposed scope.

The V-Wrap' CFRP Composite System has been previously approved by the USNRC and installed on the interior of concrete encased, buried carbon steel piping for safety-related applications at the Surry Power Station in 2018 with the upgrade program continuing through 2024 (Reference letter to Virginia Electric & Power Company from USNRC, dated December 20, 2017, ML17303A068).

A similar application to install the V-Wrap' CFRP Composite System in the Emergency Cooling Water System piping at South Texas Project Electric Generating Station (STPEGS), Units 1 and 2 was submitted to the USNRC (Reference letter to USNRC from South Texas Project Nuclear Operating Company, dated September 26, 2019, ML19274C393). The USNRC has concluded that the licensee adequately addressed all regulatory requirements set forth in 10 CFR 50.55a(z)(1) and the proposed alternates provide an acceptable level of safety (Reference letter to South Texas Project Units 1 and 2 [G. T. Powell, President and CEO], from the USNRC [Jennifer L. Dixon-Herrity, Chief, Plant Licensing Branch], dated September 3, 2020, ML20227A385).

A similar application to install the V-Wrap' CFRP Composite System in the safety-related Essential Cooling Pond Supply piping at Entergy Arkansas Nuclear One, Units 1 and 2 was submitted to the USNRC (Reference letter from Entergy to USNRC, dated July 15, 2020, Document No.

0CAN072001, ML20218A672). The USNRC has concluded that the licensee adequately addressed all regulatory requirements set forth in 10 CFR 50.55a(z)(1) and the proposed alternates provide an acceptable level of safety (Reference letter to Entergy Operations, Inc. [ANO Site Vice President],

NON-PROPRIETARY INFORMATION Enclosure 11 Page 8 of 57 from the USNRC [Jennifer L. Dixon-Herrity, Chief, Plant Licensing Branch], dated September 30, 2021, ML21188A022).

A similar application to install the V-Wrap' CRP Composite System in SW System piping has been submitted for Brunswick Electric Steam Plant, Units 1 and 2 (Reference letter from Duke Energy Progress, LLC to USNRC, dated February 24, 2021, ML21055A797). The USNRC has concluded that the licensee adequately addressed all regulatory requirements set forth in 10 CFR 50.55a(z)(1) and the proposed alternates provide an acceptable level of safety (Reference letter to Duke Energy Progress, from the USNRC [David J. Wrona, Plant Licensing Branch II-2], December 20, 2021, ML21343A200).

Any repair/replacement and/or inspections of the V-Wrap' CFRP Composite System will be conducted in accordance with the applicable edition of ASME B&PVC,Section XI or alternative thereto, at the time of the repair/replacement or inspection.

The V-Wrap' CFRP Composite System is proposed to have a minimum 50-year service life.

Design, qualification, material manufacture, installation, testing, and inspection details of the proposed V-Wrap' CFRP Composite System are discussed in subsequent sections of this document in Enclosures 2 through 9. The proposed approach allows for the installation of the V-Wrap' CFRP Composite System for up to the complete length, or partial lengths of the SW System piping as described in Enclosure 2.

9. ((

NON-PROPRIETARY INFORMATION Enclosure 11 Page 9 of 57

))

10. Material Manufacturing The proposed V-Wrap' CFRP Composite System has been used extensively to repair and strengthen pipe systems and is comprised of high strength carbon fiber fabrics and glass fiber fabrics, fully saturated in a two-part 100% solids epoxy matrix. These laminates are bonded to the interior surface of the pipe forming a structural lining within the pipe. This lining can be designed for the degraded portions of the SW System piping without reliance on the degraded piping for the service life of the CFRP Composite System, except at the terminal ends of the repair.

V-Wrap' CFRP Composite System material components include:

NON-PROPRIETARY INFORMATION Enclosure 11 Page 10 of 57 V-Wrap' C400HM Carbon Fiber Fabric.

V-Wrap' 770 Epoxy (Components A & B).

V-Wrap' EG50B Glass Fiber Fabric.

Expansion Ring Assembly.

Cab-O-Sil TS-720 Fumed Silica Powder.

V-Wrap' CFRP Composite System epoxy components and fiber materials are manufactured as

((

))

Expansion ring assembly components include an elastomeric rubber gasket, expansion rings, shims, and wedges. ((

))

Material Verification & Control a) V-Wrap' CFRP Composite System epoxy and fabric materials ((

))

b) Products that have exceeded their shelf life/use by date shall not be used and shall immediately, upon discovery, be tagged to prevent usage.

c) All materials are stored in accordance with the written recommendations of the Manufacturer.

NON-PROPRIETARY INFORMATION Enclosure 11 Page 11 of 57 d) V-Wrap' 770 Epoxy component materials ((

))

provides additional information on the ((

))

11. Design To ensure the pipe continues to fulfill its design function over the design life the proposed V-Wrap' CFRP Composite System is ((

))

, Attachment A provides the ((

))

, Attachment B provides ((

))

, Attachment C provides a ((

))

, Attachment D provides ((

))

, Attachment E provides a ((

))

12. Installation The successful installation of the proposed V-Wrap' CFRP Composite System ((

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))

14.

((

))

The V-Wrap' CFRP Composite System ((

NON-PROPRIETARY INFORMATION Enclosure 11 Page 21 of 57

))

15. Preservice and Inservice Examinations Preservice inspection activities shall include:

a. System flow test per the ASME B&PVC,Section XI Code to verify the functional requirements of the SW System.

b. VT2 visual examination shall be conducted of the accessible external surfaces for evidence of leakage.

c. Inaccessible portions of piping not accessible for direct observation during leakage testing shall be inspected by the observation of areas surrounding the repair location, or ground surface areas above or adjacent to repairs on buried piping where accessible; or leakage collection systems, if available, shall be monitored. Minimum holding time at pressure prior to visual examination of accessible areas shall be 10 minutes, and of inaccessible areas shall be twenty-four hours.

Inservice inspection activities for the V-Wrap' CFRP Composite System installed per the proposed alternative to ASME Code material requirements, will include a system flow test in accordance with the ASME Section XI Code, to verify the functional requirements of the SW System piping. This proposed alternative will apply inservice inspection activities in accordance with ASME Section XI Code, subparagraphs IWA-5000, System Pressure Testing. This proposed inservice inspection, which directs the system pressure test for non-isolable buried components using ASME Section XI Code, IWA-5244(b)(2), shall consist of a test to confirm that flow during operation is not impaired. This system leakage tests will be performed for the remaining life of the plant in accordance with the CCNPP System Pressure Test Plan and ASME the Section XI Code requirements listed above.

Per the CCNPP, Units 1 and 2, Updated Final Safety Analysis Report (UFSAR), Section 16.2.2, Age-Related Degradation Inspection (ARDI) Aging Management Program (AMP) requires a variety of inspections on a sampling basis for the SW System. There are adequate tests and inspections in place through the period of extended operation to manage the effects of aging on the V-Wrap' CFRP Composite System in support of safe plant operation. Based on the results of the ARDI inspections required by the AMP, components of the SW System not meeting ARDI criteria will be addressed using the Preventive Maintenance (PM) AMP (UFSAR Section 16.2.23).

16. ((

NON-PROPRIETARY INFORMATION Enclosure 11 Page 22 of 57

))

17. Summary of Enclosures Enclosures that are attached are listed below:

• Enclosure 2 - Scope and Schedule

• - Definitions and Acronyms o Attachment A - Definition of Terms o Attachment B - Acronyms

((

NON-PROPRIETARY INFORMATION Enclosure 11 Page 23 of 57

))

• 0 - Applications for withholding proprietary Information from Public Disclosure

• 1 - Proposed Alternative to ASME Section XI Requirements for Repair/Replacement of Salt Water (SW) System Buried Piping in accordance with 10 CFR 50.55a(z)(1) (Non-Proprietary)

18. Duration of Proposed Alternative The V-Wrap' CFRP Composite System alternative will be proactively implemented as a contingency repair depending on the extent of degradation.

The V-Wrap' CFRP Composite System alternative is to remain in service for the life of the repair and any repair/replacement and/or inspections of the repaired piping will be conducted in accordance with the applicable edition of ASME B&PV Code,Section XI, Rules for In-Service Inspection of Nuclear Power Plant Components, or alternative thereto, at the time of the repair/replacement or inspection.

19. Precedents The proposed V-Wrap' CFRP Composite System has been installed on multiple projects at multiple Nuclear facilities with the same project team (Designer, Manufacturer, and Installer) on approximately 1,000 linear feet of safety-related Essential Cooling Water, Circulating Water and Service Water System carbon steel pipe including 30-inch, 42-inch, and 96-inch diameter piping.

These installations required multiple layers of V-Wrap' CFRP composite totaling over 110,000 square-feet (See Enclosure 9, Attachment A for additional operating experience information).

20. Conclusion 10 CFR 50.55a(z) states: Alternatives to codes and standards requirements. Alternatives to the requirements of paragraphs (b) through (h) of this section or portions thereof may be used when authorized by the Director, Office of Nuclear Reactor Regulation, or Director, Office of New Reactors, as appropriate. A proposed alternative must be submitted and authorized prior to implementation. The applicant or licensee must demonstrate that:

1. Acceptable level of quality and safety. The proposed alternative would provide an acceptable level of quality and safety; or (2) Hardship without a compensating increase in quality and safety. Compliance with the specified requirements of this section would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.

Based on foregoing discussion, CEG has determined that the conditions of 10 CFR 50.55a(z)(1) are met in that use of the proposed V-Wrap' CFRP Composite System as applied to the subject SW System piping provides an acceptable level of quality and safety.

NON-PROPRIETARY INFORMATION Enclosure 11 Page 24 of 57 ENCLOSURE 2 Scope and Schedule Constellation Energy Generation, LLC (CEG)

Calvert Cliffs Nuclear Power Plant (CCNPP) Units 1 and 2 Relief Request Serial No. ISI-05-021 Request for Relief for a Proposed Alternative to ASME Boiler & Pressure Vessel Code Section XI Requirements for Repair/Replacement of Saltwater System Piping in Accordance with 10 CFR 50.55a(z)(1)

NON-PROPRIETARY INFORMATION Enclosure 11 Page 25 of 57 Constellation Energy Generation, LLC (CEG)

Calvert Cliffs Nuclear Power Plant (CCNPP), Units 1 and 2 ENCLOSURE 2 Scope and Schedule TABLE OF CONTENTS, Attachment A: Scope and Schedule, Attachment B: CCNPP Unit No. 1 SW System Piping Layout

, Attachment C: CCNPP Unit No. 2 SW System Piping Layout

NON-PROPRIETARY INFORMATION Enclosure 11 Page 26 of 57 Constellation Energy Generation, LLC (CEG)

Calvert Cliffs Nuclear Power Plant (CCNPP), Units 1 and 2 ENCLOSURE 2 Attachment A - Scope and Schedule

1) Scope Calvert Cliff Nuclear Power Plant (CCNPP) is proactively requesting approval to use the proposed V-Wrap' CFRP Composite System as an internal upgrade to the Saltwater (SW) System piping.

Additional details depicting piping sections to be lined with the proposed V-Wrap' Carbon Fiber Reinforced Polymer (CFRP) Composite System, site layout, and directional changes are provided in Attachments B and C. The SW System piping at CCNPP Unit Nos. 1 and 2 consists of 30 and 36 inch diameter, ductile iron pipe conveying saltwater from Chesapeake Bay.

The piping to be lined is buried and not subject to 10CFR50.48c, National Fire Protection Association Standard NFPA 805, "Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants, 2001 edition requirements. As depicted in Attachments B and C the CFRP Composite System will terminate onto existing piping. Access to base material at terminal ends for future inservice inspections will be considered in the 10CFR50.59, Changes, Tests and Experiments process. These terminal end areas are accessible allowing for preservice and in-service inspections of the piping to be performed per ASME Section XI requirements. Fire protection considerations required by 10CFR50.48c, National Fire Protection Association Standard NFPA 805, "Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants, 2001 edition for piping inside of the buildings will be addressed as part of the 10CFR50.59 process.

2) General Information

a.

CCNPP Unit 1, Saltwater (SW) System

i.

Approximately 1,396 linear feet (LF) of safety related, buried 30 and 36 inch diameter, cement mortar lined, bell and spigot ductile iron pipe.

Line Designation Diameter (Inches)

Approximate Length (LF)

Maximum Temperature

(°F)

Normal Operating Temperature

(°F)

Supply 36-LC-2-1001 36 303 121 32 - 95 Supply 36-LC-2-1002 36 303 121 32 - 95 Supply 30-LC-2-1003 30 177 121 32 - 95 Supply 30-LC-2-1004 30 146 121 32 - 95 Supply 30-LC-2-1005 30 16 121 32 - 95 Supply 30-LC-2-1006 30 13 121 32 - 95 Return 30-LC-2-1008 30 271 121 32 - 95

NON-PROPRIETARY INFORMATION Enclosure 11 Page 27 of 57

b. CCNPP Unit 2, SW System

i. Approximately 1,266 linear feet (LF) of safety related, buried 30 and 36 inch diameter, cement mortar lined, bell and spigot ductile iron pipe:

Line Designation Diameter (Inches)

Approximate Length (LF)

Maximum Temperature

(°F)

Normal Operating Temperature

(°F)

Supply 36-LC-2-2001 36 295 121 32 - 95 Supply 36-LC-2-2002 36 299 121 32 - 95 Supply 30-LC-2-2003 30 165 121 32 - 95 Supply 30-LC-2-2004 30 143 121 32 - 95 Supply 30-LC-2-2005 30 18 121 32 - 95 Supply 30-LC-2-2006 30 16 121 32 - 95 Return 30-LC-2-2008 30 51 121 32 - 95 Access points allowing for personnel entry and/or ventilation are depicted on Attachments B and C. Additional personnel access may be installed to enhance personnel safety and improve schedule performance.

Access 1: Personnel access into the piping within the Unit 1 Intake Structure at the West Wall location. Ventilation point can be set up in this location with compressors staged near outside wall with air-lines running through blind flanges.

Access 2: Unit 2 Intake Structure approximately 20 away from Unit 1, Access Area 1.

Access 3: Primary personnel access through Rams Head in Unit 1 Turbine Building (North End). Manholes in the floor can be used for ventilation.

Access 4: Access either through Service Water (SRW) Heat Exchange room or through the Radiological Controlled Area (RCA) as an alternate. SRW Heat Exchange room access is congested and has limited time to remain open.

Access 5: Ventilation only access point through manhole near low pressure feedwater heaters. Route provides access to discharge conduit.

NOTE: Additional Ventilation only access is provided through the Component Cooling Water (CCW) Heat Exchange room.

Access 6: Ventilation access near Turbine Building personnel elevator.

Access 7: Personnel access through Rams Head near Unit 2 Turbine Building personnel elevator.

NON-PROPRIETARY INFORMATION Enclosure 11 Page 28 of 57 Access 8: Access either through Salt Water (SRW) Heat Exchanger room or through the Radiological Controlled Area (RCA) as an alternate. SRW Heat Exchanger room access is congested and has limited time to remain open.

NOTE: Ventilation access is provided through the Component Cooling Water (CCW) Heat Exchange room.

ii.

The original Construction Code for Non-Nuclear Power piping at Calvert is the USAS B31.1 Nuclear Power Piping Code, 1967 Edition with the B31.1a (1971), B31.1b (1971), B31.1c (1972), and B31.1d (1972) Addenda.

iii.

The applicable American Society of Mechanical Engineers (ASME) Boiler & Pressure Vessel Code (B&PVC),Section XI ISI Class for this piping is ISI Class 3.

iv.

Scope of work does not include any pumps, valves, expansion joints, or threaded connections.

v.

Piping:

(1) Is below grade, buried and has long straight runs with minimal bends and elbows.

(2) Is ductile cast iron conforming to ASTM A377, Standard Index of Specifications for Ductile-Iron Pressure Pipe / ANSI A21.51, American National Standard for Ductile-Iron Pipe, Centrifugally Cast, for Water.

(3) Is cement mortar lined per ANSI A21.4, Cement-Mortar Lining for Ductile Iron Pipe and Fittings.

(4) Has typically been coated with Carboline or approved equal.

(5) Does not have an Impressed Current Cathodic Protection system installed to mitigate corrosion.

vi.

Fittings are ductile cast iron conforming to ASTM A126, Class B, Standard Specification for Gray Iron Castings for Valves, Flanges, and Pipe Fittings / ANSI A21.10, American National Standard for Ductile-Iron and Gray-Iron Fittings for Water.

vii.

Mechanical joint piping underground have thrust blocks at each direction change.

3) Function The SW System moves saltwater from the intake structure, through the system and back to the circulating water discharge conduits. SW System piping included in this request is safety-related and consists of two subsystems in each unit. Each subsystem provides saltwater to Service Water (SRW) heat exchangers, Component Cooling (CC) heat exchangers and the Emergency Core Cooling System (ECCS) pump room air cooler to transfer heat from those systems to the Chesapeake Bay. Seal water for the circulating water pumps is supplied by both subsystems. A self-cleaning strainer is installed upstream of each SRW heat exchanger.

NON-PROPRIETARY INFORMATION Enclosure 11 Page 29 of 57

4) Schedule a) Installation of the V-Wrap' CFRP Composite System will be accomplished, as required, to support available refueling outage work windows, inspection results and may include partial segment lengths which would continue sufficient distance onto competent piping at the terminal ends.

b) For the 5th ISI interval at CCNPP Unit 1 ends in June 2029 the applicable code is ASME B&PVC,Section XI, "Rules for lnservice Inspection of Nuclear Power Plant Components",

2013 Edition, No Addenda.

c) For the 5th ISI interval at CCNPP Unit 2 ends in June 2029 the applicable code is ASME B&PVC,Section XI, "Rules for lnservice Inspection of Nuclear Power Plant Components",

2013 Edition, No Addenda.

NON-PROPRIETARY INFORMATION 1 Page 30 of 57 Attachment A - CCNPP Unit 1 SW System Piping Layout

NON-PROPRIETARY INFORMATION 1 Page 31 of 57 Attachment B - CCNPP Unit No. 2 SW System Piping Layout

NON-PROPRIETARY INFORMATION 1 Page 32 of 57 ENCLOSURE 3 Definitions and Acronyms Constellation Energy Generation, LLC (CEG)

Calvert Cliffs Nuclear Power Plant (CCNPP), Units 1 and 2 Relief Request Serial No. ISI-05-021 Request for Relief for a Proposed Alternative to ASME Boiler & Pressure Vessel Code Section XI Requirements for Repair/Replacement of Saltwater System Piping in Accordance with 10 CFR 50.55a(z)(1)

NON-PROPRIETARY INFORMATION 1 Page 33 of 57 Constellation Energy Generation, LLC (CEG)

Calvert Cliffs Nuclear Power Plant (CCNPP), Units 1 and 2 ENCLOSURE 3 Definition of Terms and Acronyms TABLE OF CONTENTS

Attachment A - Definition of Terms

Attachment B - Acronyms

NON-PROPRIETARY INFORMATION 1 Page 34 of 57 Constellation Energy Generation, LLC (CEG)

Calvert Cliffs Nuclear Power Plant (CCNPP), Units 1 and 2 ENCLOSURE 3 Attachment A - Definition of Terms Acceptance Test: A test or series of tests conducted to determine whether a material system or component conforms to the specified requirements.

Adhesive: A substance capable of holding materials together by surface attachment.

Amine Blush: Surface oiliness or "sweating" that occurs when epoxy is cured in a cool or high-humidity environment.

Approved Drawings - Project specific drawings that have been prepared and approved by the Design Authority.

Batch/Lot: A quantity of material produced in a single manufacturing run. (Also see Lot)

Batch/Lot Number: An identification number assigned to a particular quantity of material from a single manufacturer.

Blister: Void between the layers of the Carbon Fiber Reinforced Polymer (CFRP) system that contains fluid.

Bond Length: The length at the repair terminations over which the CFRP system is designed to remain bonded to the host pipe to transfer longitudinal forces and maintain watertightness at the ends of the CFRP system.

Bond Strength: The direct pull-off bond strength between the CFRP system and substrate obtained in accordance with ASTM D4541, Standard Test for Pull-Off Strength of Coatings Using a Portable Adhesion Tester.

Bubble: Void between the layers of the CFRP system that contains air.

Buckling: A limit state involving a sudden change in the geometry of the structure or structural elements thereof due to compressive forces exceeding stable equilibrium.

Carbon Fiber: A solid semi-crystalline organic material consisting on the atomic level of planar two-dimensional arrays of carbon atoms. Carbon fibers are used in CFRP renewal and strengthening in the form of unidirectional fabric.

Carbon Fiber Reinforced Polymer (CFRP) Composite System: is used to repair and strengthen piping. The CFRP system is comprised of high strength carbon fiber fabrics and/or glass fiber fabrics, fully saturated in a two-part 100% solids epoxy matrix. These laminates are bonded both longitudinally and circumferentially to the interior surface of the pipe forming a structural lining within the pipe.

NON-PROPRIETARY INFORMATION 1 Page 35 of 57 Characteristic Value: Statistically based property value representing the 80% lower confidence bound on the 5th-percentiIe value of a specified population, determined in accordance with ASTM D7290, Standard Practice for Evaluating Material Property Characteristic Values for Polymeric Composites for Civil Engineering Structural Applications.

Characteristic Strength: Characteristic value of strength calculated in accordance with ASTM D7290, Standard Practice for Evaluating Material Property Characteristic Values for Polymeric Composites for Civil Engineering Structural Applications using short-term laboratory test data.

Characteristic Modulus: Characteristic value of modulus of elasticity calculated in accordance with ASTM D7290, Standard Practice for Evaluating Material Property Characteristic Values for Polymeric Composites for Civil Engineering Structural Applications using short-term laboratory test data.

Characteristic Ultimate Strain: Characteristic strength divided by the Weibull mean modulus.

Circumferential Direction: Circumferential direction of the host pipe.

Compressive Failure: Failure by reaching compressive strength without buckling.

Constructor: The party that provides the work and materials for placement or installation.

Crazing: Micro-Cracking.

Creep: Time-dependent deformation under constant load.

Creep Rupture: Failure under a sustained load that is lower than the short-term strength.

Debondinq: Separation between the CFRP system and the pipe substrate.

Delamination: Inter-Ply separation.

Demand: Strain or stress created in the structure by the design loads.

Design Authority: NRC Authorized Licensee or Organization appointed by the Owner and under contract to be responsible for a design or modification of a design.

Design Strength: Nominal resistance in end-use condition, Rn, multiplied by resistance factor, time effect factor, and material adjustment factor Design Ultimate Strain: Characteristic ultimate strain reduced by applicable resistance factor, time effect factor, and material adjustment factor.

Dry Lay-Up: The process of saturation of reinforcing fabric with epoxy after the fabric has already been placed onto the host structure. The dry lay-up method is not permitted.

Durability: The ability to resist weathering action, chemical attack, abrasion, and other conditions of service.

Edge Lift: A gap located at the edge of the fabric.

Effective Factor of Safety: Ratio of the controlling load factor divided by the product of the resistance factor, time effect factor and material adjustment factor (Required Effective Factor of Safety); or product of the Required Effective Factor of Safety and the controlling strength/demand ratio (Actual Effective Factor of Safety), used in Load Resistance Factor Design (LRFD) based design approach.

NON-PROPRIETARY INFORMATION 1 Page 36 of 57 End-Use Conditions: The chemical and load exposure conditions to which the structure is subjected to during its service.

Engineer of Record: The licensed professional engineer who is responsible for sealing the design documents related to CFRP renewal and strengthening.

End-Use Conditions: The chemical and load exposure conditions to which the structure is subjected to during its service.

Epoxy: The polymeric material used to bind together the reinforcing fibers in CFRP.

Expansion Ring Assembly: The expansion ring, shims and associated EPDM rubber strip which is expanded out onto the installed CFRP system.

Factor of Safety: Ratio of the short-term strength and allowable stress (Required Factor of Safety), or ratio of short-term strength to unfactored demand (Actual Factor of Safety), used in ASD-based design approach.

Factored Load: Product of design load and a load factor.

Factored Strain or Factored Stress: Strain or stress created in the structure by the design loads, multiplied by the applicable load factors.

Fatigue: Progressive development of damage, such as cracking, fretting and similar effects, resulting from repeated application of loads.

Fiber Orientation: Orientation or alignment of the longitudinal axis of the fiber with respect to a stated reference axis.

Field Leader: Includes Project Manager, Construction Manager, Superintendent, Field Engineer and Project Engineer.

Fillers: Substance added in the matrix or adhesive material to alter its engineering properties, performance, and/or cost.

Finish Layer: Provides an abrasion barrier and protection against chemicals, flow, debris, etc. Is typically a thickened epoxy, either with or without a pigment added to facilitate inspection. Is compatible with appropriate exposure conditions including moisture, saltwater, elevated temperature, abrasion, and chemical exposure.

Glass Transition Temperature (T): Midpoint of the temperature range at which the polymer matrix changes from a glassy to a rubbery state.

Gravity Load: Vertical loads, including earth load, pipe and fluid weights, surcharge, and surface live loads.

Hold Point: Steps within the installation procedure which requires inspector approval prior to proceeding.

Intake Structure: Reinforced concrete Seismic Category 1 structure on the southeast corner of the plant.

Lamina: A layer of reinforcing fabric and epoxy.

Laminate Architecture: Construction of the laminate from laminae with different types and orientations of unidirectional carbon fiber fabrics and unidirectional and woven glass fabrics.

NON-PROPRIETARY INFORMATION 1 Page 37 of 57 Limit State: A condition in which a structure or component thereof is judged either to be no longer useful for its intended function (serviceability limit state) or to have reached its ultimate load-carrying capacity (strength or stability limit states).

Load Combination: Combination of the effects of design loads based on the likelihood of their simultaneous occurrence and uncertainty in each load.

Load Duration (Time Effect): The period of continuous application of a load, or the cumulative period of intermittent applications of a load.

Load Factor: A factor that accounts for unavoidable deviations of the actual load from the nominal load and for uncertainties in the analysis that transforms the load into a load effect.

Load and Resistance Factor Design (LRFD): A method of proportioning structural components (members, connectors, connecting elements, and assemblages) such that the design strength equals or exceeds the required strength for all applicable limit states.

Longitudinal Direction: Longitudinal direction of the host pipe.

Lot: A quantity of material produced in a single manufacturing run (Also see Batch).

Lot Number: An identification number assigned to a quantity of material from a single manufacturer. (Also see Batch Number).

Long-Term Strength: Strength of CFRP under sustained load with duration equal to the service life of the structure.

Manufacturer: The party that manufactures, fabricates, produces, or supplies materials or products.

Material Adjustment Factor: Factors that define the resistance-in the end use condition in terms of laboratory strength values.

Material Organization: Material manufacturer or material suppliers of CFRP repair system components.

Matrix: The continuous constituent of a CFRP system that surrounds the fibers. It consists of 100 percent solids, VOC compliant, epoxy with fillers and additives.

Measurement and Testing Equipment (MTE) - Includes all devices or systems used to certify, measure, gauge, test, or inspect for acquiring data to verify conformance to specified requirements.

Misalignment: General or local deviation in the orientation of CFRP or GFRP layers from their design orientation.

Nominal Loads: The loads and load combinations specified for the design.

Nominal Strength or Nominal Resistance: The strength of a structure or component in the end-use conditions (without resistance factor or time-effect factors applied).

Non-Structural Layers: Dielectric Barrier is used to avoid galvanic corrosion of metallic materials in proximity to carbon fibers. A dielectric barrier layer shall be used for isolation of a metallic material from the CFRP laminate. Dielectric barrier includes a layer of glass fiber, saturating epoxy and thickened epoxy. All materials shall be compatible with the epoxy used to saturate the carbon fibers.

NON-PROPRIETARY INFORMATION 1 Page 38 of 57 Ovality: Deviation of the host pipe geometry from the original circular shape, calculated as the pipe deflection divided by the original diameter.

Overlap Separation: Unacceptable separation between fabric sheets; typically resulting from insufficient overlap.

Overlap Length: The design shall provide a minimum overlap in the direction of the fibers of 12 in., but not less than the manufacturers recommended development length as established through testing in accordance with ASTM D7616.

Performance Standard: Stipulated minimum performance threshold(s), requirement(s), or expectation(s) that must be met by a manufactured structure to be appraised at a level of performance. It can be based on tests that approximate the end-use conditions.

Pot Life: Time interval, after mixing of epoxy, during which the mixture can be applied without degrading the performance of the resulting CFRP composite system beyond specified limits.

Pre-Cured Laminates: Composite materials in which the reinforcing fabric has been saturated with epoxy and cured off-site. The use of pre-cured laminates is not permitted.

Primers: Are mixed according to the recommended procedure. Primer has sufficiently low viscosity and surface tension to thoroughly wet and coat the pipe surface and provide sufficient adhesion to accommodate design loads between the host pipe and the thickened epoxy or saturating epoxy.

Purchaser: The person, company, or organization that purchases any materials or work to be performed.

Reference Strength: Strength calculated based on the characteristic material properties obtained from short-term laboratory tests.

Relaxation: Time-dependent reduction in stress under a constant strain.

Reliability: Probability that a system will perform its intended function for a specific period under a given set of conditions.

Reliability Index: A parameter in reliability analysis that is correlated to probability of failure.

Required Strength: The load effect or structural action (force, moment, or stress) acting on a structural system, member, or connection, as determined by structural analysis from the factored loads, considered in appropriate combinations.

Resistance: Generic term describing the capacity of a structure, component, or connection to withstand the effects of load; determined from specified material strengths, stiffness, dimensions, and formulas derived from accepted principles of structural mechanics or by field or from laboratory tests of scaled models, allowing for modeling effects and differences between laboratory and field conditions.

Resistance Factor: A factor that accounts for unavoidable deviations and variability of the actual strength from the nominal end-use value and for the manner and consequences of failure.

Restraining Components (e.g., Pipe supports): Components that are not functionally safety related, but that are required to be seismically restrained, supported or anchored to prevent damage to nearby safety related equipment.

Roving: Large number of continuous parallel filaments or a group of untwisted parallel strands.

NON-PROPRIETARY INFORMATION 1 Page 39 of 57 Rupture: Failure in tension through breakage of fibers.

Safety Related: Plant systems, portions of systems, structures and equipment whose failure could result in a release of radioactivity that could endanger public safety, or whose purpose is to mitigate the effect of such failure, or required for safe operation, shutdown, and removal of residual heat Shear Bond Strength: Strength of the bond in shear between the CFRP system and the host pipe as determined by laboratory testing according to ASTM D7616.

Shear Bond Failure: Shear failure of the bond between CFRP system and substrate at the repair terminations.

Shelf-Life: Indicator of the raw materials life in their unmixed, uninstalled life. Prior to mixing, the materials are in an unstable condition that limits their shelf life Service Life: Indication of the anticipated duration of the "in-service" life following mixing of epoxies, saturation of fabric and installation.

Short-Term Strength: Strength of CFRP laminate under loads applied at the loading rate equal to that specified by the relevant ASTM Standard.

Stress Range: Magnitude of change in stress due to the repeated application and removal of service loads, used in checking susceptibility to fatigue.

Subject Matter Expert (SME) - Person who is an authority with special knowledge in an area or topic.

Surface Imperfections - Imperfections on the adhesion surface which include mill scale, rust, loose coating materials, weld with sharp edges, weld splatter/slag, plate lamination, sharp edges, manual weld irregularities, undercut, and gas cut surfaces.

Surface Preparation - To ensure that salt, oil, grease, rust, and other contaminants are removed, and the surface is ready to accept CFRP system installation and provide a mechanical bond where required.

System Pressure Boundary: The function of mechanical components (e.g., valves, piping, pumps, tanks, accumulators, ducting, dampers, etc.) used to maintain system integrity and avoid system leakage. Ensures nuclear safety functions provided by other safety systems or equipment.

Tack Free: The attainment of a sufficiently robust state to resist damage by contact or handling.

Thickening Agents: Are mixed with the epoxy according to the recommended procedure to form a thickened epoxy. Thickened epoxy can be used as a primer or over a primer to provide a smooth surface for the application of the CFRP laminate.

Time-Effect Factor: The ratio of the creep rupture strength of laminate subjected to sustained load to the strength under short-term loading.

Toughness: Toughness (area under stress-strain curve or moment rotation curve) is the ability to absorb energy and can be quantified by computing the work done per unit mass of material.

Tow: Twisted bundle of continuous carbon fibers.

Unfactored Strain or Unfactored Stress: Strain or stress created in the structure by the nominal design loads.

NON-PROPRIETARY INFORMATION 1 Page 40 of 57 V-Wrap 770 Epoxy' - Two-part epoxy adhesive for high strength composite bonding.

V-Wrap C400HM': Unidirectional high strength carbon fiber fabric.

V-Wrap' Carbon Fiber Anchors: Two-part epoxy adhesive and unidirectional high strength carbon fabric.

V-Wrap' Carbon Fiber Rods: Pre-manufactured composite carbon/resin rods.

V-Wrap' CFRP Composite System: Structural strengthening system for the restoration of damaged/weakened pressure pipe.

V-Wrap EG50B': Custom bi-directional high strength glass fiber fabric.

Watertightness: Prevention of water or other fluids from one side to the other side of a barrier.

Watertightness Layer: Layer Of bidirectional glass fiber reinforced polymer embedded in the CFRP repair system.

Waviness: Deviation from the best-fit oval shape of the host pipe or the CFRP repair system, measured as the radial offset on the substrate.

Weibull Distribution: A probability distribution function used in evaluation of strength and life data.

Wet Lay-Up: The process of on-site saturation of the reinforcement fabric with epoxy followed by application of the saturated fabric to the host structure to cure in-place.

Wet surface: A surface that depicts visible moisture on a tissue that is held to the surface of the pipe for a minimum of 30 seconds.

Wrinkle: Localized misalignment and raised surface of the primary fiber direction.

NON-PROPRIETARY INFORMATION 1 Page 41 of 57 Constellation Energy Generation, LLC (CEG)

Calvert Cliffs Nuclear Power Plant (CCNPP), Units 1 and 2 ENCLOSURE 3 Attachment B - Acronyms ANII: Authorized Nuclear In-Service Inspector ANSI: American National Standards Institute AS: Aerospace Standards ASD: Allowable Stress Design ASME: American Society of Mechanical Engineers ASTM: American Society of Testing and Materials AWWA: American Water Works Association B&PVC: Boiler and Pressure Vessel Code CAR: Corrective Action Request/Report CBT: Computer Based Training CFR: Code of Federal Regulations CFRP: Carbon Fiber Reinforced Polymer CLCI CLC2 CLC3 CLC4: Circumferential Load Combinations COC: Certification of Conformance/Compliance CPS: Centipoise CR: Condition Report CMTR: Certified Material Test Report DSC: Differential Scanning Calorimetry DSR: Demand Strength Ratio

NON-PROPRIETARY INFORMATION 1 Page 42 of 57 EPDM: Ethylene-Propylene Diene Monomer O F: Degrees Fahrenheit FFD: Fitness for Duty FRP: Fiber Reinforced Polymer FEA: Finite Element Analysis FME: Foreign Material Exclusion FMEA: Failure Mode and Effects Analysis Ft: Feet GFRP: Glass Fiber Reinforced Polymer IAS: International Accreditation Service In: Inches ISI: Inservice Inspection ISO: International Organization for Standardization JSHA: Job Safety Hazard Analysis KSI: Kips per Square Inch LLC: Limited Liability Corporation LLCI LLC2 LLC3 LLC4: Longitudinal Load Combinations LOCA: Loss of Coolant Accident LOOP: Loss of Offsite Power LRFD: Load and Resistance Factor Design LS: Limit State MTE: Measuring & Test Equipment

NON-PROPRIETARY INFORMATION 1 Page 43 of 57 NACE: National Association of Corrosion Engineers NCR: Nonconformance Report NDE: Non-Destructive Examination NEI: Nuclear Energy Institute NIST: (USA) National Institute of Standards Technology NRC: Nuclear Regulatory Commission NQA: Nuclear Quality Assurance NSF: National Science Foundation OBE: Operating Basis Earthquake QC: Quality Control OE: Operating Experience OSHA: Occupational Safety and Health Administration Oz: Ounces PCCP: Prestressed Concrete Cylinder Pipe PFD: Process Flow Diagram PQP: Project Quality Plan PWR: Pressurized Water Reactor PSI: Pounds per square inch PSF: Pounds per square foot QAP: Quality Assurance Program RCA: Radiologically Controlled Area REST: Components being restrained

NON-PROPRIETARY INFORMATION 1 Page 44 of 57 RH: Relative Humidity SAR: Safety Analysis Report SCWE: Safety Conscious Work Environment SSE: Safe Shutdown Earthquake SDR: Strength Demand Ratio SGH: Simpson Gumpertz & Heger SOP: Standard Operating Procedure S-R: Safety Related SS: Stainless Steel SSE: Safe Shutdown Earthquake STRU: Provide Structural Integrity SIF: Stress Intensification Factor SSPC: Society for Protective Coatings SW: Salt Water SWR: Service Water SYPB: System Pressure Boundary U: Unit UA: Unescorted Access UHS: Ultimate Heat Sink UT: Ultrasonic Testing USAS: United States of America Standards WRF: Water Research Foundation

NON-PROPRIETARY INFORMATION 1 Page 45 of 57 Yd: Yard

NON-PROPRIETARY INFORMATION 1 Page 46 of 57 ENCLOSURE 4

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Constellation Energy Generation, LLC (CEG)

Calvert Cliffs Nuclear Power Plant (CCNPP), Units 1 and 2 Relief Request Serial No. ISI-05-021 Request for Relief for a Proposed Alternative to ASME Boiler & Pressure Vessel Code Section XI Requirements for Repair/Replacement of Saltwater System Piping in Accordance with 10 CFR 50.55a(z)(1)

NON-PROPRIETARY INFORMATION 1

Page 47 of 57 Constellation Energy Generation, LLC (CEG)

Calvert Cliffs Nuclear Power Plant (CCNPP), Units 1 and 2 ENCLOSURE 4

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NON-PROPRIETARY INFORMATION 1 Page 48 of 57 ENCLOSURE 5

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Constellation Energy Generation, LLC (CEG)

Calver Cliffs Nuclear Power Plant (CCNPP), Unit Nos. 1 and 2 Relief Request Serial No. ISI-05-021 Request for Relief for a Proposed Alternative to ASME Boiler & Pressure Vessel Code Section XI Requirements for Repair/Replacement of Salt Water System Piping in Accordance with 10 CFR 50.55a(z)(1)

NON-PROPRIETARY INFORMATION 1 Page 49 of 57 Constellation Energy Generation, LLC (CEG)

Calvert Cliffs Nuclear Power Plant (CCNPP), Unit Nos. 1 and 2 ENCLOSURE 5

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NON-PROPRIETARY INFORMATION 1 Page 50 of 57 ENCLOSURE 6

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Constellation Energy Generation, LLC (CEG)

Calvert Cliffs Nuclear Power Plant (CCNPP), Units 1 and 2 Relief Request Serial No. ISI-05-021 Request for Relief for a Proposed Alternative to ASME Boiler & Pressure Vessel Code Section XI Requirements for Repair/Replacement of Saltwater System Piping in Accordance with 10 CFR 50.55a(z)(1)

NON-PROPRIETARY INFORMATION 1 Page 51 of 57 Constellation Energy Generation, LLC (CEG)

Calvert Cliffs Nuclear Power Plant (CCNPP), Units 1 and 2 ENCLOSURE 6

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NON-PROPRIETARY INFORMATION 1 Page 52 of 57 ENCLOSURE 7

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Constellation Energy Generation, LLC (CEG)

Calvert Cliffs Nuclear Power Plant (CCNPP), Units 1 and 2 Relief Request Serial No. ISI-05-021 Request for Relief for a Proposed Alternative to ASME Boiler & Pressure Vessel Code Section XI Requirements for Repair/Replacement of Saltwater System Piping in Accordance with 10 CFR 50.55a(z)(1)

NON-PROPRIETARY INFORMATION 1 Page 53 of 57 Constellation Energy Generation, LLC (CEG)

Calvert Cliffs Nuclear Power Plant (CCNPP), Units 1 and 2 ENCLOSURE 7

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NON-PROPRIETARY INFORMATION 1 Page 54 of 57 ENCLOSURE 8

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Constellation Energy Generation, LLC (CEG)

Calvert Cliffs Nuclear Power Plant (CCNPP), Units 1 and 2 Relief Request Serial No. ISI-05-021 Request for Relief for a Proposed Alternative to ASME Boiler & Pressure Vessel Code Section XI Requirements for Repair/Replacement of Saltwater System Piping in Accordance with 10 CFR 50.55a(z)(1)

NON-PROPRIETARY INFORMATION 1 Page 55 of 57 Constellation Energy Generation, LLC (CEG)

Calvert Cliffs Nuclear Power Plant (CCNPP), Units 1 and 2 ENCLOSURE 8

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NON-PROPRIETARY INFORMATION 1 Page 56 of 57 ENCLOSURE 9

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Constellation Energy Generation, LLC (CEG)

Calvert Cliffs Nuclear Power Plant (CCNPP), Units 1 and 2 Relief Request Serial No. ISI-05-021 Request for Relief for a Proposed Alternative to ASME Boiler & Pressure Vessel Code Section XI Requirements for Repair/Replacement of Saltwater System Piping in Accordance with 10 CFR 50.55a(z)(1)

NON-PROPRIETARY INFORMATION 1 Page 57 of 57 Constellation Energy Generation, LLC (CEG)

Calvert Cliffs Nuclear Power Plant (CCNPP), Units 1 and 2 ENCLOSURE 9

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