NOC-AE-19003684, Proposed Alternative to ASME Boiler & Pressure Vessel Code Section XI Requirements for Repair/Replacement of Essential Cooling Water (Ecw) System Class 3 Buried Piping in Accordance with 10 CFR 50.55a(z)(1)

Proposed Alternative to ASME Boiler & Pressure Vessel Code Section XI Requirements for Repair/Replacement of Essential Cooling Water (Ecw) System Class 3 Buried Piping in Accordance with 10 CFR 50.55a(z)(1)

ML19274C393
Person / Time
Site:	South Texas
Issue date:	09/26/2019
From:	Dunn R South Texas
To:	Document Control Desk, Office of Nuclear Reactor Regulation
Shared Package
ML19274C391	List: NOC-AE-19003684, Proposed Alternative to ASME Boiler & Pressure Vessel Code Section XI Requirements for Repair/Replacement of Essential Cooling Water (Ecw) System Class 3 Buried Piping in Accordance with 10 CFR 50.55a(z)(1)
References
NOC-AE-19003684, RR-ENG-3-24
Download: ML19274C393 (59)

Text

Withhold Enclosures 1, 4, 5, 6, 7, 8, AND 9 from Public Disclosure in Accordance with 10 CFR 2.390.

Nuclear Operating Company South Texas Project Electric Generating Station P.O. Box 289 Wadsworth, Texas 77483 September 26, 2019 NOC-AE-19003684 10CFR50.55a 10CFR 2.390 File No. D43.01 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555-0001 South Texas Project Unit 1 and 2 Docket No. STN 50-498 and STN 50-499 Proposed Alternative to ASME Boiler & Pressure Vessel Code Section Xl Requirements for Repair/Replacement of Essential Cooling Water (ECW) System Class 3 Buried Piping in accordance with 10 CFR 50.55a(z)(1)

(Relief Request RR-ENG-3-24)

In accordance with the provisions of 10 CFR 50.55a(z)(1), STP Nuclear Operating Company (STPNOC) requests Nuclear Regulatory Commission (NRC) approval of a proposed alternative to ASME Section Xl, IWA-4221(b) requiring repair/replacement piping to meet the original Construction Code requirements for the Essential Cooling Water (ECW) piping during the third and fourth 10-year ISI intervals.

STPNOC requests approval to allow the use of a Carbon Fiber Reinforced Polymer (CFRP) composite system for the internal repair of buried ECW system piping at South Texas Project Electric Generation Station Units 1 and 2. STPNOC has determined the proposed alternative provides an acceptable level of quality and safety. The proposed alternative is provided in with additional information in support of the proposed alternative provided in Enclosures 2 through 9. Enclosure 11 provides a redacted copy of Enclosure 1.

Enclosures 1, 4, 5, 6, 7, 8, and 9 contain supporting technical information for the proposed alternative prepared by Structural Technologies, LLC., and Simpson Gumpertz & Heger, Inc.

that includes information proprietary to these two companies. It is respectfully requested that this information be withheld from public disclosure in accordance with 10 CFR 2.390. An application for withholding proprietary information from public disclosure is included in 0.

STPNOC requests NRC review and approval of this alternative request by June 30, 2020, to support the use of the proposed alternative.

Withhold Enclosure 1, 4, 5, 6, 7, 8, AND 9 from Public Disclosure in Accordance with 10 CFR 2.390. STI:34909175

Withhold Enclosures 1, 4, 5, 6, 7, 8, AND 9 from Public Disclosure in Accordance with 10 CFR 2.390. NOC-AE-19003684 Page 2 of 2 There are no commitments in this letter.

If there are any questions, please contact me at 361-972-7743 or Nic Boehmisch at 361-972-8172.

Roland Dunn General Manager, Engineering

Enclosures:

1. Proposed Alternative to ASME Boiler & Pressure Vessel Code Section Xl Requirements for Repair/Replacement of Essential Cooling Water (ECW) Class 3 Buried Piping in Accordance with 10CFR50.55a(z)(1).

a. Sections 1, 2, 3, 4, 5, 6, 7, 8, and 15. [Proprietary]

b. Sections 9, 10, 11, 12, 13, and 14. [Non-Proprietary]

2. Scope and Schedule. [Non-Proprietary]

3. Definition of Terms and Acronyms. [Non-Proprietary]

4. Material Manufacturing and Material Qualification. [Proprietary]

5. Design. [Proprietary]

6. Sample Procedures. [Proprietary]

7. Sample Training Plans. [Proprietary]

8. Failure Mode Effects Analysis. [Proprietary]

9. Operating Experience (OE). [Proprietary]

10. Applications for Withholding Proprietary Information from Public Disclosure. [ Non-proprietary]

11. Redacted copy of Enclosure 1. [Non-Proprietary]

ec:

Regional Administrator, Region IV U.S. Nuclear Regulatory Commission 1600 E. Lamar Boulevard Arlington, TX 76011-4511 Ed Miller Senior Project Manager U.S. Nuclear Regulatory Commission One White Flint North (09E01) 11555RockvillePike Rockville, MD 20852 Withhold Enclosures 1, 4, 5, 6, 7, 8, AND 9 from Public Disclosure in Accordance with 10 CFR 2.390.

NOC-AE-19003684 Enclosure 2 Enclosure 2 Scope and Schedule.

Document No. NOC-AE-19003684 Docket No. 50-498/50-499 Enclosure 2 ENCLOSURE 2 Revision 0 Scope and Schedule Document No. NOC-AE-19003684 Docket No. 50-498/50-499 Proposed Alternative to ASME Boiler & Pressure Vessel Code Section Xl Requirements for Repair/Replacement of Essential Coolinci Water (ECW) System Class 3 Buried Piping in Accordance with 10 CFR 50.55a(z)(1)

South Texas Project Nuclear Operating Company South Texas Project Electric Generating Station (STPEGS) Units 1 and 2 Page 1 of 7

Document No. NOC-AE-19003684 Docket No. 50-498/50-499 Enclosure 2 STP Nuclear Operating Company South Texas Project Electric Generating Station (STPEGS)

Units 1 and 2 ENCLOSURE 2 Scope and Schedule TABLE OF CONTENTS , Attachment A: Scope and Schedule , Attachment B: Piping Layout Page 2 of 7

Document No. NOC-AE-19003684 Docket No. 50-498/50-499 Enclosure 2 STP Nuclear Operating Company South Texas Project Electric Generating Station (STPEGS)

Units 1 and 2 ENCLOSURE 2 Attachment A - Scope and Schedule

1) Scope a) South Texas Project Electric Generating Station (STPEGS) is submitting an alternative request for the use of a Carbon Fiber Reinforced Polymer (CFRP) system for the internal structural repair of selected safety related piping in the Essential Cooling Water (ECW) System piping in Units 1 and 2.

b) The affected piping consists of 30-inch ECW System piping and fittings from the Intake Structure to the MAB and the MAB to the outfall. Discharge piping is not currently scheduled for inspection. The primary function of the Essential Cooling Water (ECW) System is to provide cooling water for carrying heat from safety-related (S-R) components to the Essential Cooling Pond (ECP),

which acts as the ultimate heat sink (UHS). The ECW System consists of three (3) 50-percent capacity trains, and, either directly or by means of intermediate systems, provides cooling required for S-R components during and after any "design basis accident" such as a Loss of Coolant Accident (LOCA), Loss of Offsite Power (LOOP), or a Safe Shutdown Earthquake (SSE). The ECW System functions during normal operation and other non-emergency operating modes to transfer heat loads from services equipment to the ECP. The ECW System provides cooling water to the following components during all emergency and non-emergency modes of operation:

i) Standby Diesel Generator (DG) Inter-Cooler.

ii) Standby DG Auxiliary Equipment Lube Oil Cooler and Water Jacket.

iii) Essential Chilled Water Chillers.

iv) Component Cooling Water Heat Exchanger.

v) Component Cooling Water Pump Supplementary Cooler.

c) A piping layout of the sections to be lined with the proposed V-Wrap' Carbon Fiber Reinforced Polymer (CFRP) Composite System is provided in Enclosure B.

Page 3 of 7

Document No. NOC-AE-19003684 Docket No. 50-498/50-499 Enclosure 2

2) Schedule a) Inspection of the ECW intake piping is anticipated to begin in 2020 during the third ISI interval and continuing into the fourth 181 interval at Units 1 and 2.

b) Inspection of ECW discharge piping will be evaluated for scheduling pending results of ECW intake piping inspections.

c) Construction of CFRP composite system will be accomplished, as required, to support inspection results and may include partial segment lengths which would continue sufficient distance onto competent pipe at the terminal ends.

Page 4 of 7

Document No. NOC-AE-19003684 Docket No. 50-498/50-499 Enclosure 2 STP Nuclear Operating Company South Texas Project Electric Generating Station (STPEGS) - Units 1 and 2 Attachment B1 - Pipinci Layout (S-1)

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PROJECT NORTH UNIT 2 RETURN LINES-Page 5 of 7

Document No. NOC-AE-19003684 Docket No. 50-498/50-499 Enclosure 2 Attachment B2 - Piping Layout (S-1B)

UNIT 2 RETURN UNES- MATCH UNE SEE S-1A ce UNIT 2 SUPPLY LINES-mj'^

UNIT 1 RETURN LlNES- <c a!

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INIT 1 SUPPLY LINES MATCH LINE SEE S-1C Page 6 of 7

Document No. NOC-AE-19003684 Docket No. 50-498/50-499 Enclosure 2 Attachment B3 - Piping Layout (S-1C)

MATCH LINE SEE S-1B i^I,

• UNIT 2 SUPPLY LINES INIT 1 SUPPLY LINES UNFT 2 RETURN LINES- UNIT 1 RETURN LINES-

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Jj Page 7 of 7

NOC-AE-19003684 Enclosure 3 Enclosure 3 Definition of Terms and Acronyms.

Document No. NOC-AE-19003684 Docket No. 50-498/50-499 Enclosure 3 ENCLOSURE 3 Revision 0 Definition of Terms and Acronyms Document No. NOC-AE-19003684 Docket No. 50-498/50-499 Proposed Alternative to ASME Boiler & Pressure Vessel Code Section XI Requirements for Repair/Replacement of Essential Coolinci Water (ECW) System Class 3 Buried Piping in Accordance with 10 CFR 50.55a(z)(1)

South Texas Project Nuclear Operating Company South Texas Project Electric Generating Station (STPEGS) Units 1 and 2 Page 1 of 13

Document No. NOC-AE-19003684 Docket No. 50-498/50-499 Enclosure 3 STP Nuclear Operating Company South Texas Project Electric Generating Station (STPEGS)

Units 1 and 2 ENCLOSURE 3 Definition of Terms and Acronyms TABLE OF CONTENTS : Attachment A - Definition of Terms : Attachment B - Acronyms Page 2 of 13

Document No. NOC-AE-19003684 Docket No. 50-498/50-499 Enclosure 3 STP Nuclear Operating Company South Texas Project Electric Generating Station (STPEGS)

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 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 pipe. 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 3 of 13

Document No. NOC-AE-19003684 Docket No. 50-498/50-499 Enclosure 3 Characteristic Value: Statistically based property value representing the 80% lower confidence bound on the Sth-percentile 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 Lav-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 Page 4 of 13

Document No. NOC-AE-19003684 Docket No. 50-498/50-499 Enclosure 3 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.

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

Expansion Rinci 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.

Faticiue: 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.

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, salt water, elevated temperature, abrasion, and chemical exposure.

Glass transition Temperature (Ta): 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.

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).

Page 5 of 13

Document No. NOC-AE-19003684 Docket No. 50-498/50-499 Enclosure 3 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 Desicin (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).

Lonq-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.

Misalianment: 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.

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

Page 6 of 13

Document No. NOC-AE-19003684 Docket No. 50-498/50-499 Enclosure 3 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 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.

Page 7 of 13

Document No. NOC-AE-19003684 Docket No. 50-498/50-499 Enclosure 3 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 Strenpth: 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 a 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.

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. Included in this definition are portions of component and process cooling systems that cool other safety systems or equipment (e.g., Component Cooling Water System and Service Water System piping, heat exchangers and pumps).

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

Thickeninci 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.

Page 8 of 13

Document No. NOC-AE-19003684 Docket No. 50-498/50-499 Enclosure 3 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 - Two-part epoxy adhesive for high strength composite bonding.

V-Wrap' C400H orV-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' EG50-B: Custom bi-directional high strength glass fiber fabric.

Watertidhtness 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 misalignmentand raised surface of the primary fiber direction.

Page 9 of 13

Document No. NOC-AE-19003684 Docket No. 50-498/50-499 Enclosure 3 STP Nuclear Operating Company South Texas Project Electric Generating Station (STPEGS)

Units 1 and 2 Attachment B - Acronyms ANII: Authorized Nuclear In-Service Inspector ANSI: American National Standards Institute AS: Aerospace Standards ASP: 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 RequesVReport 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 CMTR: Certified Material Test Report DSC: Differential Scanning Calorimetry DSR: Demand Strength Ratio ECW: Essential Cooling Water ECP: Essential Cooling Pond EPDM: Ethylene Propylene Diene Terpolymer

°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 Page 10 of 13

Document No. NOC-AE-19003684 Docket No. 50-498/50-499 Enclosure 3 FRP: Fiber Reinforced Polymer FSAR: Final Safety Analysis Report Ft: Feet GFRP: Glass Fiber Reinforced Polymer IAS: International Accreditation Service In: Inches

.181: Inservice Inspection ISO: International Organization for Standardization JHA: Job 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 MAB: Mechanical Auxiliary Building MTE: Measuring & Test Equipment NACE: National Association of Corrosion Engineers NCR: Non-Conformance 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 OE: Operating Experience OSHA: Occupational Safety and Health Administration Oz: Ounces Page 11 of 13

Document No. NOC-AE-19003684 Docket No. 50-498/50-499 Enclosure 3 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 QA/QC: Quality Assurance / Quality Control QAP: Quality Assurance Program RCA: Radiologically Controlled Area REST: Components being restrained

,RH: Relative Humidity 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 SYPB: System Pressure Boundary U: Unit UA: Unescorted Access UHS: Ultimate Heat Sink

.LIT: Ultrasonic Testing UFSAR: Updated Final Safety Analysis USAS: United States of America Standards WRF: Water Research Foundation Yd: Yard Page 12 of 13

Document No. NOC-AE-19003684 Docket No. 50-498/50-499 Enclosure 3 This Page intentionally blank Page 13 of 13

NOC-AE-19003684 Enclosure 10 Enclosure 10 Applications for Withholding Proprietary Information from Public Disclosure.

Document No. NOC-AE-19003684 Docket No. 50-498/50-499 Enclosure 10 ENCLOSURE 10 Revision 0 Applications for Withholdino Proprietary Information from F-'ublic Disclosure Document No. NOC-AE-19003684 Docket No. 50-498/50-499 Proposed Alternative to ASME Boiler & Pressure Vessel Code Section Xl Requirements for Repair/Replacement of Essential Coolina Water (ECW) System Class 3 Buried Pipincj in Accordance with 10 CFR 50.55a(z)(1)

South Texas Project Nuclear Operating Company South Texas Project Electric Generating Station (STPEGS) Units 1 and 2 page 1 of 12

Document No. NOC-AE-19003684 Docket No. 50-498/50-499 Enclosure 10 STP Nuclear Operating Company South Texas Project Electric Generating Station (STPEGS)

Units 1 and 2 ENCLOSURE 10 Applications for Withholdina Proprietary Information from Public Disclosure TABLE OF CONTENTS 0, Attachment A: Structural Group, "Application for Withholding Proprietary Information from Public Disclosure" 0, Attachment B: Simpson Gumpertz & Heger, "Application for Withholding Proprietary Information from Public Disclosure" PROPRIETARY INFORMATION NOTICE Transmitted herewith are the proprietary and non-proprietary versions of documents furnished to the NRC.

In order to conform to the requirements of 10 CFR 2.390 of the NRC regulations concerning the protection of proprietary information so submitted to the NRC, the information which is proprietary in the proprietary versions has been deleted in the non- proprietary versions. The justification for claiming the information so designated as proprietary is indicated in the non-proprietary versions.

page 2 of 12

strucWal TeCHNOLOGIES Document No. NOC-AE-19003684 Docket No. 50-498/50-499 Enclosure 10 Attachment A Structural Group, "Application for Withholding Proprietary Information from Public Disclosure U. S. Nuclear Regulatory Commission Document Control Desk 11555RockvillePike Rockviile.MD 20852

Subject:

Application for Withholding Proprietary Information from Public Disclosure

References:

1. Structural Technologies, Inc. LetterofTransmittal and attachments, titled letterof TransmittalStructural Group, Inc. Input for STPEGS Request for Use of Alternative".

2. South Texas Project Nuclear Operating Companyto Nuclear Regulatory Commission, 'Proposed Alternative to ASME Section Xl Requirements for Repair/Replacement of Essential Cooling WaterClassS Buried Piping inAccordance with 10CFR50.55a(z)(1)", Docket Nos. 50-498/499, Document No. NOC-AE-19003684.

3. 10 CFR 2.390, "Public Inspections, Exemptions, Requests /orWithholding".

Ladies and Gentlemen:

Structural Group, Inc. (SGI), has provided certain proprietary information to South Texas Project Nuclear Operating Company in connection with a request by South Texas Project Nuclear Operating Company for authorization from the U.S. Nuclear Regulatory Commission (NRC) to use an alternative to the requirements of 10 CFR 50.55a(z)(1 ). This application requests that proprietary information of SG I be protected from public disclosure.

The proprietary information forwhich withholding isbeing requested in Reference 1 isfurther identified intheattachedaffidavitsignedbytheowneroftheproprietary 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 publicdisclosurebytheNRC and addressing with specificity theconsiderations listed in paragraph (b)(4) of 10 CFR 2.390 of the NRC's regulations.

A request for withholding proprietary information has been previously approved by the NRC at the Surry Nuclear Station (Reference letter to Virginia Electric & Power Company from NRC, dated December 20, 2017, ML17303A068).

Accordingly, this letter authorizes the utilization of the accompanying Affidavit by STP Nuclear Operating Company. 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, (I

Scott Greenhaus Executive Vice President Page 3 of 12

strucWal T6CHNOLOG165 Document No. NOC-AE-19003684 Docket No. 50-498/50-499 Enclosure 10 AFFIDAVIT State of Maryland}

County of Howard)

Before me, the undersigned authority, personally appeared Scott Greenhaus, who, being by me duty sworn according to law, deposes and says that he is authorized to execute this Affidavit on behalf of Structural Group, Inc. and thatthe averments offactsetforth in this Affidavit are true and correct to the best of his knowledge, information, and belief,

• uocuSlBtwdby; W<~ ^UAuLxUS scofrxs?m<@m%us Executive Vice President Sworn to and subscribed before me this 11 day of September 2019

_zc c .'--

Notary Public ELPisE_P. BROWN

..yQlA.RY PUBLIC":'

ANNE ARUNDElCOUNTY MRYLANP""""

MYCOMMISStON E}(PJRESJUNE 9,2020 page 4 of 12

TGCHNOLOGieS Document No. NOC-AE-19003684 Docket No. 50-498/50-499 Enclosure 10 1,ScottGreenhaus,am Executive Vice President ofStructural Group, Inc. (SGI).

In my capacity as, Executive Vice President I 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 and its affiliates.

I am making this Affidavit in conformance with the provisions of 10 CFR 2.390 of the U. S. Nuclear Regulatory Commission (NRC) regulations and in conjunction with SGI's Application for Withholding Proprietary Information from Public Disclosure accompanying this Affidavit.

I have personal knowledge of the criteria and procedures utilized bySGI 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 NRC's regulations, the following is furnished for consideration by the NRC in determining whetherthe information soughttobewithheld from publicdisclosure 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 STPEGS request which include SGI proprietary information are: - Proposed Alternative to ASME Section Xl Requirements (Section listed below)

• Section 9 - Material Manufacturing

• Section 11 - Installation

• Section 12 - QA/QC Program

• Section 13 - Qualifications and Training

• Section 14 - Failure Modes and Effects Analysis (FMEA)

Enclosure 4 - Material Manufacture and Qualification Testing (withheld in its entirety)

• Attachment A - Material Manufacturing

• Attachment B - Material Qualification and Testing

• Attachment C - Watertightness Testing - Sample Procedures (withheld in its entirety)

• Attachment A - Document No. OPS-NUC-SAMPLE 1, "Process Description"

• Attachment B - Document No. OPS-NUC-SAMPLE-02, "Quality Plan"

• Attachment C - Document No. OPS-NUC-SAMPLE-02A, "QC Forms"

• Attachment D - Document No. OPS-NUC-SAMPLE-03, "Installation Procedure"

• Attachment E - Document No. OPS-NUC-SAMPLE-04, "Surface Preparation"

• Attachment F - Document No. OPS-NUC-SAMPLE-05, "Expansion Ring Assembly Installation" page 5 of 12

TeCHNOLOGIES Document No. NOC-AE-19003684 Docket No. 50-498/50-499 Enclosure 10 Enclosure 7 - Qualification and Training (withheld in its entirety)

• Attachment A - Summary of V-Wrap' CFRP System Installer Qualification Training Program Summary

• Attachment B - V-Wrap' CFRP System Installer Lesson Plan

• Attachment C - CFRP System Technical Training Lesson Plan

• Attachment D - Project Team Indoctrination Lesson Plan Enclosure 8 - Failure Modes Effects Analysis (withheld in its entirety)

• Attachment A - Failure Modes and Effects

• Attachment B - Manufacturing Related Causes of Failure and Preventative Actions

• Attachment C - Design Related Causes of Failure and Preventative Actions

• Attachment D - Installation Related Causes of Failure and Preventative Actions

• Attachment E - Post-lnstallation Related Causes of Failure and Preventative Actions Enclosure 9 - Operational Experience (withheld in its entirety)

• Attachment A - Successful Applications of CFRP Repair of Pipelines

• Attachment B - Failures of Previous CFRP Repair of Pipelines The information is of a type customarily held in confidence by SGI and not disclosed to the public. SGI hasa rational basis fordetermining 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 NRC withholding the information from public disclosure.

Under SGI's 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 ofwhich 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, orfuture development plans funded byaSGI or its customer, and programs of potential commercial value to SGI.

6) It contains patentable ideas, for which patent protection may be desirable.

page 6 of 12

TECHNOLOGIES Document No. NOC-AE-19003684 Docket No. 50-498/50-499 Enclosure 10 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. Itis, 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 availableto competitors diminishes SGI's ability to sell productsand 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) SGI's 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 tothe NRC in confidence and, under the provisions of 10 CFR 2.390, it is to be received in confidence by the NRC. 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 South Texas Project Nuclear Operating Company's Letter to the NRC, Proposed Alternative toASME Section Xl Requirements for Repair/Replacement of Essential Cooling Water Class 3 Buried Piping in Accordance with 10 CFR 50.55a(z)(1), Docket Nos. 50- 280/281, Document No.

NOC-AE-19003684, being transmitted by STPEGS letter and reflected in SGI's Application for Withholding Proprietary Information from Public Disclosure addressed to the NRC Document Control Desk. The proprietary information as submitted by SGI is that associated with the Proposed Alternative to ASME Section Xl Requirements for Repair/Replacement of Essential Cooling Water Class 3 Buried Piping in Accordance with 10 CFR 50.55a(z)(1) for STPEGS Units 1 and 2 and may be used only for that purpose.

This information is part of that which will enable Document No. NOC-AE-19003684to:

1) Provide in put to STP Nuclear Operating Company to provide to the NRC for review of the STPEGS Unit 1 and 2, 1 0 CPR 50.4'6 submittal; arid

2) Provide licensing support for the STPEGS submittal.

SGI owns or is permitted to use the proprietary information referenced in this Affidavit under agreements that include STPEGS's maintaining the confidentiality of such information, as contemplated in this Affidavit.

7 page 7 of 12

T6CHNOLOG16S Document No. NOC-AE-19003684 Docket No. 50-498/50-499 Enclosure 10 Further this information has substantial commercial value as follows;

1) The SGI plan to sell the use of this information to their customers forthe purpose of installing Carbon Fiber Reinforced Polymer (CFRP) in safety related piping.

2) That SG I can self-support and defense of the technology to their customers in the licensing process.

3) The information requested to bewithheld reveals the distinguishing aspects of a methodology which was developed by SG I.

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 meetNRC requirements forlicensing documentation without purchasing the rightto use the information.

6) Thedevelopmentofthetechnology 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 orderfor competitorstoduplicate this information, similartechnicalprogramswould have to be performed including a significant expenditure money and resources.

Further the deponent sayeth not.

page 8 of 12

Document No. NOC-AE-19003684 Docket No. 50-498/50-499 Enclosure 10 Attachment B Simpson Gumpertz & Heaer Application for Withholdinc) Proprietary Information from Public Disclosure SIMPSONGUMPERTZ&HEGER Engineering of Structures and Building Enclosures 17 September 2019 U.S. Nuclear Regulatory Commission Document Control Desk 11555 Rockville Pike Rockville, MD 20852

Subject:

Withholding of Certain Proprietary Information Pursuant to 10 CFR 2.390

Reference:

(1) Letter from STP Nuclear Operating Company to US NRC, "Proposed Alternative to ASME Boiler & Pressure Vessel Code Section Xl Requirements for Repair /Replacement of Essential Cooling Water System Class 3 Buried Piping in Accordance with 10 CFR 50.55a(z)(1)," Docket Nos. 50-498 and 50-499, Document No. NOC-AE-19003684.

(2) Letter from Structural Group, Inc. to NRC, "Application for Withholding Proprietary Information from Public Disclosure," dated September 11,2019.

In Reference (1), the STP Nuclear Operating Company will provide a submittal to the U.S. Nuclear Regulatory Commission (NRC) that contains certain proprietary information owned by Simpson Gumpertz

& Heger Inc. (SGH). SGH provided the information to STP Nuclear Operating Company or a STP Nuclear Operating Company affiliate to support the request made in Reference (1), and STP Nuclear Operating Company is authorized to use this information. As explained in the attached affidavit, SGH's proprietary information contained in Reference (1) qualifies for withholding under the exemption from disclosure set forth in the Freedom of Information Act ("FOIA"), 5 U.S.C. Section 552(b)(4), the Trade Secrets Act, 18 U.S.C. Section 1905, and NRC regulations 10 CFR 9.17(a)(4) and 2.390(a)(4) for trade secrets and commercial information. SGH respectfully requests that the NRC withhold this information from public disclosure. An affidavit supporting this request is attached.

In Reference (2), STP Nuclear Operating Company consultant Structural Group, Inc. also made a similar request for certain other information contained in Reference (1).

Please contact me by phone at 781.907.9231 or email at RPOjdrovic@sgh.com if you have any questions concerning this request.

Sincerely yours,

• f^f'c Rasko P. Ojdrovic Vice President and Senior Principal Ends.

page 9 of 12

Document No. NOC-AE-19003684 Docket No. 50-498/50-499 Enclosure 10 10 OR 2.390 Affidavit page 10 of 12

Document No. NOC-AE-19003684 Docket No. 50-498/50-499 Enclosure 10 SIMPSONGUMPERTZ&HEGER INC.

10 CFR 2.390 AFFIDAVIT OF RASKO P. OJDROVIC AFFIDAVIT 1, Rasko P. Ojdrovic, hereby state as follows:

(1) I am the Vice President and Senior Principal ofSimpson Gumpertz & Heger Inc. (SGH),

and I have been authorized to execute this affidavit on behalf of SGH.

(2) STP Nuclear Operating Company will submit a transmittal to the US NRC entitled "Proposed Alternative to ASME Boiler & Pressure Vessel Code Section Xl Requirements for Repair /Replacement of Essential Cooling Water System Class 3 Buried Piping in Accordance with 10 CFR 50.55a(z)(1)," Docket Nos. 50-498 and 50- 499, Document No. NOC-AE-19003684. Certain portions ofthattransmittal contain proprietary information owned bySGH. This information should be held in confidence by the NRC and withheld from public disclosure. The following is a list of the SGH proprietary information in STP Nuclear Operating Company's transmittal that SGH requests be withheld:

• Enclosure 1, "Summary, Proposed Alternative in Accordance with 1 0 CFR 50.55a(z)(1)", Sections 10,1 Sand 14

• Enclosure 4, Attachment C, "Watertightness Testing"

• Enclosure 5, "Design,"withheld in its entirety

• Enclosure 8, "Failure Mode Effects Analysis," Section 8A, 8C, 8D, 8E (3) In making this application forwithholding of proprietary information of which it is the owner, SGH believes thatthe information qualifies forwithholding underthe exemption from disclosure set forth in the Freedom of Information Act ("FOIA"), 5 U.S.C. Section 552(b)(4), the Trade Secrets Act, 18 U.S.C. Section 1905, and NRC regulations 10 CFR 9.17(a)(4) and 2.390(a)(4) for trade secrets and commercial information because:

i. This information is and has been held in confidence bySGH.

ii. This information is of a type that is customarily held in confidence by SGH, and there is a rational basis for doing so because the information includes proprietary information that was developed and compiled by SGH at a significant cost to SGH. This information is classified as proprietary because it contains information relevant to analytical approaches and methodologies not available elsewhere.

i". The information is being transmitted to the NRC voluntarily and in confidence.

iv. This information is not available in public sources and could not be gathered readily from other publicly available information.

v, A substantial effort has been expended by SGH to develop and evaluate this information. Public release of this information could lead to additional significant cost to SGH and is likely to cause substantial harm to SGH's competitive position and foreclose or reduce the availability ofprofit-making opportunities. The value of this information to SGH would be lost or devalued if the information were disclosed to the public.

vi. Public disclosure of the information sought to be withheld would provide other parties, including competitors, with valuable information. SGH's competitive advantage would be lost if its competitors are able to use the results of SGH's page 11 of 12

Document No. NOC-AE-19003684 Docket No. 50-498/50-499 Enclosure 10 activities to aid their own commercial activities. For example, SGH's competitive advantage would be lost if its competitors are able to use the results of SGH's analyses to normalize or verify their own process or if they are able to claim an equivalent understanding by demonstrating that they can arrive at the same or similar conclusions. Making such information available to competitors without there having been required to undertake a similar expenditure of resources would unfairly provide competitors with awindfall, and deprive SGH of the opportunity to exercise its competitive advantage to seek an adequate return on its large investment.

vii. The commercial value of the information extends beyond the original development cost and includes development of the expertise to determine and apply the appropriate evaluation process to the information. The research, development, engineering, and analytical costs that went into generating this information comprise a substantial investment of time and money by SGH. The precise value of this information is difficultto quantify, but clearly is substantial.

I declare under penalty of perjury under the laws of the United States of America that the foregoing is true and correct.

Executed on September 17, 2019. ,fcL^ Uf^f^/lC Rasko P. Ojdrovic page 12 of 12

NOC-AE-19003684 Enclosure 11 Enclosure 11 Redacted copy of Enclosure 1 .

Document No. NOC-AE-19003684 Docket No. 50-498/50-499 Enclosure 1 Redacted copy of Enclosure 1 ENCLOSURE 1 Revision 0 Summary Document No. NOC-AE-19003684 Docket No. 50-498/50-499 Proposed Alternative to ASME Boiler & Pressure Vessel Code Section Xl Requirements for Repair/Replacement of Essential CoolinQ Water (ECW) System Class 3 Buried Pipina in Accordance with 10 CFR 50.55a(z)(1)

South Texas Project Nuclear Operating Company South Texas Project Electric Generating Station (STPEGS) Units 1 and 2 contains Information that is being withheld from public disclosure under 10CFR 2.390. Upon separation this page is decontrolled.

Page 1 of 21

Document No. NOC-AE-19003684 Docket No. 50-498/50-499 Enclosure 1 PROPRIETARY WITHHOLD FROM PUBLIC DISCLOSURE UNDER 10CFR 2.390 contains information in Sections 9, 10, 11, 12, 13 and 14 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 submitter's 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 competitor's 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 submitteror 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.

Page 2 of 21

Document No. NOC-AE-19003684 Docket No. 50-498/50-499 Enclosure 1 STP Nuclear Operating Company South Texas Project Electric Generating Station (STPEGS)

Units 1 and 2 ENCLOSURE 1 Summary TABLE OF CONTENTS , Section 1: Plant Site - Units , Section 2: Interval Dates , Section 3: Requested Date for Approval , Section 4: ASME B&PVC Components Affected , Section 5: Applicable Code Edition and Addenda , Section 6: Applicable ASME B&PV Code Requirement , Section 7: Reason for Request , Section 8: Proposed Alternative and Basis for Use , Section 9: Material Manufacturing , Section 10: Design , Section 11: Installation , Section 12: QA/QC Program , Section 13: Qualifications and Training , Section 14: Failure Modes & Effects Analysis (FMEA) , Section 15: Summary of Enclosures Page 3 of 21

Document No. NOC-AE-19003684 Docket No. 50-498/50-499 Enclosure 1 STP Nuclear Operating Company South Texas Project Electric Generating Station (STPEGS)

Units 1 and 2 Summary Proposed Alternative in Accordance with 10 CFR 50.55a(z)(1)

1) Plant Site - Units South Texas Project Electric Generating Station (STPEGS), Units 1 and 2

2) Interval Dates The proposed alternative is requested for the STPEGS:

• Unit 1: Third 10-year Inservice Inspection (ISI) Interval which began on September 25, 2010 and ends on September 24, 2020 and the fourth 10-year ISI Interval which begins on September 25, 2020 and ends on September 24, 2030.

• Unit 2: Third ISI Interval which began on October 19, 2010 and ends on September 24, 2020 and the fourth 10-year ISI Interval which begins on September 25, 2020 and ends on September 24, 2030.

3) Requested Date for Approval The requested date for approval is June 30, 2020.

4) ASME Code B&PVC Components Affected a) The primary function of the Essential Cooling Water (ECW) System is to provide cooling water for carrying heat from safety-related (S-R) components to the Essential Cooling Pond (ECP), which acts as the ultimate heat sink (UHS). The ECW System consists of three (3) redundant trains, and, either directly or by means of intermediate systems, provides cooling required for S-R components during and after any "design basis accident" such as a Loss of Coolant Accident (LOCA), Loss of Offsite Power (LOOP), or a Safe Shutdown Earthquake (SSE).

The ECW System functions during normal operation and other non- emergency operating modes to transfer heat loads from services equipment to the ECP. The ECW System provides cooling water to the following components during all emergency and non-emergency modes of operation:

i) Standby Diesel Generator (DG) Inter-Cooler.

Page 4 of 21

Document No. NOC-AE-19003684 Docket No. 50-498/50-499 Enclosure 1 ii) Standby DG Auxiliary Equipment Lube Oil Cooler and Water Jacket.

iii) Essential Chilled Water Chiller Condenser.

iv) Component Cooling Water Heat Exchanger.

v) Component Cooling Water Pump Supplementary Cooler.

b) Bio-treatment consists of sodium hypochlorite (12%), sodium bromide (10/1 ratio) and poly acrylic acid which is added as an anti-scaling agent.

c) A detailed listing of the piping sections to be lined with the proposed V-Wrap' Carbon Fiber Reinforced Polymer (CFRP) Composite System is provided in Enclosure 2. The affected piping:

i) Consists of 30-inch Essential Cooling Water (ECW) System intake piping and fittings from the Intake Structure to the MAB and the discharge piping from the MAB to the discharge structure.

ii) Was designed and installed in accordance with American Society of Mechanical Engineers (ASME), Boiler & Pressure Vessel Code (B&PVC),Section III "Rules for Construction of Nuclear Facility Components", Division 1, Subsection ND, "Class 3 Components", 1974 Edition, with addenda up to and including Winter 1975.

iii) Has no pumps, valves, expansion joints, flange joints, or threaded connections included in the scope of work.

iv) Is below grade, buried and has long straight runs with minimal bends and elbows. See Enclosure 2 for specific details.

v) Has a coal-tar coating on the pipe exterior surfaces and an impressed current cathodic protection (ICCP) system installed to mitigate corrosion. No degradation of the exterior pipe wall has been identified to date. Soil has high resistive characteristics further reducing the possibility of corrosion on the piping exterior surface.

vi) Is fabricated of aluminum-bronze material conforming to ASTM SB169, "Standard Specification for Aluminum Bronze Sheet, Strip and Rolled Bar", Alloy CA-614.

5) Applicable ASME B&PV Code Edition and Addenda For the third ISI interval the applicable code is ASME B&PVC, Section Xl, "Rules for Inservice Inspection of Nuclear Power Plant Components", 2004 Edition, No Addenda.

For the fourth ISI interval the applicable code is ASME B&PVC, Section Xl, "Rules for Inservice Inspection of Nuclear Power Plant Components", 2013 Edition, No Addenda.

Page 5 of 21

Document No. NOC-AE-19003684 Docket No. 50-498/50-499 Enclosure 1

6) Applicable ASME B&PV Code Requirement The ASME B&PVC requirement applicable to repairing piping is Section Xl, "Rules for In-Service Inspection of Nuclear Power Plant Components", Article IWA-4000, subparagraph IWA-4221(b)(1), which states:

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.

7) Reason for Request STPEGS will be performing ISI of the ECW piping in February 2020 and is pro-actively requesting approval to use the proposed V-Wrap' CFRP Composite as part of the contingency planning process to address any potential degradation within the ECW System pipe wall. The most likely internal degradation mechanism is expected to be flow induced erosion. Buried ECW piping is not susceptible to selective leaching due to pipe material composition.

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 recent technology improvement which was not available in the 1960's or 1970's to meet the construction code to which original ECW System piping was constructed. There are no provisions in ASME B&PVC, Section Xl or an available ASME B&PVC,Section III 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 STPEGS, Units 1 and 2 ECW System piping that provides an acceptable level of quality and safety. It is proposed that the ECW System piping be repaired with the V-Wrap' CFRP Composite System produced by Structural Technologies, LLC. Enclosure 2 provides the proposed scope.

The V-Wrap' CFRP Composite System has been previously approved by the NRC and installed on the interior of concrete encased, buried carbon steel piping for a Safety Related (S-R) application at the Surry Nuclear Station in 2018 over two outages with the upgrade program continuing through 2024 (Reference letter to Virginia Electric & Power Company from NRC, dated December 20, 2017, ML17303A068).

The V-Wrap' CFRP composite system piping is proposed to have a minimum 50-year service life and any repair/replacement and/or inspections of the CFRP Composite System will be conducted in accordance with the applicable edition ofASME B&PVC, Section Xl or alternative thereto, at the time of the repair/replacement or inspection.

Page 6 of 21

Document No. NOC-AE-19003684 Docket No. 50-498/50-499 Enclosure 1 Design, qualification, manufacture, installation, testing, and inspection details of the proposed V-Wrap' CFRP Composite System are discussed in subsequent sections of this Enclosure, as well as Enclosures 2 through 9. The approach used allows for the installation of the V-Wrap' CFRP Composite System for the complete length of the ECW System piping from the Intake Structure to the Mechanical Auxiliary Building (MAB) or partial lengths depending on ISI results.

Inspections on ECW Buried Piping will be conducted in each ten year period, beginning with the ten year period prior to extended operation. The inspections will be conducted IAW criteria set forth in the STP Updated Final Safety Analysis Report (UFSAR), Chapter 19A, Section 19A. 1.18 "Buried Piping and Tanks Inspection".

The ISI inspection activities that will be implemented following installation of the proposed CFRP System are discussed below:

a) For the CFRP Composite System installed under this Alternative, ISI activities will include system flow testing at least once each ISI Interval, for the remaining life of the plant, to verify adequate flow through the ECW System piping. This testing will be in accordance with STPEGS Unit 1, System Pressure Test Plans, third and fourth ISI Interval, as well as STPEGS Unit 2, System Pressure Test Plans, third and fourth 181 Interval.

The testing, as described in the ISI Test Plan, is in accordance with ASME B&PVC, Section Xl, IWA-5244(2), which directs that the system pressure test (OPSP15-EW-0001) for non-isolable buried components shall consist of a test to confirm that flow during operation is not impaired. This testing will demonstrate and document performance ofVT-2 examinations required by STPEGS' ISI program on the ECW Systems' flow paths that support the required safety functions.

(1) ISI are performed by qualified personnel who inspect and evaluate the condition of the piping and components to:

(a) Determine the extent of biological fouling, sediment buildup, and corrosion (including microbiologically induced corrosion MIC).

(b) Assess the effectiveness of biofouling control mechanisms and protective coating technologies.

(c) Monitor the material integrity of metallic components and protective coating, and installed expansion ring seals.

(2) Inspections on ECW Buried Piping will be conducted in each ten year period, beginning with the ten year period prior to extended operation. The inspections will be conducted IAW criteria set forth in the STP Updated Final Safety Analysis Report (UFSAR), Chapter 19A, Section 19A.1.18 "Buried Piping and Tanks Inspection".

Page 7 of 21

Document No. NOC-AE-19003684 Docket No. 50-498/50-499 Enclosure 1 (3) Corrosion Inspection Criteria to be identified and quantified includes:

(a) Localized Pitting.

(b) General Pipe Wall Thinning.

(c) Microbiologically Influenced Corrosion (MIC).

(4) Biological inspection criteria include inspecting for typical biological growth and species including:

(a) Hydroid and bryozoan growth.

(b) Clams in the ECW Intake Structure Pump Bays General macrofouling.

Page 8 of 21

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Document No. NOC-AE-19003684 Docket No. 50-498/50-499 Enclosure 1

15) Summary of Enclosures Additional enclosures that are attached are listed below; a) Enclosure 2 - Scope and Schedule b) Enclosure 3- Definitions of Terms and Acronyms i) Attachment A - Definition of Terms ii) Attachment B - Acronyms c) Enclosure 4- Material Manufacturing and Material Qualification i) Attachment A - Material Manufacturing ii) Attachment B - Material Qualification and Testing iii) Attachment C - Watertightness Testing d) Enclosure 5- Design i) Attachment A - Design Basis ii) Attachment B - Design Illustrations iii) Attachment C - Typical Calculations e) Enclosure 6- Sample Procedures i) Attachment A - Document No. OPS-NUC-SAMPLE 1, Process Description ii) Attachment B - Document No. OPS-NUC-SAMPLE-02, Quality Plan iii) Attachment C - Document No. OPS-NUC-SAMPLE-02A, QC Forms iv) Attachment D - Document No. OPS-NUC-SAMPLE-03, Installation Procedure v) Attachment E - Document No. OPS-NUC-SAMPLE-04, Surface Preparation vi) Attachment F - Document No. OPS-NUC-SAMPLE-05, Expansion Ring Assembly Installation f) Enclosure 7- Sample Training Plans i) Attachment A - Summary of V-Wrap' CFRP System Installer Qualification Training Program Summary ii) Attachment B - V-Wrap' CFRP System Installer Lesson Plan iii) Attachment C - CFRP System Technical Training Lesson Plan iv) Attachment D - Project Team Indoctrination Lesson Plan Page 19 of 21

Document No. NOC-AE-19003684 Docket No. 50-498/50-499 Enclosure 1 g) Enclosure 8- Failure Modes Effects Analysis (FMEA) i) Attachment A - Failure Modes and Effects ii) Attachment B - Manufacturing Related Causes of Failure and Preventative Actions iii) Attachment C - Design Related Causes of Failure and Preventative Actions iv) Attachment D - Installation Related Causes of Failure and Preventative Actions v) Attachment E - Post-Installation Related Causes of Failure and Preventative Actions h) Enclosure 9- Operational Experience i) Attachment A - Successful Applications of CFRP Repair of Pipelines ii) Attachment B - Failures of Previous CFRP Repair of Pipelines

16) Duration of Proposed Alternative The CFRP repair system alternative will be implemented in the Unit 1 third 10-year ISI Interval that began on September 25, 2010 and ends on September 24, 2020 and the fourth 10-year ISI Interval which begins on September 25, 2020 and ends on September 24, 2030.

The CFRP composite system alternative for Unit 2 will be implemented during the Unit 2 third ISI Interval which began on October 19, 2010 and ends on September 24, 2020 and the fourth 10-year ISI Interval which begins on September 25, 2020 and ends on September 24, 2030. The CFRP composite system alternative will remain in place for the life of plant.

The repaired piping 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 Boiler & Pressure Vessel (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.

17) Precedents The Nuclear industry has implemented multiple projects involving CFRP repair systems with the same project team (Designer, Manufacturer, and Installer) on approximately 600 linear feet (LF) of 30-inch, 42-inch, and 96-inch Safety Related CW and SW carbon steel pipe with similar configurations. (See Enclosure 9, Attachment A for additional operating experience information).

18) References a) ASME Section XI, Rules for In-Service Inspection of Nuclear Power Plant Components, 2004 and 2013 Editions, No Addenda b) ASME Section III Rules for Construction of Nuclear Facility Components, Division 1, Subsection ND, Class 3 Components, 1974 Edition, with addenda up to and including Winter 1975.

Page 20 of 21

Document No. NOC-AE-19003684 Docket No. 50-498/50-499 Enclosure 1 c) South Texas Project Electric Generating Station, Units 1 and 2, Updated Final Safety Analysis Report (UFSAR), Section 9.2.1.2, and 9A - Essential Cooling Water (ECW)

System.

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