RA-20-0353, Proposed Alternative to ASME Boiler & Pressure Vessel Code Section XI Requirements for Repair/Replacement of Service Water (SW) System 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 Service Water (SW) System Buried Piping in Accordance with 10 CFR 50.55a(z)(1)

ML21055A797
Person / Time
Site:	Brunswick
Issue date:	02/24/2021
From:	Krakuszeski J Duke Energy Progress
To:	Document Control Desk, Office of Nuclear Reactor Regulation
Shared Package
ML21055A796	List: RA-20-0353, Proposed Alternative to ASME Boiler & Pressure Vessel Code Section XI Requirements for Repair/Replacement of Service Water (SW) System Buried Piping in Accordance with 10 CFR 50.55a(z)(1)
References
RA-20-0353
Download: ML21055A797 (51)

Text

Enclosures 1, 4, 5, 6, 7, 8, and 9 Contain Proprietary Information Contains Security-Related Information Withhold in Accordance with 10 CFR 2.390 When Separated from Proprietary/Sensitive Information This Document Is Decontrolled John A. Krakuszeski Vice President Brunswick Nuclear Plant 8470 River Rd SE Southport, NC 28461 o: 910.832.3698 Enclosures 1, 4, 5, 6, 7, 8, and 9 Contain Proprietary Information Contains Security-Related Information Withhold in Accordance with 10 CFR 2.390 When Separated from Proprietary/Sensitive Information This Document Is Decontrolled February 24, 2021 Serial: RA-20-0353 10CFR 50.55a(z)(1)

U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Brunswick Steam Electric Plant, Unit Nos. 1 and 2 Docket Nos. 50-325 and 50-324 Renewed License Nos. DPR-71 and DPR-62

Subject:

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

Ladies and Gentlemen:

In accordance with the provisions of 10 CFR 50.55a(z)(1), Duke Energy Progress, LLC (Duke) requests approval to allow the use of the V-Wrap' Carbon Fiber Reinforced Polymer (CFRP)

Composite System for the internal repair of the buried Service Water (SW) System piping at Brunswick Steam Electric Plant (BSEP).

The subject BSEP SW System piping is experiencing degradation of the cement mortar lining materials. American Society of Mechanical Engineers (ASME) Boiler & Pressure Vessel Code, In-service 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 BSEP does not provide the requirements for the design, fabrication, installation, examination, and testing of a CFRP composite system. Consequently, an USNRC-approved alternative is required to permit the use of a CFRP composite system for the internal repair of the SW System piping that provides an acceptable level of quality and safety.

Repair 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 provided in Enclosure 1. Additional information in support of the requested alternative is provided in Enclosures 2 through 9.

Enclosures 1, 4, 5, 6, 7, 8, and 9 Contain Proprietary Information Contains Security-Related Information Withhold in Accordance with 10 CFR 2.390 When Separated from Proprietary/Sensitive Information This Document Is Decontrolled U.S. Nuclear Regulatory Commission Page 2 of 4 Enclosures 1, 4, 5, 6, 7, 8, and 9 Contain Proprietary Information Contains Security-Related Information Withhold in Accordance with 10 CFR 2.390 When Separated from Proprietary/Sensitive Information This Document Is Decontrolled BSEP Unit 1 is presently in the 5th 10-year inservice inspection (ISI) interval which ends on May 10, 2028. BSEP Unit 2 is presently in the 5th 10-year inservice inspection (ISI) interval which ends on May 10, 2028. As further discussed in the enclosed alternative request and supporting information, the repair effort at BSEP Unit 1 will be performed during 5th 10-year ISI interval which began on May 11, 2018. Repair efforts at BSEP Unit 2 will be performed during the 5th 10-year ISI interval which began on May 11, 2018.

A pre-submittal teleconference was held on January 21, 2021, in which Duke presented its plan to the USNRC with respect to the use of a CFRP Composite System to repair existing SW System piping.

Associated in part with post September 11, 2001, response related to security sensitive information, Duke has determined that the illustrations provided in Enclosure 2, Attachments B, C, D, E, and F should be withheld from public disclosure consistent with USNRC Regulatory Issue Summary (RIS) 2005-31, Revision 1, "Control of Security-Related Sensitive Unclassified Nonsafeguards Information Handled by Individuals, Firms, and Entities subject to USNRC Regulation of the Use of Source, Byproduct, and Special Nuclear Material." Duke has concluded that the illustrations contained in Enclosure 2 meet the intent of RIS 2005-31 which states, in part: "information should be withheld to prevent inadvertent assistance to those who might wish to use security-related information for malevolent acts." Therefore, Duke requests the illustrations provided in Enclosure 2, Attachments B, C, D, E, and F be withheld from public disclosure in accordance with 10 CFR 2.390.

Enclosures 1, and 5 through 9 contain supporting technical information for the proposed alternative request prepared by Structural Group, Inc., and Simpson Gumpertz & Heger, Inc.,

that includes information proprietary to these two companies. This information is supported by affidavits, signed by Structural Group, Inc., and Simpson Gumpertz & Heger, Inc., the owners of the information. The affidavits set forth the bases by which the information may be withheld from public disclosure by the Commission and addresses with specificity the considerations listed in paragraph (b)(4) of 10 CFR 2.390 of the Commission's regulations.

It is respectfully requested that the information, which is proprietary to Structural Group, Inc. and Simpson Gumpertz & Heger, Inc., be withheld from public disclosure in accordance with 10 CFR 2.390 of the Commissions regulations. The affidavits are included in Structural Group, Inc., and Simpson Gumpertz & Heger, Inc. letters to the USNRC entitled, "Application for Withholding Proprietary Information from Public Disclosure," and "Withholding of Certain Proprietary Information Pursuant to 10 CFR 2.390." The Structural Group, Inc., and Simpson Gumpertz &

Heger, Inc., authorization letters are provided in Enclosure 10. In conformance to the requirements of 10 CFR 2.390 concerning the protection of proprietary information, the proprietary information included in Enclosure 1 is contained within brackets. As Enclosures 4 through 9 are considered to be proprietary in their entirety, these enclosures have been marked proprietary in the manner authorized by 10 CFR 2.390(b)(1)(i)(A).

Enclosures 1, 4, 5, 6, 7, 8, and 9 Contain Proprietary Information Contains Security-Related Information Withhold in Accordance with 10 CFR 2.390 When Separated from Proprietary/Sensitive Information This Document Is Decontrolled U.S. Nuclear Regulatory Commission Page 3 of 4 Duke requests USNRC review and approval of this alternative request by November 30, 2021, to support the use of the proposed alternative for plant outage planning purposes.

No regulatory commitments are contained in this submittal.

Should you have any questions concerning this letter, or require additional information, please contact Art Zaremba, Director - Nuclear Fleet Licensing, at (980) 373-2062.

Sincerely, John A. Krakuszeski Enclosures 1, 4, 5, 6, 7, 8, and 9 Contain Proprietary Information Contains Security-Related Information Withhold in Accordance with 10 CFR 2.390 When Separated from Proprietary/Sensitive Information This Document Is Decontrolled

Enclosures 1, 4, 5, 6, 7, 8, and 9 Contain Proprietary Information Contains Security-Related Information Withhold in Accordance with 10 CFR 2.390 When Separated from Proprietary/Sensitive Information This Document Is Decontrolled U.S. Nuclear Regulatory Commission Page 4 of 4 Enclosures 1, 4, 5, 6, 7, 8, and 9 Contain Proprietary Information Contains Security-Related Information Withhold in Accordance with 10 CFR 2.390 When Separated from Proprietary/Sensitive Information This Document Is Decontrolled

Enclosures:

1.

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

(Sections 8, 9, 10, 11, 12, 13, and 14 Proprietary)

2.

Scope and Schedule Summary (Attachments B - E, Security-Related)

3.

Definition of Terms and Acronyms

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 (Proprietary)

10. Applications for Withholding Proprietary Information from Public Disclosure

11. Proposed Alternative to ASME Section XI Requirements for Repair/Replacement of Service Water (SW) System Buried Piping in accordance with 10 CFR 50.55a(z)(1)

(Non-Proprietary) 12 Scope and Schedule Summary (Non-Security-Related) cc:

L Dudes, USNRC Regional Administrator, Region II G. Smith, USNRC Sr. Resident Inspector - BSEP A. Hon, USNRC NRR Project Manager - BSEP With Enclosures 3, 10,11, and 12 Only Chair - North Carolina Utilities Commission C. Dautrich - North Carolina Department of Labor Bureau Chief

RA-20-0353 Page 1 of 15 ENCLOSURE 3 Definition of Terms and Acronyms Duke Energy Progress, LLC Brunswick Steam Electric Plant (BSEP), Unit Nos. 1 and 2 Relief Request Serial No. RA-20-0353 Request for Relief RA-20-0353 for a Proposed Alternative to ASME Boiler & Pressure Vessel Code Section XI Requirements for Repair/Replacement of Service Water System Piping in Accordance with 10 CFR 50.55a(z)(1)

RA-20-0353 Page 2 of 15 Duke Energy Progress, LLC Brunswick Steam Electric Plant (BSEP), Unit Nos. 1 and 2 ENCLOSURE 3 Definition of Terms and Acronyms TABLE OF CONTENTS

Attachment A - Definition of Terms

Attachment B - Acronyms

RA-20-0353 Page 3 of 15 Duke Energy Progress, LLC Brunswick Steam Electric Plant (BSEP), Unit Nos. 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 terminal ends 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.

RA-20-0353 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:

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

RA-20-0353 Page 5 of 15 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: Chemical and load exposure conditions to which the structure is subjected to during its service.

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

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

Expansion Ring Assembly: 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.

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 (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: Layer of reinforcing fabric and epoxy.

RA-20-0353 Page 6 of 15 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: 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): Period of continuous application of a load, or the cumulative period of intermittent applications of a load.

Load Factor: 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): 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: Quantity of material produced in a single manufacturing run (Also see Batch).

Lot Number: 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: 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: 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: Loads and load combinations specified for the design.

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

RA-20-0353 Page 7 of 15 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: 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: 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: 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: Parameter in reliability analysis that is correlated to probability of failure.

Required Strength: 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.

RA-20-0353 Page 8 of 15 Resistance Factor: 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 terminal ends.

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.

Service Water Conventional Header: Service water conventional header normally supplies cooling water to the turbine building closed cooling water heat exchangers, lubricating water for the circulating water pump bearings, the Chlorination System (system no longer used), and fill water for the circulating water system. When required, the conventional header also provides cooling water to the RHR "A" heat exchanger and the RHRSW pumps "A" and "C" and their motor cooling. As stated previously, these parallel heat loads can be cross-connected between each of the service water headers by means of normally closed cross-connect valves.

Service Water Nuclear Header: Components normally supplied from the service water nuclear header are the reactor building closed cooling water heat exchangers, RHR "B" heat exchanger, all RHR pump seal cooling heat exchangers, all fan cooling units for the pump rooms in the reactor building (Core Spray and RHR pump rooms), RHR service water (RHRSW) pumps "B" and "D" and their motor cooling, and standby diesel generator cooling. The nuclear portion of the Service Water System is essentially a manual operation except for the vital header isolation valve to the nuclear header. This valve is backed up with a remote manually operated valve which can be cycled periodically.

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.

RA-20-0353 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.

System Pressure Boundary: 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: Attainment of a sufficiently robust state to resist damage by contact or handling.

Terminal End: The zone at and near the repair terminations where host pipe has at least the required minimum wall thickness.

Thickening Agents: 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: 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 - 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' EG50-B: 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.

RA-20-0353 Page 10 of 15 Weibull Distribution: Probability distribution function used in evaluation of strength and life data.

Wet Lay-Up: 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: 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.

RA-20-0353 Page 11 of 15 Duke Energy Progress, LLC Brunswick Steam Electric Plan (BSEP), Unit Nos. 1 and 2 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 CLC1a CLC1b CLC2 CLC3 CLC4 CLC5 CLC6 CLC7 CLC8: Circumferential Load Combinations CLS1 CLS2 CLS3 CLS4: Circumferential Limit States COC: Certification of Conformance/Compliance CMTR: Certified Material Test Report CPS: Centipoise CR: Condition Report CS: Core Spray

RA-20-0353 Page 12 of 15 DSC: Differential Scanning Calorimetry DSR: Demand Strength Ratio EDG: Emergency Diesel Generator 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 LLC1 LLC2 LLC3 LLC4: Longitudinal Load Combinations LLS1 LLS2 LLS3 LLS4 LLS5: Longitudinal Limit States

RA-20-0353 Page 13 of 15 LOCA: Loss of Coolant Accident LOOP: Loss of Offsite Power LRFD: Load and Resistance Factor Design LS: Limit State 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 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

RA-20-0353 Page 14 of 15 PSI: Pounds per square inch PSF: Pounds per square foot QA/QC: Quality Assurance / Quality Control QAP: Quality Assurance Program QC: Quality Control RCC: Reactor Closed Cooling RCA: Radiologically Controlled Area REST: Components being restrained RH: Relative Humidity RHR: Residual Heat Removal 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

RA-20-0353 Page 15 of 15 SSPC: Society for Protective Coatings SW: Service Water SYPB: System Pressure Boundary TCC: Turbine Building Closed Cooling U: Unit UA: Unescorted Access UHS: Ultimate Heat Sink UT: Ultrasonic Testing USAS: United States of America Standards WRF: Water Research Foundation Yd: Yard

RA-20-0353 0 Page 1 of 14 ENCLOSURE 10 Duke Energy Progress, LLC Brunswick Steam Electric Plant (BSEP), Unit Nos. 1 and 2 Relief Request Serial No. RA-20-0353 Request for Relief RA-20-0353 for a Proposed Alternative to ASME Boiler & Pressure Vessel Code Section XI Requirements for Repair/Replacement of Service Water System Piping in Accordance with 10 CFR 50.55a(z)(1)

RA-20-0353 0 Page 2 of 14 Duke Energy Progress, LLC Brunswick Steam Electric Plant (BSEP), Unit Nos. 1 and 2 ENCLOSURE 10 TABLE OF CONTENTS Attachment A: Structural Group, Inc., Application for Withholding Proprietary Information from Public Disclosure Attachment B: Simpson Gumpertz & Heger, Inc., Application for Withholding Proprietary Information from Public Disclosure

RA-20-0353 0 Page 3 of 14 ATTACHMENT A STRUCTURAL GROUP, INC., "APPLICATION FOR WITHHOLDING PROPRIETARY INFORMATION FROM PUBLIC DISCLOSURE"

[Document Begins on Next Page]

struc'tural group 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:

RA-20-0353 0 Structural Group, Inc. (SGI), has provided certain proprietary information for Brunswick Electric Steam Plant (BSEP) Unit Nos. 1 and 2 in connection with a request by Duke Energy Progress, LLC 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) (Reference 4). This application requests that proprietary information of SGI be protected from public disclosure. The proprietary information for which withholding is being requested in the reference 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 at the Surry Nuclear Station (Reference 1), South Texas Project (Reference 2) and Arkansas Nuclear One (Reference 3). Accordingly, this letter authorizes the utilization of the accompanying Affidavit by Duke Energy Progress, 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

REFERENCES:

1.

USN RC letter to Virginia Electric & Power Company, "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)", (ML17303A068), dated December 20, 2017.

2.

USNRC letter to South Texas Project Nuclear Operating Company, "South Texas Project Units 1 and 2 - Proposed Alternative RR-ENG-3-24 to ASME Boiler & Pressure Page 4 of 14

RA-20-0353 O Code Requirements for Repair of Essential Cooling Water (ECW) System Class 3 Buried Piping", (EPID-L-2019-LLR-0096), dated September 3, 2020.

3.

Letter from Entergy Operations, Inc. to USNRC Document Control Desk, " Proposed Alternative to ASME Boiler & Pressure Vessel Code Section XI Requirements for Repair/Replacement of Service Water (SW) System Piping in Accordance with 10 CFR 50.55a(z)(1)," Docket Nos. 50-313 and 50-368, Document No. 0CAN072001.

4.

Letter from Duke Energy Progress, LLC to USNRC Document Control Desk, " Proposed Alternative to ASME Boiler & Pressure Vessel Code Section XI Requirements for Repair/Replacement of Service Water (SW) System Piping in Accordance with 10 CFR 50.55a(z)(1)," Docket Nos. 50-325 and 50-324, RA-20-0353.

5.

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

Page 5 of 14

Structural Group, Inc.

10150 Old Columbia Road Columbia, MD 21046 State of Maryland )

County of Howard )

AFFIDAVIT RA-20-0353 0 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 that the averments of fact set forth in this Affidavit are true and correct to the best of his knowledge, information, and belief.

Scott Greenhaus Executive Vice President Page 6 of 14

RA-20-0353 Enclosure I, Scott Greenhaus, am Executive Vice President of Structural 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 (USNRC) regulations and in conjunction with SGl's 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 1 0 CFR 2.390 of the USNRC's 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 Duke Energy Progress, LLC request which include SGI proprietary information are: - Proposed Alternative to ASME Section XI Requirements for Repair/Replacement of ECP Supply Class 3 Buried Piping in accordance with 10 CFR 50.55a(z)(1)

(sections listed below)

Section 8 - Proposed Alternative and Basis for Use Section 9 - Material Manufacturing and Material Qualification Section 1 O - Design Section 11 - Installation Section 12 - QA/QC Program Section 13 - Qualifications and Training Section 14-Failure Modes & Effects Analysis - Material Manufacture and Material Qualification (withheld in its entirety including all attachments) - Sample Procedures (withheld in its entirety including all attachments) - Sample Training Plans (withheld in its entirety including all attachments) - Failure Modes Effects Analysis (withheld in its entirety including all attachments) - Operating Experience (withheld in its entirety including all attachments)

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 Page 7 of 14 10

RA-20-0353 Enclosure 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 SGl'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 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.

6.

It 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 SGl's competitive position.

2.

It is information that is marketable in many ways. The extent to which such information is available to competitors diminishes SGl's 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.

Page 8 of 14 10

RA-20-0353 Enclosure

6.

SGl'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 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 Duke Energy Progress, LLC letter to the USNRC, "Proposed Alternative to ASME Boiler & Pressure Vessel Code Section XI Requirements for Repair/Replacement of Service Water (SW) System Piping in Accordance with 10 CFR 50.55a(z)(1)", Docket Nos. 50-325/324, Document No. RA-20-0353 being transmitted by Duke Energy Progress, LLC letter and reflected in SGl's Application for Withholding Proprietary Information from Public Disclosure addressed to the USNRC Document Control Desk. The proprietary information as submitted by SGI is that associated with the "Proposed Alternative to ASME Boiler & Pressure Vessel Code Section XI, Requirements for Repair/Replacement of Service Water (SW) System Piping in Accordance with 10 CFR 50.55a(z)(1)" for Brunswick Electric Steam Plant (BSEP), Unit Nos. 1 and 2, and may be used only for that purpose.

This information is part of that which will enable SGI to:

1.

Provide input to Duke Energy Progress, LLC. to provide to the USNRC for review of the Brunswick Electric Steam Plant (BSEP), Unit Nos. 1 and 2, 10 CFR 50.46 submittal; and

2.

Provide licensing support for the Duke Energy Progress, LLC submittal.

SGI owns or is permitted to use the proprietary information referenced in this Affidavit under agreements that include Duke Energy Progress, LLC maintaining the confidentiality of such information, as contemplated in this Affidavit.

Further this information has substantial commercial value as follows:

1.

The SGI plan to sell the use of this information to their customers for the purpose of installing the V-Wrap TM 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.

Page 9 of 14 10

RA-20-0353 Enclosure

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.

Page 10 of 14 10

RA-20-0353 0 Page 11 of 14 ATTACHMENT B SIMPSON GUMPERTZ & HEGER, INC., "APPLICATION FOR WITHHOLDING PROPRIETARY INFORMATION FROM PUBLIC DISCLOSURE"

[Document Begins on Next Page]

18 February 2021 U.S. Nuclear Regulatory Commission Document Control Desk 11555 Rockville Pike Rockville, MD 20852

Subject:

Application for Withholding of Certain Proprietary Information per 10 C.F.R. § 2.390

References:

(1) Letter from Duke Energy Progress to USNRC Document Control Desk, Proposed Alternative to ASME Boiler & Pressure Vessel Code Section XI Requirements for Repair/Replacement of Service Water (SW) System Piping in accordance with 10 CFR 50.55a(z)(1), Docket Nos. 50-325 and 50-324, Serial No. RA-20-0353.

(2) 10 CFR 2.390, Public inspections, exemptions, requests for withholding.

(3) U.S. Nuclear Regulatory Commission (USNRC) letter to Virginia Electric & Power Company, 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), (ML17303A068),

dated December 20, 2017.

(4) USNRC letter to South Texas Project Nuclear Operating Company, South Texas Project Units 1 and 2 - Proposed Alternative RR-ENG-3-24 to ASME Boiler & Pressure Code Requirements for Repair of Essential Cooling Water (ECW) System Class 3 Buried Piping, (EPID L-2019-LLR-0096), dated September 3, 2020.

(5) Letter from Entergy Operations, Inc. to USNRC Document Control Desk, Proposed Alternative to ASME Boiler & Pressure Vessel Code Section XI Requirements for Repair/Replacement of Service Water (SW) System Piping in accordance with 10 CFR 50.55a(z)(1), Docket Nos. 50-313 and 50-368, Document No. 0CAN072001.

Simpson Gumpertz & Heger Inc. (SGH) has provided certain proprietary information for Brunswick Steam Electric Plant Unit Nos. 1 and 2 in connection the Duke Energy Progress, LLC request for authorization (Reference 1) from the U.S. Nuclear Regulatory Commission (USNRC) to use an alternative to the requirements of the American Society of Mechanical Engineers Boiler & Pressure Vessel Code,Section XI, IWA-42221(b), pursuant to 10 C.F.R. § 50.55a(z)(1). This application requests that SGH proprietary information be withheld by the USNRC from public disclosure. The proprietary information is identified in the attached affidavit, which sets forth the basis on which the information may be withheld and addresses considerations in 10 C.F.R. § 2.390(b)(4) (Reference 2).

Requests for withholding proprietary information have been previously approved by the USNRC for the Surry Nuclear Station (Reference 3), South Texas Project (Reference 4), and Arkansas Nuclear One (Reference 5). Accordingly, this letter authorizes the utilization of the accompanying affidavit by Duke Energy Progress, LLC. Correspondence with respect to the proprietary aspects of the Application or the Affidavit should reference this letter and be addressed to Dr. Rasko Ojdrovic, Senior Principal, Simpson Gumpertz & Heger Inc., 480 Totten Pond Road, Waltham, MA 02451.

Sincerely yours, Rasko P. Ojdrovic Vice President and Senior Principal Simpson Gumpertz & Heger Inc.

I:\\BOS\\Projects\\2020\\201551.00-BRUN\\WP\\001RPOjdrovic-L.201551.00.eac.docx RA-20-0353 0 Page 12 of 14

Affidavit Page 1

\\\\\\DC - 035120/000001 - 3152313 v1 SIMPSON GUMPERTZ & HEGER INC.

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

(1)

I am a Vice President and Senior Principal of Simpson Gumpertz & Heger Inc. (SGH),

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

(2)

Duke Energy Progress, LLC will submit a letter to the USNRC entitled Proposed Alternative to ASME Boiler & Pressure Vessel Code Section XI Requirements for Repair/Replacement of Service Water (SW) System Buried Piping in accordance with 10 CFR 50.55a(z)(1), Docket Nos. 50-324 and 50-325, Serial No. RA-20-0353. Certain portions of that letter contain proprietary information owned by SGH. This information should be held in confidence by the USNRC and withheld from public disclosure. The following is a list of the SGH proprietary information in the Duke Energy Progress, LLC letter that SGH requests be withheld:

• Enclosure 1, Summary of Material Exemption Request(§§ 10 and 14).

• Enclosure 4, Material Manufacturing and Material Qualification (Attachment C -

Watertightness Testing).

• Enclosure 5, Design (all Attachments).

• Enclosure 8, FailureModes andEffectsAnalysis (Attachments8A,8C,8D, and 8E).

(3)

In making this application for withholding of proprietary information of which it is the owner, SGH believes that the information qualifies for withholding under the exemption from disclosure set forth in the Freedom of Information Act per 5 U.S.C. § 552(b)(4), the Trade Secrets Act per 18 U.S.C. § 1905, and NRC regulations at 10 C.F.R. §§ 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 by SGH as a trade secret.

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.

This information is classified as proprietary because it contains information relevant to analytical approaches and methodologies not available elsewhere.

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

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

v. Substantial cost and time have 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 competitive harm to SGHs position and foreclose or reduce the availability of profit-making opportunities for SGH. The economic value of this information to SGH would be lost or severely reduced if the information were disclosed to the public.

RA-20-0353 0 Page 13 of 14

Affidavit Page 2

\\\\\\DC - 035120/000001 - 3152313 v1 vi. Public disclosure of the information sought to be withheld would provide other parties, and specifically SGHs competitors, with economically valuable information. SGHs competitive advantage would be lost if its competitors are able to use the results of SGHs efforts 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 SGHs 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 their having been required to undertake a similar expenditure of resources would unfairly provide competitors with a windfall and would 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 difficult to 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 18 February 2021.

Rasko P. Ojdrovic RA-20-0353 0 Page 14 of 14

RA-20-0353 1 Page 1 of 11 ENCLOSURE 11 Duke Energy Progress, LLC Brunswick Steam Electric Plant (BSEP), Unit Nos. 1 and 2 Relief Request Serial No. RA-20-0353 Request for Relief RA-20-0353 for a Proposed Alternative to ASME Boiler & Pressure Vessel Code Section XI Requirements for Repair/Replacement of Service Water System Piping in Accordance with 10 CFR 50.55a(z)(1)

Non-Proprietary

NON-PROPRIETARY RA-20-0353 1 Page 2 of 11 NON - PROPRIETARY 1 contains information in Sections 8, 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 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.

Proprietary information is designated within (( BRACKETS )).

NON-PROPRIETARY RA-20-0353 1 Page 3 of 11 Duke Energy Progress, LLC Brunswick Steam Electric Plant (BSEP), Unit Nos. 1 and 2 ENCLOSURE 11 TABLE OF CONTENTS 1, Section 1: Plant Site - Units 1, Section 2: Interval Dates 1, Section 3: Requested Date for Approval 1, Section 4: ASME B&PVC Components Affected 1, Section 5: Applicable Code Edition and Addenda 1, Section 6: Applicable ASME B&PV Code Requirement 1, Section 7: Reason for Request 1, Section 8: Proposed Alternative and Basis for Use 1, Section 9: Material Manufacturing 1, Section 10: Design 1, Section 11: Installation 1, Section 12: QA/QC Program 1, Section 13: Qualifications and Training 1, Section 14: Failure Modes & Effects Analysis (FMEA) 1, Section 15: Summary of Enclosures 1, Section 16: Duration of Proposed Alternative 1, Section 17: Precedents 1, Section 18: Conclusion

NON-PROPRIETARY RA-20-0353 1 Page 4 of 11 Duke Energy Progress, LLC Brunswick Steam Electric Plant (BSEP), Unit Nos. 1 and 2 Proposed Alternative in Accordance with 10 CFR 50.55a(z)(1)

1)

Plant Site - Units Brunswick Electric Steam Plant (BSEP), Unit Nos. 1 and 2.

2)

ISI Interval Dates BSEP Unit 1 is presently in the 5th 10-year inservice inspection (ISI) interval which ends on May 10, 2028. BSEP Unit 2 is presently in the 5th 10-year inservice inspection (ISI) interval which ends on May 10, 2028. As further discussed in the enclosed alternative request and supporting information, the repair effort at BSEP Unit 1 will be performed during 5th 10-year ISI interval which began on May 110, 2018. Repair efforts at BSEP Unit 2 will be performed during the 5th 10-year ISI interval which began on May 11, 2018.

3)

Requested Date for Approval The requested date for approval is November 30, 2021.

4)

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

Additional access points may be installed to enhance personnel safely and gain efficiencies.

i) BSEP Unit 1, Conventional Service Water (SW) Header (1) Approximately 320 linear feet of buried 30 inch diameter cement mortar lined carbon steel pipe identified as 1-SW-100-30-157 with pipe and fittings routed from the SW Pump Building to a pipe tee in 1-SW-199-30-157.

(2) Approximately 95 linear feet of buried 30 inch diameter cement mortar lined carbon steel pipe identified as 1-SW-199-30-157 with pipe and fittings routed from a pipe tee in 1-SW-100-30-157 to the Reactor Building.

(3) Personnel access points include the blind flange in the SW Pump Building and a 24 inch accessway in the Radwaste Building.

ii) BSEP Unit 1, Nuclear SW Header (1) Approximately 403 linear feet of buried 30 inch diameter cement mortar lined carbon steel pipe with welded joints identified as 1-SW-103-30-157 with pipe and fittings routed

NON-PROPRIETARY RA-20-0353 1 Page 5 of 11 from the SW Pump Building to the Reactor Building.

(2) Personnel access points include a blind flange located in the SW Pump Building and a 24 inch riser located in the yard at the diesel tap-off location.

iii) BSEP Unit 2, Conventional SW Header (1) Approximately 446 linear feet of buried 30 inch diameter cement mortar lined carbon steel pipe identified as 2-SW-100-30-157 with pipe and fittings routed from the SW Pump Building to the Reactor Building.

(2) Personnel access points include the blind flange in the SW Pump Building and through a 24 inch accessway in the Radwaste Building.

iv) BSEP Unit 2, Nuclear SW Header (1) Approximately 650 linear feet of buried 30 inch diameter cement mortar lined carbon steel pipe with welded joints identified as 2-SW-103-30-157 with pipe and fittings routed from the SW Pump Building to the Reactor Building.

(2) Personnel access points include the blind flange located in the SW Pump Building.

b) BSEP Unit No. 1 and No. 2 SW Systems:

i) Piping is fabricated of carbon steel material conforming to ASTM SA/A-672.

ii) Fittings are fabricated of ASTM SA/A-105.

iii) Code of record, original and current design code is American National Standards Institute (ANSI) B31.1, Power Piping Code, 1967 Edition with load combinations per UFSAR.

iv) Current code for Materials, Fabrication, Installation and Testing is 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, 1986 edition, no addenda.

v) Does not include pumps, valves, expansion joints, flange joints, or threaded connections included in the scope of work. See simplified BSEP isometric drawings provided in Enclosure

2.

vi) Is below grade, buried and has long straight runs with minimal bends and elbows. See for additional details.

vii) Has an interior cement mortar lining.

viii) Has a bituminous wrap on the exterior surfaces installed to mitigate corrosion.

NON-PROPRIETARY RA-20-0353 1 Page 6 of 11 c) Branch Connections are listed below and described further in Enclosure 2:

i)

Tee connection between 1-SW-199-30-157 and 1-SW-100-30-157 may not receive the CFRP composite system and may be replaced with an ASTM B462 (AL-6XN) fitting.

ii) Two (2) new accessways may be added on 1-SW-100-30-157.

iii) Two (2) branch connections will have CFRP composite system installed. 1-SW-494-24-157 that leads to the existing accessway and the other is 1-SW-29-18-157.

iv) One (1) new accessway may be added on 1-SW-103-30-157.

v) Two (2) new accessways may be added on 2-SW-100-30-157.

vi) One (1), 3 foot long, 10 inch branch connection on 2-SW-103-30-157.

vii) Three (3) new accessways may be added on 2-SW-103-30-157.

d) The SW System piping included in this request is a safety-related cooling water source to the Reactor Building and Radwaste Building providing cooling water to/for the following components:

i)

Emergency Diesel Generator (EDG) Jacket Water Coolers.

ii) Reactor Closed Cooling (RCC) Water Heat Exchangers.

iii) Turbine Building Closed Cooling (TCC) Water Heat Exchangers.

iv) Residual Heat Removal (RHR) Heat Exchangers.

v) RHR Pump Seal Coolers.

vi) RHR Room Coolers.

vii) Core Spray (CS) Room Coolers.

viii) RHR Service Water Booster Pumps.

5)

Applicable In-Service-Inspection (ISI) ASME B&PV Code Edition and Addenda For the 5th ISI interval at BSEP Unit No. 1 the applicable code is ASME B&PVC,Section XI, "Rules for lnservice Inspection of Nuclear Power Plant Components", 2007 Edition, including 2008 Addenda.

NON-PROPRIETARY RA-20-0353 1 Page 7 of 11 For the 5th ISI interval at BSEP Unit No. 2 the applicable code is ASME B&PVC,Section XI, "Rules for lnservice Inspection of Nuclear Power Plant Components", 2007 Edition, including 2008 Addenda.

6)

Applicable 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, 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

The SW System piping at BSEP Unit Nos. 1 and 2 consists of 30 inch diameter, cement mortar lined, carbon steel pipe constructed in 1975 and 1976 conveying brackish river water from the Cape Fear River since mid-1970s.

BSEP is proactively evaluating repair options, including repair with the V-Wrap' CFRP Composite System on the interior of the SW System piping which, once fully implemented, will take the place of the host pipe and resist all design loading without reliance on the host structure.

Per the response to Generic Letter 89-13, each of the BSEP Service Water (SW) Headers are internally inspected on a 4-year frequency (one header per refueling outage). During these inspections, typical remediation includes cosmetic concrete repairs and, occasionally, very minor weld repairs to replace minimal wall loss that has occurred over time. The condition of the cement mortar lining is generally found in good condition with patch repairs required to ensure continued reliability of the carbon steel piping beneath. Recent inspections have found minimal weld repairs required when the cement mortar lining is removed for repairs and the concrete is simply patched.

With respect to the external condition of the buried SW piping, the external surfaces of the piping cannot be examined without full piping excavation (approximately 16.5 feet below grade). Limited excavations have been completed by the site in recent years resulting in two condition reports being submitted for very localized through wall failures and some general pitting. These sections of piping were repaired or replaced and a Long-Term Action Manager (LTAM) item was created to replace/refurbish the buried SW piping at the site. This LTAM has resulted in the site pursuing the installation of a CFRP system to ensure long-term reliability of the buried SW piping at BSEP.

Installation of the V-Wrap' 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.

NON-PROPRIETARY RA-20-0353 1 Page 8 of 11

8)

Proposed Alternative and Basis for Use Pursuant to 10 CFR 50.55a(z)(1), Duke requests an alternative for the repair of the subject BSEP Unit Nos. 1 and 2 SW System piping that provides an acceptable level of quality and safety. Duke proposes that the subject supply piping be repaired with the V-Wrap' Carbon Fiber Reinforced Polymer (CFRP) Composite System produced by Structural Technologies, LLC. Enclosure 2 provides the proposed scope of the repair.

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 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 BSEP, Unit Nos.

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 provides 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 Nuclear 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), Unit Nos. 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 Unit Nos. 1 and 2 [G. T. Powell, President and CEO], from the USNRC

[Jennifer L. Dixon-Herrity, Chief, Plant Licensing Branch], dated September 3, 2020)

The USNRC is currently performing a technical review for a similar application of the V-Wrap' CFRP Composite System in the safety-related Essential Cooling Pond Supply piping at Entergy Arkansas Nuclear One, Unit Nos. 1 and 2 (Reference letter from Entergy to USNRC, dated July 15, 2020, document no. 0CAN072001, USNRC Docket Nos. 50-313 and 50-368, Renewed Facility Operating License Nos. DPR-51 and NRF-6).

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.

NON-PROPRIETARY RA-20-0353 1 Page 9 of 11 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 of the SW System piping as described in Enclosure 2 or partial lengths.

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9) Material Manufacturing

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10) Design

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11) Installation

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12)

QA/QC Program

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13) Qualifications and Training

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14) Failure Mode Effects Analysis (FMEA) and Operational Experience

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15) Summary of Enclosures Additional enclosures that are attached are listed below:

a) Enclosure 2 - Scope and Schedule b) Enclosure 3 - Definitions and Acronyms i)

Attachment A - Definition of Terms ii) Attachment B - Acronyms c) Enclosure 4 - Material Manufacturing and Material Qualification

NON-PROPRIETARY RA-20-0353 1 Page 10 of 11

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d) Enclosure 5 - Design

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e) Enclosure 6 - Sample Procedures

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f) Enclosure 7 - Qualification and Training

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g) Enclosure 8 - Failure Modes Effects Analysis (FMEA)

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h) Enclosure 9-Operational Experience

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16) 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.

17) 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 (LF) 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).

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 non Safety Related Essential Cooling Water, Circulating Water and Service Water System carbon steel pipe with similar configurations (See Enclosure 9, Attachment A for additional operating experience information).

18) Conclusion

NON-PROPRIETARY RA-20-0353 1 Page 11 of 11 From 10 CFR 50.55a (z) 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, Duke 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.

RA-20-0353 2 Page 1 of 7 ENCLOSURE 12 Scope and Schedule Duke Energy Progress, LLC Brunswick Steam Electric Plant (BSEP), Unit Nos. 1 and 2 Relief Request Serial No. RA-20-0353 Request for Relief RA-20-0353 for a Proposed Alternative to ASME Boiler & Pressure Vessel Code Section XI Requirements for Repair/Replacement of Service Water System Piping in Accordance with 10 CFR 50.55a(z)(1)

NON-SECURITY-RELATED

RA-20-0353 2 Page 2 of 7 Duke Energy Progress, LLC Brunswick Steam Electric Plant (BSEP), Unit Nos. 1 and 2 ENCLOSURE 12 Scope and Schedule TABLE OF CONTENTS 2, Attachment A: Scope and Schedule 2, Attachment B: Piping Layout 2, Attachment C: BSEP Unit No. 1 SW Header 1-SW-100-30-157 (Conventional) 2, Attachment D: BSEP Unit No. 2 SW System 1-SW-103-30-157 (Nuclear) 2, Attachment E: BSEP Unit No. 2 SW System 2-SW-100-30-157 (Conventional) 2, Attachment F: BSEP Unit No. 2 SW System 2-SW-103-30-157 (Nuclear)

NON-SECURITY-RELATED

RA-20-0353 2 Page 3 of 7 Duke Energy Progress, LLC Brunswick Steam Electric Plant (BSEP), Unit Nos. 1 and 2 ENCLOSURE 12 Attachment A - Scope and Schedule

1) Scope BSEP is proactively requesting approval to use the proposed V-Wrap' CFRP Composite System as an upgrade of the Service Water (SW) System piping internal wall surfaces. It has not been determined whether the cement mortar lining will be removed or remain in place.

Hydraulic and structural analysis will be performed to justify either condition, (1) cement mortar lining removed or (2) cement mortar lining remains. Additional details depicting site layout, appropriate lengths and directional changes are provided in Attachments C, D, E, and F.

The Service Water (SW) System piping at BSEP Unit Nos. 1 and 2 consists of 30 inch diameter, cement mortar lined, carbon steel pipe constructed in 1975 and 1976 conveying brackish river water from the Cape Fear River.

Piping sections to be lined with the proposed V-Wrap' Carbon Fiber Reinforced Polymer (CFRP) Composite System are further described in Enclosure 2 and are summarized below.

Additional access points may be installed to enhance personnel safely and gain efficiencies as depicted on Attachments C, D, E and F. Access to base material at terminal ends for future inservice inspections will be considered in the 10CFR50.59 engineering change process.

Within the SW Pump House, there are sections of the Unit 1 and Unit 2 Nuclear and Conventional SW Headers that will not be lined with CFRP under this project. This piping runs from the discharge of the SW intake pumps (10 total) and exits the SW Pump House below grade. These penetrations out of the SW Pump House are where the installation of CFRP will begin in each header (approximately 1 foot within the SW Pump House). The piping within the SW Pump House is always accessible and is monitored by Engineering and Operations for signs of degradation while online and during refueling outages. If repairs are required, they can be executed within the building during refueling outages or, if necessary, emergently by draining the affected header. Additionally, if degradation is suspected, non-destructive exams can be completed due to the accessibility of the piping. As such, the decision was made to exclude this piping from the CFRP installation project.

The piping to be lined is buried and not subject to 10CFR50.48 c, 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, C, D, E and F, the piping that terminates inside the Reactor Building, Pipe Tunnel or SW Pump House will terminate onto existing piping. These terminal end areas are accessible allowing for preservice and in-service inspections of the interior and exterior piping to be performed per ASME Section XI requirements. Fire protection considerations required by 10CFR50.48 c, National Fire Protection Association Standard NFPA 805, "Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants, 2001 edition for pipe inside of the buildings and pipe tunnel will be addressed as part of the 10CFR50.59, Changes, Tests and Experiments process.

a) BSEP Unit 1, Conventional Service Water (SW) Header (Attachment C)

RA-20-0353 2 Page 4 of 7 i)

Approximately 320 linear feet of buried 30 inch diameter cement mortar lined carbon steel pipe identified as 1-SW-100-30-157 with pipe and fittings routed from the SW Pump Building to a pipe tee in 1-SW-199-30-157.

ii) Approximately 90.25 linear feet of buried 30 inch diameter cement mortar lined carbon steel pipe identified as 1-SW-199-30-157 with pipe and fittings routed from a pipe tee in 1-SW-100-30-157 to the Reactor Building.

iii) Personnel access points include a blind flange in the SW Pump Building and a 24 inch access point in the Radwaste Building.

b) BSEP Unit 1, Nuclear SW Header (Attachment D) i)

Approximately 403.5 linear feet of buried 30 inch diameter cement mortar lined carbon steel pipe with welded joints identified as 1-SW-103-30-157 with pipe and fittings routed from the SW Pump Building to the Reactor Building. 1-SW-494-24-157 and 1-SW-29-18-157 are short branch lines depicted on Attachment D.

ii) Personnel access points include a blind flange located in the SW Pump Building and a 24 riser located in the yard at the diesel tap-off location.

c) BSEP Unit 2, Conventional SW Header (Attachment E) i)

Approximately 443.75 linear feet of buried 30 inch diameter cement mortar lined carbon steel pipe identified as 2-SW-100-30-157 with pipe and fittings routed from the SW Pump Building to the Reactor Building.

ii) Personnel access points include a blind flange in the SW Pump Building and a 24 inch accessway in the Radwaste Building.

d) BSEP Unit 2, Nuclear SW Header (Attachment F) i)

Approximately 650 linear feet of buried 30 inch diameter cement mortar lined carbon steel pipe with welded joints identified as 2-SW-103-30-157 with pipe and fittings routed from the SW Pump Building to the Reactor Building.

ii) Personnel access points include a blind flange located in the SW Pump Building.

2) General Information BSEP Unit No. 1 and No. 2 SW Systems:

a) Piping is fabricated of carbon steel material conforming to ASTM SA/A-672.

b) Fittings are fabricated of ASTM SA/A-105.

c) Code of record, original and current design code is American National Standards Institute (ANSI) B31.1, Power Piping Code, 1967 Edition with load combinations per UFSAR.

d) Current code for Materials, Fabrication, Installation and Testing is 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

RA-20-0353 2 Page 5 of 7 Components, 1986 edition, no addenda.

e) Does not include pumps, valves, expansion joints, flange joints, or threaded connections included in the scope of work. See simplified BSEP isometric drawings provided in Enclosure 2, Attachments C through F.

f) Is below grade, buried and has long straight runs with minimal bends and elbows. See, Attachments C through F, for additional details.

g) Has an interior cement mortar lining.

h) Has a bituminous wrap on the exterior surfaces installed to mitigate corrosion.

i)

Branch Connections are listed below and depicted on Attachments C, D, E and F:

i)

Tee connection between 1-SW-199-30-157 and 1-SW-100-30-157 may not receive the CFRP composite system and may be replaced with an ASTM B462 (AL-6XN) fitting.

ii) Two (2) new accessways may be added on 1-SW-100-30-157.

iii) Two (2) branch connections will have CFRP composite system installed. 1-SW-494 157 that leads to the existing accessways and the other is designated as 1-SW-29 157.

iv) One (1) new accessway may be added on 1-SW-103-30-157.

v) Two (2) new accessways may be added on 2-SW-100-30-157.

vi) One (1), 3 foot long, 10 inch branch connection on 2-SW-103-30-157.

vii) Three (3) new accessways may be added on 2-SW-103-30-157.

3) Function The SW System piping included in this request is a safety-related cooling water source to the Reactor Building and Radwaste Building providing cooling water to/for the following components:

a) Emergency Diesel Generator (EDG) Jacket Water Coolers.

b) Reactor Closed Cooling (RCC) Water Heat Exchangers.

c) Turbine Building Closed Cooling (TCC) Water Heat Exchangers.

d) Residual Heat Removal (RHR) Heat Exchangers.

e) RHR Pump Seal Coolers.

f) RHR Room Coolers.

g) Core Spray (CS) Room Coolers.

RA-20-0353 2 Page 6 of 7 h) RHR Service Water Booster Pumps.

4) Schedule a) For the 5th ISI interval at BSEP Unit No. 1 the applicable code is ASME B&PVC,Section XI, "Rules for lnservice Inspection of Nuclear Power Plant Components", 2007 Edition, including 2008 Addenda.

b) For the 5th ISI interval at BSEP Unit No. 2 the applicable code is ASME B&PVC,Section XI, "Rules for lnservice Inspection of Nuclear Power Plant Components", 2007 Edition, including 2008 Addenda.

c) Installation of the V-Wrap' 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.

RA-20-0353 2 Page 7 of 7 Attachment B - Piping Layout Security Related - Withheld per 10 CFR 2.390

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Attachment C - BSEP Unit No. 1 SW System 1-SW-100-30-157/1-SW-199-30-157 (Conventional)

Security Related - Withheld per 10 CFR 2.390

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Security Related - Withheld per 10 CFR 2.390

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Attachment E - BSEP Unit No. 2 SW System 2-SW-100-30-157 (Conventional)

Security Related - Withheld per 10 CFR 2.390

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Security Related - Withheld per 10 CFR 2.390

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