3F1097-21, Application for LAR 221,Rev 0 to License DPR-72,adding Methodology to Monitor Indication Growth in Group of Tubes within Crystal River Unit 3 B Otsg.Ts Pages,Encl

Application for LAR 221,Rev 0 to License DPR-72,adding Methodology to Monitor Indication Growth in Group of Tubes within Crystal River Unit 3 B Otsg.Ts Pages,Encl

ML20217D267
Person / Time
Site:	Crystal River
Issue date:	10/01/1997
From:	Richard Anderson FLORIDA POWER CORP.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20217D271	List: 3F1097-21, Application for LAR 221,Rev 0 to License DPR-72,adding Methodology to Monitor Indication Growth in Group of Tubes within Crystal River Unit 3 B Otsg.Ts Pages,Encl ML20217D274
References
3F1097-21, NUDOCS 9710030100
Download: ML20217D267 (12)

Text

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1 October 1.1997 l 3F1097 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C. 20555-0001

Subject:

License Amendment Request No. 221, Revision 0, "B" Once Through Steam Generator Tube Surveillance Program

References:

1. FPC to NRC letter,3F0494 09, dated April 19,1994

2. FPC to NRC letter,3F0595-07, dated May 31,1995

3. FPC to NRC letter,3F039619, dated March 21,1996

4. FPC to NRC letter,3F0496-04, dated April 8,1996

5. FPC to NRC letter,3F0397-16, dated March 27,1997

6. FPC to NRC letter,3F0597-23, dated May 1,1997

7. FPC to NRC letter, 3F0897-09, dated August 20,1997

8. FPC to NRC letter,3F089710, dated August 20,1997

Dear Sir:

Florida Power Corporation (FPC) hereby submits License Amendment Request (UAR) No. 221, Revision 0, proposed amendment to Operating License Nn. DPR 72. As part of this request, the IRE-LAR and the proposed new Technical Specification pages are provided in Attachment A. This submittal fulfills a commitment made by FPC in Reference 7 to submit a License Amendment g-g Request to address how FPC will monitor first-span intergranular attack (IGA) indications and disposition growth during future "B" Once-Through Steam Generator (OTSG) eddy current g

examinations. To assist in reviewing this request, a set of the changed pages with new or g'

g revised information shown in shadowed font are provided in Attachment B.

g This LAR proposes to add a methodology to monitor indication growth in a group of tubes within the Crystal River Unit 3 (CR 3) "B" OTSG. This specific group of tubes contains eddy current indications that exhibit signals which are characteristic of pit-like IGA. Previously submitted correspondence associated with Technical Specification Change Request Notice (TSCRN) 211 described how FPC is inspecting these indications and determining acceptability for continued service (References 5,6, and 7).

The inspections described in TSCRN 211 are designed to determine the extent of degradation attributable to pit-like IGA, to ensure that the damage mechanism is not changing morphology, and to ensure that the IGA indications do not mask the presence of a new damage mechanism in this reolon. This LAR specifically addresses how FPC will monitor and disposition growth of 9710030100 971001 DR

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ADOCKOSOOg2 CRYSTAL RIVI:R IMMU) LUMPLt.At utw W. Power Line Street a Crystal River. Norida 344284708 e (362) 7954488 A horMa Progress Company

I U 'S, Nuclear Regulat:ry C:mmissi:n 3F1097 21 Page 2 I

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first span IGA indications during future inspections. Additionally, this submittal proposes implementing special reporting requirements for operational assessments associated with this degradation mechanism. Methodology, growth monitoring criteria, and reporting requirements are all addressed in the proposed changes to the improved Technical Specifications provided in Attachment A.

The improved Technical Specification (ITS) pages provided in Attachments A and B have been affected by previously proposed changes in TSCRN 211, Revision 1 (Reference 8). Changes provided in Attachments A and B were made to the current ITS pages (as approved by Amendment 154). Once TSCRN 211 is approved, FPC will provide updated ITS pages for LAR 221 in accordance with the license amendment approving TSCRN 211.

As stated above, FPC intends to use these proposed growth monitoring requirements and operational assessment techniques during future OTSG inspections. As such, FPC requests NRC approval of this LAR by September 30,1998 with a 30-day implementation period.

If questions arise during your review, please contact Mr. David Kunsemiller, Manager, Nuclear Licensing, at (352) 563-4566.

Sincerely,

'o) A. Anderson Seplor Vice President uclear Operations RAA/jbm/lve xc: Regional Administrator, Region ll Senior Resident inspector NRR Project Manager Attachments:

A. License Amendment Request and Proposed Technical Specification Pages B. Set of Changed Pages With New or Revised Information Shown in Shadowed Font C. List of Regulatory Commitments i

i  !

U. S. Nuclear Regul: tory C:mmission 3F1097 21 Page 3

' STATE OF FLORIDA COUNTY OF CITRUS I

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Roy A. Anderson states (nat he is the Senior Vice President, Nuclear Operations for Florida Power Corporation; that he is authorized on the part of said company to sign and file with the Nuclear Regulatory Commission the information attached hereto; and that all such statements made and matters set forth therein are true and correct to the best of his knowledge,information, and balief.

a

$L oy . Anderson Se ior Vice President clear Operations Swom to and subscribed before me this /

1. day of dedStr 1997, by Roy A.

Anderson. ,

f)a//wc /hWNt Signature of Notary Public State of Florida

_ - _ - - - - - - = _ _ - _ _ __

(Print, ty W 6-' MZ,7,U1

-= c- sd Name of Notary Public)

Personally Produced 04 Known Identification

U. S. Nuclear R:gul: tory Commission 3F1097 21 Page 4 ATTACHMENT A LICENSE AMENDMENT REQUEST No. 221, REVISION 0 "B" ONCE THROUGH STEAM GENERATOR TUBE SURVEILLANCE PROGRAM License Amendment Request and Proposed ITS Pages 1

i U. B. Nucle:r Regul:t:ry C:mmissi:n 3F1097 21 Page5 FLORIDA POWER CORPORATION l

CRYSTAL RIVER UNIT 3 DOCKET NO. 50 302/ LICENSE NO. DPR 72 LICENSE AMENDMENT REQUEST No. 221. REVISION 0 "B" ONCE THROUGH STEAM GENERATOR TUBE SURVEILLANCE PROGRAM LICENSE DOCUMENT INVOLVED: Technical Specifications PORTIONS: Specification 5.6.2.10,"OTSG Tube Surveillance Program" Specification 5.7.2, 'Special Reports *

SUMMARY

OF CHANGES:

This proposed change to the Crystal River (CR 3) Improved Technical Specifications (ITS) incorporates a new section 5.3.2.10.4.c. This new section provides growth monitoring criteria for the first span section of tubes in the "B" Once Through Steam Generator (OTSG) with pit like intergranular attack (IGA) indications.

Florida Power Corporation (FPC) is also proposing changes to the OTSG Special Report requirements described in ITS 5.7.2.c to require submittal of information relative to operational assessments of the "B" OTSG. The proposed changes are patterned after the NRC *Model Technical Specifications

• found in Generic Letter (GL) 95-05,' Voltage Based Repair Criteria for Westinghouse Steam Generator Tubes Affected by Outside Diameter Stress Corrosion Cracking."

1. CHANGE TO SPECIFICATION 5.6.2.10, OTSG Tube Surveillance Program x Description qf Specification Channu Add new paragraph "c" to TS 5.6.2.10.4, page 5.017, after item "4.b." This paragraph defines the growth monitoring criteria for applicable tubes in the "B" OTSG first span. Paragraph "c"is proposed to read as follows:

c. Its service tubes with pit like IGA indications in the first span of the "B" OTSG shall be monitored for growth of these indications in the following fashion: ,

1. Tubes that were in:pected with the high frequency bobbin probe in 1997 shall have the indicated % throughwall value from the current inspection compared to the 1997 indicated % throughwall value. A high frequency bobbin probe comparable to the high frequency bobbin probe used in the 1997 inspections shall be used for this comparison.

2. Tubes shall have the indicated voltage on the 400 kHz channel from the current inspection compared to the 1997 indicated voltage on the 400 kliz channel. A mid-range frequency bobbin prube comparable to the mid-range frequency bobt,in probe used in the 1997 inspections shall be used for this comparison.

6 3. Nucle:r Regul: tory Commissi:n 3F10U 21 l' ape 6 The identities of known tubes with pit like IGA in the first span of the "B" OTSG (both inservice and thcJe removed fro;a service) were pieviously provided in Table 1 in correspondence associatGd with TSCRM 211 (References 5 and 7).

The crowth monitoring der.crAd 6bove is required using indicated percent throughwall from the high fieque.tcy bobbin coil probe as well as the indicated voltage from the mid range bobbin coil probe. This 9pproach will ensKs that tubes r,ot inspected in 1997 with the high frequency bobbin coil probe a.4 ;w>reunted in the baseline year data

2. CHANGE TO SPEC ACATION 6,7.2, Special Reports Descriotion of Specification Chanan Add new iterns 5 and 6 after 5.7.2.c.4. (the second set of requirements), page 5.0 29A. This section defines the special reporting requirements associated with the OTSG inservice inspe:tions. These items are required to be reported within 90 days following the completion of an OTSG inspection. Items 5 and 6 are proposed to read as follows:

5. For first span "B" OTSG pit like IGA, a summary of analyses performed to determine if estimated leakage based on the projected end-of cycle percent throughwall distribution exceeds the leak limit (determined from the licensing basis dose calculation for the main steamline break) for the next operating cycle.

6. For first span "B" OTSG pit-like IGA, a summary of analyses performed to determine if the calculated conditionalo' urst probability based on the projected end of cycle (or if not practical, using the actual measured end-of-cycle) percent throughwall distribution exceeds 1x10~2, and an assessment of the safety significance of the occurrence if exceeded.

By adding a requirement to submit summaries of the operational assessment to the NRC, FPC is commi"ing to determine a limiting growth rate associated with the probabilistic determination of cycle run length (based on the pit-like IGA indications). Because the limiting growth rate will vary due to cycle run length, actual measured growth distributions, number of indications left in service, etc., a specific value of growth rate is not delineated.

The above reporting requirements are modelled after items 4.4.5.5.d.1 and 4.4.5.5.d.5 of the Model Technical Specifications provided in Attachment 2 of GL 95-05.

Reason for Request_

During OTSG tube inspections extending back to 1980, FPC has observed pit-like indications in the "B" OTSG first span region. Dectructive examination of tube samples pulled from the "B" OTSG in 1992 and 1994 determined the cause for these indications to be a specific degradation mechanism: pit iike IGA. Burst tests of CR-3 pulled tube samples with pit like IGA have shown that tube structural capability remains ebove calculated Regulatory Guide (RG) 1.121 structural integnty limits. Burst presbutes substantially greater ihan CR 3 calculated limits prescribed by RG 1.01 have been recorded for all pulled samples. Continuing observation of these indications during recurring inspections shows a growth distribution curve centered about the zero point.

This information has been previously submitted in References 1,2,3, and 4.

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U.'S Nucle:r Regulatory Ccmmissi:n 3F1097 21 Page 7 TSCRN 211 (References 5,6,7 and 8) incorporated into ITS 5.6.2.10 the FPC protocol used to detect and confirm that the degradation mechanism is pit like IGA in the "B" OTSG first span.

TSCRN 211 also replaced the voltage and geometry based sizing criteria for this first span IGA that was previously approved under License Amendment 154. FPC replace (i this acceptance criteria based upon the development of a site specific throughwall sizing criteria that has been qualified in accordance with the guidance found in EPRI TR 106589 V1. PWR Steam Generator Examination Guidelines, Revision 4." The 40% throughwall repair criteria for tubes is used for these "B" OTSG first span pit like IGA Indications.

Although FPC has been monitoring a percentage of these indications since 1992 to detect any apparent growth, ITS 5.6.2.10 currently does not contain any formal requirements for monitoring growth of these indications. This submittal proposes to incorporate a growth monitoring methodology into ITS 5.6.2.10. The incorporation of formalized growth monitoring criteria using standardized equipment and setups is intended to reduce some of the overall variability and uncertainty associated with past growth assessments.

Additionally, reporting requirements based on probabilistic assessments of tube structural integrity, both leakage and burst, are proposed. The use of probabilistic assessment techniques will provide reasonable assurance that the condition of the tubing will remain within prescribed limits. These operational assessments will be based upon the proposed growth monitoring criteria. By using operational n'.sessment tools, plugging limits based upon growth of the indications will be established by FPC to realize the desired cycle run length. The implementation of probabilistic operational assessments is considered to be a conservative, yet flexible approach towards addressing growth concerns for these pit like IGA indications.

Justification for Reaugal Backoround The CR 3 OTSGs were subjected to a post fabrication full vessel stress relief at 1100 - 1150*F for 10 20 hours2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br />. This heat treatment produced a sensitized microstructure in the tubing, that is, increased carbide decoration in the grain boundaries, but with an accompanying chromium depletion. The sensitized microstructure increases the resistance of the tubing to caustic stress corrosion cracking, but increases its susceptibility to intergranular attack (IGA) by sulfur oxyanions.

Laboratory studies and field experience with this type of lGA have shown that the attack occurs at low temperatures (less than 170'F) typical of shutdowns, in acidic, oxidizing conditions, and

-in the presence of reduced sulfur ions. Under this combination of conditions, nickel is preferentially dissolved at the grain boundaries due to the lower chromium content present there, thus producing the IGA.

Tubes pulled from the "B" OTSG in 1952 and 1994 were destructively examined in the lejratory. Detailed results of the pulled tube examinations have been previously reported in References 1 and 2. In the tubes that were pulled, numerous small patches of pit-like IGA were found on the tubes in the first freespan region. Surface analysis of some of these defects by 7 energy dispersive spectrometry (EDS) and x ray photoelectron spectroscopy (XPS) detected significant levels of sulfur present (2 5 wt%), predominately as sulfate, with slight nickel depletion at the grain boundaries. These findings suggest that IGA, by sulfur oxyanions in mildly

UJS. Nucle:r R:gul:t:ry C:mmissi:n 3F1097 21 Page8 1 alkaline to acidic conditions, was the probable cause of the degradation.

Sections of tubing removed in 1992 and 1994 were subjected to burst testing to evaluate structural integrity. All sections excr.eded the calculated Regulatory Guide (RG) 1.121 structural t

integrity limits. Burst data for one tube section was particularly relevant to demonstrating the

, structural integrity of OTSG tubing as it relates to pit like IGA. Tube secticn 68-46 3 contained a defect in the lower tube sheet region which was 75% throughwall. Despite the relatively large size of this indication in comparison to other pit like IGA indications identified, the burst pressure for the tube section was 7000 psi, which is greater than the calculated CR 3 RG 1.121 limit of 1

4050 psi. References 1 through 7 contain additional background information pertaining to this discussion.

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A review of available limited historical eddy current data on the first span of the "B" OTSG IGA l i suggests that the eddy current indications in this region were present as far back as 1980. The results of previous growth studies performed on "B" OTSG first span indications, which have i concluded that the growth distributions are centered about the zero point, have been previously I reported in References 1,2,3, and 4.

Growth assessments performed during the 1997 OTSG inspection continue to indicato that the growth distributions are centered about the zero point for the "B" OTSG first span pit like IGA i indications. A growth assessment based upon the 1997 steam generator inspection results will be submitted to the NRC prior to CR 3 entering Mode 4, in accordance with CR 3 ITS 5.7.2.c item 3.

Evaluation This License Amendment Request is proposing to add a requirement to implement growth assessments for the "B" OTSG first span IGA indications. The proposed requirement establishes 1997 as the baseline year from which future growth studies on these indications will be based.

4 In 1997, FPC performed a 100% bobbin coilinspection of the OTSGs. This 100% inspection was performed with a 100 foot length ZETEC A 510-M/ULC bobbin probe. After the data from this inspection was analyzed and compiled, tubes with Non-Quantifiable Indications (NQls) in the first span of the "B" OTSG were inspected further with a Plus Point coil, Pancake coil, and high frequency bobbin col'. Pit like IGA indications were assigned a percent throughwall using the data acquired by using the high frequency bobbin coll, a 100 foot length ZETEC A 510-M/ULC/HF. The detailed analysis protocol that was used to disposition these indications is delineated in Reference 7. One hundred fifty nine (159) tubec with pit like IGA indications < 40%

throughwall in the first span of the "B" OTSG were left inservice using this approach.

FPC will establish 1997 as the baseline year for future monitoring of the growth of pit-like IGA

. Indications in the first span of the "B" OTSG. To monitor growth, FPC is proposing two methodologies:

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U.'S. Nucle:r Regulat:ry C:mmissi:n 3F1097-21 Page9 Comparing future eddy current inspection indicated percent throughwall (using the regression technique and protocol described in Reference 7) to the 1997 indicated percent throughwall.

• Comparing future eddy current inspection indicated voltage on the mid-range coil 400 kHz channel to the 1997 mid range coil 400 kHz indicated voltage.

Following the completion of future inspections, these growth assessments will be submitted to the NRC as part of the special reporting requirements of CR 3 ITS 5.7.2.c, item 3 (prior to ascending to Mode 4).

Establishing a baseline year for future comparisons is desirable to alleviate technical concerns and questions about the cumulative impact of

• minor" changes to the eddy current acquisition +

and analysis systems and techniques between inspections. By themselves, changes such as utilizing different calibration standard hole diameters, changing the model of the Remote Data Acquisition Unit (RDAU) between inspections, changing from expendable cables to low loss slip rings, etc., may not cause a noticeable change in the system response or the results obtained.

However, if a multitude of these minor changos are implemented over the course of several inspections, the possibility of inadvertently masking a small overall growth rate is considered feasible.

To maximize the accuracy and consistency of the proposed growth assessments, FPC will utilize the following data acquisition and analysis variables on the first span pit like IGA indications during future eddy current inspections:

'~

Characten~stic 1997 Setup ASME Calibration Standard Design 4 x 20% 0.1875" n aminal diameter throughwall hole diameters

' Voltage Normalization on 4 x 20% throughwall holes 4.00 VoltINak to peak nominal Regression Technique Constants for Use with High Referencei Ti Docuraent Frequency Bobbin Probe #51 5000276-00 High Frequency Bobbin Probe Mfr./Model 100 foot length ZETEC A 510-M/ULC/HF bobbin probe Mid-range Bobbin Probe Mfr/Model 100 foot length ZETEC A 510-M/ULC bobbin probe Remote Data Acquisition Unit (RDAU) ZETEC MlZ 30

_ Slip Ring ZETEC Universal Slip Ring Extension Cables ZE T EC Universal Cable Data Acquisition On Pull Acquisition Speed 40 inches per second nominal Tata Sampling Rate 1391 samples per second These variables are considered to be the " critical" variables for the bobbin coil examinations being used to monitor the growth of these pit like IGA indications. By keeping these variables constant between inspections, FPC expects to have a more consistent representation of the status of the indications.

U.*S. Nuclear R:gul:t:ry Commission 3F1097 21 Page 10 Framatome Technologies Inc. (FTI) document # 51-500276-00 records the required analyst setup and regression formala variables developed for use at CR 3. Only CR 3 first span IGA destructive examination was used for development of the regression variables. The root mean square error of this technique is 9.8 when applied only to CR 3 first span IGA data.

One hundred fifty nine (159) tubes with pit like IGA indications were left inservice based on 1997 eddy current inspection results. FPC is establishing 1997 as the baseline year for the two proposed methodologies to monitor growth of these indications.

FPC expects that the population of tubes containing first span pit like IGA has been substantially bounded. However, due to the probabilistic nature of eddy current examinations, FPC expects continued discovery of a limited amount of first span pit like IGA indications in futura inspections. .

For these tubes that have not received a high frequency bobbin examination in 1997, FPC will use the protocol delineated in Reference 7 to validate that these indications can be dispositioned as pit-like-lGA. The 1997 mid range bobbin data will be used as the baseline year for the voltage amplitude long term monitoring criteria discussed above. FPC will then establish the year of ' discovery" of the specific tube as the baseline year for the percent throughwall monitoring criteria.

As specified in TSCRN 211, in future outages FPC will inspect each inservice tube that has been identified with "B" OTSG first span pit like IGA. These inspections will create a substantial growth database for the pit like IGA from which operational assessments and condition monitoring will be performed. ,

FPC will use the voltage and percent throughwall growth distributions developed during the prescribed growth monitoring activities to perform operational assessments for the "B" OTSG based upon the guidance found within GL 95-05 and the Draft Regulatory Guide, DG 1074, for Steam Generator Tube Integrity, dated 9/5/97. Performing the assessments in accordance with this guidance will provide reasonable assurance that the tube integrity for tubes in the "B" OTSG affected by first span pit 'ike IGA will be maintained between successive inspections.

FPC will complete the operational assessments for first span 5t-like IGA within 90 days following plant restart. However, a preliminary assessment will be performed prior to actual tube plugging or repair activities to ensure that the repair criteria being implemented is sufficient to support the duration of the planned operating cycle. -

FPC will complete condition monitoring assessments for first span pit like IGA within 90 days following plant restart, in the event that a structural integnty condition is identified that exceeds the leakage limits or calculated conditional burst probability described above, the condition monitoring results will be reported to the NRC in accordance with the guidance found in 10 CFR 50.72.

U/S. Nucle:r R:gul: tory C:mmission 3F1097 21 Page 11 NO SIGNIFICANT HAZARDS CONSIDERATION EVALUATION This change to the OTSG Tube Surveillance Program establishes growth monitoring protocol for "B" OTSG first span IGA indications. Add tionally, new special reporting requirements providing a summary of operational assessments have been proposed. These changes are conservative enhancements to ITS 5.6.2.10.

An evaluation of the proposed License Amendment Request (LAR) has been performed in accordance with 10 CFR 50.91(a)(1) regarding significant hazards considerations, using the standards in 10 CFR 50.92(c). A discussion of these standards as they relate to this LAR follows:

Criterion 1 Does Not involve a Significant Increase in the Probability or Consequences of'an Accident i Previously Evaluated.

The purpose of OTSG tube inspection is to identify tubes that have a higher potential for in service failure due to degradation that results in a reduced ability to withstand normal and upset operating conditions. The formalincorporation of specificindication growth monitoring and repair criteria is consistent with this purpose. Therefore, the probability of an accident previously evaluated has not been increased.

Chapter 14 of the CR-3 Final Safety Analysis Report (FSAR) provides an analysis to assess the consequences of a steam generator tube rupture event, including the complete severance of a steam generator tube. This analyses concluded that CR 3 was sufficiently designed to ensure that in the event of a steam generator tube rupture, the radiological doses would not exceed the allowable limits prescribed by 10 CFR 100. Neither would this result in additional tube failures and further degradation of the integrity of the reactor coolant pressure boundary. The proposed changes do not alter this analysis in any fashion. Therefore, the consequences of an accident have not been ine:Sased.

Criterlon 2 Does not Create the Possibility of a New or Different Kind of Accident from any Accident Previously Evaluated This change does not alter the design or operation of the OTSGs. The incorporation of the proposed requirements is more conservative than the existing ITS requirements. Neither the type of inspection of OTSG tubes nor the process for performing inspections will be changed by this amendment. Therefore, this change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

I U.* S. Nucle:r Regulat::ry C:mmission 3F1097 21 Page 12 Criterion 3 Does Not involve a Significant Reduction in the Margin of Safety as defined in the Bases for any Technical Specifications The previously performed analyses on the effects of OTSG tube failures, as reported in the CR 3 FSAR, have demonstrated that onsite and offsite consequences are within allowable limits. The proposed change incorporates more conservative growth monitoring and operational assessment criteria for the B" OTSG first span pit like IGA indications. This change does not result in a significant reduction in the margin of safety as defined in the Bases for any Technical Specifications.

ENVIRONMENTAL IMPACT EVALUATION 10 CFR 51.22(c)(9) provides criteria for identif. cation of licensing and regulatory actions eligible for categoric exclusion from performing an environmental assessment. A proposed amendment to an operating license for a facility requires no environmental assessment if operation of the facility in accordance with the proposed amendment would not:

(i) involve a significant hazards consideration, (ii) result in a significant change in the types or significant increase in the amounts of any effluents that may be released offsite, and (iii) result in a significant increase in individual or cumulatWe occupationa' radiation exposure.

FPC has reviewed this license amendment and con:,iudes it meets the eligibility criteria for categoric exclusion set forth in 10 CFR 51.2:'(c)(9). Pursuant to 10 CFR 51.22(c), no environmental impact statement or environmental sssessment needs to be prepared in connection with the issuance of the proposed license amendment for changing the "B" OTSG tube inspection and reporting requirements.

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