Text

License Application No. 322 Regarding Steam Generator Tube Repair Using Alloy 800 Sleeves
	ML040300696
Person / Time
Site:	Beaver Valley
Issue date:	01/27/2004
From:	Pearce L; FirstEnergy Nuclear Operating Co
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	L-04-009
	Download: ML040300696 (42)
	v • d • e

FENOC 110 %

Beaver Valley Power Station Route 168 PO. Box4 FirstEnergy Nuclear Operating Company Shippingport PA 15077-0004 L. WJillian Pearce 724-682-5234 Site Vice President Far: 724-643-8069 January 27, 2004 L-04-009 U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555-0001

Subject:

Beaver Valley Power Station, Unit No. 1 Docket No. 50-334, License No. DPR-66 License Amendment Request No. 322 Steam Generator Tube Repair Using Alloy 800 Sleeves Pursuant to 10 CFR 50.90, FirstEnergy Nuclear Operating Company (FENOC) requests an amendment to the above license for Beaver Valley Power Station (BVPS) Unit No. 1 in the form of changes to the Technical Specifications. The proposed amendment will allow steam generator tube repair using Alloy 800 sleeves.

The FENOC evaluation of the proposed changes are presented in the Enclosure. The proposed Technical Specification changes are presented in Attachment A. Attachment B provides the proposed information-only changes to the Technical Specification Bases that reflect the proposed license amendment. Attachment C identifies the commitments made in this submittal.

The Beaver Valley review committees have reviewed the changes. The changes were determined to be safe and do not involve a significant hazard consideration as defined in 10 CFR 50.92 based on the attached safety evaluation and no significant hazard evaluation.

FENOC requests approval of the proposed amendment by September 30, 2004, in order to support implementation of the proposed changes for the next BVPS Unit 1 refueling outage in the fall of 2004. Once approved, the amendment shall be implemented within 60 days.

Enclosed are:

1. One copy of WCAP-15919-P, "Steam Generator Tube Repair for Westinghouse Designed Plants with 7/8 Inch Inconel 600 Tubes Using Leak Limiting Alloy 800 Sleeves" (Proprietary) dated August 2003.

Beaver Valley Power Station, Unit No. 1 License Amendment Request No. 322 L-04-009 Page 2

2. One copy of WCAP-15919-NP, "Steam Generator Tube Repair for Westinghouse Designed Plants with 7/8 Inch Inconel 600 Tubes Using Leak Limiting Alloy 800 Sleeves" (Nonproprietary) dated August 2003.

Also enclosed are a Westinghouse authorization letter, CAW-03-1750, accompanying affidavit, Proprietary Information Notice, and Copyright Notice.

As Item 1 contains information proprietary to Westinghouse Electric Company LLC, it is supported by an affidavit signed by Westinghouse, the owner of the information. The affidavit sets forth the basis on which the information may be withheld from public disclosure by the Commission and addresses with specificity the considerations listed in paragraph (b) (4) of Section 2.790 of the Commission's' regulations.

Accordingly, it is respectfully requested that the information which is proprietary to Westinghouse be withheld from public disclosure in accordance with 10 CFR Section 2.790 of the Commission's regulations.

Correspondence with respect to the copyright or proprietary aspects of the items listed above or the supporting Westinghouse Affidavit should reference CAW-03-1750 and should be addressed to J. S. Galembush, Acting Manager, Regulatory Compliance and Plant Licensing, Westinghouse Electric Company LLC, P.O. Box 355, Pittsburgh, Pennsylvania 15230-0355.

If there are any questions concerning this license amendment request, please contact Mr. Larry R. Freeland, Manager, Regulatory Affairs/Performance Improvement at 724-682-5284.

I declare under penalty of perjury that the foregoing is true and correct. Executed on January p1 , 2004.

Sincerely,

'aw le Pearce

Beaver Valley Power Station, Unit No.

License Amendment Request No. 322 L-04-009 Page 3

Enclosures:

FENOC Evaluation of the Proposed Change.

Westinghouse authorization letter, CAW-03-1750, dated December 5, 2003

Proprietary Information Notice

Copyright Notice Attachments:

A. Proposed Technical Specification Changes (mark-ups)

B. Proposed Changes to Technical Specification Bases (Information only)

C. List of Regulatory Commitments D. WCAP- 15919-NP, Revision 00 (Non-Proprietary)

E. WCAP-15919-P, Revision 00 (Proprietary) c: Mr. T. G. Colburn, NRR Senior Project Manager Mr. P. C. Cataldo, NRC Sr. Resident Inspector Mr. H. J. Miller, NRC Region I Administrator Mr. D. A. Allard, Director BRP/DEP (w/o Attachment E)

Mr. L. E. Ryan (BRP/DEP) (w/o Attachment E)

t ENCLOSURE Beaver Valley Power Station, Unit No. 1 License Amendment Request No. 322 FENOC Evaluation of the Proposed Change

Subject:

Application for Amendment of Technical Specification 3/4.4.5 to Allow Steam Generator Tube Repair Using Alloy 800 Sleeves.

Table of Contents Section Title Page

1.0 DESCRIPTION

................................ 1

2.0 PROPOSED CHANGE

S ................................ 1

3.0 BACKGROUND

................................ 2

4.0 TECHNICAL ANALYSIS

................................. 3 5.0 REGULATORY SAFETY ANALYSIS ................................ 13 5.1 No Significant Hazards Consideration .................... ............ 13 5.2 Applicable Regulatory Requirements/Criteria ................................ 16

6.0 ENVIRONMENTAL CONSIDERATION

................................ 17

7.0 REFERENCES

................................ 18 Attachments Number Title A Proposed Technical Specification Changes B Proposed Technical Specification Bases Changes C Commitment Summary D WCAP -15919-NP, Revision 00 (Non-Proprietary)

E WCAP -15919-P, Revision 00 (Proprietary) i

Beaver Valley Power Station Unit No. 1 License Amendment Request No. 322

1.0 DESCRIPTION

FirstEnergy Nuclear Operating Company (FENOC) requests to amend Operating License DPR-66 for Beaver Valley Power Station (BVPS) Unit No. 1. The proposed amendment would revise Technical Specification 3.4.5, "Steam Generators," to allow repair of steam generator tubes by utilizing leak limiting Alloy 800 leak limiting sleeves.

2.0 PROPOSED CHANGE

The proposed amendment would revise Technical Specification 3.4.5 to allow repair of steam generator tubes by installation of leak limiting Alloy 800 leak limiting sleeves.

The leak limiting Alloy 800 sleeves were developed by Westinghouse Electric LLC (Westinghouse). The technique to use leak limiting Alloy 800 sleeves to repair degraded steam generator tubes is described in Westinghouse WCAP-15919-NP, Revision 00, "Steam Generator Tube Repair for Westinghouse Designed Plants with 7/8 Inch Inconel 600 Tubes Using Leak Limiting Alloy 800 Sleeves," dated August 2003 (nonproprietary) contained in Attachment D and WCAP-15919-P, Revision 00, "Steam Generator' Tube Repair for Westinghouse Designed Plants with 7/8 Inch Inconel 600 Tubes Using Leak Limiting Alloy 800 Sleeves," dated August 2003 (proprietary),

contained in Attachment E. These reports detail the analyses and testing performed to verify the adequacy of Alloy 800 sleeves for installation in a steam generator tube and demonstrate sleeving to be an acceptable repair technique.

The proposed Technical Specification change, which is submitted for Nuclear Regulatory Commission (NRC) review and approval, is provided in Attachment A.

FirstEnergy Nuclear Operating Company is proposing to modify the BVPS Unit No. 1 Technical Specifications to revise Surveillance Requirements (SRs) 4.4.5.4.a.6 and 4.4.5.4.a.9. These two SRs currently describes plugging and repair criteria which allows for Westinghouse laser welded sleeves and the former ABB Combustion Engineering tungsten inert gas (TIG) welded sleeves. These SRs are proposed to be revised to also list Westinghouse Alloy 800 leak limiting sleeves as an additionally acceptable sleeve method. The proposed ability to utilize Westinghouse Alloy 800 leak limiting sleeves is only being requested for Cycle 17 of BVPS Unit No. 1 and will include a note indicating that Alloy 800 sleeves are only applicable to Cycle 17. SR 4.4.5.4.a.6 will also include a note indicating that tubes repaired with Alloy 800 leak limiting sleeves will be plugged on detection of any service induced imperfection, degradation or defect in the sleeve or in the pressure boundary portion of the original tube wall in the leak limiting sleeve/tube assembly as defined in Technical Specification 4.4.5.4. SR 4.4.5.2.b.3 is being revised to require an inspection of all inservice Alloy 800 sleeves using a plus point coil or equivalent technique during each refueling outage.

Page

,I Beaver Valley Power Station Unit No. 1 License Amendment Request No. 322 The changes proposed to the Technical Specification Bases are provided in Attachment B. The proposed Technical Specification Bases changes do not require NRC approval.

The Beaver Valley Power Station Technical Specification Bases Control Program controls the review, approval and implementation of Technical Specification Bases changes. The Technical Specification Bases changes are provided for information only.

Attachment C provides a list of commitments associated with this License Amendment Request (LAR).

The proposed change to the Technical Specifications and Technical Specification Bases have been prepared electronically. Deletions are shown with a strike-through and insertions are shown double-underlined. This presentation allows the reviewer to readily identify the information that has been deleted and added.

To meet format requirements the Index, Technical Specifications and Bases pages will be revised and repaginated as necessary to reflect the changes being proposed by this LAR.

3.0 BACKGROUND

Pressurized water reactor steam generators (SGs) have experienced tube degradation related to corrosion phenomena such as wastage, pitting, intergranular attack, stress corrosion cracking and crevice corrosion along with other phenomena such as denting and vibration wear. Tubes that experience excessive degradation reduce the integrity of the primary to secondary pressure boundary. These tubes are considered defective and must be repaired or removed from service by plugging. The installation of steam generator tube plugs removes the heat transfer surface of the plugged tube from service and leads to a reduction in the primary coolant flow available for core cooling. Sleeving is a steam generator tube repair method which was previously incorporated into the Beaver Valley Unit I Technical Specifications by Amendments 176 and 208. These amendments permitted the use of the Westinghouse laser welded sleeves and the former ABB Combustion Engineering tungsten inert gas (TIG) welded sleeves. Sleeving technology has been enhanced with the introduction of the Westinghouse leak limiting Alloy 800 sleeves. The option to use this sleeving method is requested to provide an additional option for use in maintaining the operability of the steam generator.

FENOC is planning to replace the BVPS Unit No.1 steam generators in the refueling following Cycle 17. The proposed changes are only being requested for Cycle 17 to allow for the use of Alloy 800 sleeves if needed to maintain the BVPS Unit No. 1 steam generators within the analyzed plugging limits.

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Beaver Valley Power Station Unit No. I License Amendment Request No. 322

4.0 TECHNICAL ANALYSIS

The proposed changes revise the Technical Specifications SRs 4.4.5.4.a.6, 4.4.5.4.a.9 and 4.4.5.2.b.3 to permit the installation of leak limiting Alloy 800 sleeves developed by Westinghouse to repair SG tubes at Beaver Valley Unit No. 1. Westinghouse provides two types of leak limiting Alloy 800 sleeves. The first type of sleeve spans the transition zone (TZ) of the parent SG tube at the top of the tubesheet and is called a TZ sleeve. The TZ sleeve is hydraulically expanded into the SG tube at the upper end and is hard rolled into the SG tube within the SG tubesheet. The length of the TZ sleeves permits the sleeve to span the degraded SG tube section at the top of the tubesheet. The second type of sleeve spans degraded areas of the SG tube at a Tube Support Plate (TSP) elevation or in a free span section and is called a tube support (TS) sleeve. The TS sleeve is hydraulically expanded into the SG tube near each end of the sleeve.

There are two distinct advantages associated with the leak limiting Alloy 800 sleeves compared to other sleeve designs. First, no welding, brazing, or heat treatment is required during sleeve installation. Secondly, the strain within the tube is low, thereby reducing the likelihood of future degradation due to stress-influenced mechanisms.

Although the Alloy 800 sleeves may allow slight leakage past the sleeve (assuming the parent SG tube is leaking), the sleeve is designed to maintain normal operation and postulated post-accident leakage to be extremely small compared to the Technical Specification primary-to-secondary leakage limits.

The SG tube with the installed sleeve meets the structural requirements of SG tubes that are not degraded. Even in the event of the severance of the SG tube, the sleeve will provide the required structural support and acceptable primary-to-secondary leakage for normal operating and accident conditions. Extensive analyses and testing have been performed on the sleeve and repair joints to demonstrate that the design and licensing criteria are met.

Analysis was performed by Westinghouse for SG tube repair in Westinghouse designed plants with 7/8 inch Outside Diameter (OD) Inconel 600 tubes of varying wall thickness and addresses a combination of one TZ sleeve and/or up to two TS sleeves that could be installed in a single SG tube. Acceptable sleeve locations covered by the analysis are in the SG tube straight legs from the top of the tubesheet up to the upper most tube support plant region. WCAP-15919-P, Revision 00, provides a detailed description of the design, installation, and testing associated with the leak limiting Alloy 800 sleeves.

In addition to the analysis and test programs discussed in WCAP-15919-P, Revision 00, a significant number of Alloy 800 sleeves have been in operation for a number of years Page 3

.6 Beaver Valley Power Station Unit No. 1 License Amendment Request No. 322 with no service induced degradation or significant leakage. No degradation of the installed sleeves or SG tubes in the area of the expansions has been identified.

The principal accident associated with the proposed changes is the Steam Generator Tube Rupture (SGTR) event. The consequences associated with a SGTR event are discussed in BVPS Unit No. I Updated Final Safety Analysis Report (UFSAR) Section 14.2.4, "Steam Generator Tube Rupture." The SGTR event is a breach of the barrier between the reactor coolant system and the main steam system. The integrity of this barrier is significant from the standpoint of radiological safety in that a leaking SG tube allows the transfer of reactor coolant into the main steam system. In the event of a SGTR, radioactivity contained in the reactor coolant mixes with water in the shell side of the affected SG. This radioactivity is transported by steam to the turbine and then to the condenser, or directly to the condenser via the turbine bypass valves, or directly to the atmosphere via the atmospheric dump/relief valves, main steam safety valves, or the auxiliary feedwater pump turbine exhaust. Non-condensable radioactive gases in the condenser are removed by the condenser air removal system and discharged to the plant vent. The use of leak limiting Alloy 800 sleeves allows the repair of degraded SG tubes such that the function and integrity of the SG tube is maintained. Therefore the SGTR accident is not affected by the use of leak limiting Alloy 800 sleeves.

The consequences of a hypothetical failure of a leak limiting Alloy 800 sleeve and/or the associated SG tube would be bounded by the current SGTR analysis. Due to the slight reduction in the inside diameter of the SG tube caused by the sleeve wall thickness, primary coolant release rates through a ruptured parent tube would be slightly less than assumed for the SGTR analysis and, therefore, would result in lower total primary fluid mass release to the secondary system. A Main Steam Line Break (MSLB) or Feedwater Line Break (FLB) will not cause a SGTR since the sleeves are analyzed for a design basis accident differential pressure greater than that predicted in the BVPS safety analysis. The impact of sleeving on SG performance, heat transfer, and flow restriction is minimal and/or insignificant compared to plugging. The proposed BVPS Unit No. 1 Technical Specification changes to allow the use of leak limiting Alloy 800 sleeves do not adversely impact any other previously evaluated design basis accident.

Evaluation of the proposed leak limiting Alloy 800 sleeves indicates no detrimental effects on the sleeve or sleeved tube assembly from reactor system flow, primary coolant chemistry, secondary coolant chemistry, thermal conditions or transients, or other pressure conditions that may be experienced at BVPS Unit No. 1. Any leakage, which is assumed but not expected, experienced during normal operation and post-accident conditions is extremely small relative to the primary-to-secondary operational leakage limits in the Technical Specifications and the BVPS Unit No. 1 accident induced MSLB leak limit. Data and calculation methodology concerning the reduction Page 4

Beaver Valley Power Station Unit No. 1 License Amendment Request No. 322 in primary coolant flow rate and sleeve-to-plug equivalency ratios is contained in Section 10 of WCAP-15919-P, Revision 00. Table 1 of this Attachment provides a comparison of loading conditions assumed in WCAP-15919-P, Revision 00, with respect to corresponding BVPS Unit No. 1 operating and accident values. The values assumed in WCAP-15919-P, Revision 00, are either equivalent or more conservative than BVPS Unit No. 1 plant specific values.

Table 1 LOADING CONDITIONS COMPARISON Beaver Valley WCAP-15919-P Unit 1 T-Hot (Primary) Inlet Actual -607 F 594 F Design 650 F 650 F T-Steam (Secondary) Actual >509 F 467.5 F Design 560 F 550 F Primary-to-secondary AT Actual <98 F 126.5 F Primary Pressure Actual 2250 psia 2250 psia Design 2500 psia 2500 psia Secondary Pressure Actual -800 psia 700 psia Design 1100 psia 1130 psia Normal Operating Actual <1490 psi 1550 psi Primary-to-secondary AP MSLB S2405 psi 2650 psi FLB <2650 psi Primary-to-secondary AP LOCA <l 100 psi 1130 psi Secondary-to-Primary AP WCAP-15919-P, Revision 00, describes the specific qualifications of leak limiting Alloy 800 sleeves. The summary of the results from WCAP-15919-P, Revision 00, is discussed below.

Sleeve Installation Requirements The sleeves will be installed in accordance with the processes provided by the vendor and described in the associated reports which address sleeve design, qualification, installation methods, non-destructive examination and ALARA considerations. The Westinghouse leak limiting Alloy 800 sleeving process is described in Westinghouse WCAP-15919-NP, Revision 00, "Steam Generator Tube Repair for Westinghouse Page 5

Beaver Valley Power Station Unit No. 1 License Amendment Request No. 322 Designed Plants with 7/8 Inch Inconel 600 Tubes Using Leak Limiting Alloy 800 Sleeves," dated August 2003 (nonproprietary) contained in Attachment D of this letter and WCAP-15919-P, Revision 00, "Steam Generator Tube Repair for Westinghouse Designed Plants with 7/8 Inch Inconel 600 Tubes Using Leak Limiting Alloy 800 Sleeves," dated August 2003 (proprietary), contained in Attachment E of this letter.

A plant specific document that specifies the allowable location of tube eddy current testing indications in order to perform a successful sleeve installation in accordance with WCAP-15919-P requirements will be established upon implementation of the amendment which approves the proposed Technical Specification changes supporting tube repair by leak limiting Alloy 800 sleeves. This document will be utilized to determine that a tube is an acceptable sleeving candidate. Tubes with indications outside of the acceptable locations would not be sleeved.

To prepare for sleeve installation, the current installation process requires the inside surface of the parent SG tube to be cleaned with a high speed buffing tool. After the parent SG tube is cleaned, the sleeve is inserted in the parent tube and positioned at the desired location. Sleeve expansion equipment is used to provide the required structural fit-up of the sleeve by making the required number of hydraulic expansion joints with the parent tube. The expansion equipment is controlled and monitored to ensure proper diametrical expansion. For the TZ sleeve, a hard roll is performed with sleeve rolling equipment in the lower part of the sleeve to expand the sleeve into contact with the SG tube within the SG tubesheet. The torque of the rolling equipment is monitored and controlled to ensure an acceptable joint. After installation, all sleeve-tube joints undergo initial eddy current test acceptance and baseline inspection of 100 percent of the installed sleeves.

General Structural Assessment The Alloy 800 tubing, from which the sleeves are fabricated, is procured to the requirements of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code,Section II, Part B, SB-163, NiFeCr Alloy, Unified Numbering System N08800, and Section III, Subsection NB-2000. Alloy 800 is incorporated in ASME Code Case N-21 and is considered acceptable for use by Regulatory Guide 1.85, "Materials Code Case Acceptability ASME Section III, Division 1," Revision 24, dated July 1986. Additionally, supplemental requirements more tightly controlling parameters within the limits allowed by the ASME specification are imposed.

Fatigue and stress analysis of the sleeved tube assemblies have been completed in accordance with the requirements of Section III of the ASME Boiler and Pressure Vessel Code and NRC Regulatory Guide (RG) 1.121, "Bases for Plugging Degraded Page 6

Beaver Valley Power Station Unit No. I License Amendment Request No. 322 PWR Steam Generator Tubes," August, 1976. SG tubes with installed Alloy 800 sleeves meet the structural integrity requirements of tubes that are not degraded. Even in the event of the severance of the SG tube in the region behind the sleeve, the sleeve will provide the required structural support and acceptable leakage between the primary and secondary systems for normal operating and accident conditions. The selected design criteria for the sleeves ensure that all design and licensing requirements are considered. Extensive testing and analysis have been performed on the sleeve and sleeve-to-tube joints to demonstrate that these design criteria are met.

Mechanical testing has been performed to support the analyses prepared using ASME Code stress allowable values. Corrosion testing of sleeve-tube assemblies has been performed in Belgium (Laborelec Laboratories) and the U.S. (Westinghouse) with satisfactory results. These results, when analyzed in conjunction with corrosion test results from the tungsten inert gas-welded sleeve program, confirm the adequacy of the sleeve joint design. The Alloy 800 sleeve material showed no signs of degradation under high temperature and pressure conditions in a caustic environment, while the sleeve-tube specimens maintained primary side pressure and exhibited no leakage throughout the duration of the test program. Earlier design variations of this sleeve-tube assembly (larger diametrical hydraulic expansion or varying number of expansions/configurations) were used at KORI I (South Korea) and Tihange 3 (Belgium) steam generators. The current design configuration is in service or recently in service at Angra I (Brazil), KRSKO (Slovenia), Ringhals 4 (Sweden), Tihange 2 (Belgium), Ulchin 1 & 2 (South Korea), and Calvert Cliffs 1 and 2 (United States) steam generators.

RG 1.121, along with Electric Power Research Institute (EPRI) Technical Report 10001191, "Steam Generator Degradation Specific Management Flaw Handbook,"

dated 2001, which adds margin to account for the configuration of a long axial crack, are used to develop the structural limit of the sleeve should sleeve wall degradation occur as described in Section 8.2 of WCAP-15919-P. Leak limiting Alloy 800 sleeves are shown (by test and analysis) to retain burst strength in excess of three times the normal operating pressure differential at end of operating cycle conditions. No credit for the presence of the parent SG tube behind the sleeve was assumed for the minimum wall burst evaluation for the Alloy 800 sleeve. Bounding normal operating, design seismic, and transient loading conditions on the SG tube sleeves were used for the structural analysis of the sleeves and are summarized in Section 8.5 of WCAP-15919-P.

The loading conditions assumed in WCAP-15919-P as supplemented by Westinghouse calculation CN-SGDA-04-4 bound the loading conditions listed in BV UFSAR Table 4.1-10.

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Beaver Valley Power Station Unit No. 1 License Amendment Request No. 322 The RG 1.121 bounding structural limit for leak limiting Alloy 800 sleeves is 45 percent through-wall detailed in Section 8.2.1 of WCAP-15919-P, Revision 00, which is based on normal operating conditions for the worst case envelopment of SG conditions for Westinghouse Model 44, 44F, and 51 steam generators.

The eddy current inspection method used has a documented qualification, per Appendix H of EPRI Technical Report TR-107569-V1R5, "PWR Steam Generator Examination Guidelines: Revision 5, Volume 1: Requirements," dated September 1997, of the Alloy 800 sleeve for 3/4 (0.750) inch tubing. An equivalency assessment was performed to establish that the essential variables developed for the eddy current examination of the Alloy 800 sleeve for a 3/4 (0.750) inch tube can be applied to a 7/8 (0.875) inch tube.

Corrosion Assessment Historically, Alloy 800 has been used successfully for SG tubes, tube plugs, and sleeves primarily in Western Europe. Over 200,000 Alloy 800 tubes have been used for up to 19 years with only minimal tube failures (thinning/wastage, wear). No evidence of primary or secondary side stress corrosion cracking has been identified in any Alloy 800 tube. Over 5,300 Alloy 800 sleeves of the leak limiting type design have been used in 10 nuclear plants worldwide of which none have identified any service induced stress corrosion cracking in the sleeved tube assembly to-date. Accelerated corrosion testing of Alloy 800 sleeve-tube assemblies has been performed in simulated primary and secondary side SG environments and the Alloy 800 sleeves showed no signs of cracking in both the primary and secondary side tests. The specific details of Alloy 800 sleeve corrosion performance are contained in Section 6 of WCAP-15919-P, Revision 00.

Mechanical Integrity Assessment Mechanical testing of Alloy 800 sleeve-tube assemblies was performed using mock-up SG tubes. The tests determined axial load, collapse pressure, burst pressure, leak rates, wear, and thermal cycling capability. The demonstrated load capacity of the assemblies provides an adequate safety factor for normal operating and postulated accident conditions. The load capacity of the upper and lower sleeve joints is sufficient to withstand thermally induced stresses and displacements resulting from the temperature differential between the sleeve and the SG tube and pressure induced stresses resulting from normal operating and post-accident conditions. The burst and collapse pressures of the sleeve provide margin over the limiting pressure differential. The mechanical testing demonstrated that the installed sleeve will withstand the cyclic loading resulting from power changes in the plant and other transients. The loading conditions developed in Section 8 of WCAP-15919-P were used to develop the conditions for the mechanical tests described in Section 7 of WCAP-15919-P. The temperature and pressure Page 8

Beaver Valley Power Station Unit No. 1 License Amendment Request No. 322 differentials described in Section 8 of WCAP-15919-P are conservative with respect to BVPS Unit No. 1 operating and accident conditions.

Leak Rate Assessment Although the Alloy 800 sleeve to SG tube joint is not required to be leak tight, conservative leak rate tests have been performed to provide the basis for leak rate calculations considering normal operating and accident conditions. The Alloy 800 TZ and TS sleeve leakage characteristics were evaluated at shutdown, normal operating, and accident temperatures so that all possible plant conditions would be enveloped by the test results. Based on a conservative sleeve leak rate determined from the sleeve leak rate tests and excluding calculated leakage from alternate plugging criteria in effect, over 11,000 TZ sleeves or 4000 TS sleeves could be installed and still meet the BVPS Unit No. 1 Technical Specification 3.4.6.2, "RCS Operational Leakage," leakage limits of 150 gallons per day primary to secondary leakage for a single SG. Under MSLB and FLB accident conditions, over 30,000 TS or TZ sleeves could be installed without exceeding the 1.0 gallon per minute post-accident leakage limit in the affected steam generator. Details of the leakage assessment are contained in Section 7 of WCAP-15919-P.

FENOC will conservatively assume all installed sleeves will leak for post-accident leakage calculations. The leak rate for each sleeve will be based on the upper 95 percent confidence limit on the mean value of leakage for appropriate temperature and pressure conditions. The total sleeve leak rate will be combined with the total amount of leakage from all other sources (i.e. Alternate Repair Criteria (ARC) and nonalternate repair criteria indications) for comparison against the limit on accident induced leakage as specified in the UFSAR for the MSLB radiological consequences analysis. This total calculated accident induced leakage will be reported in the 90-day report required by NRC Generic Letter 95-05, Attachment 1, Section 6.b.

Sleeve Inspections Post-installation As required by EPRI Technical Report 1003138, post-installation (pre-service) examination will be performed on the full length of 100 percent of leak limiting Alloy 800 sleeve/tube assemblies using Plus Point probes or an equivalent EPRI Appendix H qualified technique, if available. This examination will establish in-service inspection baseline data and initial installation acceptance data on the primary pressure boundary of the sleeve/SG tube assembly repair.

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Beaver Valley Power Station Unit No. 1 License Amendment Request No. 322 In-service Inspection Alloy 800 sleeves are not expected to be in operation exceeding one cycle and, hence, no inservice inspection is expected. However, should inservice inspection be needed, examination will be performed on the full length of 100 percent of the leak limiting Alloy 800 sleeve/tube assemblies (i.e., the sleeve-to-tube joint) using Plus Point probes or an equivalent EPRI Appendix H qualified technique, if available. This inspection frequency exceeds the 20 percent sampling requirement of Section 3.4.1 of EPRI Technical Report 1003138 and therefore is conservative with respect to current industry requirements.

Plugging Requirements for Tubes With Alloy 800 Sleeves To ensure that a defect in the pressure boundary of a sleeve does not adversely impact the leakage integrity of the sleeve, a sleeved tube will be plugged if an imperfection is detected in any portion of the sleeve. In addition, to ensure that a defect in the pressure boundary of a sleeve does not adversely impact the structural integrity of the sleeve, a sleeved tube will be plugged if an imperfection is detected in the pressure boundary portion of the original tube wall in the leak limiting sleeve/tube assembly (i.e., at the sleeve-tube joint(s)). Imperfections that are detected in the non-pressure boundary portion of the original parent tube wall associated with a sleeve do not impact the pressure boundary of the sleeve/tube assembly and do not impact the structural integrity of the sleeve.

Effects of Sleeving on Operation The effects of sleeve installation on SG heat removal capability and reactor coolant system flow rate are discussed in Section 10 of WCAP-15919-P, which in summary states that the installation of the sleeves does not substantially affect the primary system flow rate or the heat transfer capability of the SGs. The typical hydraulic equivalency of plugs and installed sleeves, called the sleeve/plug ratio or sleeve to plug equivalency ratio, is contained in Table 10-1 of WCAP-15919-P for different configurations of TZ sleeves and TS sleeves in 7/8 inch OD SG tubes. The Table 10-1 sleeve/plug ratio values are an approximation only based on assumed operating parameters and sleeve types for SGs with 7/8 inch tubes and some variations in the sleeve/plug ratio will occur based on operating parameters and SG conditions. FENOC will use the sleeve/plug ratio values contained in Table 10-1 of WCAP-15919-P to determine the equivalent SG plugging due to installed leak limiting Alloy 800 sleeves, unless more appropriate values become available. The total SG plugging level for each SG will be determined by adding the equivalent SG plugging percentage due to installed leak limiting Alloy Page 10

Beaver Valley Power Station Unit No. I License Amendment Request No. 322 800 sleeves to the percent of SG tubes plugged. The total SG plugging level must be maintained less than the limit allowed by accident analyses of record.

Alloy 800 was designed for SG tubing as an alternative to Alloy 600 and is comprised of the same three major metallurgical components (nickel, iron, chrome) as Alloys 600 and 690. It has been in use in SGs for many years in European nuclear plants and has performed well in a primary chemistry environment similar to BVPS Unit No. 1.

Therefore, Alloy 800 is compatible with the primary chemistry regime used at BVPS Unit No. 1 and no changes to this regime are necessary.

Relationship between TS Sleeves and TSP ARC For sleeves installed at Tube Support Plate (TSP) locations, TSP Outside Diameter Stress Corrosion Cracking (ODSCC) ARC will no longer apply to the sleeved TSP intersections. No Technical Specification change is necessary to clarify this relationship for sleeved tubes because the sleeve will remove the TSP ODSCC ARC indications from service.

Severe Accident Considerations Severe accidents can lead to high primary pressure of 2500 psi and high primary temperature between 1200'F and 1500'F. At severe accident conditions, pressure tends to loosen the tube joint and temperature tends to tighten it. As the temperature reaches 1500'F, both the sleeve and tube yield at steam line break pressures. Because the sleeve material is specified to have a low yield stress (30 ksi minimum and controlled maximum), the sleeve will yield at a lower temperature (or pressure) than the tube, thereby tending to tighten the tube joint. At 1500'F, the ultimate stress of the sleeve material is comparable to that of the SG tube and the integrity of the sleeve repair is commensurate with the integrity of the inservice SG tubes. Therefore, under severe accident conditions, sleeving is expected to have no impact on the plant risk.

Conclusion Based on past usage, extensive testing, and analysis, the leak limiting Alloy 800 sleeves provide satisfactory repair of defective SG tubes. Design criteria were established based on the requirements of the ASME Code and RG 1.121.

Precedent The NRC has previously approved the use of leak limiting Alloy 800 sleeves for the Watts Bar Nuclear Plant Unit 1 in License Amendment No. 44 to Facility Operating Page 11

i~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~

Beaver Valley Power Station Unit No. I License Amendment Request No. 322 License No. NPF-90, "Watts Bar Nuclear Plant, Unit 1 - Issuance of Amendment for Steam Generator Tube Repair (TAC No. MB6976)," dated August 15, 2003 (ADAMS #

ML032300143), and for the Calvert Cliffs plant in License Amendment No. 231 to Facility Operating License No. DPR-53 and Amendment No. 207 to Facility Operating License No. DPR-69, "Calvert Cliffs Nuclear Power Plant, Unit Nos. 1 and 2 - Issuance of Amendment RE: Steam Generator Tube Repair Using Leak Limiting Alloy 800 Sleeves (TAC Nos. MA4278 and MA4279)," dated September 1, 1999 (ADAMS #

MLI010520103).

Calvert Cliffs applied the technique in ABB-Combustion Engineering Report CEN-633-P, Revision 3, "Steam Generator Tube Repair for Combustion Engineering Designed Plants with 3/4 - .048" Wall Inconel 600 Tubes Using Leak Limiting Alloy 800 Sleeves," dated October 1998 (ABB-Combustion Engineering proprietary) as the basis for the acceptability of the leak limiting Alloy 800 sleeve. Watts Bar applied the technique in Westinghouse WCAP-15918-P, Revision 0, (CEN-633-P, Revision 05-P),

"Steam Generator Tube Repair for Combustion Engineering and Westinghouse Designed Plant with 3/4 Inch Inconel 600 tubes Using Leak Limiting Alloy 800 Sleeves," dated November 2002 (proprietary) as the basis for the acceptability of the leak limiting Alloy 800 sleeve.

Revision 3 of the CEN-633-P report addressed the specific 3/4 inch O.D. 0.048 inch wall thickness SG tube size contained in the Calvert Cliffs Combustion Engineering SGs. Since 1998, the CEN-633-P, Revision 3, report was revised to include additional testing and analysis, to incorporate other industry comments, to reflect the purchase of ABB-Combustion Engineering by Westinghouse, and to include evaluation for SG tube repair for Westinghouse designed plants with 3/4 inch O.D. Inconel 600 tubes.

Westinghouse WCAP-15918-P, Revision 0, (CEN-633-P, Revision 05-P), "Steam Generator Tube Repair for Combustion Engineering and Westinghouse Designed Plant with 3/4 Inch Inconel 600 tubes Using Leak Limiting Alloy 800 Sleeves," dated November 2002 (proprietary) provides the basis for SG tube repair using leak limiting Alloy 800 sleeves for Westinghouse plants with 3/4 inch Inconel 600 tubes.

The Westinghouse WCAP-15918-P, Revision 00, (CEN-633-P, Revision 05-P), report has been updated to address Westinghouse plants with 7/8 inch O.D. Inconel 600 tubes in Westinghouse WCAP-15919-P, Revision 00, "Steam Generator Tube Repair for Westinghouse Designed Plants with 7/8 Inch Inconel 600 Tubes Using Leak Limiting Alloy 800 Sleeves," dated August 2003 (proprietary). The FENOC request for approval to use leak limiting Alloy 800 sleeves is based on Westinghouse WCAP-15919-P, Revision 00.

Page 12

Beaver Valley Power Station Unit No. 1 License Amendment Request No. 322 A similar request for NRC approval to use leak limiting Alloy 800 sleeves has been made based on WCAP-15918-P, Revision 00, (CEN-633-P, Revision 05-P), by TXU Generation Company LP (TXU Energy) for Comanche Peak Steam Electric Station in the letter CPSES-200301190, "Comanche Peak Steam Electric Station (CPSES), Docket Nos. 50-445 and 50-446, License Amendment Request (LAR) 03-03, Revision to Technical Specification 5.5.9, Steam Generator Repair Using Leak Limiting Alloy 800 Sleeves," dated July 21, 2003 (ADAMS # ML032120445).

A similar request for NRC approval to use leak limiting Alloy 800 sleeves has been made based on WCAP-15919-P, Revision 00, by Pacific Gas & Electric Company (PG&E) for Diablo Canyon Power Plant Units 1 and 2, PG&E letter DCL-03-132, Diablo Canyon Power Plant Units 1 and 2 Docket Nos. 50-275 and 50-323, License Amendment Request (AR) 03-15, "Steam Generator Tube Repair Using Leak Limiting Alloy 800 Sleeves" and Revision to Technical Specification Table 5.5.9.-2, "Steam Generator Tube Inspection" dated October 22, 2003 (ADAMS # 033010563).

5.0 REGULATORY SAFETY ANALYSIS FirstEnergy Nuclear Operating Company (FENOC) is proposing to modify the Beaver Valley Power Station (BVPS) Unit I Technical Specification to revise Surveillance Requirement (SR) 4.4.5.4.a.6 and SR 4.4.5.4.a.9. These two SRs currently describe plugging and repair criteria which allows for Westinghouse laser welded sleeves and the former ABB Combustion Engineering tungsten inert gas (TIG) welded sleeves. These SRs are proposed to be revised to also list Westinghouse Alloy 800 leak limiting sleeves as an additionally acceptable sleeve method. The proposed ability to utilize Westinghouse Alloy 800 leak limiting sleeves is only being requested for Cycle 17 of BVPS Unit No. 1 and will include a note indicating that Alloy 800 sleeves are only applicable to Cycle 17. SR 4.4.5.4.a.6 will also include a note indicating that tubes repaired with Alloy 800 leak limiting sleeves will be plugged on detection of any service induced imperfection, degradation or defect in the sleeve or in the pressure boundary portion of the original tube wall in the leak limiting sleeve/tube assembly. SR 4.4.5.2.b.3 is proposed to be revised to require an inspection of all inservice Alloy 800 sleeves during each refueling outage.

5.1 No Significant Hazards Consideration FENOC has evaluated whether or not a significant hazards consideration is involved with the proposed amendments by focusing on the three standards set forth in IOCFR50.92, "Issuance of amendment," as discussed below:

Page 13

Beaver Valley Power Station Unit No. 1 License Amendment Request No. 322

1. Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?

No.

The leak limiting Alloy 800 sleeves are designed using the applicable American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code and, therefore, meet the design objectives of the original steam generator (SG) tubing.

The applied stresses and fatigue usage for the sleeves are bounded by the limits established in the ASME Code. Mechanical testing has shown that the structural strength of sleeves under normal, upset, emergency, and faulted conditions provides margin to the acceptance limits. These acceptance limits bound the most limiting (three times normal operating pressure differential) burst margin recommended by NRC Regulatory Guide 1.121, "Bases for Plugging Degraded PWR Steam Generator Tubes." Burst testing of sleeve-tube assemblies has confirmed the analytical results and demonstrated that no unacceptable levels of primary-to-secondary leakage are expected during any plant condition.

The leak limiting Alloy 800 sleeve depth-based structural limit is determined using NRC guidance and the pressure stress equation of ASME Code,Section III with additional margin added to account for the configuration of long axial cracks. An Alloy 800 sleeved tube will be plugged on detection of an imperfection in the sleeve or in the pressure boundary portion of the original tube wall in the leak limiting sleeve/tube assembly.

Evaluation of the repaired SG tube testing and analysis indicates no detrimental effects on the leak limiting Alloy 800 sleeve or sleeved tube assembly from reactor system flow, primary or secondary coolant chemistries, thermal conditions or transients, or pressure conditions as may be experienced at Beaver Valley Power Station (BVPS) Unit 1. Corrosion testing and historical performance of sleeve-tube assemblies indicates no evidence of sleeve or tube corrosion considered detrimental under anticipated service conditions.

The implementation of the proposed change has no significant effect on either the configuration of the plant or the manner in which it is operated. The consequences of a hypothetical failure of the leak limiting Alloy 800 sleeve-tube assembly is bounded by the current SG tube rupture (SGTR) analysis described in the BVPS Unit No. I Updated Final Safety Analysis Report. Due to the slight reduction in the inside diameter caused by the sleeve wall thickness, primary coolant release rates through' the parent tube would be slightly less than assumed for the SGTR analysis and therefore, would result in lower total primary fluid mass release to the secondary Page 14

Beaver Valley Power Station Unit No. 1 License Amendment Request No. 322 system. A main steam line break or feedwater line break will not cause a SGTR since the sleeves are analyzed for a maximum accident differential pressure greater than that predicted in the BVPS Unit No. 1 safety analysis. The sleeve-tube assembly leakage during plant operation would be minimal and is well within the allowable Technical Specification leakage limits.

Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

2. Does the proposed change create the possibility of a new or different kind of accident from any accident previously evaluated?

No.

The leak limiting Alloy 800 sleeves are designed using the applicable ASME Code as guidance, and therefore meet the objectives of the original SG tubing. As a result, the functions of the SG will not be significantly affected by the installation of the proposed sleeve. The proposed sleeves do not interact with any other plant systems.

Any accident as a result of potential tube or sleeve degradation in the repaired portion of the tube is bounded by the existing SGTR accident analysis. The continued integrity of the installed sleeve-tube assembly is periodically verified by the Technical Specification requirements and a sleeved tube will be plugged on detection of an imperfection in the sleeve or in the pressure boundary portion of the original tube wall in the leak limiting sleeve/tube assembly.

Implementation of the proposed change has no significant effect on either the configuration of the plant, or the manner in which it is operated.

Therefore, the proposed change does not create the possibility of a new or different accident from any accident previously evaluated.

3. Does the proposed change involve a significant reduction in a margin of safety?

No.

The repair of degraded SG tubes with leak limiting Alloy 800 sleeves restores the structural integrity of the degraded tube under normal operating and postulated accident conditions. The reduction in core cooling margin due to the addition of Alloy 800 sleeves is not significant because the cumulative effect of all repaired (sleeved) and plugged tubes will continue to be less than the currently allowed core cooling margin threshold established by the total steam generator tube plugging Page 15

Beaver Valley Power Station Unit No. 1 License Amendment Request No. 322 level. The design safety factors utilized for the sleeves are consistent with the safety factors in the ASME Boiler and Pressure Vessel Code used in the original SG design. The sleeve and portions of the installed sleeve-tube assembly that represent the reactor coolant pressure boundary will be monitored and a sleeved tube will be plugged on detection of an imperfection in the sleeve or in the pressure boundary portion of the original tube wall in the leak limiting sleeve/tube assembly. Use of the previously identified design criteria and design verification testing assures that the margin to safety is not significantly different from the original SG tubes.

Therefore, the proposed change does not involve a significant reduction in a margin of safety.

Based on the above, FENOC concludes that the proposed amendments present no significant hazards consideration under the standards set forth in 10CFR50.92(c), and, accordingly, a finding of "no significant hazards consideration" is justified.

5.2 Applicable Regulatory Requirements/Criteria Title 10 of the Code of Federal Regulations Part 50 (10 CFR 50), Appendix A, "General Design Criterion (GDC)," Criterion 14, Reactor Coolant Pressure Boundary, contains requirements applicable to SG tubes since they are part of the reactor coolant pressure boundary. GDC 14 requires that the reactor coolant pressure boundary be designed, fabricated, erected, and tested in order to have an extremely low probability of abnormal leakage, of rapidly propagating failure, and of gross failure. The repair of the existing reactor coolant pressure boundary is performed in accordance with Section XI of ASME Boiler and Pressure Vessel Code, which refers to Section III of the ASME Code. The original SG tubes are designed in accordance with Section III of the ASME Code (1965 edition through Summer 1967 addenda). The design criteria for the leak limiting sleeves were established to meet the loading condition and stress requirements of Section III of the ASME Code (1995 edition, no addenda), which is consistent with the section of the ASME Code that applies to the original SG tubes.

10 CFR 50, Appendix B, "Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants," requires a quality assurance program for the design, fabrication, construction, and operation of structures, systems, and components in nuclear power plants. The requirements of Appendix B apply to all activities affecting the safety-related functions of those structures, systems, and components. The activities include designing, purchasing, fabricating, handling, shipping, storing, cleaning, erecting, installing, inspecting, testing, operating, maintaining, repairing, refueling, and modifying safety-related structures, systems and components. The leak limiting sleeves Page 16

Beaver Valley Power Station Unit No. 1 License Amendment Request No. 322 are considered safety-related components and therefore will be required to meet the Appendix B requirements.

Regulatory Guide (RG) 1.121 provides guidance for determining the minimum wall thickness at which a SG tube should be plugged. The RG 1.121 performance criteria recommend that the margin of safety against SGTR under normal operating conditions should not be less than 3 at any tube location where defects have been detected. The margin of safety against tube failures under postulated accident conditions should be consistent with the margin of safety determined by the stress limits specified in the ASME Code. The RG 1.121 requirements were used to develop the structural limit of leak limiting Alloy 800 sleeve should sleeve wall degradation occur. In addition, the fatigue and stress analysis of the sleeved tube assemblies have been completed in accordance with the requirements of RG 1.121.

Based on past usage, extensive testing and analysis, the leak limiting Alloy 800 sleeves provide satisfactory repair of degraded SG tubes. Qualified nondestructive examination techniques will be used to perform necessary sleeve and parent SG tube inspections for defect detection, and to verify proper installation of the repair sleeve.

In conclusion, based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

6.0 ENVIRONMENTAL CONSIDERATION

A review has determined that the proposed amendment would change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10CFR20, or would change an inspection or surveillance requirement. However, the proposed amendment does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluent that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10CFR51.22(c)(9). Therefore, pursuant to 10CFR51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.

Page 17

I Beaver Valley Power Station Unit No. 1 License Amendment Request No. 322

7.0 REFERENCES

1. Westinghouse Electric LLC WCAP-15919-P, Revision 00, "Steam Generator Tube Repair for Westinghouse Designed Plants with 7/8 Inch Inconel 600 Tubes Using Leak Limiting Alloy 800 Sleeves," dated August 2003 (proprietary).

2. Westinghouse Electric LLC WCAP-15919-NP, Revision 00, "Steam Generator Tube Repair for Westinghouse Designed Plants with 7/8 Inch Inconel 600 Tubes Using Leak Limiting Alloy 800 Sleeves," dated August 2003 (nonproprietary).

3. American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code,Section II, Part B, SB-163, NiFeCr Alloy UNS N08800, and Section III, Subsection NB-2000.

4. Regulatory Guide 1.85, "Materials Code Case Acceptability ASME Section III, Division 1," Revision 24, dated July 1986.

5. Regulatory Guide 1.121, "Bases for Plugging Degraded PWR Steam Generator Tubes," dated August, 1976.

6. EPRI Technical Report 10001191, "Steam Generator Degradation Specific Management Flaw Handbook," dated 2001.

7. EPRI Technical Report TR-107569-VIR5, "PWR Steam Generator Examination Guidelines: Revision 5, Volume 1: Requirements," dated September, 1997.

8. EPRI Technical Report 1003138, "Pressurized Water Reactor Steam Generator Examination Guidelines: Revision 6, Requirements," dated October, 2002.

9. ABB-Combustion Engineering Report CEN-633-P, Revision 3, "Steam Generator Tube Repair for Combustion Engineering Designed Plants with 3/4" - .048" Wall Inconel 600 Tubes Using Leak Limiting Alloy 800 Sleeves," dated October 1998 (proprietary).

10.Westinghouse Electric LLC WCAP-15918-P, Revision 00, (CEN-633-P, Revision 05-P), "Steam Generator Tube Repair for Combustion Engineering and Westinghouse Designed Plant with 3 Inch Inconel 600 tubes Using Leak Limiting Alloy 800 Sleeves," dated November 2002 (proprietary).

1. Westinghouse Electric LLC WCAP-14797, Revision 1, "Generic W* Tube Plugging Criteria for 51 Series Steam Generator Tubesheet Region WEXTEX Expansions,"

dated February 1997 (proprietary).

Page 18

Beaver Valley Power Station Unit No. 1 License Amendment Request No. 322

12. Westinghouse Electric LLC WCAP-14798, Revision 1, "Generic W* Tube Plugging Criteria for 51 Series Steam Generator Tubesheet Region WEXTEX Expansions,"

dated February 1997 (nonproprietary).

13.License Amendment No. 231 to Facility Operating License No. DPR-53 and Amendment No. 207 to Facility Operating License No. DPR-69, "Calvert Cliffs Nuclear Power Plant, Unit Nos. 1 and 2 - Issuance of Amendment RE: Steam Generator Tube Repair Using Leak Limiting Alloy 800 Sleeves (TAC Nos. MA4278 and MA4279)," dated September 1, 1999 (ADAMS # ML010520103).

14.Tennessee Valley Authority letter "Watts Bar Nuclear Plant (WBN) - Unit 1 -

Proposed License Amendment Request Change No. WBN-S-02 Steam Generator Tube Repair Sleeve," dated December 13, 2002 (ADAMS #

ML023520628).

15.TXU Generation Company LP (TXU Energy) letter CPSES-200301190, "Comanche Peak Steam Electric Station (CPSES), Docket Nos. 50-445 and 50-446, License Amendment Request (LAR) 03-03, Revision to Technical Specification 5.5.9, Steam Generator Repair Using Leak Limiting Alloy 800 Sleeves," dated July 21, 2003 (ADAMS # ML032120445).

16.Pacific Gas & Electric Company (PG&E) letter DCL-03-132, "Diablo Canyon Power Plant Units 1 and 2 Docket Nos. 50-275 and 50-323, License Amendment Request (LAR) 03-15, "Steam Generator Tube Repair Using Leak Limiting Alloy 800 Sleeves and Revision to Technical Specification Table 5.5.9.-2, "Steam Generator (SG) Tube Inspection". dated October 22, 2003 (ADAMS #

ML033010563).

17. Beaver Valley Power Station Unit No. I Updated Final Safety Analysis Report.

Page 19

Westinghouse Westinghouse Electric Company Nuclear Services P.O. Box 355 Pittsburgh Pennsylvania 15230-0355 USA U.S. Nuclear Regulatory Commission Direct tel: (412) 374-5036 Document Control Desk Directfax: (412) 3744011 Washington, DC 20555-0001 e-mail: galem1js@westinghouse.com Our ref: CAW-03-1750 December 5, 2003 APPLICATION FOR WITHHOLDING PROPRIETARY INFORMATION FROM PUBLIC DISCLOSURE

Subject:

WCAP-15919-P, "Steam Generator Tube Repair for Westinghouse Designed Plants with 7/8 Inch Inconel 600 Tubes Using Leak Limiting Alloy 800 Sleeves" (Proprietary)

The proprietary information for which withholding is being requested in the above-referenced report is further identified in Affidavit CAW-03-1750 signed by the owner of the proprietary information, Westinghouse Electric Company LLC. The affidavit, which accompanies this letter, sets forth the basis on 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 Section 2.790 of the Commission's regulations.

Accordingly, this letter authorizes the utilization of the accompanying affidavit by First Energy Nuclear Operating Company.

Correspondence with respect to the proprietary aspects of the application for withholding or the Westinghouse affidavit should reference this letter, CAW-03-1750, and should be addressed to J. S. Galembush, Acting Manager, Regulatory Compliance and Plant Licensing, Westinghouse Electric Company LLC, P.O. Box 355, Pittsburgh, Pennsylvania 15230-0355.

Very truly yours, J. S. u , Acting Manager Regulatory Compliance and Plant Licensing Enclosures cc: D. Holland B. Benney E. Peyton A BNFL Group company

CAW-03-1750 bcc: J. S. Galembush (ECE 4-7A) IL R. Bastien, IL, IA (Nivelles, Belgium)

C. Brinkman, IL, IA (Westinghouse Electric Co., 12300 Twinbrook Parkway, Suite 330, Rockville, MD 20852)

RCPL Administrative Aide (ECE 4-7A) I L, IA (letter and affidavit only)

R. J. Sterdis, Waltz Mill E. A. Dzenis, ECE 4-3 G. W. Whiteman, ECE-410C R. F. Keating, Waltz Mill W. K. Cullen, Waltz Mill N. B. Closky, ECE 4-3 A BNFL Group company

CAW-03-1 750 AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA:

ss COUNTY OF ALLEGHENY:

Before me, the undersigned authority, personally appeared H. A. Sepp, who, being by me duly sworn according to law, deposes and says that he is authorized to execute this Affidavit on behalf of Westinghouse Electric Company LLC (Westinghouse), and that the averments of fact set forth in this Affidavit are true and correct to the best of his knowledge, information, and belief:

c24/

H. A. Sepp, Manager Regulatory Compliance and Plant Licensing Sworn to and subscribed before me this L day of Z 2003 A,71/

Notary Public I.~ ;*i; L-;;';'j;;NotarW Seal Sharon L oroNoary c

~ ~~~~~~Mnov~

7#~~~*n,0Xy to.o -no Cou MY Ccrss ores y 229 007 ma o *rn', Member. Pensqvaia Assodation of Ntaies

2 CAW-03-1750 (1) I am Manager, Regulatory Compliance and Plant Licensing, in Nuclear Services, Westinghouse Electric Company LLC (Westinghouse), and as such, I have been specifically delegated the function of reviewing the proprietary information sought to be withheld from public disclosure in connection with nuclear power plant licensing and rule making proceedings, and am authorized to apply for its withholding on behalf of Westinghouse.

(2) 1am making this Affidavit in conformance with the provisions of 10 CFR Section 2.790 of the Commission's regulations and in conjunction with the Westinghouse "Application for Withholding" accompanying this Affidavit.

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

(4) Pursuant to the provisions of paragraph (b)(4) of Section 2.790 of the Commission's regulations, the following is furnished for consideration by the Commission in determining whether the information sought to be withheld from public disclosure should be withheld.

(i) The information sought to be withheld from public disclosure is owned and has been held in confidence by Westinghouse.

(ii) The information is of a type customarily held in confidence by Westinghouse and not customarily disclosed to the public. Westinghouse has a rational basis for determining the types of information customarily held in confidence by it and, in that connection, utilizes a system to determine when and whether to hold certain types of information in confidence. The application of that system and the substance of that system constitutes Westinghouse policy and provides the rational basis required.

Under that 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:

(a) The information reveals the distinguishing aspects of a process (or component, structure, tool, method, etc.) where prevention of its use by any of Westinghouse's competitors without license from Westinghouse constitutes a competitive economic advantage over other companies.

3 CAW-03-1750 (b) 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.

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

(d) It reveals cost or price information, production capacities, budget levels, or commercial strategies of Westinghouse, its customers or suppliers.

(e) It reveals aspects of past, present, or future Westinghouse or customer funded development plans and programs of potential commercial value to Westinghouse.

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

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

(a) The use of such information by Westinghouse gives Westinghouse a competitive advantage over its competitors. It is, therefore, withheld from disclosure to protect the Westinghouse competitive position.

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

(c) Use by our competitor would put Westinghouse at a competitive disadvantage by reducing his expenditure of resources at our expense.

(d) 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

4 CAW-03-1 750 may be the key to the entire puzzle, thereby depriving Westinghouse of a competitive advantage.

(e) Unrestricted disclosure would jeopardize the position of prominence of Westinghouse in the world market, and thereby give a market advantage to the competition of those countries.

(f) The Westinghouse capacity to invest corporate assets in research and development depends upon the success in obtaining and maintaining a competitive advantage.

(iii) The information is being transmitted to the Commission in confidence and, under the provisions of 10 CFR Section 2.790, it is to be received in confidence by the Commission.

(iv) The information sought to be protected is not available in public sources or available information has not been previously employed in the same original manner or method to the best of our knowledge and belief.

(v) The proprietary information sought to be withheld in this submittal is that which is appropriately marked in WCAP-I5919-P, "Steam Generator Tube Repair for Westinghouse Designed Plants with 7/8 Inch Inconel 600 Tubes Using Leak Limiting Alloy 800 Sleeves" (Proprietary) dated August 2003. The information is provided in support of a submittal to the Commission, being transmitted by FirstEnergy Nuclear Operating Company letter (FENOC-03-223) and Application for Withholding Proprietary Information from Public Disclosure, to the Document Control Desk. The proprietary information as submitted for use by Westinghouse for Beaver Valley Unit I is expected to be applicable for other licensee submittals in support of the installation of Alloy 800 sleeves that span the degraded sections of the original steam generator tubes.

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

(a) Discuss the design features of the Alloy 800 sleeve.

5 CAW 1750 (b) Document the acceptability of installing Alloy 800 sleeves for the repair of the hot or cold leg of the Beaver Valley Unit I steam generator tubes.

(c) Discuss analysis and testing programs used in support of the development of the Alloy 800 sleeves.

Further this information has substantial commercial value as follows:

(a) Westinghouse plans to sell the use of similar information to its customers for purposes of meeting NRC requirements for licensing documentation.

(b) Westinghouse can sell support and defense of this information to its customers in the licensing process.

(c) The information requested to be withheld reveals the distinguishing aspects of a methodology which was developed by Westinghouse.

Public disclosure of this proprietary information is likely to cause substantial harm to the competitive position of Westinghouse because it would enhance the ability of competitors to provide similar licensing support documentation and licensing defense services for commercial power reactors without commensurate expenses. Also, public disclosure of the information would enable others to use the information to meet NRC requirements for licensing documentation without purchasing the right to use the information.

The development of the technology described in part by the information is the result of applying the results of many years of experience in an intensive Westinghouse effort and the expenditure of a considerable sum of money.

In order for competitors of Westinghouse to duplicate this information, similar technical programs would have to be performed and a significant manpower effort, having the requisite talent and experience, would have to be expended.

Further the deponent sayeth not.

PROPRIETARY INFORMATION NOTICE Transmitted herewith are proprietary and/or non-proprietary versions of documents furnished to the NRC in connection with requests for generic and/or plant-specific review and approval.

In order to conform to the requirements of 10 CFR 2.790 of the Commission's regulations concerning the protection of proprietary information so submitted to the NRC, the information which is proprietary in the proprietary versions is contained within brackets, and where the proprietary information has been deleted in the non-proprietary versions, only the brackets remain (the information that was contained within the brackets in the proprietary versions having been deleted). The justification for claiming the information so designated as proprietary is indicated in both versions by means of lower case letters (a) through (f) located as a superscript immediately following the brackets enclosing each item of information being identified as proprietary or in the margin opposite such information. These lower case letters refer to the types of information Westinghouse customarily holds in confidence identified in Sections (4)(ii)(a) through (4)(ii)(f) of the affidavit accompanying this transmittal pursuant to 10 CFR 2.790(b)(1).

COPYRIGHT NOTICE The reports transmitted herewith each bear a Westinghouse copyright notice. The NRC is permitted to make the number of copies of the information contained in these reports which are necessary for its internal use in connection with generic and plant-specific reviews and approvals as well as the issuance, denial, amendment, transfer, renewal, modification, suspension, revocation, or violation of a license, permit, order, or regulation subject to the requirements of 10 CFR 2.790 regarding restrictions on public disclosure to the extent such information has been identified as proprietary by Westinghouse, copyright protection notwithstanding. With respect to the non-proprietary versions of these reports, the NRC is permitted to make the number of copies beyond those necessary for its internal use which are necessary in order to have one copy available for public viewing in the appropriate docket files in the public document room in Washington, DC and in local public document rooms as may be required by NRC regulations if the number of copies submitted is insufficient for this purpose. Copies made by the NRC must include the copyright notice in all instances and the proprietary notice if the original was identified as proprietary.

Attachment A Beaver Valley Power Station, Unit No. 1 License Amendment Request No. 322 Proposed Technical Specification Changes The following are the affected pages:

3/4 4-9 3/4 4-lOb 3/4 4-1Oc

i REACTOR COOLANT SYSTEM SURVEILLANCE REQUIREMENTS (Continued)

2. Tubes in those areas where experience has indicated potential problems, and

3. Except for Alloy 800 leak-limitingsleeves, at least 3 percent of the total number of sleeved tubes in all three steam generators. A sample size less than 3 percent is acceptable provided all the sleeved tubes in the steam generator(s) examined during the refueling outage are inspected. AllJinservice Alloy 800 -sleeves sh thebefuni -- ln-cth 3x g a ~p 1 x s p ~ n t c j J r eaui val nt ui a i e dh techr ehelin refurn These inspections will include both the tube and the sleeve, and

4. A tube inspection pursuant to Specification 4.4.5.4.a.8. If any selected tube does not permit the passage of the eddy current probe for a tube or sleeve inspection, this shall be recorded and an adjacent tube shall be selected and subjected to a tube inspection.

5. Indications left in service as a result of application of the tube support plate voltage-based repair criteria (4.4.5.4.a.10) shall be inspected by bobbin coil probe during all future refueling outages.

c. The tubes selected as the second and third samples (if required by Table 4.4-2) during each inservice inspection may be subjected to a partial tube inspection provided:

1. The tubes selected for these samples include the tubes from those areas of the tube sheet array where tubes with imperfections were previously found, and

2. The inspections include those portions of the tubes where imperfections were previously found.

d. Implementation of the steam generator tube-to-tube support plate repair criteria requires a 100-percent bobbin coil inspection for hot-leg and cold-leg tube support plate intersections down to the lowest cold-leg tube support plate with known outside diameter stress corrosion cracking (ODSCC) indications. The determination of the lowest cold-leg tube support plate intersections having ODSCC indications shall be based on the performance of at least a 20-percent random sampling of tubes inspected over their full length.

The results of each sample inspection shall be classified into one of the following three categories:

BEAVER VALLEY - UNIT 1 3/4 4-9 Amendment No. 479-

DPR-66 REACTOR COOLANT SYSTEM SURVEILLANCE REQUIREMENTS (Continued)

6. Plugging or Repair Limit means the imperfection depth at or beyond which the tube shall be removed from service by plugging or repaired by sleeving in the affected area because it may become unserviceable prior to the next inspection. The plugging or repair limit imperfection depths are specified in percentage of nominal wall thickness as follows:

a) Original tube wall 40%

This definition does not apply to tube support plate intersections for which the voltage-based repair criteria are being applied. Refer to 4.4.5.4.a.10 for the repair limit applicable to these intersections.

b) ABB Combustion Engineering TIG welded sleeve wall 32%

c) Westinghouse laser welded sleeve wall 25%

d) Westi ouse Alloy 800 leak iting asleeve*: Plugon detection of any srie induced iPerfction.

degradation or efect in t (a) Ileeado bI pressre bsadry oortion of the original tubewll in the sleeve/tube ass blyi.e. the sleeve-to-tube joint).

7. Unserviceable describes the condition of a tube if it leaks or contains a defect large enough to affect its structural integrity in the event of an Operating Basis Earthquake, a loss-of-coolant accident, or a steamline or feedwater line break as specified in 4.4.5.3.c, above.

8. Tube Inspection means an inspection of the steam generator tube from the point of entry (hot-leg side) completely around the U-bend to the top support to the cold-leg.

9. Tube Repair refers to sleeving which is used to maintain a tube in-service or return a tube to service. This includes the removal of plugs that were installed as a corrective or preventive measure. The following sleeve designs have been found acceptable:

a) ABB Combustion Engineering TIG Welded Sleeves, CEN-629-P, Revision 02 and CEN-629-P Addendum 1.

b) Westinghouse laser welded sleeves, WCAP-13483, Revision 1.

.i p.PicahLe only to Ce 17.l BEAVER VALLEY - UNIT 3/4 4-10b Amendment No. 2 REACTOR COOLANT SYSTEM SURVEILLANCE REQUIREMENTS (Continued)

Westinghouse Alloy 800 sleeves, WCAP-15919-P I Revision 00. *

10. Tube Support Plate Plugging Limit is used for the disposition of an alloy 600 steam generator tube for continued service that is experiencing predominantly axially oriented' outside diameter stress corrosion cracking confined within the thickness of the tube support plates. At tube support plate intersections, the plugging (repair) limit is based on maintaining steam generator tube serviceability as described below:

a) Steam generator tubes, whose degradation is attributed to outside diameter stress corrosion cracking within the bounds of the tube support plate with bobbin voltages less than or equal to 2.0 volts will be allowed to remain in service.

b) Steam generator tubes, whose degradation is attributed to outside diameter stress corrosion cracking within the bounds of the tube support plate with a bobbin voltage greater than 2.0 volts will be repaired or plugged, except as noted in 4.4.5.4.a.10.c below.

c) Steam generator tubes, with indications of potential degradation attributed to outside diameter stress corrosion cracking within the bounds of the tube support plate with a bobbin voltage greater than 2.0 volts but less than or equal to the upper voltage repair limit(l) may remain in service if a rotating pancake coil or acceptable alternative inspection does not detect degradation. Steam generator tubes, with indications of outside diameter stress corrosion cracking degradation with a bobbin voltage greater than the upper voltage repair limit(l) will be plugged or repaired.

d) If an unscheduled mid-cycle inspection is performed, the following mid-cycle repair limits apply instead of the limits identified in 4.4.5.4.a.10.a, 4.4.5.4.a.10.b, and 4.4.5.4.a.10.c.

Appicable only ts Cycle 17.

(1) The upper voltage repair limit is calculated according to the methodology in Generic Letter 95-05 as supplemented.

BEAVER VALLEY - UNIT 1 3/4 4-10c Amendment No. 29

Attachment B Beaver Valley Power Station, Unit No. 1 License Amendment Request No. 322 Proposed Technical Specification Bases Changes Technical Specification Bases changes are provided for information only.

The following is the only affected page:

B 3/4 4-2

DPR-66 REACTOR COOLANT SYSTEM ProIidedfor Information Only.

BASES 3/4.4.5 STEAM GENERATORS (Continued) operation would be limited by the limitation of steam generator tube leakage between the Primary Coolant System and the Secondary Coolant System (primary-to-secondary LEAKAGE = 150 gallons per day per steam generator). Axial cracks having a primary-to-secondary LEAKAGE less than this limit during operation will have an adequate margin of safety to withstand the loads imposed during normal operation and by postulated accidents. Operating plants have demonstrated that primary-to-secondary LEAKAGE of 150 gallons per day per steam generator can readily be detected. Leakage in excess of this limit will require plant shutdown and an unscheduled inspection, during which the leaking tubes will be located and plugged or repaired by sleeving. The technical bases for sleeving are described in the approved vendor reports listed in Surveillance Requirement 4.4.5.4.a.9.

Wastage-type defects are unlikely with the all volatile treatment (AVT) of secondary coolant. However, even if a defect of similar type should develop in service, it will be found during scheduled inservice steam generator tube examinations. Plugging or repair will be required of all tubes with imperfections exceeding the plugging or repair limit. Degraded steam generator tubes may be repaired by the installation of sleeves which span the degraded tube section. A steam generator tube with a sleeve installed meets the structural requirements of tubes which are not degraded, therefore, the sleeve is considered a part of the tube. The surveillance requirements identify those sleeving methodologies approved for use. o I Alloy 800 sleeves. if an installed sleeve is found to have through I wall penetration greater than or equal to the plugging limit, the tube must be plugged. The plugging limit for the sleeve is derived from R.G. 1.121 analysis which utilizes a 20 percent allowance for eddy current uncertainty in determining the depth of tube wall penetration and additional degradation growth. Steam generator tube inspections of operating plants have demonstrated the capability to reliably detect degradation that has penetrated 20 percent of the original tube wall thickness. All tubes wdithA11N 80 sleeveswill be oluraed un detection of any service induced imerfection.

deiradation or defect in the sl /or the px.surjeyundarv of the orinal tube wall in the sleeve/tube assembly (i.e., the sleeve-to-tube oint)

The voltage-based repair limits of these surveillance requirements (SR) implement the guidance in Generic Letter (GL) 95-05 and are applicable only to Westinghouse-designed steam generators (SGs) with outside diameter stress corrosion cracking (ODSCC) located at the tube-to-tube support plate intersections. The voltage-based repair limits are not applicable to other forms of SG tube degradation nor are they applicable to ODSCC that occurs at other locations within the SG. Additionally, the repair criteria apply only to indications where the degradation mechanism is dominantly axial ODSCC with BEAVER VALLEY - UNIT 1 B 3/4 4-2a Amendment No. Ale

Attachment C Beaver Valley Power Station, Unit No. 1 License Amendment Request No. 322 Commitment Summary i

The following list identifies those actions committed to by FirstEnergy Nuclear Operating Company (FENOC) for Beaver Valley Power Station (BVPS), Unit No. 1 in this document.

Any other actions discussed in the submittal represent intended or planned actions by Beaver Valley. These other actions are described only as information and are not regulatory commitments. Please notify Mr. Larry R. Freeland, Manager, Regulatory Affairs/Performance Improvement, at Beaver Valley on (724) 682-5284 of any questions regarding this document or associated regulatory commitments.

Commitment Due Date The sleeves will be installed in accordance with the Process to address this processes provided by the vendor and described in the commitment will be in place upon associated reports which address sleeve design, implementation of the amendment qualification, installation methods, non-destructive which approves the proposed examination and ALARA considerations. Technical Specification changes supporting tube repair by leak limiting Alloy 800 sleeves.

A plant specific document that specifies the allowable Process to address this location of tube eddy current testing indications in commitment will be in place upon order to perform a successful sleeve installation will be implementation of the amendment established in accordance with WCAP-15919-P which approves the proposed requirements. This document will be utilized to Technical Specification changes determine that a tube is an acceptable sleeving supporting tube repair by leak candidate. limiting Alloy 800 sleeves.

Attachment C Commitment Summary Page 2 Commitment Due Date FENOC will conservatively assume all installed Process to address this sleeves will leak for post-accident leakage calculations. commitment will be in place upon The leak rate for each sleeve will be based on the upper implementation of the amendment 95 percent confidence limit on the mean value of which approves the proposed leakage for appropriate temperature and pressure Technical Specification changes conditions. The total sleeve leak rate will be combined supporting tube repair by leak with the total amount of leakage from all other sources limiting Alloy 800 sleeves.

(i.e. alternate repair criteria and non-alternate repair criteria indications) for comparison against the limit on accident induced leakage as specified in the UFSAR for the MSLB radiological consequences analysis.

This total calculated accident induced leakage will be reported in the 90-day report required by NRC Generic Letter 95-05, Attachment 1, Section 6.b.

As required by EPRI Technical Report 1003138, post- Process to address this installation (pre-service) examination will be commitment will be in place upon performed on the full length of 100 percent of leak implementation of the amendment limiting Alloy 800 sleeve/tube assemblies using Plus which approves the proposed Point rotating coil or an equivalent EPRI Technical Technical Specification changes Report 1003138 Appendix H technique if one becomes supporting tube repair by leak available. This examination will establish in-service limiting Alloy 800 sleeves.

inspection baseline data and initial installation acceptance data on the primary pressure boundary of the sleeve/SG tube assembly repair.

FENOC will use the sleeve/plug ratio values contained Process to address this in Table 10-1 of WCAP-15919-P to determine the commitment will be in place upon equivalent SG plugging due to installed leak limiting implementation of the amendment Alloy 800 sleeves, unless more appropriate values which approves the proposed become available. The total SG plugging level for each Technical Specification changes SG will be determined by adding the equivalent SG supporting tube repair by leak plugging percentage due to installed leak limiting Alloy limiting Alloy 800 sleeves.

800 sleeves to the percent of SG tubes plugged.

The above commitments are only applicable to Cycle 17.

Attachment D Beaver Valley Power Station, Unit No. 1 License Amendment Request No. 322 Westinghouse WCAP-15919-NP, Revision 00, "Steam Generator Tube Repair for Westinghouse Designed Plants With 7/8 Inch Inconel 600 Tubes Using Leak Limiting Alloy 800 Sleeves" Note: The attached WCAP is Westinghouse non-proprietary.

I Attachment E Beaver Valley Power Station, Unit No. 1 License Amendment Request No. 322 Westinghouse WCAP-15919-P, Revision 00, "Steam Generator Tube Repair for Westinghouse Designed Plants With 7/8 Inch Inconel 600 Tubes Using Leak Limiting Alloy 800 Sleeves" M

Note: The attached WCAP is Westinghouse proprietary.

v t e Letter Sequence Request
TAC:MC1857, (Approved, Closed)
Initiation Request, Request Acceptance... Administration Withholding Request Acceptance Questions 11 May 2004 Answers Results Approval Other: ML042810515
MONTHYEAR2004-10-05 [Table View]

L-04-009, License Application No. 322 Regarding Steam Generator Tube Repair Using Alloy 800 Sleeves

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L-04-009, License Application No. 322 Regarding Steam Generator Tube Repair Using Alloy 800 Sleeves

Text

Subject:

Enclosures:

Subject:

1.0 DESCRIPTION

2.0 PROPOSED CHANGE

3.0 BACKGROUND

4.0 TECHNICAL ANALYSIS

6.0 ENVIRONMENTAL CONSIDERATION

7.0 REFERENCES

1.0 DESCRIPTION

2.0 PROPOSED CHANGE

3.0 BACKGROUND

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