DCL-04-019, Voltage-Based Repair Criteria Benchmarking and EOC-12 Projections

Voltage-Based Repair Criteria Benchmarking and EOC-12 Projections

ML040830711
Person / Time
Site:	Diablo Canyon
Issue date:	03/16/2004
From:	Womack L Pacific Gas & Electric Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
DCL-04-019
Download: ML040830711 (47)

Text

Pacidc Gas and Electric Company Lawrence F.Womack Diablo Canyon Power Plant Vice President PO. Box 56 Nuclear Services Avila Beach. CA 93424 March 16, 2004 805.545.4620 Fax: 805.545.4234 PG&E Letter DCL-04-019 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Docket No. 50-275, OL-DPR-80 Diablo Canyon Unit 1 DCPP Unit 1 Voltage-Based Repair Criteria Benchmarking and EOC-12 Proiections

Dear Commissioners and Staff:

Pacific Gas & Electric Company (PG&E) provided the 90-day report of steam generator (SG) tube inspections performed during the 2002 Unit 1 eleventh refueling outage (1R11) in PG&E Letter DCL-02-098, dated August 22, 2002.

PG&E provided responses to NRC questions regarding the 1R11 inspections in PG&E Letter DCL-03-113, dated September 15, 2003. PG&E's response to NRC questions 7 and 8, regarding voltage-based repair criteria, committed to perform Unit 1 benchmarking analyses of voltage dependent growth (VDG) methods and probability of prior cycle detection (POPCD) methods prior to the next Unit I SG tube inspections during the Unit 1 twelfth refueling outage (1R12),

scheduled to begin in late March 2004. In addition, in an October 7, 2003, NRC/PG&E meeting, the NRC requested that the Unit 1 benchmarking analyses address the applicable NRC questions previously addressed for Unit 2 in PG&E Letter DCL-03-121, dated September 30, 2003. The NRC also requested that PG&E provide revised Unit 1 end of cycle (EOC) 12 projections to compare with the as-found conditions during 1R12.

The enclosure provides the Unit 1 prior cycle benchmarking analyses using POPCD and VDG methods, and also addresses applicable NRC questions in PG&E Letter DCL-03-121, dated September 30, 2003. The Unit 1 benchmarking analyses show that the projected steam line break (SLB) leak rate and probability of burst values exceeded the as-found values for all steam generators for both EOC-10 and EOC-1 1, thus demonstrating that use of POPCD provides conservative projections.

The enclosure also provides the revised EOC-12 projections using conservative VDG methods and the DCPP Units 1 and 2 POPCD distribution approved by the NRC in License Amendment (LA-164) for Unit 2 Cycle 12 (Cases 3 and 5). A 17 case using the prior cycle detection factor of 0.6 is also provided for sensitivity (Case 4). Each case shows sufficient margin against the allowable limits for A member of the STARS (Strategic Teaming and Resource Sharing) Alliance Callaway

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Document Control Desk PG&E Letter DCL-04-019 March 16, 2004 Page 2 burst and SLB leak rate at EOC-12. These results will be used to benchmark the methodologies with the as-found conditions during 1R1 2.

EPRI is currently developing an outlier growth method for application to voltage-based repair criteria coincident with the use of POPCD. Upon completion of the methodology development, expected by second quarter 2004, the methodology will be submitted to the NRC, and PG&E will provide the NRC with revised Unit 1 EOC-12 projections using the new method.

If you have further questions please contact John Arhar at (805) 545-4629.

Sin(

Lawrence F.Womack CJc Vice President Nuclear Services ddm/469/A0594730 Enclosure cc/enc: Bruce S. Mallett David L. ProuIx Girija S. Shukla State of California, Pressure Vessel Unit Diablo Distribution A member of the STARS (Strategic Teaming and Resource Sharing) Alliance CatLaway

• Comanche Peak

• Diablo Canyon

• Palo Verde

• South Texas Project

• Wolf Creek

PG&E Letter DCL-04-019 Enclosure Framatome ANP DCPP Unit 1 Voltage-Based ARC Benchmarking Results and Revised EOC-12 Projections Document Identifier 86-5039942-00 A member of the STARS (Strategic Teaming and Resource Sharing) Alliance Callaway

• Comanche Peak

• Diablo Canyon

• Palo Verde

• South Texas Project

• Wolf Creek

20697-6 (2/2002)

A CALCULATION

SUMMARY

SHEET (CSS)

FRAMATOME ANP Document Identifier 86 - 5039942 - 00 Title DCPP Unit I Voltage-Based ARC Benchmarking Results and Revised EOC 12 Projections PREPARED BY: REVIEWED BY:

METHOD: 3 DETAILED CHECK aI INDEPENDENT CALCULATION NAME Alan M B rowmiI NAME Jeffrey M Fleck SIGNATURE }//r--6 ,44/W g'^ ~ act of SIGNATUR TITLE Engineer IV DATE 243/4y TITLE Manager DATE COST REF. TM STATEMENT: (1/

CENTER 12742 PAGE(S) Y6 REVIEWER INDEPENDENCE YJQ PURPOSE AND

SUMMARY

OF RESULTS:

This document provides updated probability of burst and leak rate calculations for Diablo Canyon Unit I Cycle

12. These calculations are being updated to Include the use of two new methods: a voltage dependent probability of detection (referred to as POPCD) and voltage dependent growth. This document also provides the results of a benchmarking effort which was performed on previous outage results to show that the new methodologies provide reasonable and conservative results.

This document provides a non-proprietary summary of the results. The supporting proprietary calculations and necessary code verifications required for safety-related calculations are provided in Reference 15.

The benchmarking of the prior cycle results showed that the projected probability of burst and leak rate using the new methodologies were conservative when compared to the as-found conditions.

The new projections for EOC-12 (the current cycle) show that the probability of burst and leak rate limits are not exceeded even when using conservative growth rates that include data from Unit 2. These calculations will be used to benchmark the methodologies when the EOC-12 as-found results are available during the next Unit 1 inspections in April 2004 (outage 1R12).

THE FOLLOWING COMPUTER CODES HAVE BEEN USED INTHIS DOCUMENT: THE DOCUMENT CONTAINS ASSUMPTIONS THAT MUST BE VERIFIED PRIOR TO USE ON SAFETY-RELATED WORK CODE/VERSIONIREV CODENVERSION/REV tkr97v30 / 3.0 pob97v2O / 2.0 __ YES Z NO Page I of 42 vZ%"easy A,-L 6 X-2 OtpF

86-5039942-00 Page 2 of 42 Record of Revision Revision Chanaed Section(s) Description of Change(s) 0 All Initial Release Table of Contents Section Description Page 1.0 Introduction 3 2.0 Prior Cycle Benchmarking 4 2.1 BOC Voltage Distributions 4 2.2 Voltage Growth Rates 4 2.3 Leak and Burst Correlations 5 2.4 POPCD Correlation 5 2.5 NDE Uncertainties 5 2.6 Cycle Lengths 5 2.7 Benchmarking Results 6 3.0 Recalculated EOC-12 Projections 20 3.1 BOC Voltage Distributions 20 3.2 Voltage Growth Rates 20 3.3 POPCD Correlation 23 3.4 Cycle Length 23 3.5 EOC-12 Leak Rate and POB Results 23 4.0 Conclusions 41 5.0 References 42

86-5039942-00 Page 3 of 42

1.0 INTRODUCTION

The current NRC-approved method for accounting for undetected flaws in the voltage-based alternate repair criteria for ODSCC at support plates requires the use of a constant probability of detection (POD) of 0.6. However, it is well known and documented that the POD is a function of voltage, i.e.,

the POD increases with increasing voltage. Using the constant POD of 0.6 usually underestimates the number of small voltage indications but overestimates the number of large voltage indications at the end of the next cycle. This significant overestimation of the number of large voltage indications has a significant, but unrealistic, impact on the probability of burst and leak rate calculations required by Generic Letter 95-05 (Reference 1). Utilizing a more realistic voltage-dependent POD should give a better estimation of future conditions of the steam generator tubes in both the number of flaws and the probability of burst (POB) and leak rate results.

The purpose of this report is to document new POB and leak rate results using two new methods: a DCPP-specific voltage-dependent POD (referred to as POPCD) and voltage dependent growth (VDG). The details of the DCPP-specific POPCD are documented in Reference 2. This document provides new projections for the end of the current operating cycle (Cycle 12). It also contains prior cycle (EOC-10 and EOC-11) benchmarking projections to ensure that the new methodology provides reasonable and conservative results compared to the as-found conditions at EOC-10 and EOC-1 1.

During the 2R1 1 inspection in February 2003, several bobbin coil indications were detected that were larger than expected. An extensive study was performed to determine the cause of the large growth rates during Unit 2 Cycle 11. This study concluded that Unit 2 was experiencing higher than expected voltage-dependent growth. This simply means that the larger indicabons returned to service generally experience larger growth rates. Based on these results, a methodology was developed to first determine voltage breakpoints and then apply voltage-dependent growth to the leak rate and probability of burst calculations. This methodology uses a 'piecewise linear regression analysis' to determine where there may be changes in the growth rate as a function of beginning-of-cycle (BOC) voltage (Reference 3).

Using the 0.6 POD from Reference 1 gives unrealistic and overly conservative leak rate and POB results. Therefore, approval of a voltage-dependent POD (commonly referred to as POPCD or Probability of Prior Cycle Detection) was pursued. Approval of the use of a DCPP-specific POPCD for Unit 2 Cycle 12 was obtained via Reference 4. This approval, however, didn't apply to Unit 1 or to future cycles at Unit 2. Benchmarking of prior Unit 2 cycles has already been performed and is documented in Reference 2. This report provides similar benchmarking results for Unit 1. In addition, this document provides new projections for Unit 1 EOC-12 using the new methodologies.

Framatome ANP uses Monte Carlo codes to provide the leak rate and POB results. These codes were revised per References 5 and 6 to incorporate the new POPCD and VDG methodologies.

86-5039942-00 Page 4 of 42 2.0 PRIOR CYCLE BENCHMARKING In order to benchmark the new methodologies, the operational assessment calculations for Cycles 10 and 11 were recalculated and compared to the as-found results. In addition, the as-found results were also recalculated using the latest leak and burst correlations to be consistent with the projected results. This section provides the inputs and the results from these calculations.

2.1 BOC Voltage Distributions The beginning-of-cycle voltage distributions used in these benchmarking calculations were obtained from the 90-Day Reports from 1R9 and 1R10 (References 7 and 8). Since the benchmarking calculations used the POPCD methodology, the number of undetected indications in each voltage bin is calculated by the Monte Carlo codes. Therefore, the voltage inputs are limited to the as-found voltages and the repaired voltages, i.e., no POD adjustment of the input voltage distribution is required. Tables 2-1 and 2-2 provide the voltage distributions used in the benchmarking calculations.

2.2 Voltage Growth Rates The growth rates used in the calculations for this benchmarking exercise were developed based on the requirements and recommendations in References 1 and 3. For the EOC-10 calculation, the growth rates used for the benchmarking were the same as those used in the 1R9 90 day report (Reference 7). An industry bounding curve was used because the Unit 1 Cycle 9 growth distribution contained less than the 200 data points required by Reference 1. Since tubes were deplugged in 1R9, an industry bounding curve for deplugged tubes was also used for the EOC-10 projection. The active and deplugged bounding growth curves were combined based on the number of active and deplugged tubes being returned to service for Cycle 10 using the methods shown in Reference 9.

Since no voltage dependent growth was evident in the Cycle 9 data, a voltage independent growth distribution was used. Table 2-3 shows the growth rates used for the EOC-10 projections.

For the EOC-1 1 projections, the growth rates used for the benchmarking differed from those used in the IRIO 90 day report (Reference 8), primarily due to additional knowledge gained using VDG methods and also due to experience with deplugged and active tubes at DCPP having no significant differences In growth. DCPP-1 actual growth data was used since more that 200 data points were available. During 1R110, tubes with distorted ODSCC bobbin signals (DOS) were deplugged and returned to service in SG 1-1 and SG 1-2. Since DCPP now had growth data from previously deplugged tubes, the DCPP-specific growth rates for deplugged tubes could be used. For this benchmarking exercise, however, the active and deplugged growth rates were combined since none of the prior growth analyses at DCPP have shown significant differences between the active and deplugged populations. A comparison of the growth rates for the individual steam generators showed that SG 1-1 had the limiting growth distribution. As a conservative measure, this growth distribution from SG 1-1 was applied to all steam generators for the EOC-1 I projections. The SG 1-1 growth data was also reviewed for voltage dependency. This data showed a slight voltage dependency.

Using the methodology described in Reference 3, the SG 1-1 data was determined to have a

'breakpoint at 0.62 volts. Figure 2-1 shows the growth versus BOC voltage for SG 1-1 Cycle 10 and results of the breakpoint analysis.

In addition to the VDG analysis discussed above, a comparison of growth rates from Cycles 9 and 10 was performed. The purpose of this comparison is to determine if the growth rates are increasing with time and to allow for corrective actions if such a change is occurring. For SG 1-1, the growth rate for indications < 0.62v increased from 0.103vIEFPY during Cycle 9 to 0.161v/EFPY during Cycle

10. Likewise, the growth rate for indications >0.62v increased from 0.228v/EFPY during Cycle 9 to 0.248v/EFPY during Cycle 10. For this benchmarking exercise, it was assumed that this increase in the growth rate would continue for Cycle 11. Therefore, values of 0.058v/EFPY for the lower bin and 0.02v/EFPY for the upper bin were added to each Cycle 10 data point prior to binning the growth data. This is the same as the 'delta-volts VDG strategy" discussed in the response to RAI Question

1. 3 in Reference 2.

86-5039942-00 Page 5of 42 Based on this analysis, two different growth distributions were used for the EOC-1 I projections based on the BOC voltage (<=0.62v and >0.62v). These growth distributions are shown in Table 2-4.

2.3 Leak and Burst Correlations During the 2R1 I outage, sections from two tubes in SG 2-4 were removed and sent to Lynchburg for destructive examination and laboratory testing. The data from these tests were used to supplement the data in the latest industry database (Reference 9). Based on the results of these tests, the Reference 9 correlation parameters were updated and provided to DCPP via Reference 10. These updated parameters are provided in Tables 2-5 through 2-7 and were used for all of the benchmarking calculations in this section.

2.4 POPCD Correlation Per Reference 4, the NRC approved the use of the DCPP-specific POPCD for Unit 2 Cycle 12. The POPCD correlation that was approved is provided in Table 3 of Reference 11 and is labeled as 'New NRC POPCD". However, the benchmarking calculations-of the previous results used an industry POPCD correlation since DCPP did not meet the minimum data requirements for using a site-specific POPCD correlation at these earlier outages. The industry POPCD is shown in Table 2-8 and was taken from Reference 14.

2.5 NDE Uncertainties NDE uncertainties must be taken Into account when projecting the end-of-cycle voltages for the next operating cycle. The NDE uncertainties used in these benchmarking calculations are described in Ref. 1. The acquisition uncertainty was sampled from a normal distribution with a mean of zero, a standard deviation of 7%, and a cutoff limit of 15% based on the use of the probe wear standard. The analyst uncertainty was sampled from a normal distribution with a mean of zero, a standard deviation of 10.3%, and no cutoff limit.

2.6 Cycle Lengths The projected cycle lengths used for these benchmarking calculations were taken directly from the 1R9 and 1RI0 90-Day Reports (References 7 and 8). These values are 1.58 EFPY for Cycle 10 and 1.45 EFPY for Cycle 11. It should be noted that these are the projected cycle lengths at the beginning of the respective cycle. The actual cycle lengths are now known (1.49 EFPY for Cycle 10 and 1.41 EFPY for Cycle 11). However, the actual values were not used to be consistent with the philosophy of using only the data that was known at the time the original calculations were performed.

In order to determine the impact that the differences in the cycle lengths would have on the results, a sensitivity calculation was performed. This calculation was performed for the case that had the least margin available between the projected and as-found results. This case was the EOCI I projection for POB for SG 1-1. The original calculation using 1.45 EFPY yielded a POB of 9.96E-05. Using the actual cycle length of 1.41 EFPY and the same seed number for the random number generator yielded a POB of 9.51E-05. This is still higher than the as-found POB of 8.82E-05 and not significantly different from the projected cycle length. Therefore, the differences are not significant to warrant using the actual EFPY from the cycles in the benchmarking calculations. However, if the differences were more significant, it would be appropriate for benchmarking to use the known cycle lengths to have the best comparison between projections and actual conditions.

86-5039942-00 Page 6 of 42 2.7 Benchmarking Results Table 2-9 provides the results of the benchmarking calculations for EOC-10 and EOC-1 I conditions.

Since the projected values used updated leak and burst correlations, the as-found leak rate and POB values were also recalculated using the new correlations. As shown in the table, the projected leak rate and POB values exceeded the as-found values for all steam generators for both EOC-10 and EOC-1 1.

Table 2-10 provides a comparison of the projected EOC-1 1 voltage distributions to the as-found EOC voltages. As shown in this table, the total number of indications is underpredicted in all cases, due to under predictions of small voltage indications (<lv). However, the number of high voltage indications in the '>1V" and >'2V" categories is significantly overestimated in all cases. This overestimation of the more significant flaws results in consistently conservative leak rate and POB results.

Per Reference 4, a methods assessment shall be performed if the total number of as-found indications is underestimated by more than 15 percent. This criterion was exceeded for all steam generators for EOC-1 1. Since SG 1-1 had the greatest underprediction (37%), an assessment of the significance of this underprediction was performed for SG 1-1. As shown in Table 2-10, the underprediction occurred in the smaller voltage range (L1v). Therefore, additional POB and leak rate calculations were performed after artificially adjusting the BOC voltage distribution to account for the underprediction. This adjustment was performed by first comparing the as-found voltages to the projected EOC-1 I voltages. For each voltage bin less than Iv where the number of indications was underpredicted, the BOC-1I distribution was increased by the amount of the difference between the as-found and projected numbers. Note that this adjustment is made prior to application of the POD.

When the POD is applied in the simulation, the number of indications will be further increased and thus overpredicted at the EOC.

The POB and leak rate calculations were performed again using the adjusted BOC voltage distribution. Table 2-11 provides a comparison of the results between the projections using the normal BOC distribution and the adjusted BOC distribution. As expected, using the adjusted BOC distribution yields a significant overprediction of the total number of indications. The POB is increased by 4.04E-05 and the leak rate is increased by 0.154 gpm. These increases are insignificant relative to, the limits for POB and leak rate. The change in the POB is less than 0.5% of the limit of 1.OE-02. The change in the leak rate is about 1.5% of the allowable leak rate of 10.5 gpm.

A large part of this increase in the POB and leak rate, however, is likely attributable to the fact that a lot of the indications that were added to the BOC distribution grew to more significant voltages. This is shown in Table 2-11. As shown in the table, the projected number of indications >lv increased by 66 indications despite the fact that only indications less than lv were added to the BOC distribution.

This means that 66 of the <1V indications that were added to the BOC distribution grew to voltages greater than I volt in the Monte Carlo simulation.

For comparison, the SG 1-1 EOC-11 conditions were calculated using the POD of 0.6. The results, provided in Table 2-11, also demonstrated a significant underprediction in the number of indications

<IV.

It is concluded that no methods changes are required due to underestimation of the low voltage indications. The most likely cause for the underestimation is that the industry POPCD below about 0.5 to 0.6 volt is too high for DCPP applications as can be seen from comparisons of the industry and DCPP specific POPCD distributions in Figure 2-2 (Ref. 16).

86-5039942-00 Page 7 of 42 Table 2-1 1R9 Voltages for Use in EOC-10 Projections

_ SGIII _ SGI2 SG13 SGI4 Voltage Raie Rei Bin As-Found + ReardAs-Found + ReardAs-Found + ReardAs-Found

• eaie Deplugged Deplugged Deplugged Deplugged Repaired 0.1 2 _

0.2 4 __ _ _ _5 1 _ _ _ _ _

0.3 16 13 1 3 . 2 0.4 14 1 20 2 8 2 0.5 5 12 6 2 0.6 4 1 12 3 9 2 0.7 4 10 1 6 1 2 0.8 3 2 1 9 1 0.9 2 _3 1 7 _ _ _

1 1_ _ _4 _ _ _3 _ _ _

1.2 2 == 1 ==1 1.3 22 3_

1.4 1 _

1.5 59 3 85 1 1 _ 0 1 .6 _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ 1 _ _ _ _ _ _ _ _

1 .8 1 _ _ _ _ _ _ _ _ _ _ _ _ _ _1 _ _ _ _ _ _

2.3 1 1 _ _ _ _ _

>2.4 _ _ _ _ _

Total 59 13 85 959 1 13 0

86-5039942-00 Page 8 of 42 Table 2-2 1RI0 Voltages for Use in EOC-11 Projections SGVoltageI1 SG12 SG13 SG14 Voltage A-on sFudRpie Bin As-Found + Repaired As-Fund4 Repaired As-Fund+ Repalred As-Found + Repaired Deplugged _____Deplugged Deplugged Deplugged 0.1 ___ .

0.2 2 --2 1 33 0.3 19 1 9 1 8 _

0.4 37 31 2 10 _ 5 0.5 29 42 3 13 8 1 0.6 25 27 6 13 1 16 3 0.7 20 1 22 4 8 2 0.8 16 21 3 9 1 2 _

0.9 8 10 5 3 1 8 3 2 4 1.1 12 1 6 1 1.2 5 3 4 2 1.3 1 4 1.4 _5 6 1 1 1.5 1 2 1 2 1.6 1 _ 3 1 1.7 1 1 1.8 1 1.9 ._

2 2 2.1 _ _ _ _ _ _ _ _ _

2.2 .

2.3 _ _

2.4 1 1 2.6 _

2.7-2.8 1 1 2.9 1 1 .

3

>3.0 T3.0 5_ __176 ___20_96_ _54 _4 otl165180 20196 5m 54 .-

86-5039942-00 Page 9 of 42 Table 2-3 Growth Curves Used for EOC-10 Projections (shown in CPDF format)

Growth SG 1-1 SG 1-2 SG 1-3 SG 1-4 Sin _ _ _

0 0.0664 0.0755 0.0740 0.0755 0.1 0.2876 0.3046 0.3018 0.3046 0.2 0.5346 0.5575 0.5537 0.5575 0.3 0.7216 0.7509 0.7460 0.7509 0.4 0.8155 0.8473 0.8420 0.8473 0.5 0.8681 0.8944 0.8901 0.8944 0.6 0.8979 0.9230 0.9188 0.9230 0.7 0.9180 0.9383 0.9350 0.9383 0.8 0.9349 0.9499 0.9474 0.9499 0.9 0.9517 0.9614 0.9598 0.9614 1 0.9551 0.9637 0.9623 0.9637 1.1 0.9588 0.9681 0.9666 0.9681 1.2 0.9693 0.9771 0.9758 0.9771 1.3 0.9727 0.9794 0.9783 0.9794 1.4 0.9727 0.9794 0.9783 0.9794 1.5 0.9751 0.9824 0.9812 0.9824 1.6 0.9754 0.9827 0.9815 0.9827 1.7 0.9855 0.9896 0.9889 0.9896 1.8 0.9889 0.9919 0.9914 0.9919 1.9 0.9956 0.9965 0.9964 0.9965 2 0.9959 0.9968 0.9967 0.9968 2.1 0.9959 0.9968 0.9967 0.9968 2.2 0.9959 0.9968 0.9967 0.9968 2.3 0.9961 0.9971 0.9970 0.9971 2.4 0.9961 0.9971 0.9970 0.9971 2.5 0.9961 0.9971 0.9970 0.9971 2.6 0.9961 0.9971 0.9970 0.9971 2.7 0.9961 0.9971 0.9970 0.9971 2.8 0.9961 0.9971 0.9970 0.9971 2.9 0.9961 0.9971 0.9970 0.9971 3 0.9961 0.9971 0.9970 0.9971 3.1 0.9961 0.9971 0.9970 0.9971 3.2 0.9964 0.9974 0.9972 0.9974 3.8 0.9964 0.9974 0.9972 0.9974 3.9 0.9998 0.9998 0.9998 0.9998 4.5 0.9998 0.9998 0.9998 0.9998 7 0.9998 0.9998 0.9998 0.9998 9.4 1.0000 1.0000 1.0000 1.0000

86-5039942-00 Page 10 of 42 Table 2-4 Growth Curves Used for EOC-1 1 Projections Voltage Growth Voltage at BOC per EFPY c=0.62 Volts l >0.62 Volts

<= 0 3 1 0.1 19 4 0.2 42 6 0.3 33 2 0.4 25 2 0.5 6 1 0.6 2 0 0.7 2 0 0.8 0 0 0.9 0 0 1.0 0 0 1.1 0 0 1.2 0 1 1.3 0 0 1.4 0 0 1.5 0 0

>1.5 0 0

86-5039942-00 Page 11 of 42 Table 2-5 Burst Pressure Versus Bobbin Amplitude Correlation P. = ao + a, Iog(Volts)

Parameter Value Intercept, a. 7.48475 Slope, at -2.39502 r 79.6 %

Std. Dev., cEor 0.88248 Mean Log(V) 0.306657 SS of Log(V) 51.4665 N (data pairs) 99 Structural Limit (2405 psi)" 9.45 V p Value for a, 1.4-10-35 Reference al 68.78 ksi (2)

Notes: The number of significant figures reported simply corresponds to the output from the calculation code and does not represent true engineering significance.

(1) Value reported corresponds applying a safety factor of 1.4 on the differential pressure associated with a postulated SLB event.

(2) This is the flow stress value to which all data was normalized prior to performing the regression analysis.

86-5039942-00 Page 12 of 42 Table 2-6 Probability of Leak Correlation Pr(Leak) =1 + ee[b, +b2 log(Volts)J Parameter Value Intercept, pi -5.0503 Slope, P2 7.4342 V,, (1.3299 V1 2 -1.7253 Vz222.6861 DoFz) 115 Deviance 31.47 Pearson SD 0.594 MSE 0.274 Notes: (1) Parameters VI are elements of the covariance matrix of the coefficients, pfi, of the regression equation.

(2) Degrees of freedom.

86s5o39942-oo Page 13 of 42 Table 2-7 Leak Rate Versus Bobbin Amplitude Correlation (2405 psi)

Q = I 0 [b3 +b 4 10g(Volts)]

Parameter Value Intercept, b3 -0.664317 Slope, b4 1.106101 Index of Deter., r2 17.5%

Std. Error, b5 0.772757 Mean of Log(Q) 0.55024 Std. Dev. of Log(Q) 0.83625 p Value for b4 1.0%

Data Pairs, N 31 Mean of Log(V) 1.09805 SS of Log(V) 2.99300 Note: The number of significant figures reported simply corresponds to the output from the calculation code and does not represent true engineering significance.

86-5039942-00 Page 14 of 42 Table 2-8 Industry POPCD Parameter LogLogistic Number of Data Points 72407 a.0 (intercept) 1.709 a.1 (slope) 3.047 Vii 0.000232 V12 0.000458 V22 0.001302 Deviance 83313 MSE 0.1962 Binary TRUE Chi Sqr 14209 DoF 72405 p-Value <2.9E-07

86-5039942-00 Page 15 of 42 Table 2-9 Unit 1 Prior Cycle Benchmarking Results Cycle Designation Steam Generator Projected Results POB Leak Rate As-Found Results POB Leak Rate Growth Rate Used

1. of Bins [Breakpoint(s) Data Source I1Used POPCD (2)

SG 1-1 4.12E-04 0.198 5.81 E-05 0.068 1 NA (1) Industry Bounding Industry EOC-10 SG 1-2 5.09E-04 0.226 9.49E-06 0.031 1 NA (1) Industry Bounding Industry SG 1-3 3.63E-04 0.191 3.14E-05 0.046 1 NA (1) Industry Bounding Industry SG 1-4 6.52E-05 0.030 9.49E-06 0.011 1 NA (1) Industry Bounding Industry SG 1-1 9.96E-05 0.241 8.82E-05 0.167 2 0.62 DCPP1 SG11 C10 (4) Industry SG 1-2 1.13E-04 0.261 8.14E-05 0.139 2 0.62 DCPP1 SG11 C10(4) Industry EOC-1 1 SG 1-3 1.22E-04 0.227 3.89E-05 0.088 2 0.62 DCPP1 SG11C1O (4) Industry SG 1-4 4.38E-05 0.084 2.37E-05 0.033 2 0.62 DCPP1 SG1I1 C10 (4) Industry (1) Growth rate analysis of Unit 1 Cycle 9 data showed no signs of voltage dependent growth. Therefore, a single independent growth distribution for all indications was used (industry bounding data used because there were less than 200 growth points from DCPP Unit 1).

(2) Industry POPCD used for all of the benchmarking analyses because the following requirement was not satisfied: minimum of 20 detected and RPC confirmed indications above 2.0 volt with at least 5 indications above 3.0 volt.

(3) All benchmarking cases use the leak and burst correlations referred to as Addendum 5+, which are Addendum 5 correlations as updated with DCPP Unit 2 2R1 I tube pull destructive exam results.

(4) Values of 0.058vtEFPY for the lower bin and 0.02v/EFPY for the upper bin were added to each Cycle 10 data point prior to binning the growth data in accordance with the "delta volts" strategy.

86-5039942-00 Page 16 of 42 Table 2-10 EOC-1 1 Voltage Comparison (Projected vs. As-Found)

Voltage Category/ SG 1-1 SG 1-2 SG 1-3 SG 1-4 Result Projected As-Found Projected As-Found* Projected As-Found Projected As-Found

_lv 180.77 372 170.05 296 71.72 122 51.47 95

>1V 84.86 48 89.35 42 59.87 36 28.44 11

>2V 9.03 4 9.96 5 9.92 1 3.42 1

>3V 0.56 1 0.91 0 1.65 0 0.51 0 Total 265.63 420 259.40 338 131.58 158 79.91 106 Probability of Burst 9.96E-05 8.82E-05 1.13E-04 8.14E-05 1.22E-04 3.89E-05 4.38E-05 2.37E-05 Leak Rate (gpm) 0.241 0.167 0.261 0.139 0.227 0.088 0.084 0.033

• Does not include deplugged tubes.

86-5039942-00 Page 17 of 42 Table 2-11 Comparison of SG 1-1 EOC-11 Results Using Adjusted BOC Distribution and 0.6 POD Voltage Category I Projected w/ I dustry POPCD Proj. w/ 0.6 POD As-Found Result Normal BOC Adjusted BOC Normal BOC

<=iv 180.77 518.99 181.46 372

>Iv 84.86 151.32 108.53 48

>2v 9.03 10.06 13.99 4

>3v 0.56 0.56 1.79 1 Total 265.63 670.31 290.00 420 Probability of Burst 9.96E-05 1.40E-04 1.84E-04 8.82E-05 Leak Rate 0.241 0.395 0.358 0.167

86-5039942-00 Page 18 of 42 Figure 2-1 Voltage Dependent Growth Curve for SG 1-1 Cycle 10 SG 1-1 Cycle 10 Bilinear Growth Deternination 3.000 Regression Break Point = 0.62 VoksI 2.500- _Cycle 10 Bound I = 0.62 V i  : Min. Bin= 15.

2.000 - Act Bin= IS SSE =3.484

. 1.500 -

E 1.000 E _ a-0.500-0 a

-0.500 -. , , .. . . .. . . .

0 0.5 1 1.5 2.

BOC Bobbin Atrplitude (Vols) a Data - Piece I Piece 2

86-5039942-00 Page 19 of 42 Figure 2-2 DCPP and Industry POPCD Curves Comparison of LogLogistic Industry and DCPP POPCD Distributions I .. 1 1 1 111111___ S ,

_ + DCPP POPCD LogLogistic Fit_ - __

0.9 B

• a--DCPP LogLogistic Lower 90% 1 l - Industry POPCD LogLogistic Fit _ _____

0.8

, 0- Industry POPCD Logogistic Lower 90%

0.7 c

t 0.6 a

e 0.5

.C 0.4

.0

.0 0.3 0.2 0.0 1.00 10.00 0.01 0.10 Bobbin Amplitude

86-5039942-00 Page 20 of 42 3.0 RECALCULATED EOC-12 PROJECTIONS In order to document the effect of the new POPCD and VDG methodologies, a series of leak rate and POB calculations were performed for EOC-12. These calculations use different PODs and growth rates. These calculations will also help to benchmark the EOC112 results when they are available.

Following is a brief description of the calculations that were performed.

• Cases 1 and 2 were taken directly from the I RI 1 90-Day Report (Reference 13). Both of these cases used the 0.6 POD from Reference 1. Case 1 used a single growth distribution.

Case 2 used a 2-bin voltage dependent growth curve with a breakpoint at 0.5v. These two cases also used the leak and burst correlations from the EPRI Addendum 5 database (Reference 9), i.e., without the 2R1 1 pulled tube results.

• Case 3 was performed using growth data from SG 1-1 Cycle 11 supplemented with data from SG 2-4 Cycle 10. The development of this growth distribution is discussed in Section 3.2.

This case used the DCPP-specific POPCD correlation shown in Table 3-6.

• Case 4 is identical to Case 3 except for the use of the 0.6 POD provided in Reference 1.

• Case 5 is identical to Case 3 except for the addition of the 11 .9vIEFPY growth rate from SG 2-4 Cycle 11 R44C45. Development of this growth distribution is discussed in Section 3.2.

The following sections provide the inputs and results for these calculations.

3.1 BOC Voltage Distributions As discussed in Section 1.0, the Monte Carlo code has been revised to determine the number of undetected indications in each bin using either a constant POD or a voltage dependent POPCD.

Therefore, the voltage inputs are limited to the as-found voltages and the repaired voltages, i.e., no POD adjustment of the input voltage distribution is required. Table 3-1 provides the BOC voltage distributions used in the EOC-12 projections.

Table 3-1 shows the voltage distributions in 0.1 volt bins. The actual files used as inputs to the Monte Carlo codes were changed slightly from that shown in Table 3-1 depending on the breakpoints used for the growth distribution. Additional bins were inserted to correspond to the breakpoints in the growth distribution. For example, for the cases that had a growth breakpoint at 1.18v, an additional voltage bin was added at 1.18v. Therefore, the original bin that covered voltages from 1.11v to 1.20v was split into two bins (1.1 1v to 1.18v and 1.19v to 1.20v). Adding this extra bin to the BOC voltage distribution forces the code to put the correct number of indications into each growth bin.

3.2 Voltage Growth Rates In 1Ri 1, tubes were deplugged in SG 1-2. Some plants have seen higher growth rates during the first cycle after tubes have been returned to service. However, DCPP has not observed this phenomenon. In fact, the growth rate for deplugged tubes during the first cycle after being returned to service has often been lower than the growth rate for the continuously active population.

Therefore, these EOC-12 calculations did not treat the deplugged and active populations separately.

Cases I and 2 were taken directly from Reference 13 and, therefore, used the growth distributions provided in Reference 13. For Case 1, the growth distributions used for SGs 1-1, 1-2, and 1-3 were SG-specific and were composites of Cycles 10 and 11. The Cycle 10 and 11 data was combined since the Cycle 10 data was bounding, but included less than the required 200 data points. For SG 1-4, the combined Cycle 10 and 11 data contained less than 200 data points. Therefore, a bounding CPDF curve was developed from the Cycle 10 and 11 data for all steam generators.

86-5039942-00 Page 21 of 42 Cases 3 and 4 used a growth distribution from SG 1-1 supplemented by data from SG 2-4 Cycle 10.

This distribution was developed in a manner similar to what was performed for the 2R1 1 90-Day Report (Ref. 12). Unit I has consistently had slower growth rates that Unit 2. A review of growth rates for prior cycles at Unit 2 show that the voltage-dependent growth effect started as early as Cycle 9. In Unit 1. however, the voltage dependency isn't nearly as evident as that seen in Unit 2, even through Cycle 11. In Unit 1, the only steam generator showing significant signs of voltage-dependent growth is SG 1-1, as seen in Figure 2-1 for Cycle 10 and Figure 3-1 for Cycle 11.

Previous practices for applying growth rates have been to use growth rates from the previous cycle(s) at the same unit to project voltages at the end of the next operating cycle. However, growth rates can occur that are larger than that previously seen in a particular unit. The SG 1-1 Cycle 11 has very little growth data for Indications that were greater than about 1v at BOC-1 1. Therefore, the VDG analysis for the SG 1-1 Cycle 11 data will only yield I breakpoint at 0.47 volts (see Figure 3-1). Since the growth rates for the current cycle (Cycle 12) may exceed the growth rates seen in previous cycles for Unit 1, it is believed that the Cycle 12 growth rates may yield a second breakpoint. In order to get a data set that contains a second breakpoint to use in the EOC-12 projections, the SG 1-1 Cycle 11 growth data must be supplemented with more data inthe upper voltage range. Therefore, the growth data from prior cycles at Unit 2 were reviewed and compared to the SG 1-1 Cycle 11 data.

First, based on a review of VDG curves, the data from SG 2-4 Cycle 10 provided the best comparison to SG 1-1 Cycle 11 (Figure 3-2). A trilinear regression of the SG 2-4 Cycle 10 growth data showed two breakpoints at 0.69v and 1.17v. Figure 3-2 shows that when the SG 1-1 Cycle 11 data is plotted using the same breakpoints as SG 2-4 Cycle 10, the lower two bins have nearly identical regression lines. Second, In order to further compare the SG 1-1 data to the SG 2-4 data, the SG 1-1 Cycle 11 data was segregated into three bins using the same breakpoints (0.69v and 1.17v) found for SG 2-4 Cycle 10, and the CPDF curves for the SG 1-1 and the SG 2-4 data were plotted on the same chart (Figure 3-3). This figure shows that the SG 1-1 Cycle 11 and SG 2-4 Cycle 10 curves for the lower two bins are very similar. Note that the SG 1-1 Cycle 11 curve does not have enough data at the higher voltages of Bin 3 to adequately define the growth rate in this bin. Since the lower two bins are similar, it is expected that the upper bin for SG 1-1 for the current cycle (Cycle 12) could see growth rates similar to the upper bin in SG 2-4 Cycle 10. Therefore, the 30 data points in the upper bin for SG 2-4 Cycle 10 were added to the SG 1-1 Cycle 11 data. New breakpoints were then determined for the composite data set (0.49v and 1.18v). as shown in Figure 3-4. This composite data set with breakpoints at 0.49v and 1.18v was used for Cases 3, 4, and 5. It should be noted that the 30 data points from SG 2-4 Cycle 10 contain six growth rates that are higher than any growth rates previously seen at Unit 1. Therefore, supplementing the SG 1-1 Cycle 11 data with data from SG 2-4 Cycle 10 not only allows the addition of a second breakpoint, but it also provides an allowance for increased growth rates during Cycle 12. This is a conservative allowance because, based on a delta voltage growth comparison performed between UIC10 and U1C1I, no increase was noted in average growths (in fact, the average growth decreased). The purpose of the delta voltage growth comparison is to determine if the growth rates are increasing with time and to allow for corrective actions if such a change is occurring. For SG 1-1, the average growth rate for indications s0.49v decreased from 0.164 v/EFPY during Cycle 10 to 0.106 v/ EFPY during Cycle 11. Likewise, the average growth rate for indications between 0.49 and 1.18 v/ EFPY decreased from 0.224 v/ EFPY during Cycle 10 to 0.199 v/ EFPY during Cycle 11, and the average growth rate for indications >1.18v decreased from 0.258 v/ EFPY to 0.147 v/ EFPY.

Since Unit 1 is trailing Unit 2 in terms of both average voltage growth rate and voltage-dependency by approximately one cycle, using the data from SG 2-4 Cycle 10 to supplement the SG 1-1 Cycle 11 data should provide conservative results for Unit I EOC-12. This use of the SG 2-4 data is appropriate based on the reasonable expectation that the SG 1-1 voltage growth dependency will follow that for SG 2-4 by one cycle. Table 3-2 provides the composite VDG curves that were used for Cases 3 and 4.

EPRI is currently developing a method to account for the possibility of high growth rates in projections that utilize POPCD. This method will account for the potential of a large growth similar to that of SG 2-4 R44C45 during Unit 2 Cycle 11, and provide additional conservatism in the EOC calculations.

Since this new methodology is still under development, an example calculation was performed to demonstrate additional conservatism that could result from a potential high growth rate during Unit I

86-5039942-00 Page 22 of 42 Cycle 12. This example (documented in Case 5) adds the 11.9v/EFPY growth from SG 2-4 R44C45 into the growth rate used for Cases 3 and 4. However, prior to adding this large growth point to the upper bin of the growth distribution, the number of indications in the growth curve was adjusted (normalized) so that the R44C45 growth would occur at the same frequency that it occurred in SG 2-4 Cycle 11. Since there were 976 indications in the SG 2-4 Cycle 11 growth distribution, the number of indications in the upper bin in the growth curve shown in Table 3-2 was artificially increased using a factor of 2.283. Therefore, a high growth rate can occur in the simulation at the same frequency (once per 976 indications) as it occurred in SG 2-4 Cycle 11. The VDG curves using this method are shown in Table 3-3.

3.2.1 Voltage Growth Comparison (New vs. Repeat Indications)

As part of the growth analysis for this report, a comparison of the growth rates for the new and repeat indications was performed. It is standard practice to perform 'lookups' for newly reported DOS (distorted OD signal) indications from the bobbin coil. For the newly reported indications, the bobbin coil data from the previous inspection is reviewed to determine if an indication was present at the time of the previous inspection. If there is a detectable indication at the previous inspection, a voltage measurement is taken. These lookup' voltages are then used to calculate growth rates for the new indications.

The Unit 1 Cycle 11 voltage dependent growth data for all steam generators is consolidated on a single chart in Figure 3-5. This figure clearly shows that voltage dependent growth is primarily occurring in repeat indications. This is the expected condition due to the exponential dependence of volts on depth. The low voltages of the new indications suggests that they are shallow so the exponential effect on growth is minimal for them, compared to the higher voltage repeat Indications which are likely deeper. In Figure 3-6, new and repeat cumulative growth curves were plotted along with the Cycle 11 voltage independent growth curve. This figure shows that the repeat indications do in fact grow faster than the new indications. This figure also shows that the independent curve does not, and cannot, bound the repeat growth and, as such, if the Cycle 12 operational assessment (OA) were to use an independent approach to growth, it would be non-conservative for the larger repeat indications being returned to service. Figure 3-7 provides the new and repeat indications plotted on a chart with the Cycle 11 VDG bins growth curves for all indications. This figure shows that the repeat indications are bounded by the upper bin growth curve and have a growth distribution very similar to the middle bin. Since the curve for the new indications is closely represented by the Bin 1 VDG curve, a VDG analysis inherently accounts for new indications growing at a slower rate than repeat indications. Likewise, repeat indications being returned to service (and which start the cycle at a higher BOC voltage) are grown at either the Bin 2 or Bin 3 growth rate, which again bound or closely approximate the repeat indications growth when they are not "binned". Therefore, the VDG analysis inherently accounts for the differences between the growth rates of new and repeat indications.

Figure 3-8 and 3-9 show the cumulative growth curves for Cycle 11 at both units for the new and repeat indications based on the BOC voltage. Both DCPP units show a considerable difference in the growth rates for repeat indications based on voltage. For the new indications, however, the curves for s1v and >1v show no significant differences. This indicates that the growth of new indications is independent of the BOC voltage. This also agrees with the results shown in Figure 3-5.

3.2.2 Voltage Growth Comparison (Single vs. Multiple Axial Indications)

A comparison of the growth rates for single and multiple axial ODSCC indications was also performed as part of this growth analysis. A total of 215 DOS were confirmed during the Plus Point inspections performed at 1RI 1. Twenty-four were confirmed as multiple axial indications (MAls) and 191 were confirmed as single axial indications (SAls). The remaining DOS were either not Plus Point Inspected (NI) or did not confirm (DNF) by Plus Point as degradation. The voltage growth for these indications is depicted graphically in Figure 3-10. As expected, the voltage growth for the TSP intersections affected by MAls is higher than that for intersections that are affected by SAls. The reason for this effect is that the bobbin coil voltage is an integral" of all the flaws present at the TSP, so a change in depth of any of the secondary flaws present or the development of an additional flaw during a cycle

86-5039942-00 Page 23 of 42 would have a higher resultant growth rate compared to a primary SAI growing only in depth during the cycle. The DNF/NI curve in Figure 3-10 contains the indications that were not Plus Point inspected or did not confirm with Plus Point It is important to note that if more of these indications had been inspected with Plus Point, the result would have been to "pull" the SAI and MAI growth curves to the left, since a large number of lower growth values would have been added to those curves based on the overall DOS confirmation rate of about 90 percent. Since the growth data show the expected trend that MAI growth is moderately larger than SAI growth and that the non-Plus Point inspected population could further reduce the differences, it is concluded that there is no need to separate MAls and SAls in the growth distributions used for OA analyses.

3.3 POPCD Correlation Per Reference 4, the NRC approved the use of the DCPP-specific POPCD for Unit 2 Cycle 12. The POPCD correlation that was approved is provided in Table 3 of Reference 11 and is labeled as 'New NRC POPCD'. This DCPP-specific POPCD correlation was used for Cases 3 and 5 and is shown in Table 3-4.

3.4 Cycle Length The projected cycle length for Cycle 12 is 1.61 EFPY. This value was taken from Reference 13 and was used for all of the EOC-12 calculations provided inthis report.

3.5 EOC-12 Leak Rate and POB Results Table 3-5 provides a summary of the EOC-12 leak rate and POB results. As shown in the table, all of the calculations that were augmented with SG 2-4 growth data (Cases 3 thru 5) have significantly higher probabilities of burst compared to the original 90-Day Report Calculations (Cases 1 and 2) which only used Unit 1 growth data. In addition, the inclusion of the high growth rate had a significant effect on the POB results but a lesser effect on the leak rate results. This is shown by comparing the results for cases 3 and 5. The only difference between these two cases is the inclusion of the normalized R44C45 growth in Case 5. This increased the POB results by a factor of about six but only increased the leak rate by about 19%. This shows the significant effect that a high growth point can have on the POB. The POB is heavily influenced by the sizes of the largest indications, whereas, the leak rate is influenced by both the quantity and sizes of the indications.

Case 4 was the same as Case 3 except for the use of the 0.6 POD provided in Reference 1. These calculations yielded POB and leak rate results that were about 50% higher on average than the Case 3 results which used the DCPP POPCD. This is the expected result since application of the 0.6 POD results in an overprediction of the number of large indications being returned to service.

Tables 3-6 and 3-7 provide the projected EOC-12 voltage distributions for the two cases (Cases 3 and 5) which used the DCPP POPCD correlation. These results will be used to benchmark the methodologies when the EOC-12 as-found results are available during the next Unit 1 inspections in April 2004 (outage 1R12).

86-5039942-00 Page 24 of 42 Table 3-1 1RI1 Voltages for Use in EOC-12 Projections

_ SG11 SG12 SG13 SG14 Voltage ...

Bin As-Found Repaired Depluged Repaired As-Found Repaired As-Found Repaired 0.1 I1 1 0.2 9 10 1 3 7 0.3 49 1 21 1 11 9 0.4 62 32 19 20 0.5 81 3 77 7 28 2 18 1 0.6 66 3 79 7 20 2 18 4 0.7 41 3 36 2 16 1 10 1 0.8 24 1 33 2 10 1 8 0.9 21 1 16 8 4 1 19 2 17 2 7 ___ 1 1.1 13 1 11 19 1 3 8 5 __ _ _ _ 1 1.2 __ _ _ _6 _ _ _

7 2 3 8 _ _ _ 1 _ _ _

1.3 _ _ _

6 9 2 __ _ _ _ 1 _ _ _

1.4 _ _ _ _ _ _

1.5 2 _

1.6 2 _ _ _ 3 1 _ _ _ _ _ _ _ _

1.7 2 1 _1 1.8 3 2 __ _ _ _ 2 2 1.9 __ _ 1 1 3_

_ _1 _

2 1 _ __ _ _3 _

2.2 2 2 2.3 1 1 1 1 2.4 1 1 1 1 1 1 1 1 2.1_

2 .7 1 1 _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

2.8 __ _ _ _1 1 _ _ _ _

2.9 _ _ _ _ _ _ _ _

3.3 1 1 _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

>3.3 _ _ _ _ _ _ _ _ _

420 21 365 29 158 7 106 8 Total

86-5039942-00 Page 25 of 42 Table 3-2 SG 1-1 1 SG 2-4 Composite Growth Curves (used for Cases 3 and 4)

Growth Bin B OC Voltage Ran le

<=0.49v O.50v- 1.18v >1.18v

<=O 50 27 3 0.1 101 27 3 0.2 81 27 5 0.3 24 14 3 0.4 8 17 1 0.5 3 4 2 0.6 2 5 2 0.7 _ _ _ _ _ _ 2 1 0.8 1 1 0.9 _ _ _ _ _ _ _

1.0 1 1.1 1.2 1 1.3 _1 1.4 1 1.5 1.6 _ _ _ _ _1 2

1 1 .7__

1.8 1 1.9__ _ _ _ _ _1 2.1 _ _1 l_

2 .2 _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

2.3 _ _ _ _

2 .4 _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

2.0 2 .5 _ _ _ _ _ _ _ _ _ _ _ _

23.0 __ _ _ __ _ _ _ _ _ _ _ _ _

2 2.6 2.7 _ _ _ _ _ _ _

2 .8 _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

2 .9 _ _ _ _ _ _ _ _ _ _ _ _ _ 1 3 .0 _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

> 3 .0_ _ _ _ _ _ _ _ _ _ _

[

Total 269 127 31

865039942-00 Page 26 of 42 Table 3-3 SG 1-1 / SG 2-4 Composite Growth Curves w/ Normalized R44C45 Growth (used for Case 5)

Growth Bin BOC Voltage Range GrowthBin_ <=0.49v 0.50v - 1.1 8v >1.18v

<=_ _50 27 7 0.1 101 27 7 0.2 81 27 11 0.3 24 14 7 0.4 8 17 2 0.5 3 4 5 0.6 2 5 5 0.7 2 2 0.8 _ _ _ _ _ _ 1 2 0.9 - _ _

1.0 1 1.1 5 1.2 1 1.3 2 1.4 2 1.5 1.6 _

2 1.7 1 1.8 . 2 1.9 _ _ _ _ _ _2 2.0 _

2 .1 _ _ _ _ _ _ _ _ _ _ _ _

2.2 2.3 2.4 _ _ _ _ _ _

2 .5 _ _ _ _ _ _ _ _ _ _ _ _

2.6 5 2.7 2 .8 _ _ _ _ _ _ _ _ _ _ _ _ _

2.9 2 3.0 11.8 11.9 1 12.0

>12.0 _ 127__ 73 Total _269 127 1 73

86-5039942-00 Page 27 of 42 Table 3-4 DCPP-Specific POPCD Parameter LogLogistic Number of Data Points 4688 a.0 (intercept) 1.644 a.1 (slope) 4.659 Vii 0.00522 V12 0.01043 V22 0.02654 Deviance 5221 MSE 0.1890 Binary TRUE Chi Sqr 885.5 DoF 4686 p-Value <2.9E-07

86-5039942-00 Page 28 of 42 Table 3-5 EOC-12 Projections for POB and Leak Rate Case POD Growth Breakpoints Potential High PtB CaGrowth? Leak Rate Comments SGIl SG12 SGI3 SG14 SGI1 SGI2 SG13 SGI4

_n 1 06 Nn NA From Ref. 13 No 6.89E-05 4.18E-05 2.79E-05 1.94E-05 1.11 0.86 0.44 0.23 VDG (Addendum 5 Database) 2 0.6 _1 From Ref. 13 U1C11 0.5v No 1.17E-04 NA NA NA 1.14 VDG NA NA NA (Addendum 5 Database)

SG11 3 POPCD + SG24 0.49v / 1.18v No 1.20E-03 1.08E-03 1.06E-03 3.88E-04 Cycle 10 1.02 0.99 0.77 0.28

(>1.17v)

SGIl Cycle II 4 0.6 + SG24 0.49v / 1.18v No 1.88E-03 1.91E-03 1.72E-03 5.62E-04 1.47 1.45 1.11 0.40 Cycle 10

(> 1 .17v) _ _ _ _ _ _ _ _ _ _ _ _ __ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

Yes, growth SG1i curve adjusted DCP Cycle 5 PP + SG2411 0.49v 1 1.18v R44C45to allow growth 7.23E-03 7.34E-03 7.07E-03 2.02E-03 1.20 POPCD Cyde 10 1.18 0.95 0.32 rate to occur

(>1.17v) once per 976

_ indications

86-5039942-00 Page 29 of 42 Table 3-6 EOC-12 Voltage Projections wI DCPP POPCD and SG 1-1 Cycle 11 + SG 2-4 Cycle 10 (>1.17v) Growth (Case 3)

Bobbin SG 1-1 SG 1-2 SG 1-3 SG 1-4 V oltage __ _ _ __ _ _ __ _ _ _ _ _ _

<=0.1 0.81 15.72 0.27 0.63 0.2 17.98 30.34 5.60 11.80 0.3 48.05 50.03 12.78 18.26 0.4 82.50 72.85 22.95 30.09 0.5 119.52 87.15 34.02 39.54 0.6 135.34 96.90 38.67 35.98 0.7 116.38 88.28 35.44 32.19 0.8 91.56 74.87 28.60 22.71 0.9 63.54 57.69 20.96 16.08 1 45.79 43.29 16.00 11.34 1.1 34.60 33.78 12.90 8.32 1.2 30.17 30.29 11.82 7.33 1.3 24.98 24.36 10.17 5.61 1.4 18.37 17.B9 8.08 4.05 1.5 14.16 14.14 6.59 3.05 1.6 11.25 11.18 5.46 2.34 1.7 8.69 8.60 4.44 1.81 1.8 6.50 6.38 3.50 1.38 1.9 4.82 4.66 2.74 1.05 2 3.43 3.22 2.18 0.78 2.1 2.64 2.50 1.87 0.65 2.2 2.39 2.32 1.71 0.62 2.3 1.89 1.81 I.45 0.50 2.4 1.49 1.48 1.21 0.42 2.5 1.56 1.61 1.12 0.44 2.6 1.35 1.34 0.95 0.38 2.7 0.96 0.92 0.75 0.29 2.8 0.71 0.64 0.60 0.22 2.9 0.57 0.50 0.55 0.18 3 0.52 0.47 0.54 0.15 3.1 OA6 0.45 0.47 0.13 3.2 0.49 0.54 0.43 0.13 3.3 0.85 0.98 0.53 0.23 3.4 0.91 0.98 0.54 0.23 3.5 0.72 0.76 0.48 0.19 3.6 0.58 0.59 0.41 0.15 3.7 0.46 0.44 0.34 0.12 3.8 0.37 0.33 0.31 0.10 3.9 0.32 0.28 0.31 0.09 4 0.30 0.29 0.33 0.09 5 2.29 2.28 2.30 0.67 6 1.75 1.93 1.66 0.40 7 0.704 0.593 0.841 0.285 8 0.010 0.005 0.016 0.005

>8 0.000 0.000 0.000 0.000 Total 902.72 795.67 302.90 261.00 s1v 721.47 617.14 215.30 218.61 1.Olv-2.00v 156.97 154.49 67.87 35.72 2.01v-3.00v 14.08 13.58 10.76 3.87 3.01v4.0v _ 5.44 5.65 4.16 1.44 4.01v-5.00v 2.29 2.28 2.30 0.67

>5v 2.46 2.53 2.52 0.69

86-5039942-00 Paae 30 of 42 Table 3-7 EOC-12 Voltage Projections wI DCPP POPCD and SG 1-1 Cycle 11 + SG 2-4 Cycle 10 (>1.17 v) Growth + R44C45 Potential Large Growth (Case 5)

Bobbin SG 1-1 SG 1-2 SG 1-3 SG 1-4 c=0.1 0.81 15.68 0.27 0.63 0.2 17.93 30.29 5.58 11.77 0.3 47.93 50.00 12.76 18.24 0.4 82.43 72.80 22.94 30.07 0.5 119.50 87.14 34.01 39.52 0.6 135.40 97.03 38.68 35.98 0.7 116.50 88.40 35A9 32.25 0.8 91.69 75.00 28.64 22.72 0.9 63.64 57.86 21.02 16.11 1 45.90 43.45 16.05 11.38 1.1 34.71 33.93 12.93 8.35 1.2 30.39 30.49 11.89 7.41 1.3 25.23 24.51 10.25 5.67 1.4 18.51 17.98 8.14 4.09 1.5 14.16 14.11 6.60 3.04 1.6 11.17 11.09 5.43 2.32 1.7 8.70 8.63 4.44 1.81 1.8 6.50 6.37 3.49 1.38 1.9 4.77 4.60 2.71 1.04 2 3.39 3.17 2.17 0.77 2.1 2.61 2.46 1.87 0.64 2.2 2.33 2.26 1.70 0.60 2.3 1.85 1.76 1.43 0.49 2.4 1.44 1.43 1.19 0.41 2.5 1A6 1.50 1.08 0.42 2.6 1.25 1.23 0.91 0.36 2.7 0.90 0.84 0.72. 0.28 2.8 0.66 0.59 0.59 0.21 2.9 0.55 0.48 0.55 0.17 3 0.51 0.47 0.54 0.15 3.1 0.46 0.46 0.48 0.12 3.2 0.48 0.53 0.43 0.13 3.3 0.79 0.91 0.50 0.21 3.4 0.63 0.90 0.51 0.21 3.5 0.66 0.69 0.45 0.17 3.6 0.53 0.53 0.38 0.14 3.7 0.42 0.40 0.33 0.11 3.8 0.33 0.30 0.29 0.09 3.9 0.28 0.25 0.28 0.08 4 0.27 0.25 0.29 0.08 5 2.00 1.99 2.02 0.59 6 1.83 2.02 1.71 0.41 7 0.656 0.543 0.813 0.277 8 0.009 0.005 0.014 0.004 8.01-20.00 0.000 0.00 I 0.00 0.00

>20 0.345 0.361 - 0.338 0.092 Total 902.72 795.70 302.90 261.01 s1v 721.73 617.66 215.44 218.66 1.01v-2.00v 157.54 154.87 68.05 35.88 2.01v-3.00v 13.56 13.02 10.58 3.73 3.01v-4.00v 5.05 5.23 3.94 1.36 4.01v-5.OOv 2.00 1.99 2.02 0.59 5.01v-10.00v 2.49 2.57 2.54 0.70 10.01v-20.00v 0.00 0.00 0.00 0.00

>20v 0.35 0.36 0.34 0.09

865039942-00 Page 31 of 42 Figure 3-1 Bilinear VDG Results for SG 1-1 Cycle 11 r- -

SG 1-1 Bilinear Growth Determination for Cycle 11 3.000 -

Regression Break Point =0.47 Vok 2.500 Cyc- I I;  ; you:- 47v _

Bound I = 0.47 V Mn. Bin= 15 2.000 - - Act. Bin= 138 SSE=9.518 1.500 0

1.000 0 0.0 E

0.5000 I

-0.500 -

0 0.5 1 1.5 2 I BOC Bobbin Anplitude (Voks) i a Data Piece I - Piece 2

86-5039942-00 Page 32 of 42 Figure 3-2 Voltage Dependent Growth Comparison Between SG 1-1 Cycle 11 and SG 2-4 Cycle 10 3.00 - -

3.0-lhis chart shows a comparison of the SG 1-1 Cycle I11datal to the SG 2-4 Cydle 10 data usir9 the SG 2-4 Cycle 10 2.50 - breakpoints of 0.69v and 1.17v for both cases. __ _ _ _

2.00 2.50 A A

°Io L < At O0E AA & >

0.50 - £ 0 a A A VolA 0.00 0.50 1.00 1.50 2.0 0 BOC Volts A SG24Cycle 10 SG2-4Cycle lORegression x SG I-I Cycle 11 - -SO I-I Cycle I I Regression

86-5039942-00 Page 33 of 42 Figure 3-3 SG 1-1 to SG 2-4 Growth Comparison 1.00 0 0.80

-- SG 1-1 Cycle I Bini

,/ Jl oSG I1-1 Cycle I11Bla2 60/ 1 1 -xSG 1-1 Cycle 11 MOn 0.60 11 /ISG a / _ f t// l -SG 24 24 Cyce Cycle 10 Bini 10 Bin2 o /-l,&-SG 2-4 Cycle 10 Bin3 0.40 -

It~~M i1c0.69v

-, at BOC t/l /[Bin2: 0.70v-1.17v at BOC

<//// Bin3: >1.1 Tv at BOC 0.20 0.00 oj o olV N- oa G ro owt per9EPY Voltage Growth per EFPY

86-5039942-00 Page 34 of 42 Figure 3-4 SG 1-1 I SG 2-4 Composite Voltage-Dependent Growth Results SG 1-1 / SG 2-4 Composite Growth Determination 3.00 [ I I a I 2.50 ci, 2.00

.1-0 1.50 I

0 1.00 0.50 0.00 0 0.5 1 1.5 2 BOC Volts I a Data - Regression - Regression Regression

86-5039942-00 Page 35 of 42 Figure 3-5 Voltage Dependent Growth Results DCPP1 AlI SGs Cycle 11 2.0 -Tl 0 Repeat Indications

• New Indicalions 0

1.5 U-Linear (Repeat Indications)

- - Linear (New Indications) 00 00 0

>0.5 -70 0

• 0

• O . *0

• at - 0 00 as a 0 0.5 1.5 2 BOC-11 Volts

865039942-00 Page 36 of 42 Figure 3-6 Voltage Dependent Growth Comparison (New vs. Repeat)

DCPPI All SGs Cycle *1 1.0 _

0.8 I I is l -6~New!

0.- 0.6 I / _ Repeat 00 0 0.1 0.2 0.3 0.4 0.5 0.6 0.7 0.8 0.9 1 1.1 1.2 1.3 1.4 1.5 1.6 1.7 1.8 1.9 2 Voltage Growth Per EFPY

865039942-00 Page 37 of 42 Figure 3-7 Voltage Dependent Growth Curves DCPP1 All SGs Cycle 11 1.0 A W 0 0 a W 0.8

-X->1.18VgBOC P 0.5OVto 1.18VX BOC 0.6 - -<=30.49V @ BOC

a. -New U . _ _ _ _ _p-at 0 0.1 0.2 0.3 0.4 0.5 0.6 0.7 0.8 0.9 1 1.1 1.2 1.3 1.4 1.5 1.6 1.7 1.8 1.9 2 Voltage Growth Per EFPY

86-5039942-00 Page 38 of 42 Figure 3-8 Voltage Dependent Growth Comparison (New vs. Repeat)

DCPPI All SGs Cycle 11 1.0 - m e--4 0.8

• -a- New=l

-i-New >1v 0.6- - *- Repeat<=-v U. i. Repeat >1v 0.

0 0.1 0.2 0.3 0.4 0.5 0.6 0.7 0.8 0.9 1 1.1 1.2 1.3 1.4 1.5 1.6 1.7 1.8 1.9 2 Voltage Growth Per EFPY

86-5039942-00 Page 39 of 42 Figure 3-9 Voltage Dependent Growth Comparison (New vs. Repeat)

DCPP2 All SGs Cycle 11 1.0 - -

0.8 l I 0. -i Nw<

0.6 0.4 0.0 0.2 . - Repeat<=lv Vog G t PRepeat >v Voltage Growth Per EFPY

86-5039942-00 Page 40 of 42 Figure 3-10 Voltage Dependent Growth Curves DCPPI Al SGs Cycle 11 1.0 0.8 0.6 U-0.4 0.2 0.0 0 0.1 0.2 0.3 0.4 0.5 0.6 0.7 0.8 0.9 1 1.1 1.2 1.3 1.4 1.5 1.6 1.7 1.8 1.9 2 Voltage Growth Per EFPY

86-5039942-00 Page 41 of 42

4.0 CONCLUSION

S The benchmarking of the prior cycle results showed that the new methodologies provided consistently conservative results. The EOC-10 projections were significantly higher than the as-found results.

This was mostly due to the use of the industry bounding growth rates. The EOC-11 projections provided more reasonable results, but were still conservative in all cases. The total number of indications for EOC-1 I was underpredicted in all cases. However, the underprediction was limited to indications less than 1 volt. To help assess the impact of this under-prediction for SG 1-1 at EOC-11, the BOC-11 voltage distribution was adjusted to add more indications in the low voltage bins. The POB and leak rate were then recalculated. The projected POB increased by 4.04E-05 and the projected leak rate increased by 0.154 gpm. These increases are insignificant relative to the limits of 1.OE-02 and 10.5 gpm and are likely attributable to the fact that many of the indications that were added grew to larger voltages in the Monte Carlo simulation.

The EOC-12 projections will be used to assess and benchmark the new methodologies once the as-found results are available. Case 3 likely provides the most realistic projections. This case used a growth rate from SG 1-1 Cycle 11 supplemented with data from SG 2-4 Cycle 10 in recognition of the probable increase in voltage dependent growth in Unit I for Cycle 12. This calculation should provide conservative results provided there is no significantly high growth rate detected during Unit 1R12 inspections. Another set of calculations (Case 5) was performed which added a normalized high growth rate affect (R44C45) to the growth rates from Case 3. Case 5 provides very conservative results since a very high growth rate is not expected to occur during every cycle. The Case 5 results, however, are still under the limits of 1.OE-02 for POB and 10.5 gpm for the leak rate.

Another calculation (Case 4) was performed to show the effect of using the constant 0.6 POD. These calculations yielded POB and leak rate results that were about 50% higher on average than the Case 3 results which used the DCPP POPCD. This is the expected result since application of the 0.6 POD results in an overprediction of the number of large indications being returned to service.

86-5039942-00 Page 42 of 42

5.0 REFERENCES

1. NRC Generic Letter 95-05, "Voltage-Based Repair Criteria for the Repair of Westinghouse Steam Generator Tubes Affected by Outside Diameter Stress Corrosion Cracking". USNRC Office of Nuclear Reactor Regulation, August 3, 1995.

2. PG&E Letter to NRC DCL-03-121. 'PG&E Response to NRC Questions on 2R1 1 Steam Generator Tube Inspections", September 30, 2003.

3. Westinghouse Letter to Diablo Canyon LTR-SGDA-03-137 (Rice to Arhar), 'Voltage Dependent Growth Bin Width Determination", June 17, 2003. Note: This letter was transmitted to the NRC as Attachment 2 to Enclosure 4 of PG&E letter DCL-03-076 dated June 23, 2003.

4. NRC Letter to Diablo Canyon (Shukla to Rueger), "Diablo Canyon Nuclear Power Plant, Unit No. 2 -

Issuance of Amendment - Revised Steam Generator Voltage-Based Repair Criteria Probability of Detection Method for Diablo Canyon Unit 2 Cycle 12 (TAC No. MB9742)", October 21, 2003

5. Framatome ANP Document 51-5001151-02, "Steam Generator Leak Rate Simulation Code LKR97VBr30.F90", December 2003.

6. Framatome ANP Document 51-5001160-02, 'Steam Generator POB Simulation Code POB97VBR20.F90", December 2003

7. Framatome ANP Document 86-5003756-00, 'Diablo Canyon Unit 1 - I R9 Voltage-Based Repair Criteria 90 Day", May 1999. Note: This document was transmitted to the NRC as Enclosure 2 of PG&E letter DCL-99-076 dated June 1, 1999.

8. Framatome ANP Document 86-5010437-00, Diablo Canyon Unit 1 - I RIO Voltage-Based Repair Criteria 90 Day Report", January 2001. Note: This document was transmitted to the NRC as Enclosure 2 of PG&E letter DCL-01-010 dated February 5, 2001.

9. EPRI Report NP 7480-L, Addendum 5, 2002 Database Update, "Steam Generator Tubing Outside Diameter stress Corrosion Cracking at Tube Support Plates Database for Alternate Repair Limits",

Electric Power Research Institute, January 2003.

10. Westinghouse Letter to Diablo Canyon (Rice to Arhar), 'Revised ARC Database Parameters Including Tubes Removed During 2R1 1", June 23, 2003. Note: This letter was transmitted to the NRC as Attachment I to Enclosure 4 of PG&E letter DCL-03-076 dated June 23, 2003.

11. PG&E Letter to NRC DCL 03-109, "Supplemental Information to Support License Amendment Request 03-10, 'Revised Steam Generator Voltage-based Repair Criteria Probability of Detection Method for Diablo Canyon Unit 2 Cycle 12", September 3. 2003.

12. Framatome ANP Document 86-5029429-00, "DCPP 2R1 1 BOBBIN VOLTAGE ARC 90 DAY

SUMMARY

REPORT", June 23, 2003.

13. FramatomeANP Document 86-5019218-00, "DCPP UNIT 1 1RII 90 DAY BOBBIN COIL ARC REPORr, August 2002. Note: This document was transmitted to the NRC as Enclosure 4 of PG&E letter DCL-02-098 dated August 22, 2002.

14. Westinghouse Letter to Diablo Canyon (Rice to Arhar), "Input to POPCD RAI and 1 5' and 2n 2R111 90 Day RAI Responses, September 30, 2003.

15. Framatome ANP Document 32-5039942-00, "DCPP Unit I Voltage-Based ARC Benchmarking Results".

16. Westinghouse Email to EPRI (Pitterle to Srikantiah), "Transmittal of POPCD, Noise Analyses and Preventive Repair Guidelines for ODSCC ARC", January 20, 2004 (for Figure 2-2 only).

22422-1 (2/13/2004) Page I of 2 A DESIGN INPUT CHECKLIST AR EVA I Basic functions of each structure, system, and component. O Y E N 0 N/A

2. Performance requirements such as capacity, rating, system output. 0 Y 0 N 0 N/A

3. Codes, standards, and regulatory requirements including the applicable issue and/or addenda. 0 Y O N O N/A

4. Design conditions such as pressure, temperature, fluid chemistry and voltage. 0 Y C N 0 N/A

5. Loads such as seismic, wind, thermal and dynamic. El ON N/A

6. Environmental conditions anticipated during storage, construction and operation such as pressure, temperature, humidity, corrosiveness, site elevation, wind direction, nuclear 0 Y 0 N 0 N/A radiation, electromagnetic radiation and duration of exposure.

7. Interface requirements including definition of the functional and physical interfaces involving structures, systems and components:

(a) the effect on existing plant equipment capability, such as DC battery loads, AC bus capacity, available stored water Inventory, service Instrument air capacity, water systems 0 Y E N 0 NIA capability (intake, service, and component cooling water), and HVAC capability; I (b) the effect of cumulative tolerances in the design; Y O N ON/A (c) the effect on design and safety analyses to ensure the analytical bases remain valid; O Y O N 0 N/A (d) the compatibility with unimplemented design changes to specify any required sequence for Implementation; OY ON ON/A (e) compatibility with technical specification requirements. 0 Y O N 0 NIA

8. Material requirements including such Items as compatibility, electrical Insulation properties, 0 Y 0 N 0 N/A protective coating and corrosion resistance. l__

_ _ N__

9. Mechanical requirements such as vibration, stress, shock and reaction forces. 0 Y o N 0 N/A

10. Structural requirements covering such items as equipment foundations and pipe supports. Y El N A NIA

11. Hydraulic requirements such as pump net positive suction heads (NPSH), allowable pressure drops, and allowable fluid velocities. ,Y ON ON/A

12. Chemistry requirements including provisions for system flushing, batch sampling, and In-line sampling; power plant water chemistry treatment for primary systems, steam generator, and 0 Y 0 N 0 N/A plant limitations on water chemistry.

13. Electrical requirements such as source of power, load profile voltage, electrical insulation, motor requirements, physical and electrical separation of circuits and equipment; the effect of 0E 0 N N/A cable routing or rerouting on the cable tray system (loading, seismic capability, and capacity limitations).

14. Layout and arrangement requirements. O Y O N ONIA

15. Operational requirements under various conditions, such as startup, normal operation, Shutdown maintenance, abnormal or emergency operation, special or infrequent operation 0 Y 0 N 0 N/A Including installation of design changes, and the effect of system interaction.

16. Instrumentation and control requirements Including indicating Instruments, controls and alarms o o N 0 N/A required for operation, testing, and maintenance. Other requirements such as the type of Instrument, installed spares, range of measurement, and location of indication should also be included. _

17. Security requirements to include access and administrative control requirements and system 0 Y E N Design requirements Including redundancy, power supplies, support system requirements, 0N N/A emergency operational modes, and personnel accountability.

18. Redundancy, diversity and separation requirements of structures, systems, and components. O Y o N 0 N/A

19. Failure effects requirements of structures, systems and components, including a definition of O Y o N 0 N those events and accidents which they must be designed to withstand. ___ 0 N N/A

20. Test requirements including in-plant tests and the conditions under which they will be 0 Y a N 0 NIA performed.

86-5039942-00 Page A-I_ of A-2

22422-1 (2113/2004) Page 2 of 2 A DESIGN INPUT CHECKLIST AR EVA

21. Accessibility, maintenance, repair and inservice inspectIon requirements for the plant including o 0 the conditions under which these will be performed. IY N 0 NA

22. Personnel requirements and limitations including the qualification and number of personnel available for plant operation, maintenance, testing and inspection, and permissible personnel 0 Y 0 N 0 NJA radiation exposures for specified areas and conditions.

23. Transportability requirements such as size and shipping weight, limitations, I. C. C., - O N 0 NfA regulations. Y 0 NA

24. Fire protection or resistance requirements: 0 Y O N O N/A (a) safe shutdown analyses, the introduction of safe shutdown equipment into fire areas; o Y O N D NJA (b) routing of piping and electrical cables and the necessity for cable fireproofing and/or fire stops: QY ON ON/A (c) fire detection and fire suppression capability; Elr O N O N/A (d) fire barrier capability including fire door Installation; O Y O N 1 N/A (e) fire dampers; O Y O N O NA (f) access to fire fighting and emergency equipment: O Y O N 0 N/A (g) use of noncombustible materials; O Y O N ON/A (h) introducing combustible materials into safe shutdown areas by design or during Installation or operation; QY O N ON/A (I) smoke and toxic gas generation; OY ON ON/A

25. Handling, storage, and shipping requirements. O Y O N ONIA

26. Other requirements to prevent undue risk to the health and safety of the public. O Y EO N 0 N/A

27. Materials, processes, parts, and equipment suitable for application. O Y O N 0 N/A

28. Safety requirements for preventing personnel Injury including such Items as radiation hazards, restricting the use of dangerous materials, escape provisions from enclosures, and grounding O Y 0 N 0 NA of electrical systems.

29. Plant specific commitments. (Technical Specifications, FSAR, commitments in o o N 0 N/A correspondence with NRC, etc.)

30. Reliability requirements of structures, systems, and components including their interactions, which may impair functions important to safety. 0 Y O N 1 NA

31. Interface requirements between equipment and operation and maintenance personnel. O Y 0 N 0 N/A

32. Requirements for criticality control and accountability of nuclear materials. Q Y O N 0 N/A

33. Load path requirements for installation, removal, and repair of equipment and replacement of O Y C N 0 N/A rmajor components.

Completed by: -is662e Al LOCA.

Zf72,tl4a&<ml Printed/lyped Name 1fhurd e Aw/q Datb I 1-86-5039942-00 Page A-2 of A-2