Text

License Amendment Request No.07-007 Alloy 800 Steam Generator Tube Sleeving
	ML072670044
Person / Time
Site:	Beaver Valley
Issue date:	09/19/2007
From:	Sena P; FirstEnergy Nuclear Operating Co
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	L-07-106
	Download: ML072670044 (54)
	v • d • e

FENOC FirstEnergyNuclear OperatingCompany Peter P. Sena III 724-682-5234 Site Vice President Fax.: 724-643-8069 September 19, 2007 L-07-106 U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555-0001

Subject:

Beaver Valley Power Station, Unit No. 2 BV-2 Docket No. 50-412, License No. NPF-73 License Amendment Request No.07-007 Alloy 800 Steam Generator Tube Sleeving Pursuant to 10 CFR 50.90, FirstEnergy Nuclear Operating Company (FENOC) hereby requests an amendment to the operating license for Beaver Valley Power Station (BVPS)

Unit No. 2. The proposed amendment would modify Technical Specifications (TS) to allow an additional method of repair for Steam Generator tubes, involving use of Westinghouse leak limiting Alloy 800 sleeves. The proposed amendment would also clarify an existing reporting requirement concerning steam generator tube inspection.

The FENOC evaluation of the proposed changes, and necessary supporting documentation, are provided in Enclosure 1.

FENOC requests approval of the proposed amendment on or before October 1, 2008, in order to support implementation of the proposed changes for the BVPS Unit 2 refueling outage in the fall of 2009. Once approved, the amendment would be implemented within 120 days.

Because portions of the enclosed evaluation contain information proprietary to Westinghouse Electric Company LLC, they are supported by affidavits signed by Westinghouse, the owner of the information. The affidavits set forth the bases on which the information may be withheld from public disclosure by the Commission and address with specificity the considerations listed in paragraph (b)(4) of Section 2.390 of the Commission's regulations. Westinghouse authorization letters CAW-06-2099 and CAW-06-2100, with the accompanying affidavits, Proprietary Information Notices, and Copyright Notices, are provided as Enclosures 2 and 3. FENOC requests that information proprietary to Westinghouse be withheld from public disclosure in accordance with 10 CFR Section 2.390 of the Commission's regulations.

Adoo/

Beaver Valley Power Station, Unit No. 2 License Amendment Request No.07-007 L-07-106 Page 2 Correspondence with respect to the copyright or proprietary aspects of the items listed above or the supporting Westinghouse affidavits should reference CAW-06-2099 and/or CAW-06-2 100, as appropriate, and should be addressed to B. F. Maurer, Acting Manager, Regulatory Compliance and Plant Licensing, Westinghouse Electric Company LLC, P.O. Box 355, Pittsburgh, Pennsylvania 15230-0355.

There are no regulatory conmnitments contained in this letter. If there are questions, or if additional information is required, please contact Mr. Thomas A. Lentz, Manager -

FENOC Fleet Licensing, at 330-761-6071.

I declare under penalty of perjury that the foregoing is true and correct. Executed on September j%, 2007.

Sincerely, Peter P. Sena III

Enclosures:

1. FENOC Evaluation of the Proposed Change

2. Westinghouse authorization letter CAW-06-2099 with accompanying affidavits, Proprietary Information Notices, and Copyright Notices

3. Westinghouse authorization letter CAW-06-2100 with accompanying affidavits, Proprietary Information Notices, and Copyright Notices c: Ms. N. S. Morgan, NRR Project Manager Mr. D. L. Werkheiser, NRC Senior Resident Inspector Mr. S. J. Collins, NRC Region I Administrator Mr. D. J. Allard, Director BRP/DEP Mr. L. E. Ryan (BRP/DEP)

ENCLOSURE 1 Beaver Valley Power Station, Unit No. 2 License Amendment Request No.07-007 FENOC Evaluation of the Proposed Change

Subject:

Application for amendment of Beaver Valley Power Station Unit No. 2 Technical Specifications to allow steam generator tube repair using leak limiting Alloy 800 sleeves.

Table of Contents Section Title Page 1.0 SUM M ARY DESCRIPTION ................................................. 1 2.0 DETAILED DESCRIPTION ................................................. 1

3.0 TECHNICAL EVALUATION

........................................... 3

4.0 REGULATORY EVALUATION

..................................... 13 4.1 Significant Hazards Consideration ..................................... 14 4.2 Applicable Regulatory Requirements/Criteria ................... 18 4 .3 Precedent ......................................................................... 19 4.4 C onclusions ..................................................................... 20

5.0 ENVIRONMENTAL CONSIDERATION

......................... 20 6.0 REFEREN CES ............................................................... 20 Attachments Number Title A Proposed Unit 2 Technical Specification Changes B WCAP-15919-P, Revision 2, "Steam Generator Tube Repair for Westinghouse Designed Plants with 7/8 Inch Inconel 600 Tubes Using Leak Limiting Alloy 800 Sleeves," dated January 2006 (Proprietary).

C WCAP-15919-NP, Revision 2, "Steam Generator Tube Repair for Westinghouse Designed Plants with 7/8 Inch Inconel 600 Tubes Using Leak Limiting Alloy 800 Sleeves," dated January 2006 (Non-proprietary).

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Beaver Valley Power Station Unit No. 2 License Amendment Request No.07-007 Attachments (cont'd.)

Number Title D SG-SGDA-05-048-P, "WOG PA-MSC-0190, Revision 1: Test Results Related to TIG and Alloy 800 Sleeve Installation in 3/4 Inch and 7/8 Inch OD SG Tubing In-Service Inspection Requirements," dated January 2006 (Proprietary).

E SG-SGDA-05-048-NP, "WOG PA-MSC-0190, Revision 1:

Test Results Related to TIG and Alloy 800 Sleeve Installation in 3/4 Inch and 7/8 Inch OD SG Tubing In-Service Inspection Requirements," dated January 2006 (Non-proprietary).

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Beaver Valley Power Station Unit No. 2 License Amendment Request No.07-007 1.0

SUMMARY

DESCRIPTION FirstEnergy Nuclear Operating Company (FENOC) proposes to amend Operating License NPF-73 for Beaver Valley Power Station Unit 2. The proposed changes would revise the Technical Specifications to allow the installation of leak limiting Alloy 800 sleeves as an additional approved steam generator (SG) tube repair method and would clarify an existing reporting requirement concerning SG tube inspection.

2.0 DETAILED DESCRIPTION The proposed amendment would revise Technical Specification 5.5.5 to allow an additional method of repair for steam generator tubes by installation of leak limiting Alloy 800 sleeves developed by Westinghouse Electric LLC (Westinghouse) and would clarify an existing reporting requirement (Technical Specification 5.6.6.2.4) concerning SG tube inspection. The proposed method of tube repair is described in proprietary WCAP-15919-P, Revision 2, "Steam Generator Tube Repair for Westinghouse Designed Plants with 7/8 Inch Inconel 600 Tubes Using Leak Limiting Alloy 800 Sleeves," dated January 2006 (included as Attachment B). A non-proprietary version is provided as Attachment C.

WCAP- 15919-P describes the analyses and testing performed to demonstrate that leak limiting Alloy 800 sleeves are an acceptable method of repair for steam generator tubes. Attachment D provides test results supporting a conclusion that flaw detection capabilities within the original tube adjacent to a sleeve nickel band are not necessary in order to evaluate continued operation of the sleeved tube.

Attachment E provides a non-proprietary version of the test results.

The proposed technical specification changes, which are submitted for Nuclear Regulatory Commission (NRC) review and approval, are provided in Attachment A. FENOC is proposing the following revisions.

Technical Specification 5.5.5.2.f provides a list of approved repair methods that may be allowed by the SG program. The proposed amendment would add Specification 5.5.5.2.f.3, designating Westinghouse leak limiting Alloy 800 sleeves as described in WCAP-15919-P, Revision 2 as an additional approved repair method.

Technical Specification 5.5.5.2.c.2 describes required SG program provisions for SG tube repair criteria applicable to flaws found in installed SG tube repair Page 1

Beaver Valley Power Station Unit No. 2 License Amendment Request No.07-007 sleeves. Since the proposed amendment would allow installation of an additional type of repair sleeve (i.e., Westinghouse leak limiting Alloy 800 sleeves), this specification would be revised to require that the SG program contain an additional repair criterion for the additional sleeve type. This additional criterion would require that a tube shall be plugged upon detection of any flaw in a Westinghouse leak limiting Alloy 800 sleeve. Technical Specification 5.5.5.2.c.3 already requires that a tube shall be plugged upon detection of any flaw in a sleeve to tube joint (which includes the pressure boundary of the original tube wall).

Technical Specification 5.5.5.2.d describes required SG program provisions for SG tube inspections. It requires that the number and portions of tubes inspected and methods of inspection shall be performed with the objective of detecting flaws of any type (e.g., volumetric flaws, axial and circumferential cracks) that may be present along the length of the tube and that may satisfy the applicable tube repair criteria. Since the nickel band of an Alloy 800 sleeve would interfere with detection of flaws of any type that may be present in the original tube adjacent to the nickel band, a footnote would be provided to exclude the affected original tube region from this provision, but maintain a requirement to inspect the area and plug the tube if any flaw is detected.

Technical Specification 5.6.6.2.4 describes information to be reported to the NRC within 90 days after achieving Mode 4 following an outage in which the F* methodology was applied. This reporting requirement would be clarified by using terminology consistent with other reporting requirements in Specifications 5.6.6.2.1 and 5.6.6.2.2. The specification would also be clarified to explicitly state that the information to be reported involves only inspection results from the hot-leg tubesheet region (i.e., the only region where F* is permitted to be applied). This clarification is requested to prevent misinterpretation of the existing wording which implies, but does not explicitly state, that the reporting scope is limited to the region where F* was applied.

No changes are proposed for the Technical Specification Bases because the affected technical specifications are administrative and do not have associated Bases.

The proposed change to the technical specifications has been prepared electronically. Deletions are shown with a strike-through and insertions are shown Page 2

Beaver Valley Power Station Unit No. 2 License Amendment Request No.07-007 double-underlined. This presentation allows the reviewer to readily identify the information that has been deleted and added.

To meet format requirements the index and technical specifications will be revised and repaginated as necessary to reflect the changes being proposed by this LAR.

3.0 TECHNICAL EVALUATION

3.1 Changes to TS 5.5.5.2.c.2, 5.5.5.2.d, and 5.5.5.2.f The proposed changes would revise the Specifications 5.5.5.2.c.2, 5.5.5.2.d and 5.5.5.2.f, to permit the installation of Westinghouse leak limiting Alloy 800 sleeves to repair SG tubes at Beaver Valley Power Station Unit No. 2. Westinghouse provides two types of leak limiting Alloy 800 sleeves.

The first type of sleeve spans the transition zone (TZ) of the original SG tube at the top of the tubesheet and is called a TZ sleeve. The upper end of a TZ sleeve is hydraulically expanded into the SG tube above the tubesheet. The lower end is hard rolled into the SG tube within the tubesheet. The length of a TZ sleeve permits the sleeve to span SG tube degradation at the top of the tubesheet. The second type of sleeve is used to span 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. Acceptable sleeve locations for TS sleeves are from the top of the tubesheet up to the u-bend region in both the hot and cold legs.

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 leak limiting Alloy 800 sleeves may allow slight leakage past the sleeve (assuming the original SG tube is leaking), postulated leakage rates for normal operating and accident conditions would be extremely small compared to rates assumed in accident analyses. Any leakage would be subject to existing Technical Specification limits for operational primary to secondary leakage and accident-induced leakage, neither of which would be changed to compensate for the proposed repair method.

Steam Generator tubes with the installed sleeve meet the structural requirements of the original SG tubes and would also be subject to performance criteria for SG tube Page 3

Beaver Valley Power Station Unit No. 2 License Amendment Request No.07-007 integrity required by existing Technical Specifications. Even if severance of the original SG tube is assumed in the region between the sleeve joints, the sleeve would provide the required structural support and acceptable primary to secondary leakage for normal operating and accident conditions. Testing and analysis of the sleeve and repair joint design demonstrate that these criteria are met.

In addition to the analysis and test programs discussed in WCAP-15919-P, Revision 2, a significant number of leak limiting Alloy 800 sleeves have been in operation for a number of years with no service-induced degradation. To date, no detectable leakage has been reported from tubes with Alloy 800 sleeves installed.

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-2 Updated Final Safety Analysis Report (UFSAR) Section 15.6.3, "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 would allow the transfer of reactor coolant into the main steam system. In the event of a SGTR, radioactivity contained in the reactor coolant would mix with water in the shell side of the affected SG. This radioactivity would be transported by steam to the turbine and then to the condenser, or directly to the condenservia 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 would be removed by the condenser air removal system and discharged to the plant vent. The use of leak limiting Alloy 800 sleeves would allow repair of degraded SG tubes such that the function and integrity of the SG tube is maintained. Therefore, the SGTR accident analysis results would not be affected by the use of leak limiting Alloy 800 sleeves.

If failure of a leak limiting Alloy 800 sleeve and/or the associated SG tube is assumed, the consequences of the failure would be bounded by the current SGTR analysis because the total number of plugged SG tubes (including equivalency associated with installed sleeves) is required to be consistent with accident analysis assumptions. 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 assumed in the BVPS-2 accident analyses.

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Beaver Valley Power Station Unit No. 2 License Amendment Request No.07-007 Tubes with sleeves would also be subject to the same safety factors as the original tubes which are described in the performance criteria for SG tube integrity in the existing Technical Specifications. These performance criteria are not being changed to compensate for the proposed repair method. The impact of sleeving on SG performance, heat transfer, and flow restriction is minimal and/or insignificant compared to plugging. The proposed BVPS-2 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-2. Postulated leakage rates for normal operating and accident conditions would be extremely small compared to rates assumed in accident analyses. Existing technical specification limits for primary to secondary operational leakage and primary to secondary accident-induced leakage would not be changed by the proposed license amendment. Data and calculation methodology concerning the reduction in primary coolant flow rate and sleeve to plug equivalency ratios are discussed in Section 10 of WCAP- 15919-P, Revision 2.

The most severe loading condition assumed in WCAP-15919-P, Revision 2 bounds the corresponding BVPS-2 operating and accident value. The most severe loading on the Alloy 800 sleeve is caused by a large primary to secondary temperature difference of 127°F. This assumed loading condition is greater than the plant-specific 97°F temperature difference for BVPS-2.

WCAP-15919-P, Revision 2, describes the specific qualifications of the leak limiting Alloy 800 sleeves. The technical basis for allowing Alloy 800 sleeves to be used for tube repair is summarized below:

Sleeve Installation Requirements Sleeves would be installed in accordance with processes described in WCAP-15919-P, thus ensuring consistency with credited sleeve design, qualification, installation methods, qualified examination techniques and ALARA considerations.

Since the nickel band on TZ sleeves presents challenges to standard eddy current examination of the parent tube behind the nickel band, the parent tube in the area Page 5

Beaver Valley Power Station Unit No. 2 License Amendment Request No.07-007 of the sleeve to tube hard roll joint would be examined using qualified examination techniques prior to installation of the sleeve. Any service-induced indications observed in the parent tube wall adjacent to the location where the nickel band will be installed (the lower half of the lower joint) would preclude installation of the Alloy 800 sleeve.

To prepare for sleeve installation, the installation process would require 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, new sleeve to tube joints undergo baseline eddy current inspection and acceptance.

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-20 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 are imposed to more tightly control the parameters within the limits allowed by the ASME specification.

Analyses 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 PWR Steam Generator Tubes," August 1976.

SG tubes with installed leak limiting Alloy 800 sleeves meet the structural integrity requirements of the original SG tube. Even if severance of the parent SG tube is assumed in the region between the sleeve joints, the sleeve would provide the required structural support and acceptable primary to secondary leakage for normal Page 6

Beaver Valley Power Station Unit No. 2 License Amendment Request No.07-007 operating and accident conditions. Testing and analysis of the sleeve and repair joint design demonstrate that these criteria are inet.

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 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 1 (South Korea) and Tihange 3 (Belgium) steam generators. The current design configuration is in service or recently in service at Angra 1 (Brazil), KRSKO (Slovenia), Ringhals 4 (Sweden),

Tihange 2 (Belgium), Ulchin 1 & 2 (South Korea), Calvert Cliffs 1 and 2, and Watts Bar 1. License amendments allowing use of Alloy 800 sleeves have been granted for Beaver Valley 1 and St. Lucie 2 steam generators.

Section 8.2 of WCAP-15919-P describes how RG 1.121 was used to develop the structural limit of the sleeve should sleeve wall degradation occur. Electric Power Research Institute (EPRI) Technical Report 10001191, "Steam Generator Degradation Specific Management Flaw Handbook," dated 2001, was used as the basis for adding margin to account for the configuration of a long axial crack.

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 between the sleeve joints was assumed in the minimum wall burst evaluation for the leak limiting 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 Section 8.5 of WCAP-15919-P (supplemented by Westinghouse calculation note CN-SGDA-04-4) are at least as conservative as the reactor coolant system design transients described in BVPS-2 FSAR Table 3.9N-1.

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 2, Page 7

Beaver Valley Power Station Unit No. 2 License Amendment Request No.07-007 which is based on normal operating conditions for the worst case envelopment of SG conditions for Westinghouse Model 44, 44F, and 51 steam generators.

However, any tube with leak limiting Alloy 800 sleeve would be plugged upon detection of a flaw in the sleeve and/or the pressure boundary of the parent tube wall in the sleeve to tube joint.

An equivalency assessment was performed to establish that the essential variables developed for eddy current inspection of 3/4 inch tube sleeves can also be applied to 7/8 inch tube sleeves. The eddy current inspection method to be used for 3/4 inch tube sleeves 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.

Corrosion Assessment A significant number of sleeves have been in operation for a number of years with no service-induced degradation. Additionally, no detectable leakage has been associated with a tube that contains an Alloy 800 leak limiting sleeve. Accelerated corrosion testing of leak limiting Alloy 800 sleeve/tube assemblies has been performed in simulated primary and secondary side SG environments and the leak limiting Alloy 800 sleeves showed no signs of cracking in either the primary or secondary side tests. Leak limiting Alloy 800 sleeve corrosion performance is discussed in Section 6 of WCAP-15919-P, Revision 2.

Mechanical Integrity Assessment Mechanical testing of leak limiting Alloy 800 sleeve/tube assemblies was performed using mock 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 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 Page 8

Beaver Valley Power Station Unit No. 2 License Amendment Request No.07-007 develop the conditions for the mechanical tests described in Section 7 of WCAP-15919-P. The temperature and pressure differentials described in Section 8 of WCAP-15919-P are conservative with respect to BVPS-2 operating and accident conditions.

Leak Rate Assessment Section 7 of WCAP- 15919-P provides details regarding how conservative normal operating and accident leak rate values were determined and provides the basis for leak rate values used for calculations such as condition monitoring or operational assessments. 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.

Technical specifications reflect acceptable limits for primary to secondary leakage assumed in accident analyses. Leakage from SG tube sleeves would be extremely small compared to rates assumed in accident analyses and permitted by technical specifications. Therefore, adequate leakage margin exists to accommodate a sufficient number of sleeves to satisfy foreseeable needs while continuing to satisfy existing limits for primary to secondary operational leakage and primary to secondary accident-induced leakage.

Leakage calculations such as for condition monitoring or operational assessments would conservatively assume that each installed sleeve leaks at the upper 95 percent confidence limit on the mean value of leakage for appropriate temperature and pressure conditions. The total projected leak rate from all sleeves would be combined with the total amount of leakage from all other sources (e.g.,

Alternate Repair Criteria (ARC), F* methodology and non-alternate repair criteria indications) for comparison against the limits on accident-induced leakage.

Pre-installation Inspections:

Since the nickel band on TZ sleeves presents challenges to standard eddy current examination of the parent tube behind the nickel band, the parent tube in the area of the sleeve to tube hard roll joint would be examined using qualified examination techniques prior to installation of the sleeve. Any service-induced indications observed in this region would preclude installation of the Alloy 800 sleeve.

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Beaver Valley Power Station Unit No. 2 License Amendment Request No.07-007 Post-installation Inspections:

As required by EPRI Technical Report 1003138 (previously identified as TR 107569-VIR5), post-installation (pre-service) examination will be performed on the full length of 100 percent of the leak limiting Alloy 800 sleeve/tube assemblies using qualified examination techniques. This examination will establish in-service inspection baseline data and initial installation acceptance data on the primary pressure boundary of the sleeve/tube assembly repair.

In-service Inspection:

In-service inspection of the sleeved tubes would be done as part of the periodic inspection program of the steam generator tubing using eddy current testing techniques. In-service inspection would be performed using a rotating pancake coil probe. Other coils and/or methods would be considered for any complementary inspection capability they may provide. The inspection method qualified has been used in operating steam generators in fourteen plants for both the initial installation acceptance and the subsequent in-service inspection.

For sleeving inspections, detection capability would be established with an operational margin relative to structurally limiting flaws. Flaws would be plugged upon detection. Accordingly, it would not be necessary to determine flaw sizes so that flaws could remain in service. By this approach, sizing accuracy does not need to be quantified.

A testing program was conducted to confirm that axial and circumferential degradation of the parent tube adjacent to the nickel band, at any depth, would not prevent the sleeve from satisfying design requirements. Thus, flaw detection capabilities within the parent tube adjacent to the sleeve nickel band are not necessary in order to evaluate continued operation of the sleeved tube.

Nevertheless, as current inspection methods can identify degradation of the parent tube beginning at depths that approach a through-wall condition, sleeved tubes with identified degradation of the parent tube in this region would be removed from service by plugging prior to the degradation of the parent tube achieving the depths considered in the test program.

Plugging Requirements for Tubes with Leak Limiting 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 a flaw is detected in any portion of the sleeve. In addition, to ensure that a defect in the Page 10

Beaver Valley Power Station Unit No. 2 License Amendment Request No.07-007 pressure boundary of a sleeve does not adversely impact the structural integrity of the sleeve, a sleeved tube will be plugged if a flaw is detected in the parent tube wall in the sleeve to tube joint.

Flaws that are detected in the parent tube between the sleeve to tube joints 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 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 800 sleeves to the percent of SG tubes plugged. The total number of plugged SG tubes (including equivalency associated with installed sleeves) is required to be consistent with accident analysis assumptions.

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-2. Therefore, Alloy 800 is compatible with the primary chemistry regime used at BVPS-2 and no changes to this regime are necessary.

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Beaver Valley Power Station Unit No. 2 License Amendment Request No.07-007 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 not 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 0 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 plant performance.

3.2 Changes to TS 5.6.6.2.4 Proposed changes to Technical Specification 5.6.6.2.4 involve reporting requirements for information reported to the NRC within 90 days after achieving Mode 4 following an outage in which the F* methodology was applied. Other reporting requirements in Specifications 5.6.6.2.1 and 5.6.6.2.2 use the phrase, "A report shall be submitted within ... days after the initial entry into MODE 4 following ... ." However, since Specification 5.6.6.2.4 uses different wording, it might wrongly be interpreted that it was intended to have a different meaning. The use of terminology similar to Specifications 5.6.6.2.1 and 5.6.6.2.2 would reinforce the original intent of the reporting requirement.

Technical Specification 5.6.6.2.4 would also be clarified to explicitly state that the information to be reported involves only inspection results from the hot-leg tubesheet region (i.e., the only region where F* is permitted to be applied). This clarification is requested to prevent misinterpretation of the existing wording which implies, but does not explicitly state, that the reporting scope is limited to Page 12

Beaver Valley Power Station Unit No. 2 License Amendment Request No.07-007 the region where F* was applied. The existing reporting is required to permit the NRC staff to verify that operating experience continues to be conservative relative to the assumptions made in License Amendment No. 160 (i.e., the F* amendment).

Therefore, the information that is required to be reported would be limited in scope to portions of tubes affected by F* and the proposed wording maintains the intent of the existing wording.

4.0 REGULATORY EVALUATION

FirstEnergy Nuclear Operating Company proposes to revise Beaver Valley Power Station Unit No. 2 (BVPS-2) Technical Specification 5.5.5 to allow an additional method of repair for steam generator (SG) tubes through the use of leak limiting Alloy 800 sleeves developed by Westinghouse Electric LLC (Westinghouse). An additional revision would clarify an existing reporting requirement concerning SG tube inspection in Technical Specification 5.6.6.2.4. Specifically, the proposed technical specification changes are described as follows:

Technical Specification 5.5.5.2.f provides a list of approved repair methods that may be allowed by the SG program. The proposed amendment would add Specification 5.5.5.2.f.3, designating Westinghouse leak limiting Alloy 800 sleeves as described in WCAP-15919-P, Revision 2 as an additional approved repair method.

Technical Specification 5.5.5.2.c.2 describes required SG program provisions for SG tube repair criteria applicable to flaws found in installed SG tube repair sleeves. Since the proposed amendment would allow installation of an additional type of repair sleeve (i.e., Westinghouse leak limiting Alloy 800 sleeves), this specification would be revised to require that the SG program contain an additional repair criterion for the additional sleeve type. This additional criterion would require that a tube shall be plugged upon detection of any flaw in a Westinghouse leak limiting Alloy 800 sleeve.

Technical Specification 5.5.5.2.d describes required SG program provisions for SG tube inspections. It requires that the number and portions of tubes inspected and methods of inspection shall be performed with the objective of detecting flaws of any type (e.g., volumetric flaws, axial and circumferential cracks) that may be present along the length of the tube and that may satisfy the applicable tube repair criteria. Since the nickel band of an Alloy 800 sleeve would interfere with detection of flaws of any type that may be present in the Page 13

Beaver Valley Power Station Unit No. 2 License Amendment Request No.07-007 original tube adjacent to the nickel band, a footnote would be provided to exclude the affected original tube region from this provision, but maintain a requirement to inspect the area and plug the tube if any flaw is detected.

Technical Specification 5.6.6.2.4 describes information to be reported to the NRC within 90 days after achieving Mode 4 following an outage in which the F* methodology was applied. This reporting requirement would be clarified by using terminology consistent with other reporting requirements in Specifications 5.6.6.2.1 and 5.6.6.2.2. The specification would also be clarified to explicitly state that the information to be reported involves only inspection results from the hot-leg tubesheet region (i.e., the only region where F* is permitted to be applied). This clarification is requested to prevent misinterpretation of the existing wording which implies, but does not explicitly state, that the reporting scope is limited to the region where F* was applied.

The proposed method of tube repair is described in proprietary WCAP-15919-P, Revision 2, "Steam Generator Tube Repair for Westinghouse Designed Plants with 7/8 Inch Inconel 600 Tubes Using Leak Limiting Alloy 800 Sleeves," dated January 2006. WCAP-15919-P describes the analyses and testing performed to demonstrate that leak limiting Alloy 800 sleeves are an acceptable method of repair for steam generator tubes. Existing requirements in the BVPS-2 Technical Specifications concerning provisions in the steam generator program for condition monitoring assessments, performance criteria for SG tube integrity, SG tube inspections, and monitoring operational primary to secondary leakage would remain unchanged. Technical specification limits concerning operational primary to secondary leakage limits and accident-induced primary to secondary leakage limits would also be unchanged.

4.1 Significant Hazards Consideration FirstEnergy Nuclear Operating Company (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 10 CFR 50.92, "Issuance of amendment," as discussed below:

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

Response: No. The leak limiting Alloy 800 sleeves are designed using the applicable American Society of Mechanical Engineers (ASME)

Page 14

Beaver Valley Power Station Unit No. 2 License Amendment Request No.07-007 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. Calculations show that a depth-based limit of 45% through-wall degradation is acceptable. However, the proposed amendment provides additional margin by requiring an Alloy 800 sleeved tube to be plugged on detection of any flaw in the sleeve or in the pressure boundary portion of the original tube wall in the sleeve to tube joint. Degradation of the original tube adjacent to the nickel band of an Alloy 800 sleeve, at any depth, would not prevent the sleeve from satisfying design requirements. Thus, flaw detection capabilities within the original tube adjacent to the sleeve nickel band are not necessary in order to evaluate continued operation of the sleeved tube.

Evaluation of 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 BVPS-2. Corrosion testing and historical performance of sleeve/tube assemblies indicates no evidence of sleeve or tube corrosion considered detrimental under anticipated service conditions.

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 Page 15

Beaver Valley Power Station Unit No. 2 License Amendment Request No.07-007 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-2 Updated Final Safety Analysis Report because the total number of plugged SG tubes (including equivalency associated with installed sleeves) is required to be consistent with accident analysis assumptions. A main steam line break or feedwater line break would not cause a SGTR since the sleeves are analyzed for a maximum accident differential pressure greater than that predicted in the BVPS-2 safety analysis. The sleeve/tube assembly leakage during plant operation would be minimal and is well within the allowable Technical Specification leakage limits and accident analysis assumptions, neither of which would be changed to compensate for the proposed repair method.

Proposed changes to Technical Specification 5.6.6.2.4 only affect a reporting requirement and do not affect plant design, operation or maintenance. They are editorial in nature and are intended as clarifications that would reinforce the original intent of the reporting requirement.

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?

Response: 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. Therefore, the only credible failure mode for the sleeve and/or tube is to rupture, which has already been evaluated. The continued integrity of the installed sleeve/tube assembly is periodically verified as required by the Technical Specifications and a sleeved tube will be plugged on detection of a flaw in the sleeve or in the pressure boundary portion of the original tube wall in the sleeve to tube joint.

Proposed changes to Technical Specification 5.6.6.2.4 only affect a reporting requirement and do not affect plant design, operation or maintenance. They are editorial in nature and are intended as Page 16

Beaver Valley Power Station Unit No. 2 License Amendment Request No.07-007 clarifications that would reinforce the original intent of the reporting requirement.

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 kind of accident from any previously evaluated.

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

Response: 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 reactor coolant system flow 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 greater than the allowed reactor coolant system flow limit established in the Technical Specification LCO 3.4.1. 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. Tubes with sleeves would also be subject to the same safety factors as the original tubes which are described in the performance criteria for SG tube integrity in the existing Technical Specifications. These performance criteria are not being changed to compensate for the proposed repair method. 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 a flaw 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 ensures that the margin of safety is not significantly different from the original SG tubes.

Proposed changes to Technical Specification 5.6.6.2.4 only affect a reporting requirement and do not affect plant design, operation or maintenance. They are editorial in nature and are intended as clarifications that would reinforce the original intent of the reporting requirement.

Page 17

Beaver Valley Power Station Unit No. 2 License Amendment Request No.07-007 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 10 CFR 50.92(c), and, accordingly, a finding of "no significant hazards consideration" is justified.

4.2 Applicable Regulatory Requirements/Criteria Title 10 of the Code of Federal Regulations Part 50 (10 CFR 50),

Appendix A, "General Design Criteria for Nuclear Power Plants" Criterion 14, Reactor Coolant Pressure Boundary, contains requirements applicable to SG tubes since they are part of the reactor coolant pressure boundary. Criterion 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 were designed in accordance with Section III of the ASMfE Code (1971 edition through Summer 1972 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 are considered safety-related components and, therefore, will be required to meet the Appendix B requirements.

Page 18

Beaver Valley Power Station Unit No. 2 License Amendment Request No.07-007 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 three 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 sleeves 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 original SG tube inspections for defect detection, and to verify proper installation of the repair sleeve.

4.3 Precedent The following table identifies license amendments that have been granted to allow repair of steam generator tubes using Alloy 800 sleeves. References are provided in Section 6.0 of this LAR.

Amendment Reference Plant No. Date Topical Report No.

Calvert Cliffs 1 231 09/01/1999 CEN-633-P Rev. 3 11 Calvert Cliffs 2 207 09/01/1999 CEN-633-P Rev. 3 11 Watts Bar 1 44 08/15/2003 WCAP-15918-P Rev. 0 12 Comanche Peak 1 112 03/24/2004 WCAP-15918-P Rev. 1 13 Beaver Valley 1 260 10/05/2004 WCAP-15919-P Rev. 0 14 St. Lucie 2 144 04/18/2006 WCAP-15918-P Rev. 2 15 Page 19

Beaver Valley Power Station Unit No. 2 License Amendment Request No.07-007 Southern California Edison has also requested a license amendment (Reference 16) for San Onofre Nuclear Generating Stations, Unit Nos. 2 and 3, that would provide some relief from inspection requirements in the nickel band region of a sleeve joint. This request is under NRC review.

4.4 Conclusions 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.

5.0 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 10 CFR 20, 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 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.

6.0 REFERENCES

1. Westinghouse Electric LLC WCAP-15919-P, Revision 2, "Steam Generator Tube Repair for Westinghouse Designed Plants with 7/8 Inch Inconel 600 Tubes Using Leak Limiting Alloy 800 Sleeves," dated January 2006 (proprietary).

2. Westinghouse Electric LLC WCAP-15919-NP, Revision 2, "Steam Generator Tube Repair for Westinghouse Designed Plants with 7/8 Inch Inconel 600 Tubes Using Leak Limiting Alloy 800 Sleeves," dated January 2006 (non-proprietary).

Page 20

Beaver Valley Power Station Unit No. 2 License Amendment Request No.07-007

3. Westinghouse Electric LLC SG-SGDA-05-048-P, "WOG PA-MSC-0190, Revision 1: Test Results Related to TIG and Alloy 800 Sleeve Installation in 3/4 Inch and 7/8 Inch OD SG Tubing In-Service Inspection Requirements," dated January 2006 (proprietary).

4. 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.

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

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

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

8. EPRI Technical Report TR-107569-V1R5, "PWR Steam Generator Examination Guidelines: Revision 5, Volume 1: Requirements," dated September 1997.

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

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 Plants with 3/4 Inch Inconel 600 tubes Using Leak Limiting Alloy 800 Sleeves," dated November 2002 (proprietary).

11. 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).

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Beaver Valley Power Station Unit No. 2 License Amendment Request No.07-007

12. License Amendment No. 44 to Facility Operating 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).

13. License Amendment No. 112 to Facility Operating License No. NPF-87, "Comanche Peak Steam Electric Station (CPSES), Unit 1 - Issuance of Amendment Re: Steam Generator Tube Repair Using Leak Limiting Alloy 800 Sleeves (TAC No. MC0197)," dated March 24, 2004 (ADAMS # ML040840401).

14. License Amendment No. 260 to Facility Operating License No. DPR-66, "Beaver Valley Power Station, Unit No. 1 - Issuance of Amendment Re:

One-Cycle Use of Westinghouse Leak-Limiting Alloy 800 Steam Generator Tube Sleeves For SG Tube Repair (TAC No. MC1857),"

dated October 5, 2004 (ADAMS # ML042400116).

15. License Amendment No. 144 to Facility Operating License No. NPF-16, "St. Lucie Plant, Unit No. 2 - Issuance of Amendment Regarding Use of Westinghouse Alloy 800 Sleeves in Steam Generators (TAC No.

MC5633)," dated April 18, 2006 (ADAMS # ML061070115).

16. Southern California Edison License Amendment Request, "San Onofre Nuclear Generating Station, Units 2 and 3, Docket Nos. 50-361 and 50-362, Response to Request for Additional Information and Submittal of Proposed Technical Specification Change Number (PCN) 572, Steam Generator Tube Surveillance Program, Tube Repair" dated July 14, 2006 (ADAMS # ML061990071).

17. Beaver Valley Power Station Unit No. 2 Updated Final Safety Analysis Report.

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Westinghouse Westinghouse Electric Company Nuclear Services P.O. Box 355 Pittsburgh, Pennsylvania 15230-0355 USA U.S. Nuclear Regulatory Commission Direct tel: (412) 374-4419 Document Control Desk Direct fax: (412) 374-4011 Washington, DC 20555-0001 e-mail: maurerbf@westinghouse.com Our ref: CAW-06-2099 February 3, 2006 APPLICATION FOR WITHHOLDING PROPRIETARY INFORMATION FROM PUBLIC DISCLOSURE

Subject:

SG-SGDA-05-48-P, Rev. 1 "WOG PA-MSC-0190, Revision 1: Test Results Related to TIG and Alloy 800 Sleeve Installation in 3/4 Inch and 7/8 Inch OD SG Tubing In-Service Inspection Requirements" (Proprietary)

The proprietary information for which withholding is being requested in the above-referenced report is further identified in Affidavit CAW-06-2099 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 2.390 of the Commission's regulations.

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

Correspondence with respect to the proprietary aspects of the application for withholding or the Westinghouse affidavit should reference this letter, CAW-06-2099, and should be addressed to B. F. Maurer, Acting Manager, Regulatory Compliance and Plant Licensing, Westinghouse Electric Company LLC, P.O. Box 355, Pittsburgh, Pennsylvania 15230-0355.

Very truly yours, B. F. Maurer, Acting Manager Regulatory Compliance and Plant Licensing Enclosures cc: B. Benney L. Feizollahi A BNFL Group company

CAW-06-2099 bcc: B. F. Maurer (ECE 4-7A) IL R. Bastien, IL (Nivelles, Belgium)

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

RCPL Administrative Aide (ECE 4-7A) IL, 1A (letter and affidavit only)

G. W. Whiteman, Waltz Mill W. K. Cullen, Waltz Mill G. A. Brassart, ECE 4-13 N. B. Closky, WEC 412M A BNFL Group company

CAW-06-2099 AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA:

ss COUNTY OF ALLEGHENY:

Before me, the undersigned authority, personally appeared B. F. Maurer, 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:

B. F. Maurer, Acting Manager Regulatory Compliance and Plant Licensing Sworn to and subscribed before nie this .*"Žday of , 2006 Notary Public Notarial Seal Sharon L.Rodi, Notary Public Monroeville Boro, Allegheny County My Commission Expires January 29, 2007 Member, Pennsylvania Association Of Notaries

2 CAW-06-2099 (1) I am Acting 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 onl behalf of Westinghouse.

(2) I am making this Affidavit in conformance with the provisions of 10 CFR Section 2.390 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 2.390 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-06-2099 (b) It consists of supporting data, including test data, relative to a process (or component, structure, tool, imethod, 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 inforlrnation 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 may be the key to the entire puzzle, thereby depriving Westinghouse of a competitive advantage.

4 CAW-06-2099 (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 2.390, 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 SG-SGDA-05-48-P, Rev. 1 "WOG PA-MSC-0190, Revision 1: Test Results Related to TIG and Alloy 800 Sleeve Installation in 3/4 Inch and 7/8 Inch OD SG Tubing In-Service Inspection Requirements" (Proprietary), dated January 2006. The information is provided in support of a submittal to the Commission, being transmitted by FirstEnergy Nuclear Operating Company 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 2 is expected to be applicable to other licensee submittals in response to certain NRC requirements for justification of the use of Alloy 800 sleeves for the repair of degraded steam generator tubes.

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

(a) Demonstrate the acceptability of installing Alloy 800 sleeves in degraded tubes in the Beaver Valley Unit 2 steam generators.

(b) Provide testing program results showing the acceptability of current inspection methods in identifying degradation in the parent tube adjacent to the sleeve.

(c) Assist the customer in obtaining NRC approval of a technical specification change.

5 CAW-06-2099 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 on Alloy sleeves 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 infornation 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 2.390 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 2.390(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 2.390 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.

FirstEnergy Nuclear Operating Company Letter for Transmittal to the NRC The following paragraphs should be included in your letter to the NRC:

Enclosed are:

I. 1 copy of SG-SGDA-05-48-P, Rev. I "WOG PA-MSC-0 190, Revision 1: Test Results Related to TIG and Alloy 800 Sleeve Installation in 3/4 Inch and 7/8 Inch OD SG Tubing In-Service Inspection Requirements" (Proprietary)

2. 1 copy of SG-SGDA-05-48-NP, Rev. 1 "WOG PA-MSC-0190, Revision 1: Test Results Related to TIG and Alloy 800 Sleeve Installation in 3/4 Inch and 7/8 Inch OD SG Tubing In-Service Inspection Requirements" (Non-proprietary)

Also enclosed is Westinghouse authorization letter CAW-06-2099 with 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 2.390 of the Commission's' regulations.

Accordingly, it is respectfuilly requested that the information which is proprietary to Westinghouse be withheld from public disclosure in accordance with 10 CFR Section 2.390 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-06-2099 and should be addressed to B. F. Maurer, Acting Manager, Regulatory Compliance and Plant Licensing, Westinghouse Electric Company LLC, P.O. Box 355, Pittsburgh, Pennsylvania 15230-0355.

S Westinghouse Westinghouse Electric Company Nuclear Services P.O. Box 355 Pittsburgh, Pennsylvania 15230-0355 USA U.S. Nuclear Regulatory Commission Direct tel: (412) 374-4419 Document Control Desk Direct fax: (412) 374-4011 Washington, DC 20555-0001 e-mail: maurerbf@westinghouse.com Our ref: CAW-06-2100 February 3, 2006 APPLICATION FOR WITHHOLDING PROPRIETARY INFORMATION FROM PUBLIC DISCLOSURE

Subject:

WCAP-15919-P, Revision 2, "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-06-2100 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 2.390 of the Commission's regulations.

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

Correspondence with respect to the proprietary aspects of the application for withholding or the Westinghouse affidavit should reference this letter, CAW-06-2100, and should be addressed to B. F. Maurer, Acting Manager, Regulatory Compliance and Plant Licensing, Westinghouse Electric Company LLC, P.O. Box 355, Pittsburgh, Pennsylvania 15230-0355.

Very truly yours, B. F. Maurer, Acting Manager Regulatory Compliance and Plant Licensing Enclosures cc: B. Benney L. Feizollahi A BNFL Group company

CAW-06-2 100 bcc: B. F. Maurer (ECE 4-7A) IL R. Bastien, IL (Nivelles, Belgium)

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

RCPL Administrative Aide (ECE 4-7A) IL, 1A (letter and affidavit only)

G. W. Whiteman, Waltz Mill W. K. Cullen, Waltz Mill G. A. Brassart, ECE 4-13 N. B. Closky, WEC 412M A BNFL Group company

CAW-06-2 100 AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA:

ss COUNTY OF ALLEGHENY:

Before me, the undersigned authority, personally appeared B. F. Maurer, 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:

B. F. Maurer, Acting Manager Regulatory Compliance and Plant Licensing Sworn to and subscribed before e this 7 day of , 2006 Notary Public Notarial Seal Sharon L.Rod, Notary Public Monroeville Boro, Allegheny County My Commission Expires January 29, 2007 Member. Pennsylvania Association Of Notaries

2 CAW-06-2 100 (1) I am Acting 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 pioprietary 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.