Text

License Amendment Request 298, Revision 0: Application to Modify Improved Technical Specifications for Replacement Steam Generators
	ML080300560
Person / Time
Site:	Crystal River
Issue date:	01/22/2008
From:	Young D; Progress Energy Co
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	3F0108-14
	Download: ML080300560 (42)
	v • d • e

Progress Energy Crystal River Nuclear Plant Docket No. 50-302 Operating License No. DPR-72 Ref: 10 CFR 50.90 January 22, 2008 3F0108-14 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001

Subject:

Crystal River Unit 3 -

License Amendment Request #298, Revision 0:

Application to Modify Improved Technical Specifications for Replacement Steam Generators

References:

NRC to Crystal River Unit 3 Letter dated May 16, 2007, "Crystal River Unit 3 -

Issuance of Amendment Regarding Steam Generator Tube Inspection Program (TAC NO. MD2054)"

Dear Sir:

In accordance with the provisions of 10 CFR 50.90, Florida Power Corporation (FPC), doing business as Progress Energy Florida, Inc., hereby provides License Amendment Request (LAR)

298, Revision 0. The proposed amendment would revise the Crystal River Unit 3 (CR-3)

Improved Technical Specification (ITS) requirements related to steam generator tube integrity for replacement steam generators.

By the letter referenced above, License Amendment #223 was approved for CR-3 implementing Revision 4 to Technical Specification Task Force (TSTF) Standard Technical Specification Change Traveler 449 (TSTF-449) for the existing Steam Generators.

This LAR seeks implementation of TSTF-449 for the replacement Steam Generators which are being installed during the Fall 2009 Refueling Outage 16R.

In regard to the elements of TSTF-449, the replacement Steam Generators differ from the existing Steam Generators in that the tubing material is Alloy 690 Thermally Treated (TT) in the replacements versus Alloy 600 in the existing Generators. As appropriate to the material change, this submittal is consistent with, and utilizes elements of TSTF-449. This LAR also removes information related to repair techniques and products approved for the existing Steam Generators but not for the replacements.

Progress Energy Florida, Inc.

Crystal River Nuclear Plant 15760 W. Powerline Street Crystal River, FL 34428

U.S. Nuclear Regulatory Commission 3F0108-14 Page 2 of 3 Attachment A provides a description of the proposed change and confirmation of applicability.

Attachment B provides the existing ITS pages marked-up to show the proposed change, and Attachment C provides those same changes presented more formally with revision bars.

Attachments D and E provide similar formats for the related Bases sections. Attachment F provides a list of Regulatory Commitments.

FPC requests approval of the proposed license amendment by February 28, 2009, with the amendment to be implemented upon startup from Refueling Outage 16R.

In accordance with 10 CFR 50.91, a copy of this application with enclosures is being provided to the designated Florida State Official.

The CR-3 Plant Nuclear Safety Committee has reviewed this request and recommended it for approval.

If you have any questions regarding this submittal, please contact Mr. Dennis Herrin, Acting Supervisor, Licensing and Regulatory Programs at (352) 563-4633.

Sincerely, XV4,&_ 4 yll(_ýý Dale Young V

Vice President Crystal River Nuclear Plant DY/scp Attachments:

A.

Description and Assessment B.

Proposed Improved Technical Specification Changes (Mark-up)

C.

Proposed Improved Technical Specification Changes (Revision Bar Format)

D.

Proposed Improved Technical Specification Bases Pages (Mark-up)

E.

Proposed Improved Technical Specification Bases Pages (Revision Bar Format)

F.

List of Regulatory Commitments xc:

NRR Project Manager Regional Administrator, Region II Senior Resident Inspector State Contact

U.S. Nuclear Regulatory Commission 3F0108-14 Page 3 of 3 STATE OF FLORIDA COUNTY OF CITRUS Dale Young states that he is the Vice President, Crystal River Nuclear Plant for Florida Power Corporation, doing business as Progress Energy Florida, Inc.; that he is authorized on the part of said company to sign and file with the Nuclear Regulatory Commission the information attached hereto; and that all such statements made and matters set forth therein are true and correct to the best of his knowledge, information, and belief.

Dale Young Vice President Crystal River Nuclear Plant 14_

day of 9The foregoing document was acknowledged before me this m&ýW 2008, by Dale Young.

(Print, type, or stamp Commissioned Name of Notary Public)

Personally Produced Known

/___

-OR-Identification

PROGRESS ENERGY FLORIDA, INC.

CRYSTAL RIVER UNIT 3 DOCKET NUMBER 50-302 / LICENSE NUMBER DPR-72 LICENSE AMENDMENT REQUEST #298, Revision 0 Application to Modify Improved Technical Specifications For Replacement Steam Generators ATTACHMENT A Description and Assessment

U.S. Nuclear Regulatory Commission Attachment A 3F0108-14 Page 1 of 4 Description and Assessment

1.0 INTRODUCTION

By letter dated May 16, 2007, License Amendment #223 was approved for Crystal River Unit 3 (CR-3) implementing Revision 4 to Technical Specification Task Force (TSTF)

Standard Technical Specification Change Traveler TSTF-449 for the existing Steam Generators. This License Amendment Request (LAR) seeks implementation of TSTF-449 for the replacement Steam Generators which are being installed during the Fall 2009 Refueling Outage 16R. In regard to the elements of TSTF-449, the replacement Steam Generators differ from the existing Steam Generators in that the tubing material is Alloy 690 Thermally Treated (TT) in the replacements versus Alloy 600 in the existing Generators. As appropriate to the material change, this submittal is consistent with, and utilizes elements of TSTF-449. This LAR also removes information related to repair techniques and products approved for the existing Steam Generators but not for the replacements.

The elements of TSTF-449 regarding the Improved Technical Specification (ITS) definition of LEAKAGE and ITS 3.4.12, RCS [Reactor Coolant System] Operational LEAKAGE, were incorporated into the CR-3 ITS by License Amendment #223. Those elements are consistent with this proposed change. Since those elements are integral to the overall maintenance of steam generator tube integrity, reference to them in the Federal Register Notice (Reference 1) discussions applicable to Sections 3.0 through 8.0 below continues to remain appropriate.

2.0 DESCRIPTION

OF PROPOSED AMENDMENT The proposed ITS changes include:

Revised ITS 3.4.16, Steam Generator (OTSG) Tube Integrity

Revised ITS 5.6.2.10, Steam Generator (OTSG) Program

Revised ITS 5.7.2, Special Reports The revisions are necessary due to two factors. The inspection frequency for Alloy 690 TT tube material, as defined in TSTF-449, differs from the inspection frequency for Alloy 600, and the tube repair processes and products in the existing Technical Specifications are not applicable to the replacement OTSGs.

ITS 3.4.16 is revised to remove references to 'repair' of steam generator tubes. There are no repair processes approved for the replacement steam generators.

ITS 5.6.2.10 is revised to change the tube inspection frequency, as specified in TSTF-449, from that applicable to Alloy 600 to that applicable to Alloy 690 TT.

ITS 5.6.2.10 is revised to delete information on repair techniques, and ITS 5.7.2 is revised to remove reporting requirements associated with the deleted repair techniques.

U.S. Nuclear Regulatory Commission Attachment A 3F0108-14 Page 2 of 4 Proposed revisions to the ITS Bases are also included in this application for information only. As discussed in the NRC's model safety evaluation, adoption of the revised ITS Bases associated with TSTF-449, Revision 4, is an integral part of implementing this ITS improvement. The changes to the affected ITS Bases pages will be incorporated in accordance with the CR-3 ITS Bases Control Program.

3.0 BACKGROUND

The background for the inspection frequency is adequately addressed by the NRC Notice of Availability published on May 6, 2005 (70 FR 24126), the NRC Notice for Comment published on March 2, 2005 (70 FR 10298), and TSTF-449, Revision 4.

The repair processes in the current CR-3 Technical Specifications were specifically approved for the existing steam generators based on their history of operation, tube and tubesheet materials, and tube to tubesheet geometry. The analyses that form the basis for the approval of those repair processes are not applicable to the replacement OTSGs.

4.0 REGULATORY REQUIREMENTS AND GUIDANCE The applicable regulatory requirements and guidance associated with this application are adequately addressed by the NRC Notice of Availability published on May 6, 2005 (70 FR 24126), the NRC Notice for Comment published on March 2, 2005 (70 FR 10298),

and TSTF-449, Revision 4.

5.0 TECHNICAL ANALYSIS

Florida Power Corporation (FPC) has reviewed the safety evaluation published on March 2, 2005 (70 FR 10298) as part of the Consolidated Line Item Improvement Program (CLIIP) Notice for Comment. This included the NRC staff's Safety Evaluation (SE), the supporting information provided in TSTF-449, and the changes associated with Revision 4 to TSTF-449. FPC has concluded that the justifications presented in the TSTF proposal and the SE prepared by the NRC staff are applicable to CR-3 and justify this amendment for the incorporation of the changes to the CR-3 ITS, with one exception.

Stress analysis calculations are not complete to validate the tube plugging criterion that through-wall flaws of up to 40% are acceptable.

Stress analyses determining the allowable through-wall flaw size are scheduled for completion in June 2008. FPC will provide verification that the correct tube plugging limit for CR-3 is 40% through-wall, or revise Technical Specification 5.6.2.10 to include the calculated tube plugging limit if less than 40% by September 30, 2008.

6.0 REGULATORY ANALYSIS

A description of this proposed change and its relationship to applicable regulatory requirements and guidance was provided in the NRC Notice of Availability published on May 6, 2005 (70 FR 24126), the NRC Notice for Comment published on March 2, 2005 (70 FR 10298), and TSTF-449, Revision 4.

U.S. Nuclear Regulatory Commission 3F0108-14 Attachment A Page 3 of 4 6.1 Verification and Commitments The following information is provided to support the NRC staff's review of this amendment application:

Plant Name, Unit No.

Crystal River Unit 3 Steam Generator Model(s):

CR-3 Replacement OTSG Effective Full Power Years (EFPY) of service for currently New at startup from Refueling Outage 16R installed OTSGs Tubing Material Alloy 690 7T ( Thermally Treated)

Number of tubes per OTSG 15,607 Number and percentage of tubes OTSG A OTSG B plugged in each OTSG 0 (0%)

0 (0%)

Number of Tubes repaired in OTSG A OTSG B each OTSG N/A N/A Degradation mechanism(s)

- None identified Current primary-to-secondary Per SG: 150 gallons per day (gpd) per LCO leakage limits:

3.4.12.d Total:

No total limit specified in ITS Temperature condition leakage is evaluated at: room temperature Approved Alternate Tube Repair Criteria (ARC):

- None Approved Replacement OTSG Tube Repair Methods None Performance criteria for accident

- Primary to secondary leak rate values assumed in leakage licensing basis accident analysis, including assumed temperature conditions: 1 gpm at accident temperature assumed in the CR-3 Final Safety Analysis Report.

These are the nominal values for new generators; however, pre-service inspections may identify tubes with fabrication induced flaws that require plugging. The number of tubes requiring plugging is expected to be minimal and inconsequential.

U.S. Nuclear Regulatory Commission Attachment A 3F0108-14 Page 4 of 4 7.0 NO SIGNIFICANT HAZARDS CONSIDERATION FPC has reviewed the proposed no significant hazards consideration determination published on March 2, 2005 (70 FR 10298) as part of the CLIIP. FPC has concluded that the proposed determination presented in the notice is applicable to CR-3 and the determination is hereby incorporated by reference to satisfy the requirements of 10 CFR 50.91(a).

8.0 ENVIRONMENTAL EVALUATION FPC has reviewed the environmental evaluation included in the model SE published on March 2, 2005 (70 FR 10298) as part of the CLIIP. FPC has concluded that the staff's findings presented in that evaluation are applicable to CR-3 and the evaluation is hereby incorporated by reference for this application.

9.0 PRECEDENT This application is being made in accordance with the CLIIP. FPC is not proposing variations or deviations from the ITS changes described in TSTF-449, Revision 4, or the NRC staff's model SE published on March 2, 2005 (70 FR 10298).

10.0 REFERENCES

Federal Register Notices:

1.

Notice for Comment published on March 2, 2005 (70 FR 10298)

2.

Notice of Availability published on May 6, 2005 (70 FR 24126)

PROGRESS ENERGY FLORIDA, INC.

CRYSTAL RIVER UNIT 3 DOCKET NUMBER 50-302 / LICENSE NUMBER DPR-72 LICENSE AMENDMENT REQUEST #298, Revision 0 Application to Modify Improved Technical Specifications For Replacement Steam Generators ATTACHMENT B Proposed Improved Technical Specification Changes (Mark-up)

&44ieet4ext indicates deleted text.

ýHighlighted texk indicates added text.

OTSG Tube Integrity 3.4.16 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.16 Steam Generator (OTSG)

Tube Integrity LCO 3.4.16 OTSG tube integrity shall be maintained.

AND All OTSG tubes satisfying the tube repair criteria shall be plugged or r-paired in accordance with the Steam Generator Program.

APPLICABILITY:

MODES 1, 2,

3, and 4.

ACTIONS

NOTE----------------------------------

Separate Condition entry is allowed for each OTSG tube.

CONDITION REQUIRED ACTION COMPLETION TIME A.

One or more OTSG A.1 Verify tube integrity 7 days tubes satisfying the of the affected tube repair criteria tube(s) is maintained and not plugged o-r until the next rp-a-ired in refueling outage or accordance with the OTSG tube inspection.

Steam Generator Program.

AND A.2 Plug or repai-r the Prior to entering affected tube(s) in MODE 4 following accordance with the the next refueling Steam Generator outage or OTSG Program.

tube inspection B.

Required Action and B.1 Be in MODE 3.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time of Condition A AND not met.

B.2 Be in MODE 5.

36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months OR OTSG tube integrity not maintained.

Crystal River Unit 3 3.4-34 Amendment No. 2-3

OTSG Tube Integrity 3.4.16 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.16.1 Verify OTSG tube integrity in accordance In accordance with with the Steam Generator Program.

the Steam Generator Program SR 3.4.16.2 Verify that each inspected OTSG tube that Prior to entering satisfies the tube repair criteria is MODE 4 following a plugged o j..

"a-^red. in accordance with the OTSG tube Steam Generator Program.

inspection Crystal River Unit 3 3.4-35 Amendment No. 2-2-3

Procedures, Programs and Manuals 5.6 5.6 Procedures, Programs and Manuals 5.6.2.10 Steam Generator (OTSG)

Program A Steam Generator Program shall be established and implemented to ensure that OTSG tube integrity is maintained.

In addition, the Steam Generator Program shall include the following provisions:

a.

Provisions for condition monitoring assessments.

Condition monitoring assessment means an evaluation of the "as found" condition of the tubing with respect to the performance criteria for structural integrity and accident induced leakage.

The "as found" condition refers to the condition of the tubing during an OTSG inspection outage, as determined from the inservice inspection results or by other means, prior to the plugging er-repair of tubes.

Condition monitoring assessments shall be conducted during each outage during which the OTSG tubes are inspected-J64 plugged,---r repaired to confirm that the performance criteria are being met.

b.

Performance criteria for OTSG tube integrity.

OTSG tube integrity shall be maintained by meeting the performance criteria for tube structural integrity, accident induced leakage, and operational LEAKAGE.

1.

Structural integrity performance criterion:

All in-service steam generator tubes shall retain structural integrity over the full range of normal operating conditions (including startup, operation in the power range, hot standby, and cool down and all anticipated transients included in the design specification) and design basis accidents.

This includes retaining a safety factor of 3.0 against burst under normal steady state full power operation primary-to-secondary pressure differential and a safety factor of 1.4 against burst applied to the design basis accident primary-to-secondary pressure differentials.

Apart from the above requirements, additional loading conditions associated with the design basis accidents, or combination of accidents in accordance with the design and licensing basis, shall also be evaluated to determine if the associated loads contribute significantly to burst or collapse.

In the assessment of tube integrity, those loads that do significantly affect burst or collapse shall be determined and assessed in combination with the loads due to pressure with a safety factor of 1.2 on the combined primary loads and 1.0 on axial secondary loads.

(continued)

Crystal River Unit 3 5.0-13 Amendment No. 2 Procedures, Programs and Manuals 5.6 5.6 Procedures, Programs and Manuals 5.6.2.10 OTSG Program (continued)

2.

Accident induced leakage performance criterion: The primary to secondary accident induced leakage rate for any design basis accident, other than an OTSG tube rupture, shall not exceed the leakage rate assumed in the accident analysis in terms of total leakage rate for all OTSGs and leakage rate for an individual OTSG.

Leakage is not to exceed one gallon per minute per OTSG.

3.

The operational LEAKAGE performance criterion is specified in LCO 3.4.12, "RCS Operational LEAKAGE."

c.

Provisions for OTSG tube repair criteria.

Tubes shall be plugged if the sleeved region of a tube is found by i lsel vie i nspleti on to contaiIn fl aws i.

n the (a) s l eeve o r Eb) the pressure boundary portion of the original tube wall in the sleeve/tube assembly.

The non sleeved region of a W tube found by inservice inspection to contain flaws with a depth equal to or exceeding 40% of the nominal tube wall thickness shall be plugged or re.

_paired except if the flaws are permitted to re ervice through application of an alternate tube repair criteria discussed below.

The following alternate tube repair criteria may be applied as an alternative to the 40% depth based criteria:

t-IPit like Intergranular Attaek (IGA) indication means a bobbin coil indication confi rmed by Motorized Rotati-fg Pancake Coil

-MRP) or other qualified inspection techniques to have a volumetric, pit like morphology characteristic of IGA.

inservie tubes with pit like IGA indications in the first span of the B OTSG are acceptable provided the depth of the indication is less than 40% of the nominal tube wall thickness. InservIAee tubes with pit like IGA indications in the first span of the B TSG with a depth equal to or xceeding 40% of_ the mInl tube wall thickness shall be plugg (conti nued)

Crystal River Unit 3 5.0-14 Amendment No. 2-2-3

Procedures, Programs and Manuals 5.6 5.6 rrocedures, Programs and Manuals-5.6.2.10. 0E T..SG.

rrogr m (conti nued)

2. Tube End Cracks iTEC) are those crack-like eddy current indications,. circumferentially and,'or axi ally oriented-,

that are within the Inconel clad rgoofthe prima-ry face of the upper and lower tubesheets, but do not extend into the carbon steel to Inconel clad interface.

Tubes withIaxially oriented T[C may be left in serviee uigthe method described, in Topical Report BAW 234CrP,-

Revision 0, provided th@e, ombined projected leakage from all sources of primar"y to secondary leakage, includin axial T-lEC indiations left in service, does not exce the Main Steam Line Break (MSLB) accident leakage liiiii-t of one gallon permnue minus -150 gallons per day, per OTSG.

The contribution to MSLB leakage rates fromTC indications shall be determined utilizingth methodology in Addendum B dated August 10, 2005 t Topical Report BAW 2346P, Revision 0.

The projection of T[C leakage that may develop during the next operatin cycle shall be determined using the methodology in Addendum C dated August 300, 2005~ to Topical Report BAW 2346r, Revision 0-.

Tubes identified with TEC that are allowed t eani sericeunder the alternate repair criteria will be addto the existing list of tubes in the OTSG Inservic@ inspection Surveillance Procedure.

The inspection data for tubes with axially oriented T[C indictions. shall be compared to the previous inspection data to monitor the indications for growth.

Tubes with crack like indications within the carbon Steel portiUlo of the tubesheet, circumferentially oriented TEC, or volumetrie indications within the Inconel clad region of the tubesheet shall be repaire using the appropriate method from 5.6.2.104f or remoe from service by plugging the tube.

(conti nued)

Crystal River Unit 3 I.0-15 Ahiendment No. 2-2-3

Procedures, Programs and Manuals 5.6 5.6 Procedures, Programs and Manuals 5.6.2.10 0TSG Program (continued)

d.

Provisions for 0TSG tube inspections.

Periodic OTSG tube inspections shall be performed.

The number and portions of the 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, from the tube-to-tubesheet weld at the tube inlet to the tube-to-tubesheet weld at the tube outlet, and

that may satisfy the applicable tube repair criteria.

The tube-to-tubesheet weld is not part of the tube.

In tubes repaired -b.

sleev...,

the portion of the original tuble wall between the sleeve's Joints is not an area requiring re inspection.

In addition to meeting the requirements of d.1 through d.81 below, the inspection scope, inspection methods, and inspection intervals shall be such as to ensure that OTSG tube integrity, is maintained until the next OTSG inspection.

An assessment of degradation shall be performed to determine the type and location of flaws to which the tubes may be susceptible and, based on this assessment, to determine which inspection methods need to be employed and at what locations.

1.

Inspect 100% of the tubes in each OTSG during the first refueling outage following OTSG replacement.

2.

Inspect 100% of the tubes at sequential periods of '144__10, 72, and, thereafter,J 60 effective full power months.

The first sequential period shall be considered to begin after the first inservice inspection of the OTSGs.

in addition.

inspect 50% of the tubes by the refueling outage nearest the midpoint of the period and. the remaining 50% by the refueling otagge nearest the end of the period.-No OTSG shall operate for more than-24--72 effective full power months or eoe-.thi refueling outages (whichever is less) without being inspected.

3.

If crack indications are found in any OTSG tube, then the next inspection for each OTSG for the degradation mechanism that caused the crack indication shall not exceed 24 effective full power months or. one refueling outage (whichever is less).

If definitive information, such as from examination of a pulled tube, diagnostic non-destructive testing, or engineering evaluation indicates that a crack-like indication is not associated with a crack(s), then the indication need not be treated as a crack.

(continued)

Crystal River Unit 3 5.0-16 Amendment No. 2-23

Procedures, Programs and Manuals 5.6 5.6 Procedures, rrograms and Manuals 5.6.2.10 OTSG Program (continued)

4. Inservicle tubes with pit like IGA indicationis in the first span of the B OTSG must be inspect-ed with bobbinf and Motorized Rotating rancak Coil (MRrC) eddy current techniques from the lower tube sheet secondary face to the bottom of the first tube support plate during eac inser1vice inspection of the B OTSG.

inservice tubes with pit like IGA indications in the "B" OTSG first span shall be monitored for growth of these*-

indications by using a test probe equivalent to the high frequency bobbin probe used in the 1997 inspectio.

The indicated percentage through wall va-lu from the current inpetion shall be compared to the indiceated percentage tirough wall value from the 1997 inspection.

5. Tubes in eric with axially oriented tube end cracks (T[C) are identified in the OT-SG inservice Inspecti Surveillance Procedure.

The portion of the tube with the axial T[C must be inspected using the motorized IULrLling cil eddy current technique every 24 effectiVE full power months or one refueling outage, whichever is

6. if the plant i required to shut down due to primary to secondary leakage and the cause is determined to be degradation of the TEC portion of the tubes, 1:00% of the tubes with TEC in that OTSG shall be examined in the location of the TEC.

if more than 1% of the examined tubes satisfy the tube repar c.iteria, 1:00% of the tubes with TEC in the other OTSGJ shall be examined in the location of the T[C.

7. The repair roll in each tube will be inspected every 24 efflective full power months or one refueling outage (whichever is less) while the tube with a repair roll is inl ser vice.

8.

if the plant is requied to shut down due to prima-ry to-secondary leakage and the cause is determined to be--a flaw in aear roll, 100% of the epi rolls in bt OTSGs shall be examined.

(continued)

Crystal River Unit 3 5.0-17 Ame'ndment No. 2-2-3

Reporting Requirements 5.7 5.6 Procedures, Programs and Manuals 5.6.2.10 OTSG Program (continued)

e.

Provisions for monitoring operational primary to secondary LEAKAGE.

f. Prvsosfor OTSG tube repair methods.

Steam generato tube repair methods shall provide the means to reestablish the RCS pressure boundary integrity of OTSG tubes withou rem.i.

"-the tube f.rom servic e. For the purposes of these Speifilations, tube plugging is not a repair.

All acJceptable tube repair methods are listed below.-

1. Sleeve installation in accordance with the B&W proceess (or method) described in report BAW 23120P.

No more tha five thousand sleeves may be installed in each OT-SG.

2. installation of repair rolls in the upper and lower tubesheets in accordance with BAW 2303P, ReVision 4.

The reIpail process5 (511single, overlapping, or multiple rol maIy be pVerf Irm Inw II each tube.

The repair roII area will be ex nd using eddy curre~nt methods following installation. The repair roll must be free -of flaws for the repair to be considered acceptable. 1-ff the repair roll is unacceptable, the tube must be repaired or plugged.

(continued)

Amendment No.

22-Crystal River Unit 3 5.0-17A

Reporting Requirements 5.7 5.7 Reporting Requirements 5.7.2 Special Reports (continued)

5.

Number of tubes plugged

.,reird during the inspection outage for each active degradation mechanism,

6.

Total number and percentage of tubes plugged or-,epa,-e to date,

7.

The results of condition monitoring, including the results of tube pulls and in-situ testing,

8.

The effective plugging percentage for all plugging and tube repairs in each OTSG--.

9. Repair method utilized and the number of tubes repaired by @eah repair method, 1:0.

Location, bobbin lcil amplitude, and axial and circumferential extent (if determined) for each first span IGA indication, and an assessment of growth for indications in the first span of-OTSG B, anrd 1-1.

Number of-as found and as left tubes with TEC indications., number of ass found and as left T[C indications, the number of as found and as left TEC indications as a function of tubesheet radius, the as found, as left, probability of detection and new T[C leakage for upper and lower tubesheet indications. Th-e projected accident leakage and an assessment of growt for TEC indications will be provided. An assessmento the adequacy of the predictive methodology in Addendum C to Topical Report flAW 2346P, Revision 0, including assessing the distribution of i~ndications found in ec OTSG to ensure the assumption regarding the similarity of-the distribution of indications remin consistent from one cyce! to the next and that the assumption o linear increase in leak rate remain valid.

Corrective actions in the event that tthe assessment indicates the assumptions can not be fully supported.

Crystal River Unit 3 5.0-29 Amendment No. 2-2-3

PROGRESS ENERGY FLORIDA, INC.

CRYSTAL RIVER UNIT 3 DOCKET NUMBER 50-302 / LICENSE NUMBER DPR-72 LICENSE AMENDMENT REQUEST #298, Revision 0 Application to Modify Improved Technical Specifications For Replacement Steam Generators ATTACHMENT C Proposed Improved Technical Specification Changes (Revision Bar Format)

OTSG Tube Integrity 3.4.16 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.16 Steam Generator (OTSG)

Tube Integrity LCO 3,4.16 OTSG tube integrity shall be maintained.

AND All OTSG tubes satisfying the tube repair criteria shall be plugged in accordance with the Steam Generator Program.

APPLICABILITY:

MODES 1, 2,

3, and 4.

ACTIONS

NOTE----------------------------------

Separate Condition entry is allowed for each OTSG tube.

CONDITION REQUIRED ACTION COMPLETION TIME A.

One or more OTSG A.1 Verify tube integrity 7 days tubes satisfying the of the affected tube repair criteria tube(s) is maintained and not plugged in until the next accordance with the refueling outage or Steam Generator OTSG tube inspection.

Program.

AND A.2 Plug the affected Prior to entering tube(s) in accordance MODE 4 following with the Steam the next refueling Generator Program.

outage or OTSG tube inspection B.

Required Action and B.1 Be in MODE 3.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Compl eti on Time of Condition A AND not met.

B.2 Be in MODE 5.

36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months OR OTSG tube integrity not maintained.

Crystal River Unit 3 3.4-34 Amendment No.

OTSG Tube Integrity 3.4.16 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.16.1 Verify OTSG tube integrity in accordance In accordance with with the Steam Generator Program.

the Steam Generator Program SR 3.4.16.2 Verify that each inspected OTSG tube that Prior to entering satisfies the tube repair criteria is MODE 4 following a plugged in accordance with the Steam OTSG tube Generator Program.

inspection Crystal River Unit 3 3.4-35 Amendme'nt No.

Procedures, Programs and Manuals 5.6 5.6 Procedures, Programs and Manuals 5.6.2.10 Steam Generator (OTSG)

Program A Steam Generator Program shall be established and implemented to ensure that OTSG tube integrity is maintained.

In addition, the Steam Generator Program shall include the following provisions:

a.

Provisions for condition monitoring assessments.

Condition monitoring assessment means an evaluation of the "as found".

condition of the tubing with respect to the performance criteria for structural integrity and accident induced leakage.

The "as found" condition refers to the condition.

of the tubing during an OTSG inspection outage, as determined from the inservice inspection results or by other means, prior to the plugging of tubes.

Condition monitoring assessments shall be conducted during each outage during which the OTSG tubes are inspected and plugged to confirm that the performance criteria are being met.

b.

Performance criteria for OTSG tube integrity.

OTSG tube integrity shall be maintained by meeting the performance criteria for tube structural integrity, accident induced leakage, and operational LEAKAGE.

1.

Structural integrity performance criterion:

All in-service steam generator tubes shall retain structural integrity over the full range of normal operating conditions (including startup, operation in the power range, hot standby, and cool down and all anticipated transients included in the design specification) and design basis accidents.

This includes retaining a safety factor of 3.0 against burst under normal steady state full power operation primary-to-secondary pressure differential and a safety factor of 1.4 against burst applied to the design bas~is accident primary-to-secondary pressure differentials.

Apart from the above requirements, additional loading conditions. associated with the design basis accidents, or combination of accidents in accordance with the design and licensing basis, shall also be evaluated to determine if the associated loads contribute significantly to burst or collapse.

In the assessment of tube integrity, those loads that do significantly affect burst or collapse shall be determined and assessed in combination with the loads due'to pressure with a safety factor of 1.2 on the combined primary loads and 1.0 on axial secondary loads.

(continued)

Crystal River Unit 3 S.0-13 Amendment No.

Procedures, Programs and Manuals 5.6 5.6 Procedures, Programs and Manuals 5.6.2.10 OTSG Program (continued)

2.

Accident induced leakage performance criterion: The primary to secondary accident induced leakage rate for any design basis accident, other than an OTSG tube rupture, shall not exceed the leakage rate assumed in the accident analysis in terms of total leakage rate for all OTSGs and leakage rate for an individual OTSG.

Leakage is not to exceed one gallon per minute per OTSG.

3.

The operational LEAKAGE performance criterion is specified in LCO 3.4.12, "RCS Operational LEAKAGE."

c.

Provisions for OTSG tube repair criteria.

A tube found by inservice inspection to contain flaws with a depth equal to or exceeding 40% of the nominal tube wall thickness shall be plugged.

d.

Provisions for OTSG tube inspections.

Periodic OTSG tube inspections shall be performed.

The number and portions of the 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, from the tube-to-tubesheet weld at the tube inlet to the tube-to-tubesheet weld at the tube outlet, and that may satisfy the applicable tube repair criteria.

The tube-to-tubesheet weld is not part of the tube.

In addition to meeting the requirements of d.1 through d.3 below, the inspection scope, inspection methods, and inspection intervals shall be such as to ensure that OTSG tube integrity is maintained until the next OTSG inspection.

An assessment of degradation shall be performed to determine the type and location of flaws to which the tubes may be susceptible and, based on this assessment, to determine which inspection methods need to be employed and at what locations.

1.

Inspect 100% of the tubes in each OTSG during the first refueling outage following OTSG replacement.

2.

Inspect 100% of the tubes at sequential periods of 144, 108, 72, and, thereafter, 60 effective full power months.

The first sequential period shall be considered to begin after the first inservice inspection of the OTSGs.

In addition, inspect 50% of the tubes by the refueling outage nearest the midpoint (continued)

Crystal River Unit 3 S.0-14 Amendment No.

Procedures, Programs and Manuals 5.6 5.6 Procedures, Programs and Manuals 5.6.2.10 OTSG Program (continued) of the period and the remaining 50% by the refueling outage nearest the end of the period.

No OTSG shall operate for more than 72 effective full power months or three refueling outages (whichever is less) without being inspected.

3.

If crack indications are found in any OTSG tube, then the next inspection for each OTSG for the degradation mechanism that caused the crack indication shall not exceed 24 effective full power months or one refueling outage (whichever is less).

If definitive information, such as from examination of a pulled tube, diagnostic non-destructive testing, or engineering evaluation indicates that a crack-like indication is not associated with a crack(s), then the :indication need not be treated as a crack.

e.

Provisions for monitoring operational primary to secondary LEAK Crystal River Unit 3 (continued)

Amendment No.

5.0-15

Procedures, Programs and Manuals 5.6 THIS PAGE INTENTIONALLY LEFT BLANK Crystal River Unit 3 5.0-16 Amendment No.

Procedures, Programs and Manuals 5.6 THIS PAGE INTENTIONALLY LEFT BLANK Crystal River Unit 3 5.0-17 Amendment No.

Reporting Requirements 5.7 5.7 Reporting Requirements 5.7.2 Special Reports (continued)

5.

Number of tubes plugged during the inspection outage for each active degradation mechanism,

6.

Total number and percentage of tubes plugged to date,

7.

The results of condition monitoring, including the results of tube pulls and in-situ testing,

8.

The effective plugging percentage for all plugging in each OTSG.

Crystal River Unit 3 S.0-29 Amendment No.

PROGRESS ENERGY FLORIDA, INC.

CRYSTAL RIVER UNIT 3 DOCKET NUMBER 50-302 / LICENSE NUMBER DPR-72 LICENSE AMENDMENT REQUEST #298, Revision 0 Application to Modify Improved Technical Specifications For Replacement Steam Generators ATTACHMENT D Proposed Improved Technical Specification Bases Pages (Mark-up)

StP4ee*t4e*x indicates deleted text.

Ljghlighted tex* indicates added text.

OTSG Tube Integrity B 3.4.16 BASES BACKGROUND performance criteria are described in Specification (continued) 5.6.2.10.

Meeting the OTSG performance criteria provides reasonable assurance of maintaining tube integrity at normal and accident conditions.

The processes used to meet the OTSG performance criteria are defined by the Steam Generator Program Guidelines (Ref.

1).

APPLICABLE SAFETY ANALYSES The steam generator tube rupture (SGTR) accident is the limiting design basis event for OTSG tubes and avoiding an SGTR is the basis for this Specification.

The analysis of a SGTR event assumes a bounding primary to secondary LEAKAGE rate equal to the operational LEAKAGE rate limits in LCO 3.4.12, "RCS Operational LEAKAGE,"

plus the leakage rate associated with a double-ended rupture of a single tube.

The accident analysis for a SGTR assumes the contaminated secondary fluid is only briefly released to the atmosphere via safety valves and the majority is discharged to the main condenser.

The analysis for design basis accidents and transients other than a SGTR assume the OTSG tubes retain their structural integrity (i.e., they are assumed not to rupture).

In these analyses, the steam discharge to the atmosphere is based on the total primary to secondary LEAKAGE from all OTSGs of one gallon per minute or is assumed to increase to one gallon per minute as a result of accident induced conditions.

For accidents that do not involve fuel damage, the primary coolant activity level of DOSE EQUIVALENT 1-131 is assumed to be equal to. the LCO 3.4.15, "RCS Specific Activity," limits.

For accidents that assume fuel damage, the primary coolant activity is a

function of the amount of activity released from the damaged fuel.

The dose consequences of these events are within the limits of GDC 19 (Ref. 2),

10 CFR 50.67 (Ref.

3) or the NRC approved licensing bases (e.g., a small fraction of these limits).

Steam generator tube integrity satisfies Criterion 2 of 10 CFR 50.36(c)(2)(ii).

LCO The LCO requires that OTSG tube integrity be maintained.

The LCO also requires that all OTSG tubes that satisfy the repair criteria be plugged or-repa*i in accordance with the Steam Generator Program.

(continued)

Crystal River Unit 3 B 3.4-76 Revision No. -&S

OTSG Tube Integrity B 3.4.16 BASES LCO During an OTSG inspection, any inspected tube that (continued) satisfies the Steam Generator Program repair criteria is rep-ai-red or-removed from service by plugging.

If a tube was determined to satisfy the repair criteria but was not plugged o-r repared, the tube may still have tube integrity.

In the context of this Specification, an OTSG tube is defined as the entire length of the tube, incl uding the tube wall and any repairs made to it, between the tube-to-tubesheet weld at the tube inlet and the tube-to-tubesheet weld at the tube outlet.

The tube-to-tubesheet weld is not considered part of the tube.

An OTSG tube has tube integrity when it satisfies the OTSG performance criteria.

The OTSG performance criteria are defined in Specification 5.6.2.10, "Steam Generator Program," and describe acceptable OTSG tube performance.

The Steam Generator Program also provides the evaluation process for determining conformance with the OTSG performance criteria.

There are three OTSG performance criteria: structural integrity, accident induced leakage, and operational LEAKAGE.

Failure to meet any one of these criteria is considered failure to meet the LCO.

The structural integrity performance criterion provides a margin of safety against tube burst or collapse under normal and accident conditions, and ensures structural integrity of the OTSG tubes under all anticipated transients included in the design specification.

Tube burst is defined as, "The gross structural failure of the tube wall.

The condition typically corresponds to an unstable opening displacement (e.g., opening area increased in response to constant pressure) accompanied by ductile (plastic) tearing of the tube material at the ends of the degradation."

Tube collapse is defined as, "For the load displacement curve for a given structure, collapse occurs at the top of the load versus displacement curve where the slope of the curve becomes zero."

The structural integrity performance criterion provides guidance on assessing loads that have a significant effect on burst or collapse.

In that context, the term "significant" is defined as "An accident loading condition other than differential pressure (continued)

Crystal River Unit 3 B 3.4-77 Revision No. -&5

OTSG Tube Integrity B 3.4.16 BASES APPLICABILITY Steam generator tube integrity is challenged when the pressure differential across the tubes is large.

Large differential pressures across OTSG tubes can only be experienced in MODE 1, 2,

3, or 4.

RCS conditions are far less challenging in MODES 5 and 6 than during MODES 1, 2,

3, and 4.

In MODES 5 and 6, primary to secondary differential pressure is

low, resulting in lower stresses and reduced potential for LEAKAGE.

ACTIONS The ACTIONS are modified by a Note clarifying that the Conditions may be entered independently for each OTSG tube.

This is acceptable because the Required Actions provide appropriate compensatory actions for each affected OTSG tube.

Complying with the Required Actions may allow for continued operation, and subsequent affected OTSG tubes are governed by subsequent Condition entry and application of associated Required Actions.

A.1 and A.2 Condition A applies if it is discovered that one or more OTSG tubes examined in an inservice inspection satisfy the tube repair criteria but were not plugged owr --

-d in accordance with the Steam Generator Program as required by SR 3.4.16.2.

An evaluation of OTSG tube integrity of the affected tube(s) must be made.

Steam generator tube integrity is based on meeting the OTSG performance criteria described in the Steam Generator Program.

The OTSG repair criteria define limits on OTSG tube degradation that allow for flaw growth between inspections while still providing assurance that the OTSG performance criteria will continue to be met.

In order to determine if an OTSG tube that should have been plugged or-repaired has tube integrity, an evaluation must be completed that demonstrates that the OTSG performance criteria will continue to be met until the next refueling outage or OTSG tube inspection.

The tube integrity determination is based on the estimated condition of the tube at the time the situation is discovered and the estimated growth of the degradation prior to the next OTSG tube inspection.

If it is determined that tube integrity is not being maintained, Condition B applies.

(continued)

Crystal River Unit 3 B 3.4-79 Revision No. 6-5

OTSG Tube Integrity B 3.4.16 BASES ACTIONS A.1 and A.2 (continued)

A Completion Time of 7 days is sufficient to complete the evaluation while minimizing the risk of plant operation with an OTSG tube that may not have tube integrity.

If the evaluation determines that the affected tube(s) have tube integrity, Required Action A.2 allows plant operation to continue until the next refueling outage or OTSG inspection provided the inspection interval continues to be supported by an operational assessment that reflects the affected tubes.

However, the affected tube(s) must be plugged-rrWp-ai-red prior to entering MODE 4 following the next refueling outage or OTSG inspection.

This Completion Time is acceptable since operation until the next inspection is supported by the operational assessment.

B.1 and B.2 If the Required Actions and associated Completion Times of Condition A are not met or if OTSG tube integrity is not being maintained, the reactor must be brought to MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and MODE 5 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months .

The allowed Completion Times are reasonable, based on operating experience, to reach the desired plant conditions from full power conditions in an orderly manner and without challenging plant systems.

SURVEILLANCE SR 3.4.16.1 REQUIREMENTS During shutdown periods the OTSGs are inspected as required by this SR and the Steam Generator Program.

NEI 97-06, Steam Generator Program Guidelines (Ref. 1),

and its referenced EPRI Guidelines, establish the content of the Steam Generator Program.

Use of the Steam Generator Program ensures that the inspection is appropriate and consistent with accepted industry practices.

During OTSG inspections a condition monitoring assessment of the OTSG tubes is performed.

The condition monitoring assessment determines the "as found" condition of the OTSG tubes.

The purpose of the condition monitoring assessment is to ensure that the OTSG performance criteria have been met-for the previous operating period.

(continued)

Crystal River Unit 3 B 3.4-80 Revision No. 6-5

OTSG Tube Integrity B 3.4.16 BASES SURVEILLANCE SR 3.4.16.1 (continued)

REQUIREMENTS The Steam Generator Program determines the scope of the inspection and the methods used to determine whether the tubes contain flaws satisfying the tube repair criteria.

Inspection scope (i.e., which tubes or areas of tubing within the OTSG are to be inspected) is a function of existing and potential degradation locations.

The Steam Generator Program also specifies the inspection methods to be used to find potential degradation.

Inspection methods are a function of degradation morphology, non-destructive examination (NDE) technique capabilities, and inspection locations.

The Steam Generator Program defines the Frequency of SR 3.4.16.1.

The Frequency is determined by the operational assessment and other limits in the OTSG examination guidelines (Ref.

6).

The Steam Generator Program uses information on existing degradations and growth rates to determine an inspection Frequency that provides reasonable assurance that the tubing will meet the OTSG performance criteria at the next scheduled inspection.

In addition, Specification 5.6.2.10 contains prescriptive requirements concerning inspection intervals to provide added assurance that the OTSG performance criteria will be met between scheduled inspections.

SR 3.4.16.2 During an OTSG inspection, any inspected tube that satisfies the Steam Generator Program repair criteria is repaired or removed from service by plugging.

The tube repair criteria delineated in Specification 5.6.2.10 are intended to ensure that tubes accepted for continued service satisfy the OTSG performance criteria with allowance for error in the flaw size measurement and for future flaw growth.

In addition, the tube repair criteria, in conjunction with other elements of the Steam Generator Program, ensure that the OTSG performance criteria will continue to be met until the next inspection of the subject tube(s).

Reference 1 provides guidance for performing operational assessments to verify that the tubes remaining in service will continue to meet the OTSG performance criteria.

Steam generator tube repairs are only performed using approved, reai.mthods as desribed in the Steam Generator (rorafnin-(conti nued)

Crystal River Unit 3 B 3.4-81 Revision No.

6-5

OTSG Tube Integrity B 3.4.16 BASES SURVEILLANCE SR 3.4.16.2 (continued)

REQUIREMENTS The Frequency of prior to entering MODE 4 following a OTSG inspection ensures that the Surveillance has been completed and all tubes meeting the repair criteria are plugged or frepaired prior to subjecting the OTSG tubes to significant primary to secondary pressure differential.

REFERENCES

1.

NEI 97-06, "Steam Generator Program Guidelines."

2.

10 CFR 50 Appendix A, GDC 19.

3.

10 CFR 50.67.

4.

ASME Boiler and Pressure Vessel Code,Section III, Subsection NB.

5.

Draft Regulatory Guide 1.121, "Basis for Plugging Degraded Steam Generator Tubes," August 1976.

6.

EPRI, "Pressurized Water Reactor Steam Generator Examination Guidelines."

Crystal River Unit 3 B 3.4-82 Revision No. ý&5

PROGRESS ENERGY FLORIDA, INC.

CRYSTAL RIVER UNIT 3 DOCKET NUMBER 50-302 / LICENSE NUMBER DPR-72 LICENSE AMENDMENT REQUEST #298, Revision 0 Application to Modify Improved Technical Specifications For Replacement Steam Generators ATTACHMENT E Proposed Improved Technical Specification Bases Pages (Revision Bar Format)

OTSG Tube Integrity B 3.4.16 BASES BACKGROUND performance criteria are described in Specification (continued) 5.6.2.10.

Meeting the OTSG performance criteria provides reasonable assurance of maintaining tube integrity at normal and accident conditions.

The processes used to meet the OTSG performance criteria are defined by the Steam Generator Program Guidelines (Ref.

1).

APPLICABLE SAFETY ANALYSES The steam generator tube rupture (SGTR) accident is the limiting design basis event for OTSG tubes and avoiding an SGTR is the basis for this Specification.

The analysis of a SGTR event assumes a bounding primary to secondary LEAKAGE rate equal to the operational LEAKAGE rate limits in LCO 3.4.12, "RCS Operational LEAKAGE,"

plus the leakage rate associated with a double-ended rupture of a single tube.

The accident analysis for a SGTR assumes the contaminated secondary fluid is only briefly released to the atmosphere via safety valves and the majority is discharged to the main condenser.

The analysis for design basis accidents and transients other than a SGTR assume the OTSG tubes retain their structural integrity (i.e., they are assumed not to rupture).

In these analyses, the steam discharge to the atmosphere is based on the total primary to secondary LEAKAGE from all OTSGs of one gallon per minute or is assumed to increase to one gallon per minute as a result of accident induced conditions.

For accidents that do not involve fuel damage, the primary coolant activity level of DOSE EQUIVALENT 1-131 is assumed to be equal to the LCO 3.4.15, "RCS Specific Activity," limits.

For accidents that assume fuel damage, the primary coolant activity is a function of the amount of activity released from the damaged fuel.

The dose consequences of these events are within the limits of GDC 19 (Ref. 2),

10 CFR 50.67 (Ref.

3) or the NRC approved licensing bases (e.g., a small fraction of these limits).

Steam generator tube integrity satisfies Criterion 2 of 10 CFR 50.36(c)(2)(ii).

LCO The LCO requires that OTSG tube integrity be maintained.

The LCO also requires that all OTSG tubes that satisfy the repair criteria be plugged in accordance with the Steam Generator Program.

(continued)

Crystal River Unit 3 B 3.4-76 Revision No.

OTSG Tube Integrity B 3.4.16 BASES LCO During an OTSG inspection, any inspected tube that (continued) satisfies the Steam Generator Program repair criteria is removed from service by plugging.

If a tube was determined to satisfy the repair criteria but was not plugged, the tube may still have tube integrity.

In the context of this Specification, an OTSG tube is defined as the entire length of the tube, including the tube wall, between the tube-to-tubesheet weld at the tube inlet and the tube-to-tubesheet weld at the tube outlet.