L-PI-12-054, Application to Revise Technical Specifications Associated with Steam Generator Replacement and Adopt TSTF-510, Revision to Steam Generator Program Inspection Frequencies and Tube Sample Selection

Application to Revise Technical Specifications Associated with Steam Generator Replacement and Adopt TSTF-510, Revision to Steam Generator Program Inspection Frequencies and Tube Sample Selection

ML12207A522
Person / Time
Site:	Prairie Island
Issue date:	07/25/2012
From:	Molden J Northern States Power Co, Xcel Energy
To:	Office of Nuclear Reactor Regulation, Document Control Desk
References
L-PI-12-054, TSTF-510
Download: ML12207A522 (49)

Text

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/ Xcel EnergyB L-PI-12-054 10 CFR 50.90 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Prairie Island Nuclear Generating Plant, Units 1 and 2 Dockets 50-282 and 50-306 Renewed License Nos. DPR-42 and DPR-60 Application to Revise Technical Specifications Associated with Unit 2 Steam Generator Replacement and Adopt TSTF-510, "Revision to Steam Generator Proaram lnspection Frequencies and Tube Sample Selection" Pursuant to 10 CFR 50.90, the Northern States Power Company, a Minnesota Corporation (NSPM), doing business as Xcel Energy, hereby requests an amendment to the renewed operating licenses for Prairie Island Nuclear Generating Plant (PINGP)

Units Iand 2. Specifically, NSPM proposes to revise Technical Specifications (TS) 3.4.19 - "Steam Generator (SG) Tube Integrity," 5.5.8 - "Steam Generator (SG)

Program," and 5.6.7 - "Steam Generator Tube lnspection Report" to apply the appropriate program attributes to the Unit 2 replacement steam generators that are planned for installation in fall 201 3. Also, NSPM proposes to revise the same TS described above to adopt for Unit 1 and Unit 2 the program improvements in Technical Specifications Task Force Traveler (TSTF) 510, Revision 2, "Revision to Steam Generator Program lnspection Frequencies and Tube Sample Selection." The availability of this TS improvement was announced in the Federal Register (FR) on October 27, 201 1 (76 FR 66763). to this letter provides the evaluation of the proposed TS changes and the supporting justification, including a no significant hazards determination. Enclosure 2 provides the existing TS pages marked-up to show the proposed changes. Enclosure 3 provides the revised TS pages incorporating the proposed changes. Enclosure 4 provides, for information only, the existing TS Bases pages marked-up to show the associated proposed Bases changes. Final TS Bases changes will be implemented pursuant to TS 5.5.12, "Technical Specifications (TS) Bases Control Program," at the time the amendment is implemented.

NSPM has determined that the information for the proposed amendment does not involve a significant hazards consideration, authorize a significant change in the types or total amounts of effluent release, or result in any significant increase in individual or cumulative occupational radiation exposure. Therefore, the proposed amendment meets the categorical exclusion requirements of 10 CFR 51.22(~)(9)and an environmental impact assessment need not be prepared.

1717 Wakonade Drive East e Welch, Minnesota 55089-9642 Telephone: 651.388.1121

Document Control Desk Page 2 A copy of this submittal, including the Determination of No Significant Hazards Consideration is being forwarded to the designated State of Minnesota official pursuant to 10 CFR 50.91(b)(l).

NSPM is requesting that this proposed amendment be approved by August 1,2013 to support the steam generator replacement currently scheduled for the fall of 201 3. Once approved, the amendment shall be implemented within 60 days after reactor startup following Unit 2 steam generator replacements.

If there are any questions or if additional information is needed, please contact Glenn Adams at 612-330-6777.

Summarv of Commitments This letter contains no new commitments or revisions to existing commitments.

I declare under penalty of perjury that the foregoing is true and correct.

Executed on JUL 2 5 2012 James E. Molden C / S i t e Vice President, Prairie Island Nuclear Generating Plant Northern States Power Company - Minnesota Enclosures (4) cc: Regional Administrator, Region Ill, USNRC Project Manager, Prairie Island Nuclear Generating Plant, USNRC Resident Inspector, Prairie Island Nuclear Generating Plant, USNRC State of Minnesota

ENCLOSURE 1 Evaluation of the Proposed Change Application to Revise Technical Specifications Associated with Unit 2 Steam Generator Replacement and Adopt TSTF-510, "Revision to Steam Generator Program Inspection Frequencies and Tube Sample Selection" 1.0

SUMMARY

DESCRIPTION 2.0 DETAILED DESCRIPTION

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory RequirementsICriteria 4.2 Precedent 4.3 Significant Hazards Consideration 4.4 Conclusions

5.0 ENVIRONMENTAL CONSIDERATION

S

6.0 REFERENCES

Page 1 of 11 NSPM Steam Generator Program Changes 1.0

SUMMARY

DESCRIPTION Pursuant to 10 CFR 50.90, the Northern States Power Company, a Minnesota Corporation (NSPM), doing business as Xcel Energy, hereby requests an amendment to the renewed operating licenses for Prairie Island Nuclear Generating Plant (PINGP) Units 1 and 2. Specifically, NSPM proposes to revise Technical Specifications (TS) 3.4.19 - "Steam Generator (SG) Tube Integrity,"

5.5.8 - "Steam Generator (SG) Program," and 5.6.7 - "Steam Generator Tube lnspection Report" to apply the appropriate program attributes to the Unit 2 replacement steam generators that are planned for installation in fall 2013. Also, NSPM proposes to revise the same TS described above to adopt the program improvements in Technical Specifications Task Force Traveler (TSTF) 510, Revision 2, "Revision to Steam Generator Program lnspection Frequencies and Tube Sample Selection."

NSPM is requesting that this license amendment request (LAR) be approved prior to the Unit 2 steam generator replacement currently scheduled for the fall of 2013.

2.0 DETAILED DESCRIPTION A brief description of the proposed change is provided below. The specific wording changes to the Technical Specifications (TS) are provided in Enclosures 2 and 3.

Revise TS 3.4.19 for Steam Generator Replacement (SGR) and TSTF-510 The proposed change to TS 3.4.19 would remove any reference to steam generator tube "repair" to align with the planned removal of the Unit 2 original steam generators (OSGs), which do have approved repair methods. After installation of the Unit 2 replacement steam generators (RSGs), none of the PINGP Unit 1 or Unit 2 SGs will have approved repair criteria, so the proposed revision to TS 3.4.19 will only provide for steam generator tube plugging. The proposed change to TS 3.4.19 will also make editorial changes in accordance with TSTF-510.

Revise TS 5.5.8 for SGR and TSTF-510 The proposed change to TS 5.5.8 would remove any reference to steam generator tube "repair" to align with the planned removal of the Unit 2 OSGs, which do have approved repair methods. After installation of the Unit 2 RSGs, none of the PINGP SGs will have approved repair criteria, so the proposed revision to TS 5.5.8 will only provide for steam generator tube plugging. The proposed change to TS 5.5.8 will change the steam generator tube inservice inspection frequencies and make editorial changes in accordance with TSTF-510.

Page 2 of 11 NSPM Steam Generator Program Changes The proposed change to TS 5.5.8 would eliminate those repair and inspection provisions associated with the Unit 2 OSGs including voltage-based repair criteria, specific depth-based repairlplugging criteria, alternate repair criteria, and sleeving repairs. The proposed change subjects the Unit 2 RSG tubes to the same inspection and testing requirements that are applied to the Unit 1 RSGs.

Revise TS 5.6.7 for SGR and TSTF-510 The proposed change to TS 5.6.7 would remove any reference to steam generator tube "repair" to align with the planned removal of the Unit 2 OSGs, which do have approved repair methods. After installation of the Unit 2 RSGs, none of the PlNGP SGs will have approved repair criteria, so the proposed revision to TS 5.6.7 will only provide for steam generator tube plugging. The proposed change to TS 5.6.7 will change the steam generator tube reporting requirements and make editorial changes in accordance with TSTF-510.

The proposed change to TS 5.6.7 would eliminate those reporting provisions associated with the Unit 2 OSGs, particularly those associated with reporting flawed and unplugged tubes and special conditions associated with the use of alternate repair criteria. The proposed change subjects the Unit 2 RSGs to the same reporting requirements that are applied to the Unit 1 RSGs.

In summary, this LAR eliminates any reference to SG repair methods and adopts the NRC-approved inservice inspection frequencies, reporting requirements, and editorial changes in accordance with TSTF-510.

3.0 TECHNICAL EVALUATION

3.1

Background:

PlNGP is a dual unit site. Each unit is a two-loop Westinghouse design, licensed to an uprated power of 1677 megawatts-thermal (MWt). The units were originally provided with Westinghouse Model 51 steam generators having lnconel 600 mill annealed (MA) tube material. In 2004, the licensee replaced the OSGs in Unit 1 with steam generators fabricated by Framatome ANP having lnconel 690 thermally treated (TT) tube material. Presently, NSPM is preparing to replace the Unit 2 Westinghouse steam generators with AREVA (formerly Framatome ANP) models designed and fabricated to the same standards as the Unit Ireplacement steam generators having lnconel 690TT tube material. NSPM plans to install these replacement steam generators in fall 2013.

The following information concerning the RSGs is provided to support the NRC review of this LAR:

Page 3 of 11 NSPM Steam Generator Program Changes Unit 1 Unit 2 SG Manufacturer AREVA (Framatome-ANP)

SG Model 56119 Year of Installation 2004 2013 Tubing Material 690TT No. Tubes 1 SG 4868 Approved Alternate Repair Criteria None Approved SG Tube Repair Methods None NSPM's preliminary design review recognizes the similarity of the Unit 2 RSGs to the Unit 1 RSGs (as shown in the table above). Further, this preliminary design review indicates that the Unit 2 RSGs comport with the form, fit, and function of the OSGs that they replace and may be installed in accordance with 10 CFR 50.59.

3.2 Current Licensing Basis In 2007, NRC issued PlNGP license amendments 177 (Unit I ) and 167 (Unit 2) to revise TS 3.4.19, 5.5.8, and 5.6.7 in accordance with TSTF-449 (Reference 6.4).

These amendments provided a Steam Generator Program that prescribed inspection criteria, inspection frequency, and reporting rules for Unit 1 based on the replacement steam generator design (Inconel 690TT tubes) and a Unit 2 program based on the original steam generator design (Inconel 600MA tubes).

The Unit 2 program provides for steam generator repair, alternate repair criteria, and associated reporting requirements that are approved and applicable only to the Westinghouse OSGs that are currently installed in Unit 2. As described in Reference 6.3, the RSG design does not have any such repair criteria approved.

Therefore, the TS provide no alternate repair criteria and no associated reporting requirements for the RSG design.

3.3 Justification for the Proposed Changes This LAR adopts TSTF-510 and revises the Steam Generator Program to recognize the Unit 2 replacement steam generator design. These changes are consistent with the intent of TSTF-449, which was to establish Steam Generator Program inspection and reporting criteria that are applicable to the respective steam generator design. Following the Unit 2 steam generator replacement, all four PlNGP SGs will be of AREVNFramatome ANP design having lnconel690TT tube material. Such SGs do not have approved methods for "repair" (as described in TSTF-449). Therefore, the proposed changes are appropriate and justified in that they eliminate all inspection and repair criteria associated with the OSGs.

Following implementation of the Unit 2 SGR, none of the PlNGP SGs will have approved repair criteria.

Justifications for specific TS changes are described below:

Revise TS 3.4.19 for SGR and TSTF-510 Page 4 of 11 NSPM Steam Generator Program Changes The removal of all reference to tube repair is appropriate because the only PlNGP SGs with approved repair criteria are being replaced with steam generators without approved repair criteria.

The TSTF-510 editorial changes (to Improved Standard Technical Specification

- ISTS Section 3.4.20) are justified as generic changes applicable to PINGP, and are adopted for PlNGP TS Section 3.4.19 without alteration.

e Revise TS 5.5.8 for SGR and TSTF-510 The removal of all reference to tube repair is appropriate because the only PlNGP SGs with approved repair criteria are being replaced with steam generators without approved repair criteria.

The TSTF-510 changes to inservice testing methods, testing frequency, and editorial changes (per ISTS Section 5.5.9) are justified as generic changes applicable to PINGP, and are adopted for PINGP TS Section 5.5.8 without alteration.

e Revise TS 5.6.7 for SGR and TSTF-510 The removal of all reference to reporting tube repair is appropriate because the only PlNGP SGs with approved repair criteria are being replaced with steam generators without approved repair criteria.

The TSTF-510 changes to reporting requirements, and the associated editorial changes (per ISTS Section 5.6.7) are justified as generic changes applicable to PINGP, and are adopted for PINGP TS Section 5.6.7 without alteration.

3.4 TSTF-510 Assessment Applicabilitv of Published Safetv Evaluation: NSPM has reviewed TSTF-510, Revision 2, "Revision to Steam Generator Program Inspection Frequencies and Tube Sample Selection," and the model safety evaluation dated June 20, 201 1 as part of the Federal Register Notice for Comment. As described in Section 3.3, NSPM has concluded that the justifications presented in TSTF-510 and the model safety evaluation prepared by the NRC staff are applicable to Prairie Island Units 1 and 2, and justify this amendment for the incorporation of the changes to the PlNGP TS.

The Traveler and model Safety Evaluation discuss the applicable regulatory requirements and guidance, including the 10 CFR 50, Appendix A General Design Criteria (GDC). PlNGP was not licensed to the 10 CFR 50, Appendix A GDC. The PlNGP equivalent of the referenced GDC are PlNGP GDCs 1, 9, 16, and 36 described in USAR Sections 4. I .1, 4.1.2.1, 4.1.2.2, and 4.7 respectively. This Page 5 of 11 NSPM Steam Generator Program Changes difference does not alter the conclusion that the proposed change is applicable to PINGP.

Optional Changes and Variations: The PlNGP TS utilize different numbering than the Standard Technical Specifications on which TSTF-510 was based.

Specifically, the PlNGP TS 3.4.19 embodies Steam Generator (SG) Tube Integrity, whereas the Standard Technical Specification is numbered 3.4.20. Also, the PlNGP TS 5.5.8 embodies the Steam Generator (SG) Program, whereas the Standard Technical Specification is numbered 5.5.9. These differences are administrative and do not affect the applicability of TSTF-510 to the PlNGP TS.

The proposed change corrects an administrative inconsistency in TSTF-510, Paragraph d.2 of the Steam Generator Tube lnspection Program. In Section 2.0, "Proposed Change," TSTF-510 states that references to "tube repair criteria" in Paragraph d are revised to "tube plugging [or repair] criteria." However, in the following sentence in Paragraph d.2, this change was inadvertently omitted, "If a degradation assessment indicates the potential for a type of degradation to occur at a location not previously inspected with a technique capable of detecting this type of degradation at this location and that may satisfy the applicable tube repair criteria, the minimum number of locations inspected with such a capable inspection technique during the remainder of the inspection period may be prorated" (emphasis added).

After installation of the Unit 2 RSGs, the PlNGP SGs do not have approved tube repair criteria. Therefore, the sentence is revised to state "tube plugging" criteria.

3.5 Conclusion As discussed in the preceding paragraphs, the proposed changes to the SG Program Technical Specifications are justified because they align the SG Program requirements with the planned steam generator configuration, and because they adopt the TSTF-510 SG Program improvements in accordance with the TSTF model safety evaluation with minor administrative changes.

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirementslcriteria PlNGP TS 3.4.19, 5.5.8, and 5.6.7 establish Steam Generator Program requirements that differentiate between the OSGs (Inconel 600MA tubes) and RSGs (Inconel 690TT tubes).

Technical Specifications Task Force Traveler (TSTF) 510, Revision 2, "Revision to Steam Generator Program lnspection Frequencies and Tube Sample Selection" has been approved and the NRC has announced the availability of this TS improvement in the Federal Register (FR) on October 27, 201 1 (76 FR 66763).

Page 6 of 11 NSPM Steam Generator Program Changes Subsequently, the Technical Specifications Task Force has notified NRC of a correction to TSTF-510 and proposed an explanation to be provided in license amendment requests (Reference 6.11). This explanation is provided in Section 3.4 above.

Further, the TSTF has recently recommended that LARS include a discussion similar to the example provided in Reference 6.13 when the 10 CFR 50 Appendix A GDCs in a Traveler's model Safety Evaluation (SE) are not consistent with the plant's licensing basis.

4.2 Precedent Similar changes to remove alternate repair criteria were approved for PINGP Unit 1 (Reference 6.4), and as part of other SG replacements that have been previously sought and approved. One recent example was performed for Progress Energy's Crystal River Nuclear Plant, which the NRC approved on May 29, 2009 (Reference 6.7).

NSPM is not aware of any amendments approved pursuant to TSTF-510, Revision 2; however, NSPM does recognize that Entergy has submitted and NRC accepted a license amendment request for Waterford requesting adoption of TSTF-510 improvements as a plant-specific change as opposed to a Consolidated Line Item Improvement Process (CLIIP) change (because the TSTF had not been approved at the time of submittal). See Reference 6.8.

Additionally, amendment requests applying CLllP were recently submitted for Wolf Creek (Reference 6.9), Byron-Braidwood (Reference 6.10), and Three Mile Island (Reference 6.12).

4.3 Significant Hazards Consideration Northern States Power Company, a Minnesota Corporation (NSPM), doing business as Xcel Energy, proposes to amend the facility operating license of Prairie Island Nuclear Generating Plant (PINGP) Units 1 and 2. The purpose of this amendment is to modify the PINGP Technical Specifications (TS) to maintain the intent of the steam generator program following the Unit 2 steam generator replacement. Further, for the benefit of PINGP Units Iand 2, NSPM requests adoption of an approved change to the standard technical specifications (STS) into the plant specific technical specifications (TS), to revise the Specification 5.5.8, "Steam Generator (SG) Program," 5.6.7, "Steam Generator Tube Inspection Report," and Limiting Condition for Operation (LCO) 3.4.19, "Steam Generator Tube Integrity," to address inspection periods and other administrative changes and clarifications.

Page 7 of 11 NSPM Steam Generator Program Changes NSPM has evaluated whether or not a significant hazards consideration is involved with the proposed changes by focusing on the three standards set forth in 10 CFR 50.92(c) 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 proposed changes associated with Technical Specification Task Force Traveler (TSTF) 510 revise the Steam Generator (SG) Program to modify the frequency of verification of SG tube integrity and SG tube sample selection. A steam generator tube rupture (SGTR) event is one of the design basis accidents that are analyzed as part of a plant's licensing basis. The proposed SG tube inspection frequency and sample selection criteria will continue to ensure that the SG tubes are inspected such that the probability of a SGTR is not increased, The consequences of a SGTR are bounded by the conservative assumptions in the design basis accident analysis. The proposed change will not cause the consequences of a SGTR to exceed those assumptions.

The proposed changes associated with Unit 2 SG replacement preserve the intent of the PlNGP TS for the new plant configuration following Unit 2 steam generator replacement. In effect, these changes will eliminate the SG tube repair criteria that were only applicable to the original SGs that will be replaced.

These changes will ensure that the Unit 2 replacement SGs are subject to the inservice inspection, testing, and reporting criteria that are applicable to their design as approved for use with TSTF-510.

Therefore, it is concluded that this change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

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

Response: No The proposed changes to the Steam Generator Program associated with TSTF-510 will not introduce any adverse changes to the plant design basis or postulated accidents resulting from potential tube degradation. The proposed change does not affect the design of the SGs or their method of operation. In addition, the proposed change does not impact any other plant system or component.

The proposed changes associated with Unit 2 SG replacement preserve the intent of the PlNGP TS for the new plant configuration following Unit 2 steam Page 8 of 11 NSPM Steam Generator Program Changes generator replacement. In effect, these changes will eliminate the SG tube repair criteria that were only applicable to the original SGs that will be replaced.

Such programmatic changes do not affect the design of the SGs or their method of operation. In addition, these programmatic changes do not impact any other plant system or component.

Therefore, it is concluded that this change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

3. Do the proposed changes involve a significant reduction in a margin of safety?

Response: No The SG tubes in pressurized water reactors are an integral part of the reactor coolant pressure boundary and, as such, are relied upon to maintain the primary system's pressure and inventory. As part of the reactor coolant pressure boundary, the SG tubes are unique in that they are also relied upon as a heat transfer surface between the primary and secondary systems such that residual heat can be removed from the primary system. In addition, the SG tubes also isolate the radioactive fission products in the primary coolant from the secondary system. In summary, the safety function of a SG is maintained by ensuring the integrity of its tubes.

Steam generator tube integrity is a function of the design, environment, and the physical condition of the tube. The proposed changes do not affect tube design or operating environment. The proposed changes will continue to require monitoring of the physical condition of the SG tubes such that there will not be a reduction in the margin of safety compared to the current requirements.

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

Based on the above, NSPM has concluded that the proposed amendment presents 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.

Page 9 of 11 NSPM Steam Generator Program Changes 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

S 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 change 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 change meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(~)(9).Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed change.

6.0 REFERENCES

6.1 Federal Register Notice, Notice of Availability published on October 27, 201 1 (76 FR 66763), Models for Plant-Specific Adoption of Technical Specifications Task Force Traveler TSTF-510, Revision 2, "Revision to Steam Generator Program lnspection Frequencies and Tube Sample Selection" 6.2 Technical Specifications Task Force Traveler TSTF-510, Revision 2, "Revision to Steam Generator Program lnspection Frequencies and Tube Sample Selection" (ADAMS Accession No. M L I 10610350) 6.3 NMC letter to NRC, L-HU-06-001, Application for Technical Specification Improvement Regarding Steam Generator Tube Integrity, dated February 16, 2006 (ADAMS Accession No. ML060480440) 6.4 NRC letter and safety evaluation for PINGP License Amendments 1771167 dated March 20,2007 (ADAMS Accession No. ML070330455) 6.5 Federal Register Notice, Notice for Comment published on June 20, 201 1 (76 FR 35923), Notice of Opportunity for Public Comment on the Proposed Model Safety Evaluation for Plant-Specific Adoption of Technical Specifications, Task Force Traveler TSTF-510, Revision 2, "Revision to Steam Generator Program lnspection Frequencies and Tube Sample Selection" Page 10 of 11 NSPM Steam Generator Program Changes 6.6 Technical Specifications Task Force Traveler TSTF-449, Revision 4, "Steam Generator Tube Integrity" (ADAMS Accession No. ML051090200) 6.7 NRC Amendment 234 issued to Progress Energy on May 29, 2009, Crystal River Unit 3, Issuance of Amendment Regarding the Revision of the Steam Generator Portion of the Technical Specifications to Reflect the Replacement of the Steam Generators (TAC No. MD9547). (ADAMS Accession No. ML091100056) 6.8 Entergy letter to NRC, License Amendment Request Technical Specification Change Regarding Steam Generator Tube Integrity Waterford Steam Electric Station, Unit 3, dated July 20, 2011. (ADAMS Accession No. MLI 1224A010) 6.9 Wolf Creek Nuclear Operating Corporation letter to NRC, Application to Revise Technical Specifications to Adopt TSTF-510, "Revision to Steam Generator Program lnspection Frequencies and Tube Sample Selection," Using the Consolidated Line Item Improvement Process, dated April 26, 2012. (ADAMS Accession No. MLI 2124A339) 6.10 Exelon letter to NRC, Application to Revise Technical Specifications to Adopt TSTF-510, Revision to Steam Generator Program lnspection Frequencies and Tube Sample Selection, dated March 22, 2012 (ADAMS Accession No. ML12082A135) 6.11 TSTF letter to NRC, Correction to TSTF-510A, Revision 2, Revision to Steam Generator Program lnspection Frequencies and Tube Sample Selection, dated March 28,2012 (ADAMS Accession No. ML12088A082) 6.12 Exelon letter to NRC, License Amendment Request to Revise Steam Generator Program lnspection Frequencies and Tube Sample Selection, dated March 26, 2012 (ADAMS Accession No. ML12086A037) 6.13 TSTF letter to NRC, TSTF-12-13, Response to NRC Request to Revise TSTF Traveler Model Applications, dated July 4, 2012 (ADAMS Accession No. ML12187A184)

Page I 1 of 11

Enclosure 2 Marked-Up Technical Specification Pages 14 pages follow

SG Tube Integrity 3.4.19 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.19 Steam Generator (SG) Tube Integrity LC0 3.4.19 SG tube integrity shall be maintained.

AND All SG tubes satisfying the tube a criteria shall be plugged in accordance with erator Program APPUCABLTIY MODES 1, 2, 3, and 4.

ACTIONS

---

NOTE..................................................

Separate Condition entry is allowed for each SG tube.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or more SG tubes A. 1 Verify tube integrity of the 7 days satisfying the tube affected tube(s) is maintained until the next refueling outage or SG inspection.

Generator Program. AND A.2 Plug the affected Prior to entering tube(s) in accordance with MODE 4 the Steam Generator following the Program. next refueling outage or SG tube inspection Prairie Island Unit 1 - Amendment No. 477 Units 1 and 2 3.4.19-1 Unit 2 - Amendment No. 4-67

SG Tube Integrity 3.4.19 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B. Required Action and B.l BeinMODE3. 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> associated Completion Time of Condition A not AND met.

B.2 Be in MODE 5. 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> SG tube integrity not maintained.

SURVEILLANCE REOUIREMENTS SURVEILLANCE I FREQUENCY SR 3.4.19.1 Verify SG tube integrity in accordance with the In accordance Steam Generator Program. with the Steam Generator Program SR 3.4.19.2 Verify that each inspected SG tube that satisfies the Prior to entering tube criteria is plugged in MODE4 accordance with the Steam Generator Program. following an SG tube inspection Prairie Island Unit 1 - Amendment No. 133 Units 1 and 2 3.4.19-2 Unit 2 - Amendment No. 4-67

Programs and Manuals 5.5 5.5 Programs and Manuals (continued) 5.5.8 Steam Generator (SG) Program A Steam Generator Program shall be established and implemented to ensure that SG tube integrity is maintained. In addition, the Steam Generator Program shall include the following

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 SG inspection outage, as determined from the inservice inspection results or by other means, prior to the plugging of tubes. Condition monitoring assessnlents shall be d during each outage during which the SG tubes are inspected; m l u g g e d to confirm that the performance criteria are being met.

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

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 downL transients included in the design specification,) and design basis accidents. This includes retaining a safety factor of 3.0 against 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.

Prairie Island Unit 1 - Amendment No. 4-58 177 Units 1 and 2 5.0-13 Unit 2 - Amendment No. 449 167

Progranls and Manuals 5.5 5.5 Programs and Manuals 5.5.8 Steam Generator (SG) Program (continued)

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

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

3. The operational LEAKAGE performance criterion is specified in L C 0 3.4.14, "RCS Operational LEAKAGE."

c. Provisions for SG tube criteria&+

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

Prairie Island Unit 1 - Amendment No. 458 177 Units 1 and 2 5.0-14 Unit 2 - Amendment No. 4-49 167

Programs and Manuals 5.5 5.5 Programs and Manuals Steam Generator (SG) Program (continued)

Prairie Island Unit 1 - Amendment No. 458 177 Units 1 and 2 5.0-15 Unit 2 - Amendment No. 449 167

Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.8 Steam Generator (SG) Program (continued)

Prairie Island Unit 1 - Amendment No. 42% 177 Units 1 and 2 5.0-16 Unit 2 - Amendment No. 44-9167

Programs and Manuals 5.5 5.5 Programs and Manuals Steam Generator (SG) Program (continued)

Prairie Island Unit 1 - Amendment No. 348 177 Units 1 and 2 5.0-17 Unit 2 - Amendment No. 349 167

Programs and Manuals 5.5 5.5 Programs and Manuals Steam Generator (SG) Program (continued)

d. Provisions for SG tube inspections. Periodic SG 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 craclts) 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 The tube-to-tubesheet weld is not part of the tube. In addition to meeting the requirements of d.1, d.2?& d.3 4

&below, the inspection scope, inspection methods, and inspection intervals shall be such as to ensure that SG tube integrity is maintained until the Prairie Island Unit 1 - Amendment No. 4.58 177 Units 1 and 2 5.0-18 Unit 2 - Amendment No. 4-49 167

Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.8 Steam Generator (SG) Program (continued) next SG inspection. A degradationassessii~er~t 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 SG during the first refueling outage following SG installation

2. After the first refueling outage followi 11.g SG installation. inspect each SG at least everv 72 effective full power rnonths or at least every third refueling outage (whichever results in more frequent inspections). In adclition, the niinimum nulnber of tubes insuected at each scheduled inspection shall be the ~ m l b e of r tubes in all SGs divided bv the number of SG inspecti011outag-es schecluled in each inspection period as defined in a, b. c and d below. If a degraclatiorl assessinetlt indicates the uotential for a tvpe of cle~radationto occur at a location not previously inspected wit11 a techniuue capable of detecting. tliis t y ~ of

- e de,~radationat tliis location and that may satisfv the auulical3le tube plu,wing criteria, z

the minirn~irnnumber of locations illspecled with s~rcha c a p a l k inspection techniclue during: the re~~~airrder of the inspectio~~period 111av be proratect. The fraction of locatioils to be inspected for Illis 13ote11tiaIt m e of cte_graclatio~~

at this location at the end of the illspection period shall be no less than the ratio of the nunlber of times the SG is scheclulecl to he ins?,ectecl in the inspection ~ ~ r i o d after the cleterminatioi~that a new for111of de.~radationcould j3otentiallv be occurring: at this location clivicled by the total nunlber of timmthe

- - -- SG is schedulecl to be inspec~edin the inspection period. Each inspalion period defi'jned below mav be extellcied

- ---u

-- -p @ 3 effective full power montlis to incl~~cle a SG inspectic111ouk~,ge ill %I i~lspectiol~period and the subsequent i~lspectioilperb~l belrins at the concl~rsioilof the i11cI~~clec1 SG inspection 0~1tag:e.

Prairie Island Unit 1 - Amendment No. 458 177 Units 1 and 2 5.0-19 Unit 2 - Amendment No. 4-49 167

Programs and Manuals 5.5 a)

- - After the first r.eftieling: outage following S(; installation, inspect 100% of the tubes ciuring the next 1-44.effectiveM1 power nlonths. This constitt~iesthe fjrst inspection period;

-- b'i D L I S ~the I I ~next 120 effective Still power mot~ths,i n s ~ e d

-100% of the tubes. This constj tutes the second inspection periocl;

--- -- c'i - During the next 96 effective f~flpowermonths. iilspect

-100%

- of the tubes, This conslitutes the thifcl inspection period: and

-- - d) During the 1-emaininglife of the SGs. ins13ect 100% ofthe tubes every.72 effectivef~~ll powex-rlliontlx. This constitt~tes the

-- fotirth argj subseauent inspectb~l periods.

Prairie Island Unit 1 - Amendment No. 34% 177 Units 1 and 2 5.O-20 Unit 2 - Amendment No. 4-49 167

Programs and Manuals 5.5 5.5 Programs and Manuals Steam Generator (SG) Program (continued) a.If crack indications are found in any SG tube, then the next inspection for each affected and potelltially affected SG for the degradation mechanism that caused the crack indication shall not exceed 24 effective full power months or one refueling outage (whichever results in illore frequent iilspectiorls ). 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 LEAKAGE, Prairie Island Unit 1 - Amendment No. 4-58 177 Units 1 and 2 5.0-21 Unit 2 - Amendment No. 44-9 167

Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.8 Steam Generator (SG) Program (continued)

Prairie Island Unit 1 - Amendment No. 45% 177 Units 1 and 2 5.0-22 Unit 2 - Amendment No. 449 167

Reporting Requirements 5.6 5.6 Reporting Requirements (continued) 5.6.7 Steam Generator Tube Inspection Report

+A report shall be submitted within 180 days after the initial entry into MODE 4 following completion of an inspection performed in accordance with the Specification 5.5.8, Steam Generator (SG)

Program. The report shall include:

-a&. The scope of inspections performed on each SG,

-172, -Ddegradation mechanisms found,

-c3. Nondestructive examination techniques utilized for each degradation mechanism,

-d4. Location, orientation (if linear), and measured sizes (if available) of service induced indications,

-e5. Number plugged using the inspection outage for each egradatio ,

-f6. The number ancl percenta.~e

- of tubes plugged to date. and the an ct

,=

g7. The results of condition monitoring, including the results of tube pulls and in-situ testing, Prairie Island Unit 1 - Amendment No. M 4-99 Units 1 and 2 5.0-39Unit 2 - Amendment No. 4-87

Reporting Requirements 5.6 5.6 Reporting Requirements Steam Generator Tube Inspection Report (continued) 5.6.8 EM Report When a report is required by Condition C or I of LC0 3.3.3, "Event Monitoring (EM) Instrumentation," a report shall be submitted within the following 14 days. The report shall outline the preplanned alternate method of monitoring, the cause of the inoperability, and the plans and schedule for restoring the instrumentation channels of the Function to OPERABLE status.

Prairie Island Unit 1 - Amendment No. 4-684TJ 49-9 Units 1 and 2 5.O-40 Unit 2 - Amendment No. 4-87

Enclosure 3 Retyped Technical Specification Pages 13 pages follow

SG Tube Integrity 3.4.19 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.19 Steam Generator (SG) Tube Integrity LC0 3.4.19 SG tube integrity shall be maintained.

AND All SG tubes satisfying the tube plugging criteria shall be plugged in accordance with the Steam Generator Program APPUCABILITY MODES 1, 2, 3, and 4.

ACTIONS

---

NOTE..................................................

Separate Condition entry is allowed for each SG tube.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or more SG tubes A. 1 Verify tube integrity of the 7 days satisfying the tube affected tube(s) is plugging criteria and not maintained until the next plugged in accordance refueling outage or SG with the Steam inspection.

Generator Program.

AND A.2 Plug the affected tube(s) in Prior to entering I accordance with the Steam MODE 4 Generator Program. following the next refueling outage or SG tube inspection Prairie Island Unit 1 - Amendment No. 4-77 Units 1 and 2 3.4.19-1 Unit 2 - Amendment No. 4-67

SG Tube Integrity 3.4.19 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B . Required Action and B.l BeinMODE3. 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> associated Completion Time of Condition A not AND met.

B.2 BeinMODE5. 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> SG tube integrity not maintained.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.19.1 Verify SG tube integrity in accordance with the In accordance Steam Generator Program. with the Steam Generator Program SR 3.4.19.2 Verify that each inspected SG tube that satisfies the Prior to entering tube plugging criteria is plugged in accordance with MODE 4 I the Steam Generator Program. following an SG tube inspection Prairie Island Unit 1 - Amendment No. 4?7 Units 1 and 2 3.4.19-2 Unit 2 - Amendment No. 467

Programs and Manuals 5.5 5.5 Programs and Manuals (continued) 5.5.8 Steam Generator (SG) Program A Steam Generator Program shall be established and implemented to ensure that SG tube integrity is maintained. In addition, the Steam Generator Program shall include the following:

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 SG 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 SG tubes are inspected or plugged to confirm that the performance criteria are being met.

b. Performance criteria for SG tube integrity. SG tube integrity shall be maintained by meeting the peiformance criteria for tube structural integrity, accident induced leakage, and operational LEAKAGE.

1. Structural integrity peiformance 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), 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.

Prairie Island Unit 1 - Amendment No. 34% 477 Units 1 and 2 5.0-13 Unit 2 - Amendment No. 4-49 4-67

Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.8 Steanl Generator (SG) Program (continued)

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.

2. Accident induced leakage performance criterion: The primary to secondary accident induced leakage rate for any design basis accident, other than a SG tube rupture, shall not exceed the leakage rate assumed in the accident analysis in terms of total leakage rate for all SGs and leakage rate for an individual SG. Leakage is not to exceed 1 gpm per SG.

3. The operational LEAKAGE performance criterion is specified in LC0 3.4.14, "RCS Operational LEAKAGE."

c. Provisions for SG tube plugging criteria. Tubes 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 SG tube inspections. Periodic SG 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 plugging criteria. The tube-to-tubesheet weld is not part of the tube. In addition to meeting the requirements of d. 1, d.2 and d.3 below, the inspection scope, inspection methods, and inspection intervals shall be such as to ensure that SG tube integrity is maintained until the next SG inspection. A degradation assessment shall be Prairie Island Unit 1 - Amendment No. 458 &?7 Units 1 and 2 5-0-14 Unit 2 - Amendment No. 4-49 4-67

Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.8 Steam Generator (SG) Program (continued) pel-formed 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 SG during the first refueling outage following SG installation. I After the first refueling outage following SG installation, inspect each SG at least every 72 effective full power months or at least every third refueling outage (whichever results in more frequent inspections). In addition, the minimum number of tubes inspected at each scheduled inspection shall be the number of tubes in all SGs divided by the number of SG inspection outages scheduled in each inspection period as defined in a, b, c and d below. If a degradation assessment indicates the potential for a type of degradation to occur at a location not previously inspected with a technique capable of detecting this type of degradation at this location and that may satisfy the applicable tube plugging criteria, the minimum number of locations inspected with such a capable inspection technique during the remainder of the inspection period may be prorated. The fraction of locations to be inspected for this potential type of degradation at this location at the end of the inspection period shall be no less than the ratio of the number of times the SG is scheduled to be inspected in the inspection period after the determination that a new form of degradation could potentially be occurring at this location divided by the total number of times the SG is scheduled to be inspected in the inspection period. Each inspection period defined below may be extended up to 3 effective full power months to include a SG inspection outage in an inspection period and the subsequent inspection period begins at the conclusion of the included SG inspection outage.

a) After the first refueling outage following SG installation, inspect 100% of the tubes during the next 144 effective full power months. This constitutes the first inspection period; Prairie Island Unit 1 - Amendment No. 4-581-77 Units 1 and 2 5-0-15 Unit 2 - Amendment No. 1491-43.

Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.8 Steam Generator (SG) Program (continued) b) During the next 120 effective full power months, inspect 100% of the tubes. This constitutes the second inspection period; c) During the next 96 effective full power months, inspect 100% of the tubes. This constitutes the third inspection period; and d) During the remaining life of the SGs, inspect 100% of the tubes every 72 effective full power months. This constitutes the fourth and subsequent inspection periods.

If crack indications are found in any SG tube, then the next inspection for each affected and potentially affected SG for the degradation mechanism that caused the crack indication shall not exceed 24 effective full power months or one refueling outage (whichever results in more frequent inspections). If definitive information, such as from examination of a pulled tube, diagnostic I

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 LEAKAGE, Prairie Island Unit 1 - Amendment No. 458 477 Units 1 and 2 5.0-16 Unit 2 - Amendment No. 4-494 - S

Programs and Manuals 5.5 5.5 Programs and Manuals (continued)

This page retained for page numbering Prairie Island Unit 1 - Amendment No. 45%337 Units 1 and 2 5.0-17 Unit 2 - Amendment No. 449 W

Programs and Manuals 5.5 5.5 Programs and Manuals (continued)

This page retained for page numbering I

Prairie Island Unit 1 - Amendment No. 4-584-77 I Units 1 and 2 5.0-18 Unit 2 - Amendment No. 449 4-67

Programs and Manuals 5.5 5.5 Programs and Manuals (continued)

This page retained for page numbering Prairie Island Unit 1 - Amendment No. M 7 Units 1 and 2 5.0-19 Unit 2 - Amendment No. 449 4-67

Programs and Manuals 5.5 5.5 Prog.rams and Manuals (continued)

This page retained for page numbering Prairie Island Units 1 and 2 5.O-20 Unit 1 - Amendment No. 32% 4?7 Unit 2 - Amendment No. 149-I# I

Programs and Manuals 5.5 5.5 Programs and Manuals (continued)

This page retained for page numbering Prairie Island Unit 1 - Amendment No. 4% 137-Units 1 and 2 5 .O-21 Unit 2 - Amendment No. 44-94-67

Reporting Requirements 5.6 5.6 Reporting Requirements (continued) 5.6.7 Steam Generator Tube Inspection Report A report shall be submitted within 180 days after the initial entry into I MODE 4 following completion of an inspection performed in accordance with the Specification 5.5.8, Steam Generator (SG) Program. The report shall include:

a. The scope of inspections performed on each SG, I

b. Degradation mechanisms found, I

c. Nondestructive examination techniques utilized for each degradation mechanism,

d. Location, orientation (if linear), and measured sizes (if available) of service induced indications,

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

f. The number and percentage of tubes plugged to date, and the effective plugging percentage in each steam generator, and

g. The results of condition monitoring, including the results of tube pulls 1 Prairie Island Unit 1- Amendment No. 133 4-99 Units 1 and 2 5.0-39 Unit 2 - Amendment No. 467 4-87

Reporting Requirements 5.6 5.6 Reporting Requirements (continued) 5.6.8 EM Report I When a report is required by Condition C or I of LC0 3.3.3, "Event Monitoring (EM) Instrumentation," a report shall be submitted within the following 14 days. The report shall outline the preplanned alternate method of monitoring, the cause of the inoperability, and the plans and schedule for restoring the instrumentation channels of the Function to OPERABLE status.

Prairie Island Unit 1 - Amendment No. 4-77459 Units 1 and 2 5.0-40 Unit 2 - Amendment No. 467 4-87

Enclosure 4 Marked-Up Technical Specification Bases Pages For Information Only 6 pages follow

SG Tube Integrity B 3.4.19 BASES BACKGROUND There are three SG performance criteria: structural integrity, (continued) accident induced leakage, and operational LEAKAGE. The SG performance criteria are described in Specification 5.5.8. Meeting the SG performance criteria provides reasonable assurance of maintaining tube integrity at normal and accident conditions.

The processes used to meet the SG performance criteria are defined by the Steam Generator Program Guidelines (Ref. 1).

APPLICABLE The steam generator tube rupture (SGTR) accident is the linliting SAFEI71 design basis event for SG tubes and avoiding an SGTR is the basis ANAZYSES for this Specification. The analysis of a SGTR event assumes a bounding primary to secondary LEAKAGE rate greater than the operational LEAKAGE rate limits in L C 0 3.4.14, "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 released to the atmosphere via atmospheric steam dumps.

The analyses for design basis accidents and transients other than a SGTR assume the SG 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 of 1 gallon per minute from the faulted SG or is assumed to increase to 1 gallon per minute as a result of accident induced conditions plus 150 gallons per day from the intact SG.

Prairie Island Unit 1 - Revision 4437 Units 1 and 2 Unit 2 - Revision 48-7

SG Tube Integrity B 3.4.19 BASES APPLTCABLE For accidents that do not involve fuel damage, the primary coolant S M activity level of DOSE EQUIVALENT 1-131 is assumed to be equal ANALYSES to or greater than the L C 0 3.4.17, "RCS Specific Activity," limits.

(continued) 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 100 (Ref. 3) or the NRC approved licensing basis (e.g., a small fraction of these limits).

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

LC0 The L C 0 requires that SG tube integrity be maintained. The L C 0 also requi tubes that satisfy the be plugge in accordance with th Program.

During an SG inspection, any inspected tube that satisfies the Steam Generator Program teria but was not plugged still have tube integrity.

In the context of this Specification, an SG tube is defined as the th of the tube, including the tube wall between the tube-to-tubesheet weld at the tube inlet and

-tubesheet weld at the tube outlet. The tube-to-tubesheet weld is not considered part of the tube, Prairie Island Unit 1 - Revision 4-87 Units 1 and 2 Unit 2 - Revision 87

SG Tube Integrity B 3.4.19 BASES (continued)

APPLJCABLW Steam generator tube integrity is challenged when the pressure differential across the tubes is large. Large differential pressures across SG 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 l , 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 SG tube. This is acceptable because the Required Actions provide appropriate compensatory actions for each affected SG tube. Complying with the Required Actions may allow for continued operation, and subsequent affected SG 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 SG tubes examined in an inservice in criteria but were not plugge Steam Generator Program evaluation of SG tube integrity of the affected tube(s) must be made.

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

The SG criteria define limits on SG tube degradation that a110 growth between inspections while still providing assurance that the SG performance criteria will continue to be met.

In order to determine if an SG tube that should have been plugged M as tube integrity, an evaluation must be completed that demonstrates that the SG performance criteria will continue to be met until the next refueling outage or SG 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 Prairie Island Unit 1 - Revision 4-87 Units 1 and 2 Unit 2 - Revision 487

SG Tube Integrity B 3.4.19 BASES ACTIONS A. 1 and A.2 (continued) of the degradation prior to the next SG tube inspection. If it is determined that tube integrity is not being maintained, Condition B applies.

A Completion Time of 7 days is sufficient to complete the evaluation while minimizing the risk of plant operation with an SG 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 SG 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 prior to entering MODE 4 following the next refueling outage or SG inspection. This Completion Time is acceptable since operation until the next inspection is supported by the operational assessment.

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

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.

Prairie Island Unit 1 - Revision 4-87 Units 1 and 2 B 3.4.19-7 Unit 2 - Revision 4-87

SG Tube Integrity B 3.4.19 BASES (continued)

SURvEIlLLWa SR 3.4.19.1 REQ-During shutdown periods the SGs are inspected as required by this SR and the Steam Generator Program. NEI 97-06, Steam Generator Program Guidelines (Ref. I), 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 SG inspections a condition monitoring assessment of the SG tubes is performed. The condition monitoring assessment determines the "as found" condition of the SG tubes. The purpose of the condition monitoring assessment is to ensure that the SG performance criteria have been met for the previous operating period.

The Steam Generator Program determines the scope of the inspection and the methods used to determine whether the tubes contain flaws satisfying the tube criteria. Inspection scope (i.e., which tubes or areas of tubing within the SG 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 3.4.19.1.

The Frequency is determined by the operational assessment and other limits in the SG 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 SG performance criteria at the next scheduled inspection. In addition, Specification 5.5.8 contains prescriptive requirements concerning inspection intervals to provide added assurance that the SG performance criteria will be met between scheduled inspections. If crack indications are Prairie Island Unit 1 - Revision 487 Units 1 and 2 Unit 2 - Revision 487-

SG Tube Integrity B 3.4.19 found in any SG tube. t l ~ e ~ ~ ~ a xinsr,ection i ~ ~ ~ t l interval m for all affected and pote~~tially affected SGs is restricted by Specification 5.5.8 ~111til s~1bseflt1e13t iiisuections support exterlding the inspection interval.

BASES SURVEELANCE SR 3.4.19.2 REQ S-(continued)

During an SG inspection, any inspected tube that satisfies the Steam Generator Program oved from service by plu delineated in Specification 5.5.8 are intended to ensure that tubes accepted for continued service satisfy the SG performance criteria with allowance for error in the flaw size measurement and for future flaw growth. In addition, the tube plu,q~ing criteria, in conjunction with other elements of the Steam Generator Program, ensure that the SG 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 SG peiformance criteria.

The Frequency of prior to entering MODE 4 following an SG inspection ensures that the Surveillance has been completed and all tubes meeting the p1~1.g-gi13.g criteria are plugged prior to subjecting the SG tubes to significant primary to secondary pressure differential.

Prairie Island Unit 1 - Revision 4-87 Units 1 and 2 Unit 2 - Revision 4-87