Text

Additional Information Supporting License Amendment Request to Revise Technical Specifications (TS) 5.5.9, Steam Generator (SG) Program, and TS 5.6.9, Steam Generator (SG) Tube Inspection, .
	ML12229A131
Person / Time
Site:	Byron, Braidwood
Issue date:	08/14/2012
From:	Simpson P; Exelon Generation Co
To:	; Office of Nuclear Reactor Regulation, Document Control Desk
References
	RS-12-122
	Download: ML12229A131 (20)
	v • d • e

RS-12-122 10 CFR 50.90 August 14, 2012 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-001 Braidwood Station, Units 1 and 2 Facility Operating License Nos. NPF-72 and NPF-77 NRC Docket Nos. STN 50-456 and STN 50-457 Byron Station, Units 1 and 2 Facility Operating License Nos. NPF-37 and NPF-66 NRC Docket Nos. STN 50-454 and STN 50-455

Subject:

Additional Information Supporting License Amendment Request to Revise Technical Specifications (TS) 5.5. 9, "Steam Generator (SG) Program," and TS 5.6.9, "Steam Generator (SG) Tube Inspection Report," for Permanent Alternate Repair Criteria

References:

1)

Letter from D. M. Gullott (Exelon Generation Company, LLC) to U. S. Nuclear Regulatory Commission, "License Amendment Request to Revise Technical Specifications (TS) Sections 5.5.9, 'Steam Generator (SG) Program,' and TS 5.6.9, 'Steam Generator (SG) Tube Inspection Report,' for Permanent Alternate Repair Criteria," dated March 20, 2012 2)

Letter from M. Mahoney (U. S. Nuclear Regulatory Commission) to M. J. Pacilio (Exelon Generation Company, LLC), "Byron Station, Unit Nos. 1 and 2, and Braidwood Station, Units 1 and 2 - Request for Additional Information Related to License Amendment Request for Revise Technical Specifications 5.5.9 and 5.6.9, for Permanent Alternate Repair Criteria (TAC Nos. ME8296, ME8297, ME8298, and ME8299)," dated August 1, 2012 In Reference 1, Exelon Generation Company, LLC, (EGC) requested a license amendment to revise Technical Specifications (TS) 5.5. 9, "Steam Generator (SG) Program," and TS 5.6.9, "Steam Generator (SG) Tube Inspection Report," for Braidwood, Units 1 and 2, and Byron, Units 1 and 2. The proposed changes would establish permanent alternate repair criteria for portions of the steam generator tubes within the tubesheet of the SGs for Braidwood Unit 2 and Byron Unit 2.

In Reference 2, the U. S. Nuclear Regulatory Commission (NRC) requested additional information to complete its review of the proposed license amendment request. EGC met with the NRC on July 20, 2012, via teleconference to discuss aspects of the referenced submittal. Additional teleconferences were held on July 23 and 24, 2012. EGC is providing this supplement to address feedback and clarifying questions provided during the teleconferences.

1 RS-12-122 10 CFR 50.90 August 14, 2012 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-001 Braidwood Station, Units 1 and 2 Facility Operating License Nos. NPF-72 and NPF-77 NRC Docket Nos. STN 50-456 and STN 50-457 Byron Station, Units 1 and 2 Facility Operating License Nos. NPF-37 and NPF-66 NRC Docket Nos. STN 50-454 and STN 50-455

Subject:

Additional Information Supporting License Amendment Request to Revise Technical Specifications (TS) 5.5.9, "Steam Generator (SG) Program," and TS 5.6.9, "Steam Generator (SG) Tube Inspection Report," for Permanent Alternate Repair Criteria

References:

1) Letter from D. M. Gullott (Exelon Generation Company, LLC) to U. S. Nuclear Regulatory Commission, "License Amendment Request to Revise Technical Specifications (TS) Sections 5.5.9, 'Steam Generator (SG) Program,' and TS 5.6.9, 'Steam Generator (SG) Tube Inspection Report,' for Permanent Alternate Repair Criteria," dated March 20, 2012

2) Letter from M. Mahoney (U. S. Nuclear Regulatory Commission) to M. J. Pacilio (Exelon Generation Company, LLC), "Byron Station, Unit Nos. 1 and 2, and Braidwood Station, Units 1 and 2 - Request for Additional Information Related to License Amendment Request for Revise Technical Specifications 5.5.9 and 5.6.9, for Permanent Alternate Repair Criteria (TAC Nos. ME8296, ME8297, ME8298, and ME8299)," dated August 1,2012 In Reference 1, Exelon Generation Company, LLC, (EGC) requested a license amendment to revise Technical Specifications (TS) 5.5.9, "Steam Generator (SG) Program," and TS 5.6.9, "Steam Generator (SG) Tube Inspection Report," for Braidwood, Units 1 and 2, and Byron, Units 1 and 2. The proposed changes would establish permanent alternate repair criteria for portions of the steam generator tubes within the tubesheet of the SGs for Braidwood Unit 2 and Byron Unit 2.

In Reference 2, the U. S. Nuclear Regulatory Commission (NRC) requested additional information to complete its review of the proposed license amendment request. EGC met with the NRC on July 20, 2012, via teleconference to discuss aspects of the referenced submittal. Additional teleconferences were held on July 23 and 24, 2012. EGC is providing this supplement to address feedback and clarifying questions provided during the teleconferences.

1 RS-12-122 10 CFR 50.90 August 14, 2012 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-001 Braidwood Station, Units 1 and 2 Facility Operating License Nos. NPF-72 and NPF-77 NRC Docket Nos. STN 50-456 and STN 50-457 Byron Station, Units 1 and 2 Facility Operating License Nos. NPF-37 and NPF-66 NRC Docket Nos. STN 50-454 and STN 50-455

Subject:

Additional Information Supporting License Amendment Request to Revise Technical Specifications (TS) 5.5.9, "Steam Generator (SG) Program," and TS 5.6.9, "Steam Generator (SG) Tube Inspection Report," for Permanent Alternate Repair Criteria

References:

1) Letter from D. M. Gullott (Exelon Generation Company, LLC) to U. S. Nuclear Regulatory Commission, "License Amendment Request to Revise Technical Specifications (TS) Sections 5.5.9, 'Steam Generator (SG) Program,' and TS 5.6.9, 'Steam Generator (SG) Tube Inspection Report,' for Permanent Alternate Repair Criteria," dated March 20, 2012

2) Letter from M. Mahoney (U. S. Nuclear Regulatory Commission) to M. J. Pacilio (Exelon Generation Company, LLC), "Byron Station, Unit Nos. 1 and 2, and Braidwood Station, Units 1 and 2 - Request for Additional Information Related to License Amendment Request for Revise Technical Specifications 5.5.9 and 5.6.9, for Permanent Alternate Repair Criteria (TAC Nos. ME8296, ME8297, ME8298, and ME8299)," dated August 1,2012 In Reference 1, Exelon Generation Company, LLC, (EGC) requested a license amendment to revise Technical Specifications (TS) 5.5.9, "Steam Generator (SG) Program," and TS 5.6.9, "Steam Generator (SG) Tube Inspection Report," for Braidwood, Units 1 and 2, and Byron, Units 1 and 2. The proposed changes would establish permanent alternate repair criteria for portions of the steam generator tubes within the tubesheet of the SGs for Braidwood Unit 2 and Byron Unit 2.

In Reference 2, the U. S. Nuclear Regulatory Commission (NRC) requested additional information to complete its review of the proposed license amendment request. EGC met with the NRC on July 20, 2012, via teleconference to discuss aspects of the referenced submittal. Additional teleconferences were held on July 23 and 24, 2012. EGC is providing this supplement to address feedback and clarifying questions provided during the teleconferences.

August 14, 2012 U. S. Nuclear Regulatory Commission Page 2 Attachments 2 and 3 provide revised marked-up TS pages for the Braidwood and Byron Stations, respectively. The proposed TS changes provided in Attachments 2 and 3 supersede the changes previously provided to the NRC in Reference 1.

EGC has reviewed the information supporting a finding of no significant hazards consideration and the environmental consideration that were previously provided to the NRC in Attachment 1 of Reference 1. The additional information provided in this submittal does not affect the bases for concluding that the proposed license amendment does not involve a significant hazards consideration. In addition, the additional information provided in this submittal does not affect the bases for concluding that neither an environmental impact statement nor an environmental assessment needs to be prepared in connection with the proposed amendment.

In accordance with 10 CFR 50.91, "Notice for public comment; State consultation," paragraph (b),

a copy of this letter and its attachment are being provided to the designated State of Illinois official.

There-are no regulatory commitments contained in this submittal.

Should you have any questions concerning this letter, please contact Ms. Lisa A. Simpson at (630) 657-2815.

I declare under penalty of perjury that the foregoing is true and correct. Executed on the 14th day of August 2012.

Respectfully, Patrick R. Simpson Manager - Licensing Exelon Generation Company, LLC Attachments:

1) Additional Information Supporting Request for License Amendment Regarding Permanent Alternate Repair Criteria

2) Proposed Technical Specifications Changes for Braidwood Station, Units 1 and 2

3) Proposed Technical Specifications Changes for Byron Station, Units 1 and 2 cc:

NRC Regional Administrator, Region III NRC Senior Resident Inspector, Braidwood Station NRC Senior Resident Inspector, Byron Station NRR Project Manager - Braidwood and Byron Stations August 14,2012 U. S. Nuclear Regulatory Commission Page 2 Attachments 2 and 3 provide revised marked-up TS pages for the Braidwood and Byron Stations, respectively. The proposed TS changes provided in Attachments 2 and 3 supersede the changes previously provided to the NRC in Reference 1.

EGC has reviewed the information supporting a finding of no significant hazards consideration and the environmental consideration that were previously provided to the NRC in Attachment 1 of Reference 1. The additional information provided in this submittal does not affect the bases for concluding that the proposed license amendment does not involve a significant hazards consideration. In addition, the additional information provided in this submittal does not affect the bases for concluding that neither an environmental impact statement nor an environmental assessment needs to be prepared in connection with the proposed amendment.

In accordance with 10 CFR 50.91, "Notice for public comment; State consultation," paragraph (b),

a copy of this letter and its attachment are being provided to the designated State of Illinois official.

There are no regulatory commitments contained in this submittal.

Should you have any questions concerning this letter, please contact Ms. Lisa A. Simpson at (630) 657-2815.

I declare under penalty of perjury that the foregoing is true and correct. Executed on the 14th day of August 2012.

Patrick R. Simpson Manager - Licensing Exelon Generation Company, LLC Attachments:

1) Additional Information Supporting Request for License Amendment Regarding Permanent Alternate Repair Criteria

2) Proposed Technical Specifications Changes for Braidwood Station, Units 1 and 2

3) Proposed Technical Specifications Changes for Byron Station, Units 1 and 2 cc:

NRC Regional Administrator, Region III NRC Senior Resident Inspector, Braidwood Station NRC Senior Resident Inspector, Byron Station NRR Project Manager - Braidwood and Byron Stations August 14,2012 U. S. Nuclear Regulatory Commission Page 2 Attachments 2 and 3 provide revised marked-up TS pages for the Braidwood and Byron Stations, respectively. The proposed TS changes provided in Attachments 2 and 3 supersede the changes previously provided to the NRC in Reference 1.

EGC has reviewed the information supporting a finding of no significant hazards consideration and the environmental consideration that were previously provided to the NRC in Attachment 1 of Reference 1. The additional information provided in this submittal does not affect the bases for concluding that the proposed license amendment does not involve a significant hazards consideration. In addition, the additional information provided in this submittal does not affect the bases for concluding that neither an environmental impact statement nor an environmental assessment needs to be prepared in connection with the proposed amendment.

In accordance with 10 CFR 50.91, "Notice for public comment; State consultation," paragraph (b),

a copy of this letter and its attachment are being provided to the designated State of Illinois official.

There are no regulatory commitments contained in this submittal.

Should you have any questions concerning this letter, please contact Ms. Lisa A. Simpson at (630) 657-2815.

I declare under penalty of perjury that the foregoing is true and correct. Executed on the 14th day of August 2012.

Patrick R. Simpson Manager - Licensing Exelon Generation Company, LLC Attachments:

1) Additional Information Supporting Request for License Amendment Regarding Permanent Alternate Repair Criteria

2) Proposed Technical Specifications Changes for Braidwood Station, Units 1 and 2

3) Proposed Technical Specifications Changes for Byron Station, Units 1 and 2 cc:

NRC Regional Administrator, Region III NRC Senior Resident Inspector, Braidwood Station NRC Senior Resident Inspector, Byron Station NRR Project Manager - Braidwood and Byron Stations

ATTACHMENT 1 Additional Information Supporting Request for License Amendment Regarding Permanent Alternate Repair Criteria By letter to the U. S. Nuclear Regulatory Commission (NRC) dated March 20, 2012, Exelon Generation Company, LLC, (EGC) requested a license amendment to revise Technical Specifications (TS) 5.5.9, "Steam Generator (SG) Program," and TS 5.6.9, "Steam Generator (SG) Tube Inspection Report," for Braidwood, Units 1 and 2, and Byron, Units 1 and 2. The proposed changes would establish permanent alternate repair criteria for portions of the steam generator tubes within the tubesheet of the SGs for Braidwood Unit 2 and Byron Unit 2.

In a letter dated August 1, 2012, the U. S. Nuclear Regulatory Commission (NRC) requested additional information to complete its review of the proposed license amendment request. EGC met with the NRC on July 20, 2012, via teleconference to discuss aspects of the March 2012 submittal. Additional teleconferences were held on July 23 and 24, 2012. EGC is providing this supplement to address feedback and clarifying questions provided during the teleconferences.

NRC Question 1:

TS 5.5. 9.f.2.i lists acceptable sleeve repair methods for the Stations. What portions of tubing are approved for repair by sleeving? Are any of the approved sleeving methods applicable to the tubesheet region, anywhere below the top of the tubesheet?

a.

If yes, what changes to the requested amendment are needed to ensure that the proposed permanent alternate repair criteria in TS 5.5.9.c.1 are not applicable to sleeved tubes.

[Note, if the lower joint of the sleeve is located approximately 4 inches below the top of the tubesheet, then the upper 4 inches of the tube to tubesheet joint may not be effective in resisting tube pull-out.]

NRC Question 2:

What changes to TS 5.5.9.d in the LAR are needed to ensure that sleeved tubes are subject to inspection from the tube-to-tubesheet weld at the tube inlet to the tube-to-tubesheet weld at the tube outlet?

EGC Response to NRC Question 1 and NRC Question 2:

As stated in TS 5.5.9.f.2, one sleeve repair method is currently approved for the Braidwood and Byron Station Unit 2 SGs:

TIG welded sleeving as described in ABB Combustion Engineering Inc., Technical Reports:

Licensing Report CEN-621-P, Revision 00, "Commonwealth Edison Byron and Braidwood Unit 1 and 2 Steam Generators Tube Repair Using Leak Tight Sleeves, FINAL REPORT," April 1995; and Licensing Report CEN-627-P, "Operating Performance of the ABB CENO Steam Generator Tube Sleeve for Use at Commonwealth Edison Byron and Braidwood Units 1 and 2," January 1996; subject to the limitations and restrictions as noted by the NRC Staff.

Page 1 of 2 ATTACHMENT 1 Additional Information Supporting Request for License Amendment Regarding Permanent Alternate Repair Criteria By letter to the U. S. Nuclear Regulatory Commission (NRC) dated March 20, 2012, Exelon Generation Company, LLC, (EGC) requested a license amendment to revise Technical Specifications (TS) 5.5.9, "Steam Generator (SG) Program," and TS 5.6.9, "Steam Generator (SG) Tube Inspection Report," for Braidwood, Units 1 and 2, and Byron, Units 1 and 2. The proposed changes would establish permanent alternate repair criteria for portions of the steam generator tubes within the tubesheet of the SGs for Braidwood Unit 2 and Byron Unit 2.

In a letter dated August 1, 2012, the U. S. Nuclear Regulatory Commission (NRC) requested additional information to complete its review of the proposed license amendment request. EGC met with the NRC on July 20, 2012, via teleconference to discuss aspects of the March 2012 submittal. Additional teleconferences were held on July 23 and 24, 2012. EGC is providing this supplement to address feedback and clarifying questions provided during the teleconferences.

NRC Question 1:

TS 5.5.9.f.2.i lists acceptable sleeve repair methods for the Stations. What portions of tubing are approved for repair by sleeving? Are any of the approved sleeving methods applicable to the tubesheet region, anywhere below the top of the tubesheet?

a. If yes, what changes to the requested amendment are needed to ensure that the proposed permanent alternate repair criteria in TS 5.5.9.c.1 are not applicable to sleeved tubes.

[Note, if the lower joint of the sleeve is located approximately 4 inches below the top of the tubesheet, then the upper 4 inches of the tube to tubesheet joint may not be effective in resisting tube pull-out.]

NRC Question 2:

What changes to TS 5.5.9.d in the LAR are needed to ensure that sleeved tubes are subject to inspection from the tube-to-tubesheet weld at the tube inlet to the tube-to-tubesheet weld at the tube outlet?

EGC Response to NRC Question 1 and NRC Question 2:

As stated in TS 5.5.9.f.2, one sleeve repair method is currently approved for the Braidwood and Byron Station Unit 2 SGs:

i.

TIG welded sleeving as described in ABB Combustion Engineering Inc., Technical Reports:

licensing Report CEN-621-P, Revision 00, "Commonwealth Edison Byron and Braidwood Unit 1 and 2 Steam Generators Tube Repair Using Leak Tight Sleeves, FINAL REPORT," April 1995; and Licensing Report CEN-627-P, "Operating Performance of the ABB CENO Steam Generator Tube Sleeve for Use at Commonwealth Edison Byron and Braidwood Units 1 and 2," January 1996; subject to the limitations and restrictions as noted by the NRC Staff.

Page 1 of 2 ATTACHMENT 1 Additional Information Supporting Request for License Amendment Regarding Permanent Alternate Repair Criteria By letter to the U. S. Nuclear Regulatory Commission (NRC) dated March 20, 2012, Exelon Generation Company, LLC, (EGC) requested a license amendment to revise Technical Specifications (TS) 5.5.9, "Steam Generator (SG) Program," and TS 5.6.9, "Steam Generator (SG) Tube Inspection Report," for Braidwood, Units 1 and 2, and Byron, Units 1 and 2. The proposed changes would establish permanent alternate repair criteria for portions of the steam generator tubes within the tubesheet of the SGs for Braidwood Unit 2 and Byron Unit 2.

In a letter dated August 1, 2012, the U. S. Nuclear Regulatory Commission (NRC) requested additional information to complete its review of the proposed license amendment request. EGC met with the NRC on July 20, 2012, via teleconference to discuss aspects of the March 2012 submittal. Additional teleconferences were held on July 23 and 24, 2012. EGC is providing this supplement to address feedback and clarifying questions provided during the teleconferences.

NRC Question 1:

TS 5.5.9.f.2.i lists acceptable sleeve repair methods for the Stations. What portions of tubing are approved for repair by sleeving? Are any of the approved sleeving methods applicable to the tubesheet region, anywhere below the top of the tubesheet?

a. If yes, what changes to the requested amendment are needed to ensure that the proposed permanent alternate repair criteria in TS 5.5.9.c.1 are not applicable to sleeved tubes.

[Note, if the lower joint of the sleeve is located approximately 4 inches below the top of the tubesheet, then the upper 4 inches of the tube to tubesheet joint may not be effective in resisting tube pull-out.]

NRC Question 2:

What changes to TS 5.5.9.d in the LAR are needed to ensure that sleeved tubes are subject to inspection from the tube-to-tubesheet weld at the tube inlet to the tube-to-tubesheet weld at the tube outlet?

EGC Response to NRC Question 1 and NRC Question 2:

As stated in TS 5.5.9.f.2, one sleeve repair method is currently approved for the Braidwood and Byron Station Unit 2 SGs:

i.

TIG welded sleeving as described in ABB Combustion Engineering Inc., Technical Reports:

licensing Report CEN-621-P, Revision 00, "Commonwealth Edison Byron and Braidwood Unit 1 and 2 Steam Generators Tube Repair Using Leak Tight Sleeves, FINAL REPORT," April 1995; and Licensing Report CEN-627-P, "Operating Performance of the ABB CENO Steam Generator Tube Sleeve for Use at Commonwealth Edison Byron and Braidwood Units 1 and 2," January 1996; subject to the limitations and restrictions as noted by the NRC Staff.

Page 1 of 2

ATTACHMENT 1 Additional Information Supporting Request for License Amendment Regarding Permanent Alternate Repair Criteria The NRC approved amendments in April 1996 for Commonwealth Edison Company, the licensee for Braidwood and Byron at the time, to permit steam generator tubes to be repaired using the tungsten inert gas (TIG) welded sleeve process developed by ABB-Combustion Engineering Inc.

(Westinghouse) (Reference 1).

EGC has been informed by the sleeve vendor that TIG welded sleeves are no longer commercially available. In addition, there are no (zero) ABB Combustion Engineering Inc. TIG welded sleeves currently installed in the Braidwood Station, Unit 2, and Byron Station, Unit 2, SGs.

EGC proposes to delete the current TS 5.5.9.c.2 and TS 5.5.9.f allowance to use the ABB Combustion Engineering Inc. TIG welded sleeves as a SG tube repair methodology and to delete references to tube repair and sleeves in various IS. As a result of this change, there are no available SG tube repair methods at Braidwood Station or Byron Station. As discussed during the conference calls with the NRC in July 2012, the technical questions provided in the NRC letter dated August 1, 2012, are therefore not applicable.

Attachments 2 and 3 provide revised marked-up TS pages for the Braidwood and Byron Stations, respectively. The proposed TS changes provided in Attachments 2 and 3 supersede the changes previously provided to the NRC in EGC letter dated March 20, 2012.

Reference:

1)

Letter from G. F. Dick (U. S. NRC) to D. L. Farrar (Commonwealth Edison Company),

"Issuance of Amendments - Byron and Braidwood Stations (TAC Nos. M92375, M92376, M92377 and M92378)," dated April 12, 1996 (ADAMS ML020870035)

Page 2 of 2 ATTACHMENT 1 Additional Information Supporting Request for License Amendment Regarding Permanent Alternate Repair Criteria The NRC approved amendments in April 1996 for Commonwealth Edison Company, the licensee for Braidwood and Byron at the time, to permit steam generator tubes to be repaired using the tungsten inert gas (TIG) welded sleeve process developed by ABB-Combustion Engineering Inc.

(Westinghouse) (Reference 1).

EGC has been informed by the sleeve vendor that TIG welded sleeves are no longer commercially available. In addition, there are no (zero) ABB Combustion Engineering Inc. TIG welded sleeves currently installed in the Braidwood Station, Unit 2, and Byron Station, Unit 2, SGs.

EGC proposes to delete the current TS 5.5.9.c.2 and TS 5.5.9.f allowance to use the ABB Combustion Engineering Inc. TIG welded sleeves as a SG tube repair methodology and to delete references to tube repair and sleeves in various TS. As a result of this change, there are no available SG tube repair methods at Braidwood Station or Byron Station. As discussed during the conference calls with the NRC in July 2012, the technical questions provided in the NRC letter dated August 1, 2012, are therefore not applicable.

Attachments 2 and 3 provide revised marked-up TS pages for the Braidwood and Byron Stations, respectively. The proposed TS changes provided in Attachments 2 and 3 supersede the changes previously provided to the NRC in EGC letter dated March 20, 2012.

Reference:

1) Letter from G. F. Dick (U. S. NRC) to D. L. Farrar (Commonwealth Edison Company),

"Issuance of Amendments - Byron and Braidwood Stations (TAC Nos. M92375, M92376, M92377 and M92378)," dated April 12, 1996 (ADAMS ML020870035)

Page 2 of 2 ATTACHMENT 1 Additional Information Supporting Request for License Amendment Regarding Permanent Alternate Repair Criteria The NRC approved amendments in April 1996 for Commonwealth Edison Company, the licensee for Braidwood and Byron at the time, to permit steam generator tubes to be repaired using the tungsten inert gas (TIG) welded sleeve process developed by ABB-Combustion Engineering Inc.

(Westinghouse) (Reference 1).

EGC has been informed by the sleeve vendor that TIG welded sleeves are no longer commercially available. In addition, there are no (zero) ABB Combustion Engineering Inc. TIG welded sleeves currently installed in the Braidwood Station, Unit 2, and Byron Station, Unit 2, SGs.

EGC proposes to delete the current TS 5.5.9.c.2 and TS 5.5.9.f allowance to use the ABB Combustion Engineering Inc. TIG welded sleeves as a SG tube repair methodology and to delete references to tube repair and sleeves in various TS. As a result of this change, there are no available SG tube repair methods at Braidwood Station or Byron Station. As discussed during the conference calls with the NRC in July 2012, the technical questions provided in the NRC letter dated August 1, 2012, are therefore not applicable.

Attachments 2 and 3 provide revised marked-up TS pages for the Braidwood and Byron Stations, respectively. The proposed TS changes provided in Attachments 2 and 3 supersede the changes previously provided to the NRC in EGC letter dated March 20, 2012.

Reference:

1) Letter from G. F. Dick (U. S. NRC) to D. L. Farrar (Commonwealth Edison Company),

"Issuance of Amendments - Byron and Braidwood Stations (TAC Nos. M92375, M92376, M92377 and M92378)," dated April 12, 1996 (ADAMS ML020870035)

Page 2 of 2

ATTACHMENT 2 Proposed Technical Specifications Changes for Braidwood Station, Units 1 and 2 Braidwood Station, Units 1 and 2 Facility Operating License Nos. NPF-72 and NPF-77 Mark-up of Technical Specifications Pages 5.5-7 5.5-8 5.5-9 5.5-10 5.5-11 5.6-6 5.6-7 ATTACHMENT 2 Proposed Technical Specifications Changes for Braidwood Station, Units 1 and 2 Braidwood Station, Units 1 and 2 Facility Operating License Nos. NPF-72 and NPF-77 Mark-up of Technical Specifications Pages 5.5-7 5.5-8 5.5-9 5.5-10 5.5-11 5.6-6 5.6-7 ATTACHMENT 2 Proposed Technical Specifications Changes for Braidwood Station, Units 1 and 2 Braidwood Station, Units 1 and 2 Facility Operating License Nos. NPF-72 and NPF-77 Mark-up of Technical Specifications Pages 5.5-7 5.5-8 5.5-9 5.5-10 5.5-11 5.6-6 5.6-7

Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.9 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 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 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

-r-epai-r--ed-to confirm that the performancd\\cri teri a are being met.

o

'Inspected or plugged 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.

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.

BRAIDWOOD - UNITS 1 & 2 5.5 - 7 Amendment -144 5.5 Programs and Manuals 5.5.9 Steam Generator (SG) Program Programs and Manuals 5.5 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 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 SG inspection outage, as determined from the inservice inspection results or by other means, prior to the plugging or repair of tubes. Condition monitoring assessments shall be conducted during each outage during which the SG tubes are.

repaired to confirm that the performanc 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.

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.

BRAIDWOOD - UNITS 1 & 2 5.5 - 7 Amendment H4 5.5 Programs and Manuals 5.5.9 Steam Generator (SG) Program Programs and Manuals 5.5 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 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 SG inspection outage, as determined from the inservice inspection results or by other means, prior to the plugging or repair of tubes. Condition monitoring assessments shall be conducted during each outage during which the SG tubes are.

repaired to confirm that the performanc 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.

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.

BRAIDWOOD - UNITS 1 & 2 5.5 - 7 Amendment H4

Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.9 Steam Generator (SG) Program (continued) 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 a total of 1 gpm for all SGs.

3.

The operational LEAKAGE performance criteria is specified in LCO 3.4.13, "RCS Operational LEAKAGE."

c.

Provisions for SG tube repair criteria.

1.

Tubes found by inservice inspection to contain flaws with a depth equal to or exceeding 40% of the nominal wall thickness shall be plugged The following alternate tube repair criteria shall be applied as an alternative to the 40% depth based criteria:

14,01 For Unit 2 tubes with ervice-induced flaws located greater than inches below the top of the tubesheet do not require plugging-f-.

Tubes with service-induced flaws located in the portion of the tube from the top of the tubesheet to inches below the top of the tubesheet shall b plugged upon detection.

1 01 bed d

°Y61P7e".7 i'^V^1TY

'e'V^Ge

't^C.^'D'°T°1T^^t°ll'U°G BRAIDWOOD - UNITS 1 & 2 5.5 - 8 Amendment -166 Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.9 Steam Generator (SG) Program (continued)

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 a total of 1 gpm for all SGs.

3.

The operational LEAKAGE performance criteria is specified in LCO 3.4.13, "RCS Operational LEAKAGE."

c.

Provisions for SG tube repair criteria.

1.

Tubes found by inservice inspection to contain flaws in a non sleeved region with a depth equal to or exceeding 40% of the nominal wall thickness shall be plugged or repaired. The following alternate tube repair criteria shall be applied as an alternative to the 40% depth based criteria:

1

'--_.....l For Un i t 2 -fl+1-P-'HAG--Hf'-1H-.1f'+tfIHr-H+F:rt8f"--+'"'r-r!flfl--f:fff'-

subsequent operating cycle, tubes with ervice-induced flaws located greater than ~

inches below the top of the tubesheet do not require plugging or repair. Tubes with service-induced flaws located in the portion of the tube from the top of the tubesheet to ~

inches below the top of the tubesheet shall b plugged or repaired upon detecti on.

1 1

b 51 eeves found by i nservi ce ; nspect; on to conta; n fl aviS

'v~i th a depth equal to or e)(ceedi ng the foll O'v~i ng

~~r~i:::~~~ of the nOFFli nal sl eeve v.'all thi ckness shall 4-;-

For Unit 2 only, TIC \\ielded sleeves (per T5 5.5.9.f.2.i): 32%

3-:-

Tubes \\v;th a flaw in a sleeve to tube joint that occurs in the sl eeve or ; n the or; gi nal tube 'viall of the joint shall be plugged.

BRAIDWOOD - UNITS 1 & 2 5.5 - 8 Amendment +/-e6 Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.9 Steam Generator (SG) Program (continued)

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 a total of 1 gpm for all SGs.

3.

The operational LEAKAGE performance criteria is specified in LCO 3.4.13, "RCS Operational LEAKAGE."

c.

Provisions for SG tube repair criteria.

1.

Tubes found by inservice inspection to contain flaws in a non sleeved region with a depth equal to or exceeding 40% of the nominal wall thickness shall be plugged or repaired. The following alternate tube repair criteria shall be applied as an alternative to the 40% depth based criteria:

1

'--_.....l For Un i t 2 -fl+1-P-'HAG--Hf'-1H-.1f'+tfIHr-H+F:rt8f"--+'"'r-r!flfl--f:fff'-

subsequent operating cycle, tubes with ervice-induced flaws located greater than ~

inches below the top of the tubesheet do not require plugging or repair. Tubes with service-induced flaws located in the portion of the tube from the top of the tubesheet to ~

inches below the top of the tubesheet shall b plugged or repaired upon detecti on.

1 1

b 51 eeves found by i nservi ce ; nspect; on to conta; n fl aviS

'v~i th a depth equal to or e)(ceedi ng the foll O'v~i ng

~~r~i:::~~~ of the nOFFli nal sl eeve v.'all thi ckness shall 4-;-

For Unit 2 only, TIC \\ielded sleeves (per T5 5.5.9.f.2.i): 32%

3-:-

Tubes \\v;th a flaw in a sleeve to tube joint that occurs in the sl eeve or ; n the or; gi nal tube 'viall of the joint shall be plugged.

BRAIDWOOD - UNITS 1 & 2 5.5 - 8 Amendment +/-e6

5.5 Programs and Manuals Programs and Manuals 5.5 5.5.9 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 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.

For Unit 2

-age IS and 4

Refuel ing Out portions of the tube below inches from the top of the tubesheet are excluded from this equirement.

14.01 The tube-to-tubesheet weld is not pa 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. 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 SG during the first refueling outage following SG replacement.

2.

Inspect 100% of the Unit 1 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 SGs. In addition, inspect 50% of the tubes by the refueling outage nearest the midpoint of the period and the remaining 50% by the refueling outage nearest the end of the period. No SG shall operate for more than 72 effective full power months or three refueling outages (whichever is less) without being inspected.

Inspect 100% of the Unit 2 tubes at sequential periods of 120, 90, and, thereafter, 60 effective full power months.

The first sequential period shall be considered to begin after the first inservice inspection of the SGs. In addition, inspect 50% of the tubes by the refueling outage nearest the midpoint of the period and the remaining 50% by the refueling outage nearest the end of the period. No SG shall operate for more than 48 effective full power months or two refueling outages (whichever is less) without being inspected.

BRAIDWOOD - UNITS 1 & 2

5. 5 - 9 Amendment 4-66 Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.9 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 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. For Unit 2 during Refueling Outage 15 and the subsequent operating cycle, portions of the tube below ~

inches from the top of the tubesheet are excluded from this equirement.

The tube-to-tubesheet weld is not pa 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.

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 SG during the first refueling outage following SG replacement.

2.

Inspect 100% of the Unit 1 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 SGs.

In addition, inspect 50% of the tubes by the refueling outage nearest the midpoint of the period and the remaining 50% by the refueling outage nearest the end of the period.

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

BRAIDWOOD - UNITS 1 & 2 Inspect 100% of the Unit 2 tubes at sequential periods of 120, 90, and, thereafter, 60 effective full power months.

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

In addition, inspect 50% of the tubes by the refueling outage nearest the midpoint of the period and the remaining 50% by the refueling outage nearest the end of the period.

No SG shall operate for more than 48 effective full power months or two refueling outages (whichever is less) without being inspected.

5.5 - 9 Amendment +/-&&

Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.9 Steam Generator (SG) Program (continued)