CNL-19-067, Application to Revise Watts Bar Nuclear Plant (WBN) Unit 2 - Technical Specifications for Steam Generator Tube Repair Sleeve (WBN-TS-391-19-13)

Application to Revise Watts Bar Nuclear Plant (WBN) Unit 2 - Technical Specifications for Steam Generator Tube Repair Sleeve (WBN-TS-391-19-13)

ML19274C003
Person / Time
Site:	Watts Bar
Issue date:	09/30/2019
From:	Polickoski J Tennessee Valley Authority
To:	Document Control Desk, Office of Nuclear Reactor Regulation
Shared Package
ML19274C001	List: CNL-19-067, Application to Revise Watts Bar Nuclear Plant (WBN) Unit 2 - Technical Specifications for Steam Generator Tube Repair Sleeve (WBN-TS-391-19-13)
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CNL-19-067, WBN-TS-391-19-13
Download: ML19274C003 (199)

Text

Proprietary Information Withhold Under 10 CFR § 2.390 This letter is decontrolled when separated from Enclosure 2 Tennessee Valley Authority, 1101 Market Street, Chattanooga, Tennessee 37402 CNL-19-067 September 30, 2019 10 CFR 50.90 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555-0001 Watts Bar Nuclear Plant Unit 2 Facility Operating License No. NPF-96 Docket No. 50-391

Subject:

Application to Revise Watts Bar Nuclear Plant (WBN) Unit 2 Technical Specifications for Steam Generator Tube Repair Sleeve (WBN-TS-391-19-13)

In accordance with the provisions of Title 10 of the Code of Federal Regulations (10 CFR) 50.90, "Application for amendment of license, construction permit, or early site permit," Tennessee Valley Authority (TVA) is submitting a request for an amendment to Facility Operating License No. NPF-96 for Watts Bar Nuclear Plant (WBN), Unit 2.

The proposed license amendment request (LAR) revises WBN Unit 2 Technical Specifications (TS) 3.4.17, SG Tube Integrity, 5.7.2.12, Steam Generator (SG) Program, and TS 5.9.9, Steam Generator Tube Inspection Report, to allow the use of Westinghouse leak-limiting non-nickel banded Alloy 800 sleeves to repair degraded SG tubes as an alternative to plugging the tube. The technique for repairing the degraded tubes is described in the enclosed Westinghouse Electric LLC Proprietary Class 2 WCAP-15918-P, Revision 3, Steam Generator Tube Repair for Combustion Engineering and Westinghouse Designed Plants with 3/4 Inch Inconel 600 Tubes Using Leak Limiting Alloy 800 Sleeves. This report details the analyses and testing performed to verify the adequacy of Alloy 800 sleeves for installation in an SG tube and demonstrates non-nickel banded sleeving to be an acceptable repair technique. provides a description and technical evaluation of the proposed change, a regulatory evaluation, and a discussion of environmental considerations. Attachment 1 to provides the existing WBN Unit 2 TS pages marked-up to show the proposed changes. Attachment 2 to Enclosure 1 provides the existing WBN Unit 2 TS pages retyped to show the proposed changes. Attachment 3 to Enclosure 1 provides the existing WBN Unit 2 TS Bases pages marked-up to show the proposed changes. The changes to the TS Bases are provided for information only. provides a copy of the Westinghouse Electric Report Proprietary Class 2 WCAP-15918-P and Enclosure 3 provides a copy of the Non-Proprietary version of the report. provides the Westinghouse Affidavit, Proprietary Information Notice, and Copyright Notice.

Proprietary Information Withhold Under 10 CFR § 2.390 This letter is decontrolled when separated from Enclosure 2

Proprietary Information Withhold Under 10 CFR § 2.390 This letter is decontrolled when separated from Enclosure 2 U.S. Nuclear Regulatory Commission CNL-19-067 Page 3 September 30, 2019

Enclosures:

1. Evaluation of Proposed Change

2. Westinghouse Proprietary Class 2, WCAP-15918-P, Revision 3, Steam Generator Tube Repair for Combustion Engineering and Westinghouse Designed Plants with 3/4 Inch Inconel 600 Tubes Using Leak Limiting Alloy 800 Sleeves (Proprietary)

3. Westinghouse Non-Proprietary Class 3, WCAP-15918-NP, Revision 3, Steam Generator Tube Repair for Combustion Engineering and Westinghouse Designed Plants with 3/4 Inch Inconel 600 Tubes Using Leak Limiting Alloy 800 Sleeves (Non-Proprietary)

4. Westinghouse Affidavit, Proprietary Information Notice, and Copyright Notice cc (Enclosures):

NRC Regional Administrator - Region II NRC Project Manager - Watts Bar Nuclear Plant NRC Senior Resident Inspector - Watts Bar Nuclear Plant Director, Division of Radiological Health - Tennessee State Department of Environment and Conservation Proprietary Information Withhold Under 10 CFR § 2.390 This letter is decontrolled when separated from Enclosure 2

Enclosure 1 Evaluation of Proposed Change

Subject:

Application to Revise Watts Bar Nuclear Plant (WBN) Unit 2 Technical Specifications for Steam Generator Tube Repair Sleeve (WBN-TS-391-19-13)

CONTENTS Tennessee Valley Authority, 1101 Market Street, Chattanooga, Tennessee 37402 ................ 1 1.0

SUMMARY

DESCRIPTION ............................................................................................. 2 2.0 DETAILED DESCRIPTION.............................................................................................. 2 2.1 Proposed Changes ...................................................................................................... 2 2.2 Condition Intended to Resolve ..................................................................................... 3

3.0 TECHNICAL EVALUATION

............................................................................................. 3 3.1 System Description ...................................................................................................... 3 3.2 Technical Analysis ....................................................................................................... 4 3.2.1 General Structural Assessment ............................................................................ 6 3.2.2 Corrosion Assessment .......................................................................................... 7 3.2.3 Operating Experience ........................................................................................... 7 3.2.4 Mechanical Integrity Assessment .......................................................................... 7 3.2.5 Leakage Rate Assessment ................................................................................... 7 3.2.6 Sleeve Examination .............................................................................................. 7 3.3 Conclusion ................................................................................................................... 7

4.0 REGULATORY EVALUATION

........................................................................................ 8 4.1 Applicable Regulatory Requirements and Criteria ........................................................ 8 4.2 Precedent .................................................................................................................... 9 4.3 Significant Hazards Consideration ..............................................................................10 4.4 Conclusion ..................................................................................................................12

5.0 ENVIRONMENTAL CONSIDERATION

..........................................................................12

6.0 REFERENCES

...............................................................................................................12 ATTACHMENTS

1. Proposed TS Changes (Mark-Ups) for WBN Unit 2

2. Proposed TS Changes (Final Typed) for WBN Unit 2

3. Proposed TS Bases Changes (Mark-Ups) for WBN Unit 2 CNL-19-067 E1-1 of 12

Enclosure 1 1.0

SUMMARY

DESCRIPTION Pursuant to Title 10 of the Code of Federal Regulations (CFR) §50.90, Tennessee Valley Authority (TVA) is submitting a request for a change to Facility Operating License (OL) No. NPF-96 for the Watts Bar Nuclear Plant (WBN) Unit 2.

Specifically, TVA is requesting a license amendment to amend the WBN Unit 2 Technical Specifications (TS) 3.4.17, SG Tube Integrity, 5.7.2.12, Steam Generator (SG) Program, and TS 5.9.9, Steam Generator Tube Inspection Report, to allow the use of Westinghouse leak-limiting non-nickel banded Alloy 800 sleeves to repair degraded SG tubes as an alternative to plugging the tube. The technique for repairing the degraded tubes is described in Westinghouse Electric LLC Proprietary Class 2 WCAP-15918-P, Revision 3, Steam Generator Tube Repair for Combustion Engineering and Westinghouse Designed Plants with 3/4 Inch Inconel 600 Tubes Using Leak Limiting Alloy 800 Sleeves, which is provided in Enclosures 2 (Proprietary) and 3 (Non-Proprietary). This report details the analyses and testing performed to verify the adequacy of Alloy 800 sleeves for installation in a SG tube and demonstrates non-nickel banded sleeving to be an acceptable repair technique.

2.0 DETAILED DESCRIPTION

2.1 PROPOSED CHANGE

S The following is a detailed description of the proposed WBN Unit 2 TS changes.

• The option to repair SG tubes is being added to TS limiting condition for operation (LCO) 3.4.17; TS 3.4.17, Condition A; SR 3.4.17.2; TS 5.7.2.12; and TS 5.9.9, because these TS currently allow only tube plugging.

• A new TS 5.7.2.12f is being added as follows:

f. Provisions for SG Tube Repair Methods Steam generator tube repair methods shall provide the means to reestablish the RCS pressure boundary integrity of SG tubes without removing the tube from service. For the purposes of these Specifications, tube plugging is not a repair.

All acceptable tube repair methods are listed below.

1. Westinghouse leak-limiting Non-Nickel Banded Alloy 800 sleeves, WCAP-15918-P, Revision 3, Steam Generator Tube Repair for Combustion Engineering and Westinghouse Designed Plants with 3/4 Inch Inconel 600 Tubes Using Leak Limiting Alloy 800 Sleeves. A Non-Nickel Banded Alloy 800 sleeve installed in the hot-leg or cold-leg tubesheet region shall remain in service for no more than five fuel cycles of operation starting from the outage when the sleeve was installed.

• The following new requirement is being added to TS 5.9.9 as follows:

h. Repair method utilized and the number of tubes repaired by each repair method.

Attachment 1 to this enclosure provides the existing WBN Unit 2 TS pages marked-up to show the proposed changes. Attachment 2 to this enclosure provides the existing TS pages retyped to show the proposed changes. Attachment 3 to this enclosure provides the existing WBN Unit 2 TS Bases pages marked-up to show the proposed changes. The changes to the TS Bases are provided for information only.

CNL-19-067 E1-2 of 12

Enclosure 1 As noted in the proposed change to TS 5.7.2.12f, TVA is proposing to limit the use of the non-nickel banded alloy 800 sleeves to no more than five operating cycles for WBN Unit 2. This is acceptable because TVA plans to replace the WBN Unit 2 SGs during the WBN Unit 2 Cycle 5 refueling outage (U2R5) scheduled for Fall 2023. Also in Reference 1, the NRC authorized the use of Westinghouse leak-limiting Alloy 800 sleeves for the Beaver Valley Power Station (BVPS), Unit 2 for a total of eight fuel cycles of operation. Therefore, a limitation of five operating cycles for the non-nickel banded alloy 800 sleeves for WBN Unit 2 is considered reasonable.

2.2 CONDITION INTENDED TO RESOLVE Currently, the WBN Unit 2 TS allow defective tubes to be removed from service by installing plugs at both ends of the tube. The installation of SG tube plugs removes the heat transfer surface of the plugged tube from service and leads to a reduction in the primary coolant flow available for core cooling.

The proposed license amendment request (LAR) revises the WBN Unit 2 TS to permit the use of leak-limiting non-nickel banded Alloy 800 repair sleeves. There are two distinct advantages associated with the leak-limiting Alloy 800 repair sleeves. First, no welding, brazing, or heat treatment is required during sleeve installation. Secondly, the strain within the tube is low, thereby reducing the likelihood of future degradation due to stress-influenced mechanisms. Additional information on the Alloy 800 repair sleeves is provided in Section 3.0 of this enclosure and Enclosure 2.

The proposed LAR would also prevent, if appropriate, unnecessary plugging of SG tubes during the upcoming WBN U2R3 outage scheduled for Fall 2020 and subsequent refueling outages until the WBN Unit 2 SGs are replaced (scheduled for U2R5).

3.0 TECHNICAL EVALUATION

3.1 SYSTEM DESCRIPTION WBN Unit 2 contains four Westinghouse Model D3 recirculating pre-heater type SGs.

Each SG contains 4674 mill annealed (MA) Alloy 600 tubes that have an outer diameter of 0.75 inches with a 0.043-inch nominal wall thickness. These SGs are the same design as the original WBN Unit 1 SGs. The WBN Unit 1 SGs were replaced during the WBN U1R7 outage.

The WBN Unit 2 SGs have a vertical shell and U-tube evaporator with integral moisture separating equipment. The reactor coolant flows through the inverted U-tubes, entering and leaving through the nozzles located in the hemispherical bottom head of the SG.

The head is divided into inlet and outlet chambers by a vertical partition plate extending from the head to the tubesheet. Steam is generated on the shell side and flows upward through the moisture separators to the outlet nozzle at the top of the vessel. Details of the Unit 2 SGs are described in the WBN dual-unit updated final safety analysis report (UFSAR) Section 5.5.2.2 and UFSAR Figure 5.5-3.

The WBN Unit 2 SGs contain a flow distribution baffle (FDB) plate located approximately eight inches above the top of the tube sheet. The tube holes located in the FDB design include an increased nominal tube-to-plate diametrical gap ranging from approximately 0.115 inches to 0.150 inches, compared to 0.023 inches nominal gap at the tube support plates (TSPs).

CNL-19-067 E1-3 of 12

Enclosure 1 Materials of construction for the WBN Unit 2 SG are provided in UFSAR Table 5.2-8.

Materials are selected and fabricated in accordance with the requirements of the American Society of Mechanical Engineers (ASME) Code Section III. The heat transfer tubes and the divider plate are inconel and the interior surfaces of the reactor coolant channel heads and nozzles are clad with austenitic stainless steel. The primary side of the tubesheet is weld clad with Inconel. The tubes are roller expanded for the full depth of the tubesheet after the ends are seal welded to the tubesheet cladding.

Tube and tubesheet stress analyses of the SG, which are discussed in UFSAR Section 5.2, confirm that the SG tubesheet will withstand the loading caused by loss of reactor coolant.

3.2 TECHNICAL ANALYSIS

The principal accident associated with this proposed change is the SG tube rupture (SGTR) event. The consequences associated with a SGTR event are discussed in WBN Unit 2 UFSAR Section 15.4.3, "Steam Generator Tube Rupture. The SGTR event is a breach of the barrier between the reactor coolant system and the main steam system. The integrity of this barrier is significant from the standpoint of radiological safety in that a leaking SG tube allows the transfer of reactor coolant into the main steam system. In the event of a SGTR, radioactivity contained in the reactor coolant mixes with water in the shell side of the affected SG. This radioactivity is transported by steam to the turbine and then to the condenser, or directly to the condenser via the turbine bypass valves, or directly to the atmosphere via the atmospheric dump valves, main steam safety valves, or the auxiliary feedwater pump turbine exhaust.

Non-condensable radioactive gases in the condenser are removed by the condenser air removal system and discharged to the plant vent. The use of Westinghouse leak-limiting non-nickel banded Alloy 800 sleeves allows the repair of degraded SG tubes such that the function and integrity of the tube is maintained; therefore, the SGTR accident is not affected.

Based on the information in Enclosure 2, the consequences of a hypothetical failure of a leaklimiting non-nickel banded Alloy 800 repair sleeve and/or associated SG tube would be bounded by the current SGTR analysis described above. Due to the slight reduction in diameter caused by the sleeve wall thickness, primary coolant release rates would be slightly less than assumed for the SGTR analysis and, therefore, would result in lower total primary fluid mass release to the secondary system. A main steam line break (MSLB) or feedwater line break (FLB) will not cause a SGTR because the sleeves are analyzed for a maximum accident differential pressure greater than that predicted in the WBN Unit 2 safety analysis. The impact of repair sleeving on SG performance, heat transfer, and flow restriction is minimal and insignificant compared to plugging. The proposed amendment to allow the use of leak-limiting Alloy 800 repair sleeves does not adversely impact any other previously evaluated design basis accident.

As noted in Enclosure 2, evaluation of the proposed leak-limiting Alloy 800 repair sleeves indicates no detrimental effects on the sleeve or sleeved tube assembly from reactor system flow, primary or secondary coolant chemistries, thermal conditions, or transients, or other pressure conditions that may be experienced at WBN Unit 2. The minimal leakage, which is assumed but not expected, experienced during normal operation is well within the established leakage limits when combined with calculated leakage for other alternate plugging criteria. Data and calculation methodology concerning the reduction in primary coolant flow rate and sleeve-to-plug equivalency CNL-19-067 E1-4 of 12

Enclosure 1 ratios is contained in Section 10 of Enclosure 2. Table 1 provides a comparison of loading conditions utilized in Enclosure 2 with respect to the WBN Unit 2 corresponding operating (actual) values. The values assumed in Enclosure 2 are either equivalent to or are more conservative than WBN Unit 2 plant specific values, with the exception of the values for loss-of-coolant accident (LOCA) pressure differential as discussed in further detail below. The design values shown in Table 2 are provided to demonstrate that they bound the actual values of Table 1.

Table 1 Loading Condition Comparison Value WBN Unit 2 WCAP-15918-P Notes Higher is T-Hot (Primary) Inlet 618.6ºF 620ºF limiting Lower is T-Steam (Secondary) 542.9ºF 526.5ºF limiting Higher is Pressure Primary 2250 psia 2250 psia limiting Lower is Pressure Secondary 986 psia 877 psia limiting Higher is MSLB/FLB 2405 psi* 2850 psi limiting Loss-of-Coolant Accident Higher is 1221 psig 1198 psi (LOCA) limiting

• Based on pressurizer relief valve setting including instrument error.

Table 2 Design Value Comparison Value WBN Unit 2 WCAP-15918-P T-Hot (Primary) Inlet 650ºF 650ºF T-Steam (Secondary) 600ºF 570ºF Pressure Primary 2485 psia 2500 psia Pressure Secondary 1185 psia 1200 psia As shown in Table 1, the LOCA pressure differential is approximately two percent 2%

higher for WBN Unit 2. Page 8-7 of Enclosure 2 provides the following equation for determining whether the stress intensity for a primary pipe break LOCA is less than the allowable value of 52.5 ksi per the ASME code:

S.I.LOCA = PRo + P tmin 2 where Ro = 0.3115 in. for tmin = 0.04 in. per Reference 8.18 of Enclosure 2. Thus, substituting the higher LOCA pressure differential for WBN Unit 2 yields:

S.I.LOCA = (1.221 )(.3115 ) + (1.221 )

.040 2 S.I.LOCA = 10.1 < 0.7 Su = 52.5 CNL-19-067 E1-5 of 12

Enclosure 1 Thus, the design is still acceptable despite the higher LOCA pressure differential.

The detailed report describing the specific qualifications of Alloy 800 non-nickel banded repair sleeves is contained in Enclosure 2. The summary of results from the report are discussed below.

3.2.1 General Structural Assessment The Alloy 800 tubing, from which the repair sleeves are fabricated, is procured to the requirements of the ASME Boiler and Pressure Vessel (B&PV) Code Section II, Part B, SB-163, NiFeCr Alloy UNS N08800, and Section III, Subsection NB-2000. Additionally, supplemental requirements with more tightly controlling parameters within the limits allowed by the ASME specification are imposed. Fatigue and stress analysis of the sleeved tube assemblies have been completed in accordance with the requirements of Section III ASME B&PV Code and Regulatory Guide (RG) 1.121, Bases for Plugging Degraded PWR Steam Generator Tubes. SG tubes with installed Alloy 800 repair sleeves meet the structural integrity requirements of tubes that are not degraded. In the event of the severance of the SG tube in the region behind the sleeve, the repaired sleeve will provide the required structural support and acceptable leakage between the primary and secondary systems for normal operating and accident conditions. The selected design criteria for the repaired sleeves ensure that all design and licensing requirements are considered. Extensive testing and analysis have been performed on the repair sleeve and sleeve-to-tube joints to demonstrate that these design criteria are met.

Mechanical tests were performed on mock-up SG tubes containing sleeves to provide qualified test data describing the basic properties of the completed assemblies. These tests determined axial load, collapse, burst, leak rates, and thermal cycling capability.

Details of the mechanical testing performed are provided in Section 7.0 of Enclosure 2.

The structural analysis establishes the structural adequacy of the sleeve-tube assembly.

The methodology used is in accordance with the ASME B&PV Code,Section III and 10 CFR 50, Appendix B. Details of the structural analysis are provided in Section 8.0 of Enclosure 2.

Regulatory Guide 1.121 and the Electrical Power Research Institutes (EPRIs) SG Degradation Specific Management Flaw Handbook, Revision 2, which adds margin to account for configuration of a long axial crack, are used to develop the structural limit of the repair sleeve should sleeve wall degradation occur as described in Section 8.2 of Enclosure 2. Alloy 800 leak-limiting repair sleeves are shown (by test and analysis) to retain burst strength in excess of three times the normal operating pressure differential at end of cycle conditions. No credit for the presence of the parent tube behind the sleeve is assumed when performing the minimum wall burst evaluation for the Alloy 800 repair sleeve. For sleeves with minimum wall thickness, the structural limit imperfection depth is determined conservatively to be 48 percent (%) and bounds both normal and accident conditions. Appendix H of the EPRI Pressurized Water Reactor (PWR) SG Examination Guidelines specify that adequate flaw detection capability in the parent tube be demonstrated for flaws greater than or equal to 60% throughwall. For the purpose of this sleeve inspection qualification, these values were conservatively reduced to greater than or equal to 50% throughwall for the parent tube and greater than or equal to 45%

for the sleeve in order to provide an operational margin between the detection limit and the structural limit for defect growth. A sufficient number of flaw samples has been used CNL-19-067 E1-6 of 12

Enclosure 1 to demonstrate that the statistical requirements for probability of detection are met. The proposed TS changes require that a sleeved tube be plugged upon detection of a defect in the pressure boundary portion of the sleeve/tube assembly.

3.2.2 Corrosion Assessment The corrosion assessment of the Alloy 800 sleeve is based on long-term service performance, laboratory corrosion tests; Westinghouses welded sleeve corrosion program, and operating experience. Details of the structural analysis are provided in Section 6.0 of Enclosure 2.

3.2.3 Operating Experience Operating Experience of the Alloy 800 repair sleeve/tube assemblies, including international operating experience, is described in Section 6.2 of Enclosure 2.

3.2.4 Mechanical Integrity Assessment Mechanical testing of Alloy 800 repair sleeve/tube assemblies was performed using mock-up SG tubes. The tests determined axial load, pressure load, collapse, burst, leak rates, wear, load cycling, and thermal cycling capability. The test results correlated well with applicable structural analysis results (analyses always conservative). The loading conditions developed in Section 8.0 of Enclosure 2 were used to develop the conditions that were tested in Section 7.0 of Enclosure 2. The temperature and pressure differentials described in Section 8.0 of Enclosure 2 are conservative with respect to WBN Unit 2 operating and accident conditions.

3.2.5 Leakage Rate Assessment Details of the leakage assessment are provided in Section 7.3.1 of Enclosure 2.

3.2.6 Sleeve Examination Details of the repair sleeve and tube assembly examination methodology are provided in Section 5.0 of Enclosure 2. Qualified nondestructive examination techniques will be used to perform necessary repair sleeve and tube inspections for defect detection, and to verify proper installation of the repair sleeve.

3.3 CONCLUSION

Based on operating experience, extensive testing, and analysis, the Westinghouse non-nickel banded Alloy 800 leak-limiting repair sleeves provide satisfactory repair of defective SG tubes. Design criteria were established based on the requirements of the ASME B&PV Code and RG 1.121.

CNL-19-067 E1-7 of 12

Enclosure 1

4.0 REGULATORY EVALUATION

4.1 APPLICABLE REGULATORY REQUIREMENTS AND CRITERIA General Design Criteria WBN Units 1 and 2 were designed to meet the intent of the "Proposed General Design Criteria for Nuclear Power Plant Construction Permits" published in July, 1967. The Watts Bar construction permit was issued in January 1973. The dual-unit UFSAR, however, addresses the NRC General Design Criteria (GDC) published as Appendix A to 10 CFR 50 in July 1971, including Criterion 4 as amended October 27, 1987.

Each criterion listed below is followed by a discussion of the design features and procedures that meet the intent of the criteria. Any exception to the 1971 GDC resulting from the earlier commitments is identified in the discussion of the corresponding criterion.

Criterion 14, "Reactor Coolant Pressure Boundary" The reactor coolant pressure boundary shall be designed, fabricated, erected, and tested so as to have an extremely low probability of abnormal leakage, or rapidly propagating failure, and of gross rupture.

Compliance with GDC 14 is described in Section 3.1.2.2 of the WBN dual-unit UFSAR.

Criterion 15, "Reactor Coolant System Design" The reactor coolant system and associated auxiliary, control, and protection systems shall be designed with sufficient margin to assure that the design conditions of the reactor coolant pressure boundary are not exceeded during any condition of normal operation, including anticipated operational occurrences.

Compliance with GDC 15 is described in Section 3.1.2.2 of the WBN dual-unit UFSAR.

Criterion 16, Containment design Reactor containment and associated systems shall be provided to establish an essentially leak-tight barrier against the uncontrolled release of radioactivity to the environment and to assure that the containment design conditions important to safety are not exceeded for as long as postulated accident conditions require.

Compliance with GDC 16 is described in Section 3.1.2.2 of the WBN dual-unit UFSAR.

Criterion 19, Control room A control room shall be provided from which actions can be taken to operate the nuclear power unit safely under normal conditions and to maintain it in a safe condition under accident conditions, including loss-of-coolant accidents. Adequate radiation protection shall be provided to permit access and occupancy of the control room under accident conditions without personnel receiving radiation exposures in excess of five rem whole body, or its equivalent to any part of the body, for the duration of the accident.

Equipment at appropriate locations outside the control room shall be provided (1) with a design capability for prompt hot shutdown of the reactor, including necessary instrumentation and controls to maintain the unit in a safe condition during hot shutdown, and (2) with a potential capability for subsequent cold shutdown of the reactor through the use of suitable procedures.

CNL-19-067 E1-8 of 12

Enclosure 1 Compliance with GDC 19 is described in Section 3.1.2.2 of the WBN dual-unit UFSAR.

Criterion 30, Quality of reactor coolant pressure boundary Components, which are part of the reactor coolant pressure boundary, shall be designed, fabricated, erected, and tested to the highest quality standards practical.

Means shall be provided for detecting and, to the extent practical, identifying the location of the source of reactor coolant leakage.

Compliance with GDC 30 is described in Section 3.1.2.4 of the WBN dual-unit UFSAR.

Criterion 31, Fracture prevention of reactor coolant pressure boundary The reactor coolant pressure boundary shall be designed with sufficient margin to assure that when stressed under operating, maintenance, testing, and postulated accident conditions (1) the boundary behaves in a nonbrittle manner and (2) the probability of rapidly propagating fracture is minimized. The design shall reflect consideration of service temperatures and other conditions of the boundary material under operating, maintenance, testing, and postulated accident conditions and the uncertainties in determining (1) material properties, (2) the effects of irradiation on material properties, (3) residual, steady state and transient stresses, and (4) size of flaws.

Compliance with GDC 31 is described in Section 3.1.2.4 of the WBN dual-unit UFSAR.

Criterion 32, Inspection of reactor coolant pressure boundary Components, which are part of the reactor coolant pressure boundary, shall be designed to permit (1) periodic inspection and testing of important areas and features to assess their structural and leaktight integrity, and (2) an appropriate material surveillance program for the reactor pressure vessel.

Compliance with GDC 32 is described in Section 3.1.2.4 of the WBN dual-unit UFSAR.

The reactor coolant pressure boundary, containment boundary, and tube-bundle integrity will not be adversely affected by the application of non-nickel banded Alloy 800 leak-limiting sleeves. SG tube surveillance requirements continue to ensure that degraded tubes will be repaired or removed from service upon detection. Postulated leakage in the limiting SG shall be less than the bounding faulted condition leakage necessary to ensure that offsite doses remain a small fraction of the 10 CFR Part 100 reactor site criteria and that control room doses remain within 10 CFR 50 Appendix A, GDC 19 limits. Therefore, conformance with the applicable GDCs remains valid.

4.2 PRECEDENT This LAR is similar to the ones approved by the NRC in Reference 2 for WBN Unit 1 and References 1 and 3 for the BVPS Unit 2, which allowed the use of Westinghouse leak-limiting Alloy 800 sleeves to repair defective SG tubes as an alternative to plugging the tube. This LAR differs from References 1, 2 and 3 in that TVA is proposing to use non-nickel banded Alloy 800 leak-limiting sleeves for WBN Unit 2, which are less susceptible to corrosion and degradation. Precedent for using non-nickel banded Alloy800 leak-limiting sleeves was noted in Reference 1, in which NRC stated, The PLUSS sleeves are identical to the Alloy 800 leak-limiting sleeves at Beaver Valley, Unit2, except that there is no nickel band on the PLUSS sleeves.

CNL-19-067 E1-9 of 12

Enclosure 1 4.3 SIGNIFICANT HAZARDS CONSIDERATION Tennessee Valley Authority (TVA) proposes to revise the Watts Bar Nuclear Plant (WBN) Unit 2 Technical Specifications (TS) to allow the use of Westinghouse leak-limiting non-nickel banded Alloy 800 sleeves to repair degraded steam generator (SG) tubes as an alternative to plugging the tube.

TVA has evaluated whether or not a significant hazards consideration is involved with the proposed amendment(s) by focusing on the three standards set forth in 10 CFR 50.92, Issuance of amendment, as discussed below:

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

Response: No The Westinghouse non-nickel banded Alloy 800 leak-limiting repair sleeves are designed using the applicable American Society of Mechanical Engineers (ASME)

Boiler and Pressure Vessel (B&PV) Code; therefore, they meet the design objectives of the original SG tubing. The applied stresses and fatigue usage for the repair sleeves are bounded by the limits established in the ASME Code. Mechanical testing has shown that the structural strength of repair sleeves under normal, upset, emergency, and faulted conditions provides margin to the acceptance limits. The acceptance limits bound the most limiting (three times normal operating pressure differential) burst margin recommended by Regulatory Guide (RG) 1.121, Bases for Plugging Degraded PWR Steam Generator Tubes. Burst testing of sleeve/tube assemblies has demonstrated that no unacceptable levels of primary-to-secondary leakage are expected during any plant condition.

The Alloy 800 repair sleeve depth-based structural limit is determined using the RG 1.121 guidance and the pressure stress equation of ASME Code,Section III with additional margin added to account for configuration of long axial cracks. A bounding detection threshold value has been conservatively identified and statistically established to account for growth and determine the repair sleeve/tube assembly plugging limit. A sleeved tube is plugged on detection of degradation in the sleeve/tube assembly.

Evaluation of the repaired SG tube testing and analysis indicates no detrimental effects on the sleeve or sleeved tube assembly from reactor system flow, primary or secondary coolant chemistries, thermal conditions or transients, or pressure conditions as may be experienced at WBN Unit 2. Corrosion testing and historical performance of sleeve/tube assemblies indicates no evidence of sleeve or tube corrosion considered detrimental under anticipated service conditions.

The implementation of the proposed amendment has no significant effect on either the configuration of the plant or the manner in which it is operated. The consequences of a hypothetical failure of the sleeve/tube assembly is bounded by the current SG tube rupture (SGTR) analysis described in the WBN dual-unit Updated Final Safety Analysis Report (UFSAR). Due to the slight reduction in diameter caused by the sleeve wall thickness, primary coolant release rates would be slightly less than assumed for the SGTR analysis and; therefore, would result in lower total primary fluid mass release to the secondary system. A main steam line CNL-19-067 E1-10 of 12

Enclosure 1 break or feedwater line break will not cause a SGTR because the sleeves are analyzed for a maximum accident differential pressure greater that that predicted in the WBN Unit 2 safety analysis. The minimal leakage that could occur during repair of the sleeve/tube assembly during plant operation is well within the TS leakage limits when grouped with current alternate plugging criteria calculated leakage values.

Therefore, TVA has concluded that the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated in the WBN dual-unit UFSAR.

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

Response: No.

The Alloy 800 leak-limiting repair sleeves are designed using the applicable ASME Code as guidance; therefore, it meets the objectives of the original steam generator tubing. As a result, the functions of the SG will not be significantly affected by the installation of the proposed sleeve. The proposed repair sleeves do not interact with any other plant systems. Any accident as a result of potential tube or sleeve degradation in the repaired portion of the tube is bounded by the existing SGTR accident analysis. The continued integrity of the installed sleeve/tube assembly is periodically verified by the TS requirements and the sleeved tube plugged on detection of degradation.

The implementation of the proposed amendment has no significant effect on either the configuration of the plant, or the manner in which it is operated. Therefore, TVA concludes that this proposed change does not create the possibility of a new or different kind of accident from any previously evaluated.

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

Response: No.

The repair of degraded SG tubes with Alloy 800 leak-limiting repair sleeves restores the structural integrity of the degraded tube under normal operating and postulated accident conditions and thereby maintains current core cooling margin as opposed to plugging the tube and taking it out of service. The design safety factors utilized for the repair sleeves are consistent with the safety factors in the ASME Code used in the original SG design. The portions of the installed sleeve/tube assembly that represent the reactor coolant pressure boundary can be monitored for the initiation of sleeve/tube wall degradation and affected tube plugged on detection. Use of the previously identified design criteria and design verification testing assures that the margin to safety is not different from the original SG tubes.

Therefore, TVA concludes that the proposed change does not involve a significant reduction in a margin of safety.

CNL-19-067 E1-11 of 12

Enclosure 1 Based on the above, TVA concludes that the proposed amendment does not involve a significant hazards consideration under the standards set forth in 10 CFR 50.92 (c), and, accordingly, a finding of no significant hazards consideration is justified.

4.4 CONCLUSION

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 Commissions regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

5.0 ENVIRONMENTAL CONSIDERATION

A review has determined that the proposed amendment would change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR 20, or would change an inspection or surveillance requirement. However, the proposed amendment does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluents that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.

6.0 REFERENCES

1. NRC letter to First Energy Nuclear Operating Company, Beaver Valley Power Station, Unit 2 - Issuance of Amendment No. 193 Re: Revise Steam Generator Technical Specifications (EPID L-2018-LLA-0075), dated February 25, 2019 (ML18348B206)

2. NRC letter to TVA, Watts Bar Nuclear Plant, Unit 1 Issuance of an Amendment for Steam Generator Tube Repair (TAC No. MB6976), dated August 15, 2003 (ML032300143)

3. NRC letter to First Energy Nuclear Operating Company, Beaver Valley Power Station, Unit No. 2 - Issuance of Amendment Re: The Use of Westinghouse Leak-Limiting Alloy 800 Sleeves for Steam Generator Tubes Repair (TAC No. MD9969), dated September 30, 2009 (ML092590189)

CNL-19-067 E1-12 of 12

Enclosure 1 Attachment 1 Proposed TS Changes (Mark-Ups) for WBN Unit 2 CNL-19-067

SG Tube Integrity 3.4.17 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.17 Steam Generator (SG) Tube Integrity LCO 3.4.17 SG tube integrity shall be maintained AND All SG tubes satisfying the tube plugging or repair criteria shall be plugged or repaired in accordance with the Steam Generator Program.

APPLICABILITY: 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 plugging affected tube(s) is or repair criteria and not maintained until the next plugged or repaired in refueling outage or SG accordance with the Steam tube inspection.

Generator Program.

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

B. Required Action and B.1 Be in MODE 3. 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 /> OR SG tube integrity not maintained.

Watts Bar - Unit 2 3.4-38 Amendment XX

SG Tube Integrity 3.4.17 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.17.1 Verify steam generator tube integrity in accordance In accordance with with the Steam Generator Program. the Steam Generator Program.

SR 3.4.17.2 Verify that each inspected SG tube that satisfies the Prior to entering tube plugging or repair criteria is plugged or repaired MODE 4 following a in accordance with the Steam Generator Program. SG tube inspection.

Watts Bar - Unit 2 3.4-39 Amendment XX

Procedures, Programs, and Manuals 5.7 5.7 Procedures, Programs, and Manuals (continued) 5.7.2.12 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 a 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 inspected, or plugged, or repaired 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.

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 cooldown), all anticipated transients included in the design specification and design basis accidents. This includes retaining a safety factor of 3.0 against burst under normal steady state full power operation primary-to-secondary pressure differential and a safety factor of 1.4 against burst applied to the design basis accident primary-to-secondary pressure differentials. Apart from the above requirements, additional loading conditions associated with the design basis accidents, or combination of accidents in accordance with the design and licensing basis, shall also be evaluated to determine if the associated loads contribute significantly to burst or collapse. In the assessment of tube integrity, those loads that do significantly affect burst or collapse shall be determined and assessed in combination with the loads due to pressure with a safety factor of 1.2 on the combined primary loads and 1.0 on axial secondary loads.

(continued)

Watts Bar - Unit 2 5.0-15 Amendment XX

Procedures, Programs, and Manuals 5.7 5.7 Procedures, Programs, and Manuals 5.7.2.12 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 an 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 for all degradation mechanisms is not to exceed 150 gpd for each unfaulted SG. Leakage for all degradation mechanisms, excluding that described in Specification 5.7.2.12.c.2, is not to exceed 1 gpm in the faulted SG. Leakage for degradation mechanisms described in Specification 5.7.2.12.c.2 is not to exceed 4 gpm for the faulted SG.

3. The operational leakage performance criterion is specified in LCO 3.4.13, "RCS Operational LEAKAGE."

c. Provisions for SG tube plugging or repair criteria. Tubes found by inservice inspection to contain a flaws in a non-sleeved region with a depth equal to or exceeding 40% of the nominal tube wall thickness shall be plugged or repaired.

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

1. Tubes with service-induced flaws located in the portion of the tube from the top of the tubesheet to 1.64 inches below the top of the tubesheet, or from the bottom of the roll transition to 1.64 inches below the bottom of the roll transition, whichever is lower, shall be plugged. Tubes with service-induced flaws located below this elevation do not require plugging.

2. The voltage based methodology, in accordance with Generic Letter (GL) 95-05, shall be applied at the tube to straight leg tube support plate interface as an alternative to the 40% depth based criteria of Specification 5.7.2.12.c: Tubes shall be plugged in accordance with GL 95-05 or repaired.

Tube Support Plate Plugging Limit is used for the disposition of an Alloy 600 steam generator tube for continued service that is experiencing predominantly axially oriented outside diameter stress corrosion cracking confined within the thickness of the tube support plates and flow distribution baffles (FDB). At tube support plate intersections and FDB, (continued)

Watts Bar - Unit 2 5.0-16 Amendment 2, 28, XX

Procedures, Programs, and Manuals 5.7 5.7 Procedures, Programs, and Manuals 5.7.2.12 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 1.64 inches below the bottom of the roll transition or 1.64 inches below the top of the tubesheet, whichever is lower at the tube inlet, to 1.64 inches below the bottom of the roll transition or 1.64 inches below the top of the tubesheet, whichever is lower at the tube outlet, and that may satisfy the applicable tube plugging or repair criteria. 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 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 following SG installation, inspect each SG at least every 24 effective full power months or at least every refueling outage (whichever results in more frequent inspections). In addition, inspect 100% of the tubes at sequential periods of 60 effective full power months beginning after the first refueling outage inspection following SG installation. Each 60 effective full power month inspection period 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. 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 or repair criteria, the minimum number of locations inspected with such a capable inspection technique during the remainder of the inspection period may be prorated.

(continued)

Watts Bar - Unit 2 5.0-17 Amendment 2, XX

Procedures, Programs, and Manuals 5.7 5.7 Procedures, Programs, and Manuals 5.7.2.12 Steam Generator (SG) Program (continued)

f. Provisions for SG Tube Repair Methods:

Steam generator tube repair methods shall provide the means to reestablish the RCS pressure boundary integrity of SG tubes without removing the tube from service. For the purposes of these Specifications, tube plugging is not a repair. All acceptable tube repair methods are listed below.

1. Westinghouse leak-limiting Non-Nickel Banded Alloy 800 sleeves, WCAP-15918-P, Revision 3, Steam Generator Tube Repair for Combustion Engineering and Westinghouse Designed Plants with 3/4 Inch Inconel 600 Tubes Using Leak Limiting Alloy 800 Sleeves. A Non-Nickel Banded Alloy 800 sleeve shall remain in service for no more than five fuel cycles of operation starting from the outage when the sleeve was installed.

(continued)

Watts Bar - Unit 2 5.0-17b Amendment 2, 28, XX

Reporting Requirements 5.9 5.9 Reporting Requirements (continued) 5.9.7 DG Failures Report If an individual diesel generator (DG) experiences four or more valid failures in the last 25 demands, these failures and any nonvalid failures experienced by that DG in that time period shall be reported within 30 days. Reports on DG failures shall include the information recommended in Regulatory Guide 1.9, Revision 3, Regulatory Position C.4, or existing Regulatory Guide 1.108 reporting requirement.

5.9.8 PAMS Report When a Report is required by Condition B or F of LCO 3.3.3, Post Accident Monitoring (PAM) 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.

5.9.9 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 5.7.2.12, Steam Generator (SG) Program. The report shall include:

a. The scope of inspections performed on each SG,

b. Degradation mechanisms found,

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 or repaired during the inspection outage for each degradation mechanism,

f. The number and percentage of tubes plugged or repaired to date, and the effective plugging percentage in each SG,

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

g.h. Repair method utilized and the number of tubes repaired by each repair method.

(continued)

Watts Bar - Unit 2 5.0-35 Amendment XX

Enclosure 1 Attachment 2 Proposed TS Changes (Final Typed) for WBN Unit 2 CNL-19-067

SG Tube Integrity 3.4.17 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.17 Steam Generator (SG) Tube Integrity LCO 3.4.17 SG tube integrity shall be maintained AND All SG tubes satisfying the tube plugging or repair criteria shall be plugged or repaired in accordance with the Steam Generator Program.

APPLICABILITY: 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 plugging affected tube(s) is or repair criteria and not maintained until the next plugged or repaired in refueling outage or SG accordance with the Steam tube inspection.

Generator Program.

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

B. Required Action and B.1 Be in MODE 3. 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 /> OR SG tube integrity not maintained.

Watts Bar - Unit 2 3.4-38 Amendment XX

SG Tube Integrity 3.4.17 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.17.1 Verify steam generator tube integrity in accordance In accordance with with the Steam Generator Program. the Steam Generator Program.

SR 3.4.17.2 Verify that each inspected SG tube that satisfies the Prior to entering tube plugging or repair criteria is plugged or repaired MODE 4 following a in accordance with the Steam Generator Program. SG tube inspection.

Watts Bar - Unit 2 3.4-39 Amendment XX

Procedures, Programs, and Manuals 5.7 5.7 Procedures, Programs, and Manuals (continued) 5.7.2.12 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 a 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 inspected, plugged, or repaired 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.

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 cooldown), all anticipated transients included in the design specification and design basis accidents. This includes retaining a safety factor of 3.0 against burst under normal steady state full power operation primary-to-secondary pressure differential and a safety factor of 1.4 against burst applied to the design basis accident primary-to-secondary pressure differentials. Apart from the above requirements, additional loading conditions associated with the design basis accidents, or combination of accidents in accordance with the design and licensing basis, shall also be evaluated to determine if the associated loads contribute significantly to burst or collapse. In the assessment of tube integrity, those loads that do significantly affect burst or collapse shall be determined and assessed in combination with the loads due to pressure with a safety factor of 1.2 on the combined primary loads and 1.0 on axial secondary loads.

(continued)

Watts Bar - Unit 2 5.0-15 Amendment XX

Procedures, Programs, and Manuals 5.7 5.7 Procedures, Programs, and Manuals 5.7.2.12 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 an 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 for all degradation mechanisms is not to exceed 150 gpd for each unfaulted SG. Leakage for all degradation mechanisms, excluding that described in Specification 5.7.2.12.c.2, is not to exceed 1 gpm in the faulted SG. Leakage for degradation mechanisms described in Specification 5.7.2.12.c.2 is not to exceed 4 gpm for the faulted SG.

3. The operational leakage performance criterion is specified in LCO 3.4.13, "RCS Operational LEAKAGE."

c. Provisions for SG tube plugging or repair criteria. Tubes found by inservice inspection to contain a flaw in a non-sleeved region with a depth equal to or exceeding 40% of the nominal tube wall thickness shall be plugged or repaired.

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

1. Tubes with service-induced flaws located in the portion of the tube from the top of the tubesheet to 1.64 inches below the top of the tubesheet, or from the bottom of the roll transition to 1.64 inches below the bottom of the roll transition, whichever is lower, shall be plugged. Tubes with service-induced flaws located below this elevation do not require plugging.

2. The voltage based methodology, in accordance with Generic Letter (GL) 95-05, shall be applied at the tube to straight leg tube support plate interface as an alternative to the 40% depth based criteria of Specification 5.7.2.12.c: Tubes shall be plugged in accordance with GL 95-05 or repaired.

Tube Support Plate Plugging Limit is used for the disposition of an Alloy 600 steam generator tube for continued service that is experiencing predominantly axially oriented outside diameter stress corrosion cracking confined within the thickness of the tube support plates and flow distribution baffles (FDB). At tube support plate intersections and FDB, (continued)

Watts Bar - Unit 2 5.0-16 Amendment 2, 28, XX

Procedures, Programs, and Manuals 5.7 5.7 Procedures, Programs, and Manuals 5.7.2.12 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 1.64 inches below the bottom of the roll transition or 1.64 inches below the top of the tubesheet, whichever is lower at the tube inlet, to 1.64 inches below the bottom of the roll transition or 1.64 inches below the top of the tubesheet, whichever is lower at the tube outlet, and that may satisfy the applicable tube plugging or repair criteria. 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 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 following SG installation, inspect each SG at least every 24 effective full power months or at least every refueling outage (whichever results in more frequent inspections). In addition, inspect 100% of the tubes at sequential periods of 60 effective full power months beginning after the first refueling outage inspection following SG installation. Each 60 effective full power month inspection period 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. 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 or repair criteria, the minimum number of locations inspected with such a capable inspection technique during the remainder of the inspection period may be prorated.

(continued)

Watts Bar - Unit 2 5.0-17 Amendment 2, XX

Procedures, Programs, and Manuals 5.7 5.7 Procedures, Programs, and Manuals 5.7.2.12 Steam Generator (SG) Program (continued)

f. Provisions for SG Tube Repair Methods:

Steam generator tube repair methods shall provide the means to reestablish the RCS pressure boundary integrity of SG tubes without removing the tube from service. For the purposes of these Specifications, tube plugging is not a repair. All acceptable tube repair methods are listed below.

1. Westinghouse leak-limiting Non-Nickel Banded Alloy 800 sleeves, WCAP-15918-P, Revision 3, Steam Generator Tube Repair for Combustion Engineering and Westinghouse Designed Plants with 3/4 Inch Inconel 600 Tubes Using Leak Limiting Alloy 800 Sleeves. A Non-Nickel Banded Alloy 800 sleeve shall remain in service for no more than five fuel cycles of operation starting from the outage when the sleeve was installed.

(continued)

Watts Bar - Unit 2 5.0-17b Amendment 2, 28, XX

Reporting Requirements 5.9 5.9 Reporting Requirements (continued) 5.9.7 DG Failures Report If an individual diesel generator (DG) experiences four or more valid failures in the last 25 demands, these failures and any nonvalid failures experienced by that DG in that time period shall be reported within 30 days. Reports on DG failures shall include the information recommended in Regulatory Guide 1.9, Revision 3, Regulatory Position C.4, or existing Regulatory Guide 1.108 reporting requirement.

5.9.8 PAMS Report When a Report is required by Condition B or F of LCO 3.3.3, Post Accident Monitoring (PAM) 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.

5.9.9 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 5.7.2.12, Steam Generator (SG) Program. The report shall include:

a. The scope of inspections performed on each SG,

b. Degradation mechanisms found,

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 or repaired during the inspection outage for each degradation mechanism,

f. The number and percentage of tubes plugged or repaired to date, and the effective plugging percentage in each SG,

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

h. Repair method utilized and the number of tubes repaired by each repair method.

(continued)

Watts Bar - Unit 2 5.0-35 Amendment XX

Enclosure 1 Attachment 3 Proposed TS Bases Changes (Mark-Ups) for WBN Unit 2 CNL-19-067

SG TUBE INTEGRITY B 3.4.17 BASES (continued)

APPLICABLE The steam generator tube rupture (SGTR) accident is the limiting design SAFETY basis event for SG tubes and avoiding an SGTR is the basis for this ANALYSES Specification. The analysis of an SGTR event assumes a bounding primary to secondary LEAKAGE rate equal to the operational LEAKAGE rate limits in LCO 3.4.13, RCS Operational LEAKAGE, plus the leakage rate associated with a double-ended rupture of a single tube. The accident analysis for a SGTR assumes the contaminated secondary fluid is only briefly released to the atmosphere via safety valves and the majority is discharged to the main condenser.

The analysis for design basis accidents and transients other than an 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 150 gallons per day (gpd) per unfaulted steam generator and 1 gallon per minute (gpm) in the faulted steam generator. For accidents that do not involve fuel damage, the primary coolant activity level of DOSE EQUIVALENT I-131 is assumed to be equal to the LCO 3.4.16, RCS Specific Activity, limits. For accidents that assume fuel damage, the primary coolant activity is a function of the amount of activity released from the damaged fuel. The dose consequences of these events are within the limits of GDC 19 (Ref. 2), and 10 CFR 100 (Ref. 3) or the NRC approved licensing basis.

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

LCO The LCO requires that SG tube integrity be maintained. The LCO also requires that all SG tubes that satisfy the plugging or repair criteria be plugged or repaired in accordance with the Steam Generator Program.

During an SG inspection, any inspected tube that satisfies the Steam Generator Program plugging or repair criteria is either plugged or repairedremoved from service by plugging. If a tube was determined to satisfy the plugging or repair criteria but was not plugged or repaired, the tube may still have tube integrity.

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

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

(continued)

Watts Bar - Unit 2 B 3.4-89 Amendment XX

SG TUBE INTEGRITY B 3.4.17 BASES ACTIONS A.1 and A.2 (continued)

Condition A applies if it is discovered that one or more SG tubes examined in an inservice inspection satisfy the tube plugging or repair criteria but were not plugged or repaired in accordance with the Steam Generator Program as required by SR 3.4.17.2. An 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 plugging or repair criteria define limits on SG tube degradation that allow for flaw 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 or repaired, has 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 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 a 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 or repaired 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.1 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.

(continued)

Watts Bar - Unit 2 B 3.4-92 Amendment XX

SG TUBE INTEGRITY B 3.4.17 BASES (continued)

SURVEILLANCE SR 3.4.17.1 REQUIREMENTS 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. 1), and its referenced EPRI Guidelines, establish the content of the Steam Generator Program. Use of the Steam Generator Program ensures that the inspection is appropriate and consistent with accepted industry practices.

During 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 plugging or repair 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, nondestructive examination (NDE) technique capabilities, and inspection locations.

The Steam Generator Program defines the Frequency of SR 3.4.17.1.

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 5.7.2.12 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 found in any SG tube, the maximum inspection interval for all affected and potentially affected SGs is restricted by Specification 5.7.2.12 until subsequent inspections support extending the inspection interval.

(continued)

Watts Bar - Unit 2 B 3.4-93 Amendment XX

SG TUBE INTEGRITY B 3.4.17 BASES SURVEILLANCE SR 3.4.17.2 REQUIREMENTS (continued) During an SG inspection, any inspected tube that satisfies the Steam Generator Program plugging or repair (Ref. 7) criteria is either plugged or repairedremoved from service by plugging. The tube plugging or repair criteria delineated in Specification 5.7.2.12 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 plugging or repair 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 performance 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 plugging or repair criteria are plugged prior to subjecting the SG tubes to significant primary-to-secondary pressure differential.

REFERENCES 1. NEI 97-06, Steam Generator Program Guidelines.

2. 10 CFR 50 Appendix A, GDC 19, Control Room.

3. 10 CFR 100, Reactor Site Criteria.

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

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

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

7. WCAP-15918-P, Revision 3, Steam Generator Tube Repair for Combustion Engineering and Westinghouse Designed Plants with 3/4 Inch Inconel 600 Tubes Using Leak Limiting Alloy 800 Sleeves.

(continued)

Watts Bar - Unit 2 B 3.4-94 Amendment XX

Enclosure 2 Westinghouse Proprietary Class 2, WCAP-15918-P, Revision 3, Steam Generator Tube Repair for Combustion Engineering and Westinghouse Designed Plants with 3/4 Inch Inconel 600 Tubes Using Leak Limiting Alloy 800 Sleeves (Proprietary)

CNL-19-067 E2-1

Enclosure 3 Westinghouse Non-Proprietary Class 3, WCAP-15918-NP, Revision 3, Steam Generator Tube Repair for Combustion Engineering and Westinghouse Designed Plants with 3/4 Inch Inconel 600 Tubes Using Leak Limiting Alloy 800 Sleeves (Non-Proprietary).

CNL-19-067 E3-1

Westinghouse Non-Proprietary Class 3 WCAP-15918-NP July 2019 Revision 3 Steam Generator Tube Repair for Combustion Engineering and Westinghouse Designed Plants with 3/4 Inch Inconel 600 Tubes Using Leak Limiting Alloy 800 Sleeves

• • • This record was final approved on 8/1/2019 2:53:39 PM. (This statement was added by the PRIME system upon its validation)

Westinghouse Non-Proprietary Class 3 WCAP-15918-NP Revision 3 Steam Generator Tube Repair for Combustion Engineering and Westinghouse Designed Plants with 3/4 Inch Inconel 600 Tubes Using Leak Limiting Alloy 800 Sleeves Gary W. Whiteman*

Licensing Engineering Edward P. Kurdziel*

Steam Generator Inspection Timothy J. Schriefer Jr.*

Component Design and Management Programs Sections 8 and 10 July 2019 Reviewer: Bradley T. Carpenter*

Component Design and Management Programs Approved: Michael E. Bradley*, Manager Component Design and Management Programs

• Electronically approved records are authenticated in the electronic document management system.

Westinghouse Electric Company LLC 1000 Westinghouse Drive Cranberry Township, PA 16066, USA

© 2019 Westinghouse Electric Company LLC All Rights Reserved

• • • This record was final approved on 8/1/2019 2:53:39 PM. (This statement was added by the PRIME system upon its validation)

Westinghouse Non-Proprietary Class 3 ii LEGAL NOTICE This report was prepared as an account of work sponsored by Westinghouse Electric Company LLC (Westinghouse). Neither Westinghouse Electric Company LLC, nor any person acting on their behalf:

A. Makes any warranty of representation, express or implied, including the warranties of fitness for a particular purpose or merchantability with respect to the accuracy, completeness of usefulness of the information contained in this report, or that the use of any information, apparatus, method or process disclosed in this report may not infringe privately owned rights; or B. Assumes any liabilities with respect to the use of, or for damages resulting from the use of, any information, apparatus, method, or process disclosed in this report.

WCAP-15918-NP July 2019 Revision 3

• • • This record was final approved on 8/1/2019 2:53:39 PM. (This statement was added by the PRIME system upon its validation)

Westinghouse Non-Proprietary Class 3 ii COPYRIGHT NOTICE This report has been prepared by Westinghouse Electric Company LLC and bears a Westinghouse Electric Company copyright notice. Information in this report is the property of and contains copyright material owned by Westinghouse Electric Company LLC and /or its subcontractors and suppliers. It is transmitted to you in confidence and trust, and you agree to treat this document and the material contained therein in strict accordance with the terms and conditions of the agreement under which it was provided to you.

You are permitted to make the number of copies of the information contained in this report that are necessary for your internal use in connection with your implementation of the report results for your plant(s) in your normal conduct of business. Should implementation of this report involve a third party, you are permitted to make the number of copies of the information contained in this report that are necessary for the third party's use in supporting your implementation at your plant(s) in your normal conduct of business if you have received the prior, written consent of Westinghouse Electric Company LLC to transmit this information to a third party or parties. All copies made by you must include the copyright notice in all instances and the proprietary notice if the original was identified as proprietary.

The NRC is permitted to make the number of copies beyond those necessary for its internal use that are necessary in order to have one copy available for public viewing in the appropriate docket files in the NRC public document room in Washington, DC if the number of copies submitted is insufficient for this purpose, subject to the applicable federal regulations regarding restrictions on public disclosure to the extent such information has been identified as proprietary. Copies made by the NRC must include the copyright notice in all instances and the proprietary notice if the original was identified as proprietary.

WCAP-15918-NP July 2019 Revision 3

• • • This record was final approved on 8/1/2019 2:53:39 PM. (This statement was added by the PRIME system upon its validation)

Westinghouse Non-Proprietary Class 3 iii ABSTRACT A technique is presented for repairing degraded steam generator tubes in pressurized water reactor nuclear steam supply systems (NSSS). The technique described alleviates the need for plugging steam generator tubes which require repair. The technique consists of installing an Alloy 800 sleeve which spans the defective section of the original steam generator tube. The upper end of the sleeve is expanded into the steam generator tube and the lower end is mechanically rolled into the tubesheet for repair of a defect in the expansion transition zone at the top of the tubesheet. The Westinghouse Alloy 800 sleeve design is an evolution of the Asea Brown Boveri (ABB)

Combustion Engineering (CE) PLUg replacing sleeve which also stabilizes (PLUSS) sleeve design. The two designs are essentially identical; the only difference being the addition of the nickel band applied to the sleeve OD in the lower roll expansion joint region. The nickel band was added as an additional barrier to leakage through the tube-sleeve joint. The nominal nickel band thickness is 0.002 inch and extends for an axial length of 0.5 inch; the nickel band is located on the lower half of the roll expansion length. A 0.5-inch-wide microlok band is applied to the tube at the upper half of the roll joint. The microlok band is a thermally applied material like the sleeve material which acts to increase the coefficient of friction between the tube and sleeve, thus increasing axial load bearing capability of the sleeve joint. Currently only nickel banded tube sleeves are licensed domestically for installation to address top of tubesheet cracks. To date, the U.S. Nuclear Regulatory Commission (NRC) staff has only approved a limited life cycle for the nickel banded sleeves due to the ability to ET inspect through the nickel band. Elimination of the nickel band for the repair of the steam generator tubes, as described in this report, is expected to eliminate the regulatory concerns related to ET inspection of the parent tube wall adjacent to the sleeve nickel band. By doing so the allowable service life of the non-nickel banded sleeve is no longer expected to be limited.

For a defect at a tube support or in a free span section of the tube, the sleeve is expanded into the steam generator tube at both ends. The tube support or free span sleeve does not contain a nickel band. It also does not have a limited service life.

This report details analyses and testing performed to verify the adequacy of Alloy 800 sleeves for installation in a nuclear steam generator tube. These verifications show sleeving to be an acceptable repair technique.

WCAP-15918-NP July 2019 Revision 3

• • • This record was final approved on 8/1/2019 2:53:39 PM. (This statement was added by the PRIME system upon its validation)

Westinghouse Non-Proprietary Class 3 iv RECORD OF REVISIONS Rev. Date Revision Description 00 November Original Issue 2002 01 January 2004 Revised extensively 02 July 2004 pp. iv-xiii Revised to reflect page changes

p. 2-2 Added explanation of sleeve performance p .2-3 Added information to experience table

p. 4-3 Clarified criteria for plugging defective sleeve

p. 4-5 Clarified tube conditioning verification

p. 4-6 Added reasons for sleeve re-expansion

p. 4-7 Added reasons for re-rolling

p. 5-1 Added pre-installation inspection explanation

p. 5-2 Added word periodic to clarify Clarified ECT criteria, analysis training and guidelines

p. 5-3 Modified definition of pressure boundary

p. 5-4 Clarified description of ECT qualification samples

p. 5-5 Figure 5-1 redrawn to clarify

p. 5-6 Figure 5-2 redrawn to clarify

p. 6-2 Clarified discussion of sleeve/tube crevice corrosion

p. 8-32,35 Added further discussion of installation stresses

p. 9-2 Clarified tube conditioning verification

p. 9-3 Clarified reasons for sleeve re-expansion

p. 9-4 Clarified reasons for re-rolling operation p.10-1 Modified description of sleeve/plug ratio methodology All Removed repair from sleeve nomenclature for consistency with Sections other documents 3-A July 2019 Revised extensively to reflect the elimination of the nickel band at the lower joint of the TZ sleeve 3 July 2019 Revised Reference 5.3.2 WCAP-15918-NP July 2019 Revision 3

• • • This record was final approved on 8/1/2019 2:53:39 PM. (This statement was added by the PRIME system upon its validation)

Westinghouse Non-Proprietary Class 3 ii TABLE OF CONTENTS LIST OF TABLES ........................................................................................................................................ v LIST OF FIGURES ................................................................................................................................... viii

1.0 INTRODUCTION

........................................................................................................................ 1-1 1.1 PURPOSE ........................................................................................................................ 1-1

1.2 BACKGROUND

............................................................................................................. 1-3 2.0

SUMMARY

AND CONCLUSIONS ............................................................................................ 2-4 3.0 ACCEPTANCE CRITERIA ......................................................................................................... 3-1 4.0 DESIGN DESCRIPTION OF SLEEVES AND INSTALLATION EQUIPMENT ..................... 4-4 4.1 SLEEVE DESIGN DESCRIPTION ................................................................................ 4-4 4.2 SLEEVE MATERIAL SELECTION ............................................................................... 4-4 4.3 SLEEVE-TUBE ASSEMBLY ......................................................................................... 4-5 4.4 PLUGGING OF A DEFECTIVE SLEEVED TUBE ....................................................... 4-6 4.5 SLEEVE INSTALLATION EQUIPMENT ..................................................................... 4-6 4.5.1 Remote Controlled Manipulator ...................................................................... 4-6 4.5.2 Tool Delivery Equipment ................................................................................ 4-7 4.5.3 Tube Conditioning Equipment ........................................................................ 4-7 4.5.4 Sleeve Positioning/Expansion Equipment ....................................................... 4-7 4.5.5 Sleeve Rolling Equipment ............................................................................... 4-9 4.5.6 Nondestructive Examination ......................................................................... 4-10 4.6 ALARA Considerations ................................................................................................. 4-10

4.7 REFERENCES

FOR SECTION 4.0 .............................................................................. 4-11 5.0 SLEEVE EXAMINATION PROGRAM ...................................................................................... 5-1

5.1 BACKGROUND

............................................................................................................. 5-1 5.2 SLEEVE/TUBE SAMPLES ............................................................................................ 5-4

5.3 REFERENCES

FOR SECTION 5.0 ................................................................................ 5-4 6.0 ALLOY 800 SLEEVE CORROSION PERFORMANCE ............................................................ 6-1 6.1

SUMMARY

AND CONCLUSIONS ............................................................................... 6-1 6.2 LABORATORY DATA AND OPERATING EXPERIENCE .......................................... 6-1 6.2.1 Primary Side Performance ............................................................................... 6-1 6.2.2 Secondary Side Performance ........................................................................... 6-4 6.2.3 Overall Performance and Experience .............................................................. 6-5 6.3 SLEEVE/TUBE ASSEMBLY CORROSION TESTS ..................................................... 6-5 6.3.1 European-Based Corrosion Tests ..................................................................... 6-5 6.3.2 Welded Sleeve Corrosion Tests ....................................................................... 6-6 6.3.3 Confirmatory Alloy 800 Tests ......................................................................... 6-7 6.3.4 Discussion........................................................................................................ 6-8

6.4 REFERENCES

FOR SECTION 6.0 .............................................................................. 6-11 7.0 MECHANICAL TESTS OF SLEEVED STEAM GENERATOR TUBES .................................. 7-1 7.1

SUMMARY

AND CONCLUSIONS ............................................................................... 7-1 7.2 MECHANICAL TESTS .................................................................................................. 7-1 7.2.1 Axial Load and Pressure Tests ......................................................................... 7-3 7.2.2 Collapse Testing .............................................................................................. 7-4 7.2.3 Thermal and Load Cycling Tests ..................................................................... 7-4 WCAP-15918-NP July 2019 Revision 3

• • • This record was final approved on 8/1/2019 2:53:39 PM. (This statement was added by the PRIME system upon its validation)

Westinghouse Non-Proprietary Class 3 iii 7.3 LEAKAGE ASSESSMENT ............................................................................................ 7-7 7.3.1 Leak Rate Tests ................................................................................................ 7-7 7.3.2 Leak Test Evaluation ..................................................................................... 7-10 7.3.3 Leak Test Results Under Abnormal Installation Conditions.......................... 7-11 7.4 INSTALLATION STRESSES ....................................................................................... 7-12 7.5 EFFECTS OF CHANGES IN TUBE AND SLEEVE DIMENSIONS ......................... 7-13

7.6 REFERENCES

FOR SECTION 7.0 .............................................................................. 7-14 8.0 STRUCTURAL ANALYSIS OF SLEEVE-TUBE ASSEMBLY ................................................. 8-1 8.1

SUMMARY

AND CONCLUSIONS ............................................................................... 8-1 8.1.1 Design Sizing................................................................................................... 8-1 8.1.2 Detailed Analysis Summary ............................................................................ 8-2 8.2 EVALUATION FOR ALLOWABLE SLEEVE WALL DEGRADATION USING REGULATORY GUIDE 1.121 ........................................................................................ 8-8 8.2.1 Normal Operation Safety Margins................................................................... 8-8 8.2.2 Postulated Pipe Rupture Accidents ................................................................ 8-11 8.3 EFFECTS OF TUBE LOCK-UP OR UNLOCKED SITUATION ON SLEEVE AXIAL LOADING ..................................................................................................................... 8-12 8.3.1 Sleeved Tube in CE Plants, Unlocked at First Tube Support ........................ 8-13 8.3.2 Sleeved Tube in Westinghouse D & E Plant, Unlocked at First Tube Support .......................................................................................................... 8-14 8.3.3 Sleeved Tube in CE Plants, Locked at First Tube Support ............................ 8-14 8.3.4 Sleeved Tube in Westinghouse D & E Plants, Locked at First Tube Support .......................................................................................................... 8-15 8.3.5 Effect of Tube Pre-stress Prior to Sleeving.................................................... 8-27 8.3.6 Lower Sleeve Rolled Section Pushout Due to Restrained Thermal Expansion ...................................................................................................... 8-27 8.4 SLEEVED TUBE VIBRATION CONSIDERATIONS ................................................. 8-28 8.4.1 Effects of Increased Stiffness ........................................................................ 8-28 8.4.2 Effect of Severed Tube .................................................................................. 8-28 8.4.3 Seismic Evaluation ........................................................................................ 8-30 8.5 EVALUATION OF SLEEVE TO TUBE EXPANSION SECTION .............................. 8-31 8.5.1 Analysis of Sleeve Material ........................................................................... 8-35 8.6 EFFECTS OF SEVERED, UNLOCKED TUBE ON SLEEVE AXIAL LOADING ... 8-53

8.7 REFERENCES

FOR SECTION 8.0 ............................................................................. 8-53 9.0 SLEEVE INSTALLATION VERIFICATION .............................................................................. 9-1 9.1

SUMMARY

AND CONCLUSIONS ............................................................................... 9-1 9.2 SLEEVE-TUBE INSTALLATION SEQUENCE ............................................................ 9-1 9.2.1 Transition Zone Sleeve .................................................................................... 9-1 9.2.2 Tube Support Sleeve ........................................................................................ 9-1 9.3 EXPANSION JOINT INTEGRITY ................................................................................. 9-1 9.3.1 Tube Conditioning Qualification ..................................................................... 9-1 9.3.2 Expansion Qualification .................................................................................. 9-2 9.3.3 Summary.......................................................................................................... 9-3 9.4 ROLLED JOINT INTEGRITY ....................................................................................... 9-3

9.5 REFERENCES

FOR SECTION 9.0 ................................................................................ 9-3 10.0 EFFECT OF SLEEVING ON OPERATION.............................................................................. 10-1 WCAP-15918-NP July 2019 Revision 3

• • • This record was final approved on 8/1/2019 2:53:39 PM. (This statement was added by the PRIME system upon its validation)

Westinghouse Non-Proprietary Class 3 iv

10.1 REFERENCES

FOR SECTION 10.0 ............................................................................ 10-2 WCAP-15918-NP July 2019 Revision 3

• • • This record was final approved on 8/1/2019 2:53:39 PM. (This statement was added by the PRIME system upon its validation)

Westinghouse Non-Proprietary Class 3 v LIST OF TABLES TABLE 3-1 SLEEVING CRITERIA ......................................................................................................... 3-2 TABLE 7-1 SLEEVE-TUBE ASSEMBLY MECHANICAL TESTING RESULTS ............................... 7-15 TABLE 7-2 TUBESHEET SLEEVE-TUBE ASSEMBLY LEAK TESTING RESULTS ....................... 7-16 TABLE 7-3 TUBE SUPPORT SLEEVE-TUBE ASSEMBLY LEAK TESTING RESULTS ................. 7-17 TABLE 7-4 EFFECTS OF DIFFERENT SLEEVE AND TUBE DIMENSIONS TZ SLEEVES........... 7-18 TABLE 7-5 EFFECTS OF DIFFERENT SLEEVE AND TUBE DIMENSIONS TS SLEEVES ........... 7-18 TABLE 7-6 LEAKAGE BEFORE AND AFTER CYCLIC LOAD TESTS ........................................... 7-19 TABLE 8-1

SUMMARY

OF SLEEVE DESIGN AND ASME CODE ANALYSIS FOR TZ AND TS SLEEVES ........................................................................................................................ 8-5 TABLE 8-2A 25.0 INCH SLEEVE AXIAL MEMBER PHYSICAL PROPERTIES FOR CE PLANTS WITH 0.048" TUBE WALL AND EFFECTIVE LENGTH BETWEEN LOWER JOINT AND LAST UPPER JOINT .......................................................................................... 8-16 TABLE 8-2B 25.0 INCH SLEEVE AXIAL MEMBER PHYSICAL PROPERTIES FOR CE PLANTS WITH 0.042" TUBE WALL AND EFFECTIVE LENGTH BETWEEN LOWER JOINT AND LAST UPPER JOINT .......................................................................................... 8-17 TABLE 8-2C 25.0 INCH SLEEVE AXIAL MEMBER PHYSICAL PROPERTIES FOR WESTINGHOUSE D3 PLANTS WITH EFFECTIVE LENGTH BETWEEN LOWER JOINT AND LAST UPPER JOINT............................................................................... 8-18 TABLE 8-2D 25.0 INCH SLEEVE AXIAL MEMBER PHYSICAL PROPERTIES FOR WESTINGHOUSE D4 PLANTS WITH EFFECTIVE LENGTH BETWEEN LOWER JOINT AND LAST UPPER JOINT............................................................................... 8-19 TABLE 8-2E 25.0 INCH SLEEVE AXIAL MEMBER PHYSICAL PROPERTIES FOR WESTINGHOUSE D2 PLANTS WITH EFFECTIVE LENGTH BETWEEN LOWER JOINT AND LAST UPPER JOINT............................................................................... 8-20 TABLE 8-2F 25.0 INCH SLEEVE AXIAL MEMBER PHYSICAL PROPERTIES FOR WESTINGHOUSE D5 PLANTS WITH EFFECTIVE LENGTH BETWEEN LOWER JOINT AND LAST UPPER JOINT............................................................................... 8-21 TABLE 8-2G 25.0 INCH SLEEVE AXIAL MEMBER PHYSICAL PROPERTIES FOR WESTINGHOUSE E2 PLANTS WITH EFFECTIVE LENGTH BETWEEN LOWER JOINT AND LAST UPPER JOINT............................................................................... 8-22 TABLE 8-3A AXIAL THERMAL LOADS IN SLEEVE WITH TUBE UNLOCKED AND LOCKED INTO TUBE SUPPORT FOR CE PLANTS WITH 0.048" TUBE WALL ................... 8-23 TABLE 8-3B AXIAL THERMAL LOADS IN SLEEVE WITH TUBE UNLOCKED AND LOCKED INTO TUBE SUPPORT FOR CE PLANTS WITH 0.042" TUBE WALL ................... 8-23 WCAP-15918-NP July 2019 Revision 3

• • • This record was final approved on 8/1/2019 2:53:39 PM. (This statement was added by the PRIME system upon its validation)

Westinghouse Non-Proprietary Class 3 vi TABLE 8-3C AXIAL THERMAL LOADS IN SLEEVE WITH TUBE UNLOCKED AND LOCKED INTO TUBE SUPPORT FOR WESTINGHOUSE D3 PLANTS.................................. 8-24 TABLE 8-3D AXIAL THERMAL LOADS IN SLEEVE WITH TUBE UNLOCKED AND LOCKED INTO TUBE SUPPORT FOR WESTINGHOUSE D4 PLANTS.................................. 8-24 TABLE 8-3E AXIAL THERMAL LOADS IN SLEEVE WITH TUBE UNLOCKED AND LOCKED INTO TUBE SUPPORT FOR WESTINGHOUSE D2 PLANTS.................................. 8-25 TABLE 8-3F AXIAL THERMAL LOADS IN SLEEVE WITH TUBE UNLOCKED AND LOCKED 8-25 TABLE 8-3G AXIAL THERMAL LOADS IN SLEEVE WITH TUBE UNLOCKED AND LOCKED INTO TUBE SUPPORT FOR WESTINGHOUSE E2 PLANTS .................................. 8-26 TABLE 8-4A TUBE SLEEVE EXPANSION SECTION - TRANSIENTS CONSIDERED FOR A CE PLANT .......................................................................................................................... 8-33 TABLE 8-4B TUBE SLEEVE EXPANSION SECTION - TRANSIENTS CONSIDERED FOR A WESTINGHOUSE D OR E PLANT ............................................................................ 8-34 TABLE 8-5A STRESSES IN SLEEVE FOR CE PLANTS WITH 0.048" TUBE WALL ...................... 8-37 TABLE 8-5B STRESSES IN SLEEVE FOR CE PLANTS WITH 0.042" TUBE WALL ...................... 8-37 TABLE 8-5C STRESSES IN SLEEVE FOR WESTINGHOUSE D3 PLANTS .................................... 8-38 TABLE 8-5D STRESSES IN SLEEVE FOR WESTINGHOUSE D4 PLANTS .................................... 8-38 TABLE 8-5E STRESSES IN SLEEVE FOR WESTINGHOUSE D2 PLANTS..................................... 8-39 TABLE 8-5F STRESSES IN SLEEVE FOR WESTINGHOUSE D5 PLANTS ..................................... 8-39 TABLE 8-5G STRESSES IN SLEEVE FOR WESTINGHOUSE E2 PLANTS .................................... 8-40 TABLE 8-6A PRIMARY AND SECONDARY STRESSES AND STRESS INTENSITIES ON INSIDE SURFACE OF SLEEVE WITH LOCKED AND INTACT TUBE FOR CE PLANTS WITH 0.048" TUBE WALL .......................................................................................... 8-42 TABLE 8-6B PRIMARY AND SECONDARY STRESSES AND STRESS INTENSITIES ON INSIDE SURFACE OF SLEEVE WITH LOCKED AND INTACT TUBE FOR CE PLANTS WITH 0.042" TUBE WALL .......................................................................................... 8-42 TABLE 8-6C PRIMARY AND SECONDARY STRESSES AND STRESS INTENSITIES ON INSIDE SURFACE OF SLEEVE WITH LOCKED AND INTACT TUBE FOR WESTINGHOUSE D3 PLANTS .................................................................................. 8-43 TABLE 8-6D PRIMARY AND SECONDARY STRESSES AND STRESS INTENSITIES ON INSIDE SURFACE OF SLEEVE WITH LOCKED AND INTACT TUBE FOR WESTINGHOUSE D4 PLANTS .................................................................................. 8-43 TABLE 8-6E PRIMARY AND SECONDARY STRESSES AND STRESS INTENSITIES ON INSIDE SURFACE OF SLEEVE WITH LOCKED AND INTACT TUBE FOR WESTINGHOUSE D2 PLANTS .................................................................................. 8-44 WCAP-15918-NP July 2019 Revision 3

• • • This record was final approved on 8/1/2019 2:53:39 PM. (This statement was added by the PRIME system upon its validation)

Westinghouse Non-Proprietary Class 3 vii TABLE 8-6F PRIMARY AND SECONDARY STRESSES AND STRESS INTENSITIES ON INSIDE SURFACE OF SLEEVE WITH LOCKED AND INTACT TUBE FOR WESTINGHOUSE D5 PLANTS .................................................................................. 8-44 TABLE 8-6G PRIMARY AND SECONDARY STRESSES AND STRESS INTENSITIES ON INSIDE SURFACE OF SLEEVE WITH LOCKED AND INTACT TUBE FOR WESTINGHOUSE E2 PLANTS ................................................................................... 8-45 TABLE 8-7A PEAK STRESS INTENSITY ON INSIDE SURFACE OF SLEEVE WITH LOCKED AND INTACT TUBE FOR CE PLANTS WITH 0.048" TUBE WALL ................................. 8-47 TABLE 8-7B PEAK STRESS INTENSITY ON INSIDE SURFACE OF SLEEVE WITH LOCKED AND INTACT TUBE FOR CE PLANTS WITH 0.042" TUBE WALL ................................. 8-47 TABLE 8-7C PEAK STRESS INTENSITY ON INSIDE SURFACE OF SLEEVE WITH LOCKED AND INTACT TUBE FOR WESTINGHOUSE D3 PLANTS ............................................... 8-48 TABLE 8-7D PEAK STRESS INTENSITY ON INSIDE SURFACE OF SLEEVE WITH LOCKED AND INTACT TUBE FOR WESTINGHOUSE D4 PLANTS ............................................... 8-48 TABLE 8-7E PEAK STRESS INTENSITY ON INSIDE SURFACE OF SLEEVE WITH LOCKED AND INTACT TUBE FOR WESTINGHOUSE D2 PLANTS ............................................... 8-49 TABLE 8-7F PEAK STRESS INTENSITY ON INSIDE SURFACE OF SLEEVE WITH LOCKED AND INTACT TUBE FOR WESTINGHOUSE D5 PLANTS ............................................... 8-49 TABLE 8-7G PEAK STRESS INTENSITY ON INSIDE SURFACE OF SLEEVE WITH LOCKED AND INTACT TUBE FOR WESTINGHOUSE E2 PLANTS ............................................... 8-50 TABLE 8-8A ACCUMULATED FATIGUE IN SLEEVE MATERIAL FOR Spxr PEAK STRESS RANGE FOR CE PLANTS WITH 0.048" TUBE WALL ............................................ 8-50 TABLE 8-8B ACCUMULATED FATIGUE IN SLEEVE MATERIAL FOR Spxr PEAK STRESS RANGE FOR CE PLANTS WITH 0.042" TUBE WALL ............................................ 8-51 TABLE 8-8C ACCUMULATED FATIGUE IN SLEEVE MATERIAL FOR Spxr PEAK STRESS RANGE FOR WESTINGHOUSE D3 PLANTS ........................................................... 8-51 TABLE 8-8D ACCUMULATED FATIGUE IN SLEEVE MATERIAL FOR Spxr PEAK STRESS RANGE FOR WESTINGHOUSE D4 PLANTS ........................................................... 8-51 TABLE 8-8E ACCUMULATED FATIGUE IN SLEEVE MATERIAL FOR Spxr PEAK STRESS RANGE FOR WESTINGHOUSE D2 PLANTS ........................................................... 8-52 TABLE 8-8F ACCUMULATED FATIGUE IN SLEEVE MATERIAL FOR Spxr PEAK STRESS RANGE FOR WESTINGHOUSE D5 PLANTS ........................................................... 8-52 TABLE 8-8G ACCUMULATED FATIGUE IN SLEEVE MATERIAL FOR Spxr PEAK STRESS RANGE FOR WESTINGHOUSE E2 PLANTS ........................................................... 8-52 TABLE 10-1 TYPICAL SLEEVE TO PLUG EQUIVALENCY RATIO ................................................ 10-2 WCAP-15918-NP July 2019 Revision 3

• • • This record was final approved on 8/1/2019 2:53:39 PM. (This statement was added by the PRIME system upon its validation)

Westinghouse Non-Proprietary Class 3 viii LIST OF FIGURES FIGURE 4-1 LEAK LIMITING TZ SLEEVE ........................................................................................ 4-12 FIGURE 4-2 LEAK LIMITING TS SLEEVE......................................................................................... 4-13 FIGURE 4-3 LEAK LIMITING TZ SLEEVE INSTALLATION ........................................................... 4-14 FIGURE 4-4 LEAK LIMITING TS SLEEVE INSTALLATION ........................................................... 4-15 FIGURE 4-5 TUBE CONDITIONING TOOL ........................................................................................ 4-16 FIGURE 4-6 SLEEVE EXPANSION TOOL .......................................................................................... 4-17 FIGURE 4-7 SLEEVE ROLLING TOOL ............................................................................................... 4-18 FIGURE 5-1 TZ SLEEVE PRESSURE BOUNDARY DESCRIPTION .................................................. 5-5 FIGURE 5-2 TS SLEEVE PRESSURE BOUNDARY DESCRIPTION .................................................. 5-6 FIGURE 6-1 ALLOY 800 SLEEVE WORLDWIDE INSTALLATIONS .............................................. 6-12 FIGURE 6-2 SLEEVE CORROSION SPECIMEN ................................................................................ 6-13 FIGURE 7-1 AXIAL LOAD/CYCLIC LOAD-TZ TEST ASSEMBLY .................................................. 7-20 FIGURE 7-2 AXIAL LOAD TEST SET-UP ........................................................................................... 7-21 FIGURE 7-3 CYCLIC LOAD TEST ASSEMBLY-INTACT TUBE ....................................................... 7-22 FIGURE 7-4 CYCLIC LOAD TEST ASSEMBLY-SEVERED TUBE ................................................... 7-23 FIGURE 7-5 TS LEAK TEST ASSEMBLY............................................................................................ 7-24 FIGURE 7-6 LOCKED TUBE TEST FIXTURE .................................................................................... 7-25 FIGURE 7-7 AVERAGE LEAK RATE PROJECTIONS FOR DIFFERENT PS ............................... 7-26 FIGURE 7-8 95% CONFIDENCE ON MEAN PROJECTIONS OF LEAK RATE ............................... 7-27 FIGURE 8-1 MECHANICAL SLEEVE/TUBE ASSEMBLY ................................................................ 8-55 FIGURE 8-2 SYSTEM SCHEMATIC FOR WORST CASE CE PLANT WITH EFFECTIVE LENGTH BETWEEN LOWER JOINT AND LAST UPPER JOINT................................... 8-56 FIGURE 8-3 SYSTEM SCHEMATIC FOR WESTINGHOUSE D & E PLANTS WITH EFFECTIVE LENGTH BETWEEN LOWER JOINT AND LAST UPPER JOINT................................... 8-57 FIGURE 8-4 MODEL OF SLEEVE, LOWER TUBE, AND TUBE IN TUBESHEET; UNLOCKED AT TUBE SUPPORT ................................................................................................................... 8-58 FIGURE 8-5 MODEL OF COMPOSITE MEMBER, UPPER TUBE, SURROUNDING TUBES, AND TUBESHEET; LOCKED AT TUBE SUPPORT ................................................................... 8-59 WCAP-15918-NP July 2019 Revision 3

• • • This record was final approved on 8/1/2019 2:53:39 PM. (This statement was added by the PRIME system upon its validation)

Westinghouse Non-Proprietary Class 3 ix THIS PAGE INTENTIONALLY LEFT BLANK WCAP-15918-NP July 2019 Revision 3

• • • This record was final approved on 8/1/2019 2:53:39 PM. (This statement was added by the PRIME system upon its validation)

Westinghouse Non-Proprietary Class 3 1-1

1.0 INTRODUCTION

1.1 PURPOSE The purpose of this generic report is to document the acceptability of an Alloy 800 sleeve in a hot or cold leg steam generator tube of Combustion Engineering (CE) and Westinghouse designed steam generators with 0.750-inch OD Alloy 600 tubes. The report includes sufficient information to support a technical specification change allowing installation of these sleeves. The sleeves are designed to be installed in steam generator tubes spanning the defective section. This report demonstrates that reactor operation with sleeves installed in the steam generator tubes will not increase the probability or consequence of a postulated accident condition previously evaluated.

Also, it will not create the possibility of a new or different kind of accident and will not reduce the existing margin of safety.

Westinghouse provides two types of leak limiting Alloy 800 sleeves. The first type of sleeve spans the transition zone (TZ) of the parent steam generator tube at the top of the tubesheet. This sleeve is hydraulically expanded into the steam generator tube at the upper end and is hard rolled into the tube within the steam generator tubesheet. The Westinghouse Alloy 800 sleeve design is an evolution of the Asea Brown Boveri (ABB) CE PLUSS sleeve design. The two designs are essentially identical; the only difference being the addition of the nickel band applied to the sleeve OD in the lower roll expansion joint region. The nickel band was added as an additional barrier to leakage through the tube-sleeve joint. The nominal nickel band thickness is 0.002 inch and extends for an axial length of 0.5 inch; the nickel band is located on the lower half of the roll expansion length. A 0.5-inch-wide microlok band is applied to the tube at the upper half of the roll joint. The microlok band is a thermally applied material like the sleeve material which acts to increase the coefficient of friction between the tube and sleeve, thus increasing axial load bearing capability of the sleeve joint. Currently only nickel banded tube sleeves are licensed domestically for installation to address top of tubesheet cracks. To date, the NRC staff has only approved a limited life cycle for the nickel banded sleeves due to the ability to Eddy current (ET) inspect through the nickel band. Elimination of the nickel band for the repair of the steam generator tubes, as described in this report, is expected to eliminate the regulatory concerns related to ET inspection of the parent tube wall adjacent to the sleeve nickel band. By doing so, the allowable service life of the non-nickel banded sleeve is no longer expected to be limited. The second type of sleeve spans degraded areas of the steam generator tube at a tube support (TS) elevation or in a free span section. The sleeve used for both locations is called a TS sleeve. This TS sleeve is hydraulically expanded into the steam generator tube near each end of the sleeve. The tube support or free span sleeve does not contain a nickel band. It also does not have a limited service life.

The steam generator tube with the installed sleeve meets the structural requirements of tubes which are not degraded. Even in the event of the severance of the steam generator tube, the sleeve will provide the required structural support and acceptable leakage between the primary and secondary systems for normal operating and accident conditions. Design criteria for the sleeve were prepared to ensure that all design and licensing requirements are considered. Extensive analyses and testing have been performed on the sleeve and sleeve to tube joints to demonstrate that these design criteria are met. The effect of sleeve installation on steam generator heat removal capability and system flow rate are also discussed in this report.

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Westinghouse Non-Proprietary Class 3 1-2 After sleeves are installed, a baseline examination is performed using ET techniques. The ET examination is used to verify certain installation process steps, as well as to provide a baseline to determine if there is sleeve degradation or degradation of the pressure boundary portion of the steam generator tube spanned by the sleeve in later operating years. The ET examination and criteria for plugging sleeved generator tubes if there is degradation are described in this report.

Plugs will be installed if for any unforeseen circumstance that a sleeve installation is not successful or if there is degradation in the pressure boundary section of the sleeves or sleeved steam generator tubes. Standard, site approved, mechanical or welded plugs installed at each end of a steam generator tube may be used to take a sleeved tube out of service.

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Westinghouse Non-Proprietary Class 3 1-3

1.2 BACKGROUND

The operation of pressurized water reactor (PWR) steam generators has, in some instances, resulted in localized corrosive attack on the inside (primary side) or outside (secondary side) of the steam generator tubing. Historically, the corrective action taken for severe steam generator tube wall degradation has been to install plugs at the inlet and outlet of the steam generator tube when the degradation reached a value referred to as a plugging criterion. ET examination has been used to measure steam generator tubing degradation with the tube plugging criterion accounting for ET measurement uncertainties and degradation growth rate.

Installation of steam generator tube or sleeve plugs removes the plugged tube from service, eliminating the heat transfer surface associated with that tube. In addition, plug installation leads to reduction in the primary coolant flow available for core cooling. The repair technique described in this report for installation of sleeves allows the steam generator tube to remain in service, with minimal effect on heat transfer surface and coolant flow. The sleeves are installed at the local area of tube wall degradation and impose only a minor restriction to primary coolant flow. Thus, while providing structural integrity to the weakening effect of tube wall degradation, the effects on heat transfer and primary coolant flow are minimized.

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Westinghouse Non-Proprietary Class 3 2-4 2.0

SUMMARY

AND CONCLUSIONS This report has been prepared and reviewed in accordance with 10 CFR 50, Appendix B.

The Alloy 800 sleeve is similar to many other sleeves, except new features are provided to improve the design as follows:

No welding, brazing, or heat treatment is required, thereby greatly reducing the complexity of the installation process.

The strain within the tube is low, thereby reducing the likelihood of future corrosion cracking. Specifically, the target tube diametrical expansion is between [

]a,c which is significantly lower than other mechanical sleeve designs.

To utilize its attractive features, the Alloy 800 sleeve is a leak limiting design. Specifically, a small leakage, well within all requirements, will be permitted.

The Alloy 800 sleeves were designed to the applicable ASME Boiler and Pressure Vessel Code.

An extensive analysis and test program were undertaken to prove the adequacy of both the upper and lower mechanically expanded joints. This program determined the effect of normal operating and postulated accident conditions on the sleeve tube assembly, as well as the adequacy of the assembly to perform its intended function. The mechanical testing verified that the sleeve meets the cyclic load requirements of the original plant design. In addition, to fully confirm the adequacy of these repairs for U.S. plants, primary and secondary side caustic corrosion tests have been completed and the results evaluated relative to previous testing performed in support of both the Alloy 800 sleeve and the TIG welded sleeve.

The proposed repair has no significant effect on the configuration of the plant, and the change does not affect the way in which the plant is operated. The sleeve was designed to meet criteria that would prove the sleeve is an acceptable repair technique. These criteria conformed to the stress limits and margins of safety in Section III of the ASME B&PV Code. Based upon the results of the analytical and test programs described in this report the Alloy 800 sleeve fulfills the intended function as a leak limiting structural member and meets or exceeds all the established design criteria. Installation of the sleeves will conform to ASME B&PV Code Section XI, IWA-4420.

Evaluation of the sleeved tubes indicates no detrimental effects on the sleeve-tube assembly resulting from reactor system flow, coolant chemistries, or thermal and pressure conditions.

Structural analyses of the sleeve-tube assembly, using the demonstrated margins of safety, establish its integrity under normal and accident conditions. The structural analyses have been performed for both TZ and TS sleeves. The TZ sleeves have a length of up to [ ]a,c inches which spans the degraded tube section at the top of the tubesheet and generally places the expansions above the sludge pile. The TS sleeves have a length of up to [ ]a,c inches for a sleeve spanning a tube support section of the tube or a tube free span. The analyses also address the sleeve to plug equivalency with respect to system thermal and hydraulic effects for installation of one TZ sleeve or one tube support sleeve. Acceptable sleeve locations covered in this report are from the top of the tubesheet up to and including the u-bend/square bend region in both the hot and cold legs. The WCAP-15918-NP July 2019 Revision 3

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Westinghouse Non-Proprietary Class 3 2-5 analyses were performed for CE and Westinghouse designed plants with 3/4-inch Alloy 600 steam generator tubes. A TZ sleeve with a length of [ ]a,c inches would result in an approximately a,c

[ ] inch span between the top-of-tubesheet and the lowermost part of the sleeve/tube joint above the tubesheet.

Mechanical testing has been performed to support the analyses prepared using ASME code stress allowables. Corrosion testing of typical sleeve-tube assemblies have been completed and reveal no evidence of sleeve or tube corrosion considered detrimental under anticipated service conditions.

In addition to the analysis and test program discussed in this report, a significant number of sleeves have been in operation for several years with no service induced degradation. Additionally, no detectable leakage has been associated with a tube with an Alloy 800 leak limiting sleeve. Many Alloy 800 sleeve installations have occurred in Europe and Asia using the PLUSS sleeve. These installations were performed by the Westinghouse Mannheim office. The PLUSS design is essentially identical to the Alloy 800 sleeve installed in the U.S. except the PLUSS sleeve does not include nickel banding at the lower joint region. To date, Westinghouse is not aware of any reports of parent tube degradation in the lower joint roll region for any Westinghouse sleeve design.

Of the greater than 14,000 Alloy 800 tubesheet sleeve installations, nearly all are/were installed at plants using Alloy 600 mill annealed tubing. The only tubesheet sleeve installations in non-mill annealed tubing were two Korean plants that used Alloy 600 thermally treated tubing.

Another approximate 12,000 tube support plate sleeves were installed by Westinghouse in Korea starting in approximately 2013. These are/were installed in plants using both mill annealed and thermally treated Alloy 600 tubing.

An extensive history of Westinghouse hybrid expansion joint (HEJ) and laser welded sleeve (LWS) installations also supports the conclusion that degradation of the parent tube adjacent to the roll expansion at the lower sleeve joint is not anticipated. Neither of these designs includes nickel application to the sleeve OD. The sleeve material is Alloy 690 or in the case of one plant, Alloy 690 with an Alloy 625 cladding on the entire length of the sleeve OD. Westinghouse is not aware of, and has no knowledge of, any reports of parent tube stress corrosion cracking (SCC) in the sleeve roll joint region for any Westinghouse sleeve design.

ET examination is used to verify certain installation process steps, as well as to provide a baseline to determine if there is sleeve degradation or degradation of the pressure boundary portion of the steam generator tube spanned by the sleeve in later operating years. The ET examination of the Alloy 800 sleeves described in this report has been successfully qualified for detection of critical flaw sizes in both the sleeve and parent tube to Appendix H of the EPRI Steam Generator Examination Guidelines, Rev. 5, September 1997.

Based upon the testing and analyses performed, the sleeves do not result in a significant increase in the probability of occurrence or consequence of an accident previously evaluated, create the WCAP-15918-NP July 2019 Revision 3

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Westinghouse Non-Proprietary Class 3 2-6 possibility for a new or different kind of accident, or result in a significant reduction in a margin of safety.

In conclusion, the Alloy 800 mechanical sleeve is established as an acceptable repair method.

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Westinghouse Non-Proprietary Class 3 2-7 THIS PAGE INTENTIONALLY LEFT BLANK WCAP-15918-NP July 2019 Revision 3

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Westinghouse Non-Proprietary Class 3 3-1 3.0 ACCEPTANCE CRITERIA The objective of installing sleeves in steam generator tubes is twofold. The sleeve must maintain structural integrity of the steam generator tube during normal operating and postulated accident conditions and the sleeve must limit the primary to secondary leakage in the event of a through wall defect in the section of the steam generator tube spanned by the sleeve. Numerous tests and analyses were performed to demonstrate the capability of the sleeves to perform these functions under normal operating and postulated accident conditions. In doing so, the conditions for all the CE and Westinghouse D and E Series operating plants with 3/4-inch Inconel 600 tubes were considered. Although the absolute values may differ from those at any specific plant, the evaluations are a function of the differential pressures and temperatures which are bounded by the conservative design basis values below.

All CE Plants Westinghouse D & E Series Plants Primary Side 608.6 °F 2250 psia 620 °F (operating) 2250 psia (operating) (operating) (operating) 650 °F 2500 psia (design) 650 °F 2500 psia (design)

(design) (design)

Secondary Side 505.8°F (operating) 790 psia 526.5°F 877 psia (operating) (operating) (operating)

Note 1 560 °F (design) 1100 psia (design) 570 °F (design) 1200 psia (design)

Accident Conditions Primary to 2560 psi Primary to 2850 psi Secondary (MSLB/FLB) Secondary (MSLB)

Pressure Note 2 Pressure Secondary to 1170 psi (LOCA) Secondary to 1198 psi Primary Pressure Primary (LOCA)

Pressure Note 1: The secondary side pressure was conservatively reduced to 790 psig based on the effect of future plugging and sleeving.

Note 2: For the purposes of pressure differential conditions at CE plants, both the main steam line break (MSLB) and feedwater line break (FLB) are 2560 psig.

Table 3-1 provides a summary of the criteria established for sleeving to demonstrate the acceptability of the Alloy 800 sleeving techniques. Justification for each of the criterion is provided. Results indicating the minimum level with which the sleeves surpassed the criteria are tabulated. The section of this report describing tests or analyses which verify the characteristics for a criterion is referenced in the table.

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Westinghouse Non-Proprietary Class 3 3-2 TABLE 3-1 SLEEVING CRITERIA Reference Criterion Approach Results Section

1. Sleeve-tube assembly structural Sleeve-tube assembly meets 8.0 integrity must be maintained for applicable ASME Code normal operating and accident requirements, including fatigue.

condition per SAR. a,c

2. Sleeve/tube joint load capability Factor of safety of 3 for normal 7.0 3 times normal p (4380 psi) operating conditions and 1.4 for and 1.4 times steam line break accident. b p (3990 psi) even for a severed tube.

3. Sleeve/tube joint load/ No degradation of leak limiting 7.0 deflection capability sufficient or structural load capability for b for thermal expansion effects worst case thermal expansion with non- severed or severed cycles.

tube even if tube locked within tube supports.

4. Pressurization of annulus Prevention of sleeve failure 7.0 between sleeve and tube does based on tests. b not collapse sleeve during LOCA (1198 psi)

5. Exposure of sleeve-tube Demonstrate by corrosion 6.0 assembly to various primary testing and experience that and secondary chemistries sleeve-tube assembly corrosion without loss of functional resistance is adequate integrity. a,c WCAP-15918-NP July 2019 Revision 3

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Westinghouse Non-Proprietary Class 3 3-3 TABLE 3-1 (Continued)

SLEEVING CRITERIA Reference Criterion Approach Results Section

6. Non-destructive exam of tube Periodic exams of tubes and [ 5.0 and sleeve pressure boundary sleeves are required to verify with levels of detectability structural adequacy. Plug sufficient to show structural sleeved tube for any real adequacy. degradation, irrespective of indicated penetration. b

7. Sleeve installation to Allowable leakage established 7.0 satisfactorily limit leakage by user per technical under normal and accident specification and other conditions. requirements (site boundary dose). Number of installed sleeves limited as needed with suitable margin assuming all sleeved tubes have through wall leakage paths.

b

8. Sleeve installation effect on Allowable reduction in reactor 10.0 system flow rate or heat coolant flow rate limited by transfer capability of the steam user per technical generator is acceptable. specifications. Number of installed sleeves limited as needed. Steam pressure reduction due to reduced heat b transfer to be limited by user based on commercial considerations.

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Westinghouse Non-Proprietary Class 3 4-4 4.0 DESIGN DESCRIPTION OF SLEEVES AND INSTALLATION EQUIPMENT 4.1 SLEEVE DESIGN DESCRIPTION The sleeve for defects at the top of the tubesheet, called a transition zone (TZ) sleeve, is shown in Figure 4-1. The sleeve for defects at tube support plates or egg crates, called a tube support (TS) sleeve, is shown in Figure 4-2. These Alloy 800 sleeves have a nominal outside diameter of [

]a,c and a minimum wall thickness of [ ]a,c Each sleeve type includes a chamfer at both ends to provide a lead in for equipment used to install the sleeve and to facilitate the inspection of the parent tube and sleeve. The TZ sleeve is [ ]a,c long while the TS sleeve is [ ]a,c long. [

]a,c The TZ sleeve includes a thermally sprayed nickel alloy band at the lower end. The thermally sprayed nickel alloy band contains a rough surface finish which enhances the strength of the rolled mechanical joint. Based on the flow loss analysis detailed in Section 10, either sleeve type may be used in a steam generator tube. The flow loss analyses addressed up to two tube support sleeves in a steam generator tube and the combination of up to two TS sleeves and one TZ sleeve in the same tube.

4.2 SLEEVE MATERIAL SELECTION The Alloy 800 tubing, from which the sleeves are fabricated, is procured to the requirements of the ASME B&PV Code Section II, Part B, SB-163, NiFeCr Alloy UNS N08800, and Section III, subsection NB-2000. Additional requirements, as stated in the material specification (Reference 4.7.1), are applied including a limit on [

]a,c Other elements, [ ]a,c are also more tightly controlled within the ASME specification limits. The final annealing temperature is specified as [

]a,c The yield strength is specified to be between [ ]a,c at 68°F.

The selection criteria for the sleeve material were its [

]a,c and its excellent corrosion resistance in both primary side and faulted secondary PWR environments (Reference 4.7.2). Westinghouses justification for selection of this material and condition is based on the data discussed in Section 6.0.

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Westinghouse Non-Proprietary Class 3 4-5 The following typical high temperature data has been used to assess the response of the sleeve/tube assembly under severe accident conditions.

Alloy 600 Alloy 800 Yield Ultimate Yield Ultimate Temperature Strength Strength Strength Strength (F)

(ksi) (ksi) (ksi) (ksi)

R.T. min. 35 80 30 75 1200 25.6 54.4 20.7 45.2 1500 12.8 23.4 10.7 21.3 4.3 SLEEVE-TUBE ASSEMBLY The installed sleeve is shown in Figure 4-3 for a transition zone repair and in Figure 4-4 for a repair at a tube support. The [ ]a,c long sleeve spans the defective region of the steam generator tube at the top of the tubesheet in the TZ. [

]a,c The sleeve installed at a tube support (TS) elevation or in a free span section of the steam generator tube is [ ]a,c long. [

]a,c A plant-specific document specifies the allowable locations of tube ET indications to perform a successful sleeve installation. This criterion is utilized to determine whether a tube is an acceptable sleeving candidate. Indications outside of the acceptable locations would not be sleeved.

A sleeve installed in a steam generator tube, which does not meet the minimum requirements, details of which are discussed in Section 9.0, may be re-rolled, for the rolled joint, or re-expanded for the hydraulic expansion.

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Westinghouse Non-Proprietary Class 3 4-6 4.4 PLUGGING OF A DEFECTIVE SLEEVED TUBE In the unlikely event that a sleeved steam generator tube is found to have an unacceptable defect in the pressure boundary portion of the tube or sleeve, the steam generator tube can be taken out of service by installing standard, site approved mechanical or welded plugs at both ends of the tube. Additionally, should either of the joints not attain the required expansion/torque ranges within the number of allowed re-applications, not be positioned at the proper elevation, or have the required expansion spacing, the sleeve installation would be considered unacceptable and the tube plugged in accordance with installation procedures.

4.5 SLEEVE INSTALLATION EQUIPMENT The equipment used for remote installation of sleeves in a steam generator is made up of the following basic systems. These systems are:

1. Remote controlled manipulator

2. Tool delivery equipment

3. Sleeve installation/expansion equipment

4. Sleeve rolling equipment

5. Nondestructive examination equipment These systems, when used together, allow installation of the sleeves without entering the steam generator, hence reducing personnel exposure to radiation.

The tooling and methods described in the following sections represent the present technology for leak limiting sleeve installation. As technological advances are made in sleeve installation to improve the installation rate and/or decrease the personnel exposure, the new tooling and/or processes may be utilized after they have been laboratory-verified to provide improved sleeve installation methods.

4.5.1 Remote Controlled Manipulator The remote-controlled manipulator serves as a transport vehicle for inspection or repair equipment inside a steam generator primary head. These sleeves can be delivered off a multitude of different manipulators, including the ROSATM robotic manipulator and PEGASYS1 robot manipulator systems.

The ROSA system utilizes a tubesheet mounted base plate. The system has an arm configuration with a varying number of joints. These joints provide the degrees of freedom required for delivery 1

ROSA and PEGASYS are trademarks or registered trademarks of Westinghouse Electric Company LLC, its affiliates and/or its subsidiaries in the United States of America and may be registered in other countries throughout the world. All rights reserved. Unauthorized use is strictly prohibited. Other names may be trademarks of their respective owners.

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Westinghouse Non-Proprietary Class 3 4-7 of the tooling to the steam generator tube. Each arm is moved independently with position controlled electric motors. The arm allows motion for tool alignment in both square pitch and triangular pitch tube arrays. The PEGASYS system is a finger walker design which precisely aligns the end effector below the tube. Computer control of the manipulator allows the operator to move and position sleeving tools accurately below the steam generator tube to be sleeved.

4.5.2 Tool Delivery Equipment The purpose of the tool delivery equipment is to support and vertically position the various tools required for the sleeving operations. The tool delivery system consists of two major components; a probe pusher located outside the steam generator and a guide conduit extending from the probe pusher to the adapter on the robotic arm.

The probe pusher is an OMNI 200 or similarly configured drive system. The probe pusher is located outside the steam generator, adjacent to the manway. The guide conduit extends from the probe pusher to the adapter block located on the manipulator. The adapter block includes a fitting for mounting on the manipulator. Two pins extending above the adapter block are used to align the guide conduit relative to adjacent tube locations.

A remotely actuated sleeve loader may be used in conjunction with the probe pusher delivery system. The sleeve loader consists of a magazine mounted on an actuator which positions a single sleeve for insertion into the steam generator.

Alternate Sleeve Delivery Equipment As an alternate to the probe pusher delivery system, a tool driver mounted directly on the robotic arm can deliver the sleeves.

The tool driver is attached to the end of the manipulator arm by a fitting and lock mechanism. The tool driver includes two sets of gripper wheels that work in conjunction with one another to insert or withdraw the tool. The drive grippers are powered by electric motors to insert and remove the various sleeving tools and the sleeve into the steam generator tube. Vertical positioning of the tool is accomplished by using hardstops and/or visual references that are verified by using a small camera located on the tool driver.

4.5.3 Tube Conditioning Equipment Per the test program described in Reference 4.7.3, the equipment associated with this process step has been removed from the sleeve installation process.

4.5.4 Sleeve Positioning/Expansion Equipment The sleeve expansion equipment is used to provide the required structural fit-up of the sleeve at the upper end, for a TZ, and at both the upper and lower joints for a TS location. The expansion of the sleeve is performed with a tool that makes [ ]a,c simultaneously.

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Westinghouse Non-Proprietary Class 3 4-8 The expansion tool is then repositioned for the remaining [ ]a,c in an expansion joint.

The minimum distance between expansion joints for a a,c TS sleeve which must span a tube defect based on Figure 4-4 is a,c This will adequately cover a maximum tube defect axial length of considering the sleeve elevation tolerance of a,c a,c This span will also adequately cover the uncertainty in the elevation of the tube support plate or eggcrate support.

The sleeve is located on the sleeve expansion tool by a sleeve hardstop approximately the same OD as the sleeve. The expansion tool functions to guide the sleeve into the tube and install the sleeve to the selected elevation within the steam generator tube. For both the TZ and TS sleeves a tool hardstop on the sleeve expansion tool, which contacts the tube end is provided for proper sleeve vertical positioning within the steam generator tube. Once the sleeve is at the proper elevation within the steam generator tube, it is hydraulically expanded.

The expansion tool, shown in Figure 4-6, consists of a mandrel and a bladder. The bladder contains the water that is used as the pressurization fluid. The expansion tool simultaneously performs a,c per expanded joint. The expansion tool is then repositioned within the sleeve a,c For a sleeve at a TZ elevation, the expansion tool is a,c For a sleeve at a TS elevation, the expansion tool is a,c The sleeve is located on the expansion tool prior to insertion in the steam generator tube. A low-pressure hold is applied to the bladder to secure the sleeve on the expansion tool without distortion of the sleeve. When the sleeve is in position within the tube, the hydraulic expansion tool is pressurized, expanding the bladder directly against the inside diameter of the sleeve causing expansion of the sleeve.

[

]a,c

[

]a,c WCAP-15918-NP July 2019 Revision 3

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Westinghouse Non-Proprietary Class 3 4-9 A sleeve not meeting the minimum criteria for hydraulic expansion may be re-expanded. Re-expansion would be required only if inadequate volume is injected into the bladder and applied to the sleeve/tube assembly. Operator error is eliminated by use of the repair software loaded on the workstation for parameter control. There is no operator control of the process, other than to terminate it. Only a malfunction in the system such as a loss of power, burst expansion bladder, leaking fittings, or other equipment failure would produce such a result. Pre-operational equipment calibration, functional checks, and periodic bladder replacement are included in the installation process procedures to minimize these events. Should an acceptable joint not be obtained after the allowed number of re-expansions, the tube would be plugged. Verification of this process is discussed in Section 9.3.2.

4.5.5 Sleeve Rolling Equipment The sleeve rolling equipment is used to expand the lower end of the TZ sleeve into contact with the steam generator tube within the tubesheet, forming a strong leak tight joint. The rolling tool is positioned within the steam generator tube by the manipulator. The rolling equipment consists of the air motor, the sleeve expander, torque readout, computer control and a torque calibration unit.

The sleeve expander includes a shoulder which supports the bottom edge of the sleeve during the sleeve rolling process. The approximately [

]a,c on the lower end of the TZ sleeve. The sleeve is expanded to a torque which has been demonstrated by testing to provide a leak tight joint. A record of the rolling tool torque is taken by the computer for further evaluation of the rolling process for individual sleeves. A rolled joint that fails to meet the minimum torque criteria may be re-rolled. Such a failure almost always results from a loss of air pressure to the tool or, less frequently, from equipment damage. Pre-operational equipment calibration and functional checks are included in the installation process procedures to minimize these events. Should an acceptable roll not be obtained after the allowed number of re-rolls, the tube would be plugged. Experience with this process has shown re-rolling to be required in less than one-half of one percent of the cases. Verification of this process is discussed in Section 9.4.

The roll expander (Figure 4-7) used to hard roll the sleeve within the tubesheet has an effective length of approximately a,c The shoulder on the roll expander stops against the bottom of the sleeve during the rolling process. The sleeve is then rolled two times to a torque that results in a a,c sleeve wall reduction. This wall thinning is sufficient for leak/load requirements as well as providing adequate resistance for future corrosion cracking. The sleeve roller design and the rolling process are essentially a duplicate of those used for Westinghouses welded sleeve and mechanical plug installations. This process does not include hydraulic expansion of the sleeve before roll expansion.

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Westinghouse Non-Proprietary Class 3 4-10 4.5.6 Nondestructive Examination As described in Section 5, the +POINTTM2 Eddy current coil technology rotating probe will be used to perform an initial ET test acceptance and baseline inspection of 100% of the installed sleeves. Other ET coils and/or methods will be considered for any complementary inspection capability they may provide. The ET fixture, with conduit, is used on the manipulator arm to position the probe.

4.6 ALARA Considerations The steam generator repair operation is designed to minimize personnel exposure during installation of sleeves. The manipulator is installed from the manway without entering the steam generator. It is operated remotely from a control station outside the containment building. The positioning accuracy of the manipulator is such that it can be remotely positioned without having to install templates in the steam generator.

The sleeve delivery system allows the sleeve to be positioned on the expansion tool outside the steam generator and away from the manway. The expansion tool and sleeve are then delivered into the steam generator remotely through the guide conduit, further reducing the number of operations performed in the manway. The conduit adapter is designed so that the fitting quickly attaches to the manipulator.

The tools are simple in design and most of the sleeving operations are performed remotely. Spare tools are provided so that tool repair at the manway is not required. If tool repair is necessary, the tool is removed and the sleeving operation continues using a spare tool. The tool may or may not be repaired during the outage but repair is performed in an area which does not result in significant radiation exposure.

Air, water and electrical supply lines for the tooling are designed and maintained so that they do not become entangled during operation. This minimizes personnel exposure outside the steam generator. All equipment is operated from outside containment.

Installation of the Alloy 800 sleeve is also expected to reduce personnel exposure over that required to plug a steam generator tube. The operations required to install an Alloy 800 sleeve are similar to those required to install a plug in a steam generator tube. The Alloy 800 sleeving operations, however, are performed in one channel head, saving the exposure associated with the plugging operations in the second plenum.

In summary, the steam generator operation is designed to minimize personnel exposure and is in full compliance with ALARA standards.

2

+POINT is a trademark or registered trademark of Zetec, Inc. Other names may be trademarks of their respective owners.

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Westinghouse Non-Proprietary Class 3 4-11

4.7 REFERENCES

FOR SECTION 4.0 4.7.1 Purchasing Specification for Alloy 800 Tubing, Specification No. 00000-OSW-020, Latest Revision.

4.7.2 Corrosion Resistance of SG Tubing Material, Incoloy 800 mod. and Inconel 690 TT, by R.

Kilian, N. Wieling, and L. Stieding, from Werkstoffe und Korrosion 42, pp. 490-496 (1991).

4.7.3 Westinghouse Report MRS-DFD-1929-SLV, Qualification of Alloy 800 Mechanical Sleeve for 0.75 x 0.048 Wall S.G. Tubes without Tube Conditioning.

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Westinghouse Non-Proprietary Class 3 4-12 a,c FIGURE 4-1 LEAK LIMITING TZ SLEEVE WCAP-15918-NP July 2019 Revision 3

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Westinghouse Non-Proprietary Class 3 4-13 a,c FIGURE 4-2 LEAK LIMITING TS SLEEVE WCAP-15918-NP July 2019 Revision 3

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Westinghouse Non-Proprietary Class 3 4-14 a,c FIGURE 4-3 LEAK LIMITING TZ SLEEVE INSTALLATION WCAP-15918-NP July 2019 Revision 3

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Westinghouse Non-Proprietary Class 3 4-15 a,c FIGURE 4-4 LEAK LIMITING TS SLEEVE INSTALLATION WCAP-15918-NP July 2019 Revision 3

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Westinghouse Non-Proprietary Class 3 4-16 This picture removed due to removal of tube conditioning step FIGURE 4-5 TUBE CONDITIONING TOOL WCAP-15918-NP July 2019 Revision 3

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Westinghouse Non-Proprietary Class 3 4-17 FIGURE 4-6 SLEEVE EXPANSION TOOL WCAP-15918-NP July 2019 Revision 3

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Westinghouse Non-Proprietary Class 3 4-18 FIGURE 4-7 SLEEVE ROLLING TOOL WCAP-15918-NP July 2019 Revision 3

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Westinghouse Non-Proprietary Class 3 5-1 5.0 SLEEVE EXAMINATION PROGRAM

5.1 BACKGROUND

The sleeve examination program entails a) candidate tube pre-installation examination, b) process verification, and c) post-installation baseline and subsequent in-service inspection.

A prerequisite for sleeve installation is that no detectable degradation be present in the parent tube at the location of the hydraulic or roll expansions. Therefore, Eddy current examination of candidate tubes in these areas is required prior to establishing the final list of tubes to be sleeved.

Requirements for this inspection are contained in Westinghouse procedures and inspection guidelines.

[

]a,c In addition, there will be an inspection process for the dual purposes of process verification for individual steps as well as confirmation of the pressure boundary integrity. ET inspection methods will be used for this purpose.

For process verification, the following inspections will be performed for all sleeves at all locations until sufficient confidence is developed to do otherwise:

[

]a,c For baseline in-service inspection (ISI), all sleeves and tubes will be examined for the full length of the pressure retaining part of the sleeve and the upper most and lower expansion transitions for both the roll and hydraulically expanded joints within the tube. The inspection will be performed WCAP-15918-NP July 2019 Revision 3

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Westinghouse Non-Proprietary Class 3 5-2 using the +POINT coil rotating probe. Other coils and/or methods will be considered for any complementary inspection capability they may provide.

ISI of the sleeved tubes will be done as part of the periodic inspection program of the steam generator tubing using ET testing techniques. The ET test method is a technique whereby electrical currents are induced electromagnetically from the test coil into the sleeves and parent tube material. The electrical currents are interrupted or impeded by the presence of flaws in the material which results in a change in the test coil impedance. This impedance change is processed and displayed on the test instrument to indicate the presence of a flaw. During the installation, all sleeves will be examined. A sampling program consistent with inspection requirements will be used for subsequent examinations. The ISI inspection will be performed using the +POINT coil rotating probe. Other coils and/or methods will be considered for any complementary inspection capability they may provide. The inspection method qualified has been used in several operating steam generators in the U.S. and overseas for both the initial installation acceptance and the subsequent in-service inspection. Over 25,000 sleeves have been installed and inspected at this writing.

The objective of the installation examination is to establish ISI baseline data and initial installation acceptance data on the primary pressure boundary of the sleeve-steam generator tube assembly.

The ET inspection method used has a documented qualification, Reference 5.3.1. This original qualification was performed in accordance with Appendix H of the EPRI PWR Steam Generator Examination Guidelines, Revision 5, dated September 1997. The essential variables in Revisions 5 and 8 were reviewed for any changes that may have affected the original qualification. The main change was the use of the OMNI 200 tester, for which Westinghouse has performed an equivalency test. Others such as test frequencies, motor units and probes remain unchanged. The essential variables specified in the Appendix H portion are documented and are used in the field procedures.

Also, an analysis procedure for interpreting data has been written and used for field inspections.

All data analysts are required to review the Appendix H report and the latest revision of the analysis guidelines prior to performing any data analysis. EPRI Appendix H guidelines specify that adequate flaw detection capability be demonstrated for flaws > 60% through-wall. For the purpose of this sleeve inspection qualification, this value was reduced to >50% through-wall for the parent tube and >45% for the sleeve in order to provide an operational margin between the detection limit and the structural limit for defect growth. For sleeves with minimum wall thickness, the structurally limiting flaw depth per Regulatory Guide 1.121, calculated using a conservative crack configuration model (Section 8.2), is 48%, and for the tube the limit is greater than 60%. A sufficient number of flaw samples has been used to demonstrate that the statistical requirements for probability of detection are met.

Based upon Westinghouses experience with the installation of Alloy 800 and TIG welded sleeves and the fact that Westinghouse has not established an ECT sizing error, it has been Westinghouses recommendation and the plant owners decision to plug a tube upon the detection of a defect in the pressure boundary portion of the sleeve.

[

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Westinghouse Non-Proprietary Class 3 5-3

[

]a,c The method used for sleeving inspections has been to establish detection capability with an operational margin relative to structurally limiting flaws and to plug flaws upon detection.

Accordingly, no attempt was made to size flaws or to leave detected flaws in service at this time.

By this approach, the sizing accuracy does not need to be quantified. If future developments provide a qualified flaw sizing technique, an updated Appendix H qualification report will be prepared in support of a utility submittal.

The pressure boundary for a TZ sleeve-tube assembly is: a) the entire sleeve except for the portion above the [ ]a,c hydraulic expansions, b) the steam generator tube above the hydraulic expansions and below the rolled joint and c) the steam generator tube behind the hydraulic expansion joint and rolled joint regions. The pressure boundary for a TS sleeve-tube assembly is:

a) the sleeve from the lower of the [ ]a,c expansions in the lower joint to and including the upper of the [ ]a,c expansions for the upper joint, b) the steam generator tube above the upper expansion joint and below the lower expansion joint and c) the steam generator tube behind the hydraulic expansion joint region.

Consequently, there are four distinct regions of the pressure boundary, as shown in Figures 5-1 and 5-2, that have been addressed in the Appendix H qualification report:

1. The sleeve-tube assembly at the mechanical joint region (either expansion or roll expansion transition).

2. The sleeve between and including the upper joints and lower joints (either expansion or rolled depending on sleeve type).

3. The pressure boundary region of the steam generator tube behind sleeve.

4. The un-sleeved region of the steam generator tube.

Westinghouse considered the transition zone of the sleeve/tube joints as the limiting areas of interest for the Appendix H program since the geometry change presented the greatest inspection challenge. Thus, EDM notches were placed in the sleeve and the tube at the expansion and rolled joints as part of the defect population. It has been shown that the presence of the microlok band WCAP-15918-NP July 2019 Revision 3

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Westinghouse Non-Proprietary Class 3 5-4 does not cause any interference or changes in the +POINT probe response as compared to the tube/sleeve joint with no microlok band and, therefore, is bound by the roll transition zone Appendix H qualification program.

Westinghouse has recently performed ECT with a +POINT probe on a on sleeved tube with three axial EDM notches on the ID of the parent tube, measuring 50%, 70%, and 100% through-wall.

These sleeves contained both a nickel and microlok band. Each notch runs through (is adjacent to) the microlok and nickel bands. All three notches are easily detected adjacent to the microlok but have reduced detection adjacent to the nickel band. Figure 5-3 displays the terrain (C-scan) plots for this inspection. The black arrow in each of the C-scan plots is pointing to the nickel band area (Reference 5.3.2).

The tooling and methods described in this section represent the present technology for leak limiting sleeve inspection. As technological advances are made in NDE methods for sleeve inspection, the new equipment and/or processes may be utilized after they have been qualified to provide improved sleeve inspection.

5.2 SLEEVE/TUBE SAMPLES Samples with the sleeve-tube configuration were made for the qualification testing effort. The qualification test program was performed in accordance with 10 CFR 50, Appendix B. Each of the samples was a configuration that represents the material, dimensions and geometries of the as-installed sleeves. Qualification was performed on the probable flaw orientation as required by Appendix H. Samples were fabricated with axially and/or circumferentially oriented notches in both components representing flaws at each of the transitions and hydraulic expansion zones.

Corrosion testing of sleeve/tube samples as well as industry experience to date indicates that in the event cracking did occur it would be oriented in these directions. In addition, sleeve and tube flaws in the pressure boundary away from the expansion regions were included in the sample set.

Tooling representative of the field equipment was used to assemble the samples.

In addition to the samples with EDM notches, a limited number of samples with corrosion cracking in the parent tube were also included in the overall program. These tube samples included 16 sleeve/tube assemblies containing laboratory grown IGSCC in the parent tube behind the sleeve, as well as a pulled tube from an operating steam generator in Europe.

5.3 REFERENCES

FOR SECTION 5.0 5.3.1 EPRI Steam Generator Examination Guidelines Appendix H Qualification for Eddy Current Plus-Point Probe Examination of ABB CE I-800 Mechanical Sleeves, ABB CENO Report No. 97-TR-FSW-019P, Rev. 00.

5.3.2 Westinghouse Letter LTR-SGS-19-012, Revision 0, Parent Tube Flaw Detection Adjacent to Micro Loc Area of Sleeve, June 2019.

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Westinghouse Non-Proprietary Class 3 5-5 a,c FIGURE 5-1 TZ SLEEVE PRESSURE BOUNDARY DESCRIPTION WCAP-15918-NP July 2019 Revision 3

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Westinghouse Non-Proprietary Class 3 5-6 a,c FIGURE 5-2 TS SLEEVE PRESSURE BOUNDARY DESCRIPTION WCAP-15918-NP July 2019 Revision 3

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Westinghouse Non-Proprietary Class 3 5-1 EDM Notches Microlok Band Nickel Band Roll Transition FIGURE 5-3 TERRAIN PLOTS OF SLEEVED TUBE WCAP-15918-NP July 2019 Revision 3

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Westinghouse Non-Proprietary Class 3 6-1 6.0 ALLOY 800 SLEEVE CORROSION PERFORMANCE The corrosion assessment of the Alloy 800 sleeve is based on the following experiences and test programs:

The long-term service performance of Alloy 800 steam generator tubes and rolled tube plugs in operating steam generators Laboratory corrosion tests on full scale mock-ups of the Alloy 800 sleeve/Alloy 600 tube configuration Westinghouses welded sleeve corrosion program Correlation of operating experience with these tests Alloy 800 has been successfully used as a steam generator tube and plug material in several units located primarily in western European countries. Some of these units have operated with hot leg temperatures as high as 618F. This data, in addition to evaluations by Westinghouse and others have indicated that Alloy 800 is a viable sleeve material for domestic steam generator applications.

As is the case with many steam generator tube repair methods, the principal issue is whether the repair itself will create conditions that will lead to future failures of the susceptible Alloy 600 tubing. The Alloy 800 mechanical sleeve installation is specifically designed to address this issue by imparting the minimum amount of residual stress in the parent tube consistent with a very low leak rate. In so doing, the potential for future tube failures is minimized.

6.1

SUMMARY

AND CONCLUSIONS The Alloy 800 sleeve provides corrosion resistance under anticipated design and fault primary and secondary environments without increasing the potential for future corrosion induced failures of the pressure boundary section of the original tube. This conclusion is based on laboratory data and operating experience for both Alloy 800 and Alloy 600 steam generator tubing and is verified by corrosion tests conducted by Westinghouse.

6.2 LABORATORY DATA AND OPERATING EXPERIENCE 6.2.1 Primary Side Performance The principal concern with a sleeve joint on the primary side is the potential for primary water stress corrosion cracking (PWSCC) as a result of the stresses imparted to the tube due to the sleeve installation. PWSCC of the Alloy 800 sleeve is not a principal concern because of excellent performance of Alloy 800 steam generator tubes during extensive operating experience as well as past test results. The corrosion resistance of the sleeve/tube joint will be governed by three elements: (1) the chemical and metallurgical conditions of the sleeve and tube material, (2) the water chemistry within the sleeve/tube crevice, and (3) the stresses (residual from sleeve installation plus operating) and strains associated with the sleeve/tube mechanical joint (Reference 6.4.7). The mechanical joint will not affect the chemical composition of either the tube or sleeve and will result in only a mildly cold worked condition in either material. Some oxygen will initially WCAP-15918-NP July 2019 Revision 3

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Westinghouse Non-Proprietary Class 3 6-2 be present within the sleeve/tube crevice, however, any tendency to trap oxygen will be reduced with this design because of joint leakage at lower temperatures. Based on this, oxygen-rich crevice conditions are not considered to last long enough after startup to be of concern. Experience with Alloy 800 tubes in European steam generators, as well as testing described herein, indicates Alloy 800 exhibits excellent corrosion resistance under both primary and secondary nominal and fault environments. Further, examination of in-service sleeved tubes with similar crevices, although of the welded Alloy 690 design, have not shown any corrosion attack associated with crevice deposits. Thus, the long-term corrosion resistance of the sleeve/tube joint will depend primarily on the local stress and strain level which will be determined by the plastic deformation in the region of the joint.

Alloy 800 has seen considerable usage under PWR conditions without experiencing primary or secondary side stress corrosion cracking. As described in Reference 6.4.1, this experience is based on over two hundred thousand tubes in service with only minimal tube failures. This resistance is due to the alloys chemical composition and heat treatment. The excellent performance of Alloy 800 in previously installed sleeves (see Section 9.0), hydraulically expanded tube to tubesheet joints and rolled blind steam generator tube plugs (like the Alloy 690 plugs) have provided significant primary side experience at strain levels equal to or greater than those experienced during installation of this sleeve. For this reason, the Alloy 800 sleeve is not considered to be the limiting component of the assembly.

Most Alloy 800 sleeve installations have occurred in Europe and Asia using the PLUSS sleeve.

These installations were performed by the Westinghouse Mannheim office. The PLUSS design is essentially identical to the Alloy 800 sleeve installed in the U.S. except the PLUSS sleeve does not include nickel banding at the lower joint region. To date, Westinghouse is not aware of any reports of parent tube degradation in the lower joint roll region for any Westinghouse sleeve design.

Figure 6-1 presents a running summary of the number of Alloy 800 tubesheet sleeves in service over the past 20 years based on information contained in Reference 6.4.14. As many as 8,750 Alloy 800 tubesheet sleeves were in-service at one time with no reports of parent tube degradation.

In some cases, the installation of sleeves was used to extend the SG operating period to the point in time when SG replacement occurred; thus, on Figure 6-1 the cumulative number of in-service sleeves is reduced. In 2017 approximately 1,800 tubesheet sleeves were installed in France due to large numbers of tubes affected with PWSCC at the top-of-tubesheet expansion transition.

Of the greater than 14,000 Alloy 800 tubesheet sleeve installations, nearly all are/were installed at plants using Alloy 600 mill annealed tubing. The only tubesheet sleeve installations in non-mill annealed tubing were two Korean plants that used Alloy 600 thermally treated tubing.

Another approximate 12,000 tube support plate sleeves were installed by Westinghouse in Korea starting in approximately 2013. These are/were installed in plants using both mill-annealed and thermally-treated Alloy 600 tubing.

An extensive history of Westinghouse HEJ and LWS installations also supports the conclusion that degradation of the parent tube adjacent to the roll expansion at the lower sleeve joint is not WCAP-15918-NP July 2019 Revision 3

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Westinghouse Non-Proprietary Class 3 6-3 anticipated. Neither of these designs includes nickel application to the sleeve OD. The sleeve material is Alloy 690 or in the case of one plant, Alloy 690 with an Alloy 625 cladding on the entire length of the sleeve OD. Westinghouse is not aware of, and has no knowledge of, any reports of parent tube SCC in the sleeve roll joint region for any Westinghouse sleeve design.

Most of these installations (with subsequent SG replacement) occurred prior to 1995, which is when the +POINT probe gained widespread acceptance and application. The installations for which post-installation sleeved tube inspection likely included the +POINT probe are summarized below.

Sleeve Number Sleeves EFPY to SG Plant Type of Sleeve Installation Date Installed Replacement Beaver Valley 1 3/2000 380 5.3 LWS Braidwood 1 10/1996 897 1.5 LWS Braidwood 1 4/1997 270 1.2 LWS Byron 1 10/1995 2046 1.5 LWS Byron 1 4/1996 3527 1.2 TIG Farley 1 9/1992 44 6.3 LWS Farley 1 3/1994 77 5.1 LWS Farley 1 3/1997 919 2.4 LWS Farley 1 12/1998 243 1.1 LWS Farley 2 3/1992 21 7.6 LWS Farley 2 9/1993 216 6.3 LWS Farley 2 10/1996 826 3.8 LWS Farley 2 4/1998 108 2.5 LWS Of these, only Farley Unit 2 would have been anticipated to experience degradation of the parent tube prior to SG replacement using a Weibull initiation model based on the observed non-sleeved tube flaw initiations. As no indications were detected in Farley Unit 2 prior to replacement, there is one, two, or both possible assumptions applicable to SCC flaw initiation. These assumptions are that the residual stresses at the parent tube inside diameter (ID) surface do not support SCC initiation or that the installation of the sleeve results in a reduced tube temperature resulting in a reduced SCC initiation function (Reference 6.4.15).

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Westinghouse Non-Proprietary Class 3 6-4 An initial assessment of the Alloy 800 sleeve corrosion performance can be made by comparing the level of plastic deformation in the sleeve joint with that typically present at the top of the tubesheet in the steam generators. Whereas the strain in the tube due to sleeve installation is up to

[ ]a,c tube expansions in the tubesheet are up to 1.5% strain over a comparable [ ]a,c length. As such, it can be expected that the sleeve joint would have a longer life than the original tube to tubesheet expansion zone.

In some plants, such as Arkansas Nuclear One Unit 2 (ANO-2) and Calvert Cliffs 2, the tubing has not demonstrated significant PWSCC at the mechanically expanded tubesheet transition zone. For example, examinations of tubes removed from ANO-2 (total of 10 tubes) confirmed that the mode of degradation of the Alloy 600 tubes has been OD initiated intergranular stress corrosion cracking (IGSCC) and/or intergranular attack (IGA, References 6.4.2, 6.4.3, and 6.4.4). One German plant in 2005 had a total of 20 tubes in with indications in the hot-leg side of the tubesheet area.

Metallograhic analyses of two pulled tubes in 2006 showed the indications to be OD SCC with shallow degradation related to IGA. All cracks were filled with corrosion products with high sulfur content. In 2017, another German plant had 32 tubes in one SG with small, punctual volumetric indications. All indications were found in the cold-leg side between the top of the tubesheet and the first support plate. In-service inspection data from Spanish replacement steam generators with Alloy 800 tubing identified circumferentially oriented OD SCC in the 2009 timeframe. The cracking was associated with denting at the top of the tubesheet resulting from poor chemistry control. Chemical cleaning was applied to remove hardened deposits. There has been no stress corrosion cracking reports long term (Reference 6.4.13). Only where severe plastic deformation has occurred, as in the case of kinetically expanded sleeves at ANO-2, has any PWSCC been indicated. In these cases, it can be argued that since the sleeve imparts less strain into the tube than the tube has experienced at the tubesheet, the sleeve joint would be expected to have a life greater than that of the original tube. Even in cases where PWSCC has been experienced, the resulting sleeve joint life would be expected to be no less than the original tube life. This conclusion would be applicable to either Westinghouse or CE designed steam generators.

6.2.2 Secondary Side Performance In addition to the experience and laboratory data described in Reference 6.4.1, Westinghouse has evaluated Alloy 800 under model boiler conditions. In only one out of three boilers, run with as much as 30 ppm chloride in the secondary side bulk water, was any corrosion, in the form of modest pitting and shallow intergranular attack observed (Reference 6.4.5). Additionally, a fourth model run with sulfate fault secondary chemistry found some wastage but no stress corrosion cracking (Reference 6.4.6). Based on this data, the Alloy 800 sleeve is sufficiently resistant to potential fault chemistries to maintain its integrity in the event through wall penetrations are produced in the parent tube.

As stated in Section 6.2.1, for some plants the mode of degradation of the Alloy 600 tubes has been OD initiated intergranular stress corrosion cracking (IGSCC) and/or intergranular attack (IGA). This has been the case for circumferentially oriented degradation in the tubesheet expansion transitions and for axially oriented degradation at tube support locations. The destructive examinations of over 20 removed tubes from ANO-2 and Calvert Cliffs 2 have revealed only one tube with PWSCC. The general lack of PWSCC to date at these plants indicates that the WCAP-15918-NP July 2019 Revision 3

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Westinghouse Non-Proprietary Class 3 6-5 probability of having PWSCC is low and that the potential degradation of concern is OD initiated IGA or IGSCC.

To minimize the possibility of tube corrosion attack at the upper mechanical joints, the length and positioning of the sleeve have been designed such that the mechanical joints are located above the sludge pile and above and below the tube support elevation. Under these circumstances the potential for fault species to concentrate and cause stress corrosion failures is minimized.

Nevertheless, as in the case of primary side performance, the strains and applied stresses associated with these joints are less than those experienced by the tube to tubesheet expansion joint and as such would be expected to provide lifetimes at least as great as this section of the tube.

6.2.3 Overall Performance and Experience The sleeve/tube corrosion performance, including the mechanical joint area, is expected to be acceptable based on the following:

+POINT probe inspections after more than one fuel cycle at KORI 2 and Tihange 3 indicated no degradation of the sleeve or tube hydraulic expansion area. Some of these sleeve installations involved tube expansions resulting in higher strains (up to 2.5%) than the current design.

At ANO-2, many RPC ET examinations at the expansion transition at the top of the tubesheet have been performed over many fuel cycles. No substantial degradation has been found provided the tube location was not within the sludge pile. Since the Alloy 800 tube sleeve joint will be above the sludge pile and since tube strain for the joint will be on the order of 10% of that of an expansion transition, satisfactory tube service is expected with this design.

Although temperatures are lower, the U-bend region of the tubes at ANO-2 and Calvert Cliffs Units 1 and 2 provides another base of comparison which indicates good expected tube performance with the Alloy 800 sleeve design. Here, tube strain levels about 100 times that for the subject tube repair have been in service for many fuel cycles with satisfactory corrosion performance.

6.3 SLEEVE/TUBE ASSEMBLY CORROSION TESTS 6.3.1 European-Based Corrosion Tests Since late 1995, Westinghouse Reaktor has prepared sleeve/tube test assemblies for corrosion tests performed by Laborelec Laboratories in preparation for Alloy 800 sleeve installation at Tihange 2 and 3 (References 6.4.8.and 6.4.11). Two sets of tests were performed. The first set, using archive tubing from Tihange 3, was performed for a pre-established time to verify a minimum sleeved tube life. The second set, using SCC susceptible tubing, was conducted until all the sleeved tubes had cracked.

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Westinghouse Non-Proprietary Class 3 6-6 The sleeved specimens were prepared with tube diametrical expansions of up to [ ]b In addition, reference roll transition assemblies, prepared from the same tubing, were expanded to the original generators design configuration (approximately 2.5% with 4% wall reduction).

All assemblies were pressurized to a differential pressure of 1300 psi at 660°F with deaerated 10%

sodium hydroxide as the ID test environment.

The goal of the Tihange 3 Alloy 800 sleeving program was to keep the steam generators in service for three cycles until replacement units were available. Since the roll transitions had begun to crack after one cycle of operation, the goal of the corrosion program was for the time to failure of the sleeved assemblies to be at least three times as long as that for the reference roll transition specimens.

The four reference roll transition specimens failed after [

]b Based on this value, the goal of the sleeved specimens was a time to failure of greater than [ ]b The three sleeved assemblies maintained pressure throughout the test and the test was stopped after [ ]b of operation. No cracks were observed in the parent tube expansion transitions of these specimens.

In the case of Tihange 2, a more long-term goal was desired thus requiring an assessment of the total lifetime of the sleeved tube. Two roll expansion reference samples exhibited through wall cracking in [ ]b Nine sleeved samples were also tested and exhibited lifetimes of [ ]b representing an increased life of [ ]b times that of the roll transition.

6.3.2 Welded Sleeve Corrosion Tests Westinghouse conducted a similar corrosion test in support of welded sleeve installation in Westinghouse D Series steam generators. The purpose of the test was to determine the approximate life of the sleeve/tube joint in the as-welded and the post weld heat treated conditions.

The sleeved tube specimens were prepared using EPRI-supplied PWSCC susceptible Alloy 600 tubing. All eight samples were expanded to a tube diametrical expansion of [ ]b and welded using standard welding parameters. Four samples were then post weld heat treated.

Additionally, a series of C-rings were prepared for stress determination. The assemblies were pressurized to a differential pressure of 2250 psi at 660°F with deaerated 10% sodium hydroxide.

The as-welded specimens failed at an average time of [ ]b , while the PWHT specimens b

failed at an average time of [ ] All cracks occurred in the [

b

] Experience has shown that the roll transition region in D Series tubes begins to crack after two cycles of operation. Using this data, as well as relationships developed for time to failure for pure water stress corrosion cracking of Alloy 600, it was determined that the as-welded joint life was [

]b WCAP-15918-NP July 2019 Revision 3

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Westinghouse Non-Proprietary Class 3 6-7 6.3.3 Confirmatory Alloy 800 Tests To verify the assessments described earlier, accelerated corrosion tests were conducted with full length sleeved tube assemblies (Figure 6-2). This set of tests was performed with the goal of verifying the viability of the installed Alloy 800 sleeve in a caustic environment, as well as confirming the joint performance under aggressive conditions. These assemblies were fabricated with tube expansions ranging from the nominal value of [ ]b to the maximum value of

[ ]b, duplicating the anticipated range of expansions for sleeve installation.

This configuration was used to test both primary and secondary side response in accelerated environments. In the primary side case, the sleeve/tube assembly was pressurized on the ID to a differential pressure of approximately 1600 psi with deaerated 10% sodium hydroxide at 660F.

For the secondary side tests, the OD environment consists of deaerated 10% sodium hydroxide at 660F. In this case, the samples are immersed in an autoclave and pressurized, with deionized water, to a differential pressure of 1600 psi. C-ring samples stressed to various levels were also included in the secondary side test capsules.

It is considered that these samples represent the worst-case scenario for tubes that are either locked or that are free to move at the tube supports. This conclusion is based on the stresses measured in the installation stress assessment described in Section 7.4 and the operating stresses described in Section 8. In the case of the corrosion samples, the higher-pressure stresses resulting from the higher test temperature and the capped tube end, produce a higher applied axial tensile stress in that section than would be experienced by the in-service sleeved tube.

The assemblies were monitored on a continual basis in order to determine whether or not the assemblies maintained pressure. Loss of pressure would indicate a through wall crack in the parent tube or a test fixture problem and would require the test to be interrupted for inspection. The autoclaves containing the test assemblies were removed from service at various junctures to visually inspect the assemblies.

The primary side tests, which had average tube expansions of [ ]b, were exposed for over [ ]b with no leakage as defined by loss of pressure. Two of the three assemblies developed [

]b The secondary side tests, which had average tube expansions of [ ]b, were exposed for over [ ]b, with two assemblies being exposed for [ ]b b

respectively. One of the assemblies developed a [ ] during the test, while the other three maintained pressure until shutdown.

The Alloy 800 sleeves showed no signs of cracking in both the primary and secondary side tests (Reference 6.4.9).

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Westinghouse Non-Proprietary Class 3 6-8 6.3.4 Discussion The corrosion tests performed on various Alloy 800 sleeve and tube configurations, in conjunction with operating experience, indicate that the Alloy 800 sleeve is a viable repair methodology for use in steam generators with degraded Alloy 600 tubing.

The results of the welded sleeve corrosion tests performed by Westinghouse indicate that weld joints in the as-welded condition will have a service life, as a minimum, of [ ]b times the time to failure of the roll transition regions of the parent tube. Removal of an as-welded sleeved tube from Prairie Island after [ ]a,c of service revealed no evidence of weld joint degradation.

This field data tends to confirm the test results of the program if only on a preliminary basis. This data is applicable to the Alloy 800 program for the following reasons. The corrosion tests were performed in a similar manner for both programs. The expansions placed in the tube for the two types of sleeves are similar, with the expansions of a larger diameter imparted on the welded sleeved tube. Even with this larger diameter expansion, the [

]a,c To reiterate, this would be the equivalent of 2.5 times the time to failure of the parent steam generator tubes.

The final set of confirmatory tests performed by Westinghouse support the previous data generated, as well as the field experience. The samples accumulated [ ]b times the exposure time of the Westinghouse Reaktor samples and [ ]b times the exposure time of the as-welded samples while maintaining pressure and not exhibiting any leakage. The Alloy 800 exhibited no degradation, confirming both field experience and previous corrosion tests performed on the alloy during its development phase for nuclear applications.

The results of corrosion tests performed for Westinghouse Reaktor indicate that the installation of Alloy 800 sleeves in SCC tubing will result in a repair with a service life many times the original roll transition life.

The actual lifetime of sleeved tubes in a plant will depend specifically on the tube condition, the failure mechanism and tube joint designs of that plant. As such, a method which compares the ratio of failure times during the corrosion testing to that for the life of the original tube is the most appropriate method for determining the potential sleeved tube life.

To evaluate the life of sleeved tubes, the Arrhenius relationship established for stress corrosion cracking can be applied. Using this relationship, comparisons can be made between the ratio of failure times for the roll transition baseline and the sleeved tube, in the test environment and under primary coolant conditions.

Because the NaOH tests were conducted under isothermal conditions for both the roll transition and the sleeve mechanical joint, the temperature component of this relationship is unity. As such, the determining factor with respect to life is the total stress associated with the joints. Where tests conditions were controlled to apply the same differential pressure at temperature as is generally experienced in the steam generator (9 Mpa/1300 psi), no correction to operating conditions is WCAP-15918-NP July 2019 Revision 3

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Westinghouse Non-Proprietary Class 3 6-9 required. Sleeve life can therefore be determined from the following relationship and the appropriate value for n:

n t sleeve sleeve t rolltrans rolltrans Where:

tsleeve = Time to failure of the sleeved tube trolltrans = Time to failure of the original tube at the roll transition sleeve = Stress in the sleeved tube rolltrans= Stress in the tube at the roll transition n = Empirically determined exponent The value of n, for caustic stress corrosion cracking has been given as 2.4 to 4.0 and as 4.0 to 4.2 for PWSCC. (References 6.4.10 and 6.4.12).

Using the minimum times to failure in the caustic test:

n tsleeve sleeve a,b,c trolltrans rolltrans A mean stress ratio can then be calculated as:

a,b,c

[ ]

Using this ratio with the exponent for PWSCC the stress component of the sleeve life can be determined by:

a,b,c

[ ]

A further adjustment to the roll transition life would then be made to compensate for any temperature difference between the original and sleeved tube. Due to the insulating effect provided by the sleeve, calculations have determined that the tube temperature may be as much as 5C to10C lower in the region of the sleeve joint as it was at the original roll transition.

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Westinghouse Non-Proprietary Class 3 6-10 Using the temperature dependent function of the Arrhenius relationship, t sleeve e Q / RT sleeve Q / RT rolltrans t rolltrans e Applying a value of Q equal to 50 Kcal/mole, a factor of 2 would be applied to the roll transition life for every 10C of temperature differential (Reference 6.4.10).

Therefore, for example in a plant which had experienced roll transition cracking after two years and in which the temperature differential was calculated to be 10C; the life of the sleeved tube would be estimated as:

a,b,c

[ ]

Further margin may be applied to this calculation by considering the average time to cracking.

The ratio for the average time to cracking is approximately 70 percent greater than that for the minimum times. This would result in additional margin of 2.5 times that estimated.

An assessment of the corrosion testing performed results in the conclusion that Alloy 600 tubes repaired with the Alloy 800 sleeve can be expected to have a life considerably longer than that of the original tube.

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Westinghouse Non-Proprietary Class 3 6-11

6.4 REFERENCES

FOR SECTION 6.0 6.4.1 Corrosion Resistance of SG Tubing Material Incoloy 800 mod and Inconel 690 TT, Werkstoffe und Korrosion, p. 490, Vol. 43, 1991, Kilian, R., et al.

6.4.2 Examination of Steam Generator Tubes Removed from Arkansas Nuclear One, Unit No.

2, TR-MCC-210, ABB Combustion Engineering, August 1992.

6.4.3 Examination of Steam Generator Tubes Removed from Arkansas Nuclear One, Unit No.

2, TR-MCC-225, ABB Combustion Engineering, October 1992.

6.4.4 Examination of Steam Generator Tubes Removed from Arkansas Nuclear One, Unit No.

2, TR-MCC-258, ABB Combustion Engineering, February 1993.

6.4.5 Corrosion Performance on Alternate Steam Generator Materials and Designs, Vol. 2, Post Test Examination of a Seawater Faulted Alternative Materials Model Steam Generator, Combustion Engineering, EPRI-NP-3044, Vol. 2, July 1983, Krupowicz, J.J., et al.

6.4.6 Corrosion Performance on Alternate Steam Generator Materials and Designs, Vol. 3, Post Test Examination of a Freshwater Faulted Alternative Materials Model Steam Generator, Combustion Engineering, EPRI-NP-3044, Vol. 3, July 1983, Krupowicz, J.

6.4.7 Summary Report - Combustion Engineering Steam Generator Tube Sleeve Residual Stress Evaluation, TR-MCC-153, ABB Combustion Engineering, November 1989.

6.4.8 Tihange 3 SGs Sleeving Campaign 1995 - ABB Weldless Sleeves Corrosion Tests, Report No. C01-200-95-031/R/LZN, Laborelec Laboratories, October 10, 1995.

6.4.9 Corrosion Tests of Steam Generator Tubes with Alloy 800 Mechanical Sleeves, Report No. 98-FSW-021, ABB Combustion Engineering, October 1998.

6.4.10 Statistical Analysis of Steam Generator Tube Degradation, Staehle, R. W., et al, EPRI NP-7493, 1991.

6.4.11 Tihange 2 S.G.s Sleeving Campaign 1997 - ABB Pluss Sleeves Corrosion Tests, Report No. MATER-97-200-0047/R-Lz, Laborelec Laboratories, May 1997.

6.4.12 1987 EPRI Workshop on Secondary Side Intergranular Corrosion Mechanisms:

Proceedings, NP-5971, 1988.

6.4.13 WB2TV-19-9, Transmittal of Watts Bar Unit 2 Steam Generator Alloy 800 Sleeve License Amendment TVA/NRC Pre-application Meeting Presentation -- WBN Unit 2 OSG Non-Nickel Banded Tube Sleeve Services, June 2019.

6.4.14 LTR-SGMP-15-13, Transmittal of Alloy 800 Sleeve Installations Worldwide, Westinghouse Electric Company, March 2015.

6.4.15 LTR-SGMP-18-3, Steam Generator Alloy 800 Nickel Band Tubesheet Sleeve Operating Cycle Length Extension License Amendment Request: Technical Bases, Westinghouse Electric Company, March 2018.

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Westinghouse Non-Proprietary Class 3 6-12 FIGURE 6-1 ALLOY 800 SLEEVE WORLDWIDE INSTALLATIONS WCAP-15918-NP July 2019 Revision 3

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Westinghouse Non-Proprietary Class 3 6-13 MONEL FITTINGS (Both Ends)

ALLOY 600 TUBE ALLOY 800 SLEEVE with HYDRAULIC EXPANSIONS 25.8 TUBESHEET BLOCK SLEEVE ROLLED JOINT FIGURE 6-2 SLEEVE CORROSION SPECIMEN WCAP-15918-NP July 2019 Revision 3

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Westinghouse Non-Proprietary Class 3 6-14 THIS PAGE INTENTIONALLY LEFT BLANK WCAP-15918-NP July 2019 Revision 3

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Westinghouse Non-Proprietary Class 3 7-1 7.0 MECHANICAL TESTS OF SLEEVED STEAM GENERATOR TUBES 7.1

SUMMARY

AND CONCLUSIONS Mechanical tests were performed on mock-up steam generator tubes containing sleeves to provide qualified test data describing the basic properties of the completed assemblies. These tests determined axial load, collapse, burst, leak rates and thermal cycling capability.

Table 7-1 summarizes the results of the mechanical testing performed on the sleeve/tube assemblies. The demonstrated load capacity of the assemblies provides an adequate safety factor for normal operating and postulated accident conditions. The load capability of the upper and lower sleeve joints is enough to withstand thermally induced stresses and displacements resulting from the temperature differential between the sleeve and the steam generator tube and pressure induced stresses resulting from normal operating and postulated accident conditions. The burst and collapse pressures of the sleeve provide margin over limiting pressure differential. Mechanical testing revealed that the installed sleeve will withstand the cyclical loading resulting from power changes in the plant and other transients.

Table 7-2 summarizes the results of the leak testing performed for the tubesheet sleeves at various test and operating conditions. Table 7-3 summarizes the leak test results for the tube support sleeves under the same test conditions. The overall results of these leak tests are that leak rates are sufficiently small to allow a large number of sleeves to be installed, without exceeding typical plant allowable leak rates for either accident or normal operating conditions. As described in Section 7.4, tests were performed to determine the residual stresses in a steam generator tube resulting from installation of a sleeve, where the steam generator tube is locked at the first tube support. These stresses are well within yield stress and are expected to be acceptable based on corrosion tests in Section 6.0.

To confirm the sleeve assembly capability to withstand thermal and mechanical cyclic loads without degrading the strength or leak resistance of the expansion joint, thermal and load cycling tests which considered the operating thermal gradient and maximum expansion loads were performed. It was found that the leak rate was reduced after operating condition cycles and no degradation in strength was indicated.

These tests were performed utilizing sleeves with microlok bands and sleeves with microlok and nickel bands. The nickel has no effect on the structural capability of the sleeves as the rolled joint contact pressure and the presence of microlok contribute to this capability. The nickel adds to the leak tightness of the rolled joint, however tests with both types of sleeves displayed no leakage through the rolled joints. All leakage was through the leak limiting hydraulic expansion joints.

7.2 MECHANICAL TESTS The following mechanical tests were performed on the sleeve/tube assemblies: leakage, axial load, load cycling, burst and collapse. Loads were applied per the design requirements, or in the case of cyclic loading, until the number of cycles exceeded the expected number of cycles for the original design life of the plant. Clean, unoxidized sleeve and steam generator tube samples were WCAP-15918-NP July 2019 Revision 3

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Westinghouse Non-Proprietary Class 3 7-2 used for all tests. [

]a,c

[

]a,c Also, based on our experience, any oxide remaining on the inside of the tube after conditioning is expected to have no effect on the structural capability or leak resistance of the mechanical joint between the sleeve and tube. Therefore, mechanical testing with properly conditioned unoxidized tubes is enough to qualify the sleeve design. This would not necessarily be true if a welded joint were used.

The steam generator tubes used for construction of the test assemblies all had a room temperature yield strength of 49 ksi. The results of the tests performed on these assemblies are contained in Tables 7-1 through 7-3. A finite element stress analysis described in Reference 7.6.7 was performed to determine the effect of different tube yield strengths and different sleeve to tube radial gaps. The analysis considered tube room temperature yield strengths from 35 ksi to 60 ksi.

The contact stress at the expansions after sleeve installation was shown to be greater when the tube yield stress was higher. Depending on the gap size, the contact stress for the cases with the highest tube yield stress ranged from 8.7 to 14.8 ksi compression, and for the lowest tube yield stress the contact stress ranged from 6.3 to 7.8 ksi compression. In all cases the contact stress increased significantly, (7.7 ksi on the average) at operating conditions. [

]a,c

[

]a,c Sufficient load capability margin is demonstrated in the tests to cover such an extreme case. From this study it is judged that the tube yield stress variation anticipated to be encountered in steam generators is not a dominant parameter in the sleeve to tube leakage resistance and joint strength, provided that the extent of the tube expansion is in the range of the values tested.

A series of leak and thermal cycle tests were performed to verify this analytical prediction. Test samples were assembled with tubing having a room temperature yield strength of 38-39 ksi. The results of this program are contained in Reference 7.6.9. All samples met minimum joint strength requirements, and experienced leak rates like those found using nominal strength tubing.

With respect to the tube joint at severe accident conditions of high pressure (2500 psi) and temperature (1200-1500°F), pressure tends to loosen the joint and temperature tends to tighten it.

As the temperature increases toward 1500°F, both the sleeve and tube will yield at steam line break pressures. Because the sleeve material is specified to have a low yield stress (30 ksi minimum, WCAP-15918-NP July 2019 Revision 3

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Westinghouse Non-Proprietary Class 3 7-3 carefully controlled maximum), the sleeve will yield at a lower temperature (or pressure) than the tube, thereby tending to tighten the joint.

At 1500°F the ultimate stress of the sleeve material is comparable to that of the tube; therefore, the integrity of the sleeve repair is commensurate with the integrity of the in-service steam generator tubes. Because of this, sleeving should have no impact on the risk.

7.2.1 Axial Load and Pressure Tests

[

]b WCAP-15918-NP July 2019 Revision 3

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Westinghouse Non-Proprietary Class 3 7-4

[

]b 7.2.2 Collapse Testing

[

]b 7.2.3 Thermal and Load Cycling Tests

[

]b WCAP-15918-NP July 2019 Revision 3

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Westinghouse Non-Proprietary Class 3 7-5

[

]b WCAP-15918-NP July 2019 Revision 3

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Westinghouse Non-Proprietary Class 3 7-6

[

]b WCAP-15918-NP July 2019 Revision 3

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Westinghouse Non-Proprietary Class 3 7-7

[

]b 7.3 LEAKAGE ASSESSMENT 7.3.1 Leak Rate Tests

[

]b WCAP-15918-NP July 2019 Revision 3

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Westinghouse Non-Proprietary Class 3 7-8

[

]b WCAP-15918-NP July 2019 Revision 3

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Westinghouse Non-Proprietary Class 3 7-9

[

]b WCAP-15918-NP July 2019 Revision 3

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Westinghouse Non-Proprietary Class 3 7-10 7.3.2 Leak Test Evaluation

[

]b WCAP-15918-NP July 2019 Revision 3

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Westinghouse Non-Proprietary Class 3 7-11 Based on the above assumptions, and the design basis leakage values of Section 7.3.1, for normal operating conditions with a secondary side pressure of 790 psi, 7,673 TZ sleeves or 3205 tube support sleeves would be acceptable. The allowable number of TZ or tube support sleeves for MSLB/FLB conditions exceeds 30,000.

[

]b 7.3.3 Leak Test Results Under Abnormal Installation Conditions

[

b WCAP-15918-NP July 2019 Revision 3

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Westinghouse Non-Proprietary Class 3 7-12 represented by the ovality test, where the sleeve contacts one part of the tube before the whole comes in contact.

[

]b 7.4 INSTALLATION STRESSES

[

]b WCAP-15918-NP July 2019 Revision 3

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Westinghouse Non-Proprietary Class 3 7-13

[

]b 7.5 EFFECTS OF CHANGES IN TUBE AND SLEEVE DIMENSIONS

[

]b WCAP-15918-NP July 2019 Revision 3

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Westinghouse Non-Proprietary Class 3 7-14

[

]b

7.6 REFERENCES

FOR SECTION 7.0 7.6.1 3/4" US NSSS Sleeving Summary of Test Results Report No. GBRA 039-927, Rev. B.

7.6.2 Design Verification and Qualification Report Sleeving of E1 Steam Generator Tubing (3/4" SG) by Weldless Sleeves, Report No. GBRA 033 431.

7.6.3 Fatigue Testing of I800 Sleeved Tube Samples at Operating Temperature, Report No.

MISC-PENG-TR-096, Rev. 00.

7.6.4 Steam Generator Tube Leak Rate Testing of A800 Sleeve Samples, Test Report No. 00000-NOME-TR-0049, Rev. 00.

7.6.5 Test Report for the Locked Tube Support Mock-up Strain Testing for Installation of A800 Sleeves, Report No. 00000-NOME-TR-0051, Rev. 00.

7.6.6 Test Report on Thermal and Load Cycling Tests on Alloy 800 Sleeves, Report No. MISC-PENG-TR-100, Rev. 00.

7.6.7 Calculation Report: Sleeving of ANO2 Steam Generator Tubing (3/4") by PLUSS Sleeves with 6 x 8 mm Zero-Expansions, Report No. GBRA 040194.

7.6.8 Telefax # Ru-wg r1214-ce, from ABB Reaktor to ABB CENO, June 11, 1997, and subsequent telefax from ABB Reaktor to ABB CENO on June 19, 1997.

7.6.9 Test Report on the Alloy 800 Mechanical Sleeve - Additional Qualification Testing Using Low Yield Strength Tubing, Report No. 98-TR-FSW-005.

7.6.10 Alloy 800 Sleeve Leak Test Summary, Report No. 99-TR-FSW-0044.

7.6.11 Alloy 800 Sleeve Installation and Operational Stress Test and Analysis Summary, Report No. 99-TR-FSW-045.

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Westinghouse Non-Proprietary Class 3 7-15 TABLE 7-1 SLEEVE-TUBE ASSEMBLY MECHANICAL TESTING RESULTS COMPONENT TEST RESULTS Room Temperature Tests:

Cyclic Loading (Wear Test) [

Upper Joints Intact Tube Cyclic Loading (Axial Capability)

Upper Joints Severed Tube Operating Temperature Tests:

Axial Capability Severed Tube Sleeve Assembly Burst Pressure Sleeve Assembly Collapse Pressure Cyclic Loading (Axial Capability)

Thermal and Load Cycling Tests Sleeve Assembly Collapse Pressure Cyclic Loading (Axial Capability) Capability) ]b WCAP-15918-NP July 2019 Revision 3

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Westinghouse Non-Proprietary Class 3 7-16 TABLE 7-2 TUBESHEET SLEEVE-TUBE ASSEMBLY LEAK TESTING RESULTS PRIMARY SECONDARY PRIMARY AVERAGE 95% UPPER MAXIMUM MINIMUM PRESSURE PRESSURE TEMPERATURE LEAK RATE MEAN LEAK RATE LEAK RATE (psi) (psi) (0F) (GAL./HR) ( GAL./HR) (GAL./HR) (GAL./HR)

[

]b The upper (one sided) 95% confidence limit on the mean is calculated as follows:

X1, X2, ...XN are the leakage data for each of the N tests.

XM is the arithmetic average, or the sum of the data values/N tests.

S, the standard deviation of the sample, is the square root of the sum of the (XM-Xi) squared divided by the square root of N-1.

XM(95) is XM + t(95) times S divided by the square root of N. t(95) is the 95% value from Students t distribution with N-1 degrees of freedom. In this case, since N is 6, t(95) is 2.02.

These sleeves contained microlok bands WCAP-15918-NP July 2019 Revision 3

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Westinghouse Non-Proprietary Class 3 7-17 TABLE 7-3 TUBE SUPPORT SLEEVE-TUBE ASSEMBLY LEAK TESTING RESULTS PRIMARY SECONDARY PRIMARY AVERAGE 95% UPPER MAXIMUM MINIMUM PRESSURE PRESSURE TEMPERATURE LEAK RATE MEAN LEAK RATE LEAK RATE (psi) (psi) (0F) (gal/hr) (gal/hr) (gal/hr) (gal/hr)

[

]b The upper (one sided) 95% confidence limit on the mean is calculated as follows:

X1, X2, ...XN are the leakage data for each of the N tests.

XM is the arithmetic average, or the sum of the data values/N tests.

S, the standard deviation of the sample, is the square root of the sum of the (XM-Xi) squared divided by the square root of N-1.

XM(95) is XM + t(95) times S divided by the square root of N. t(95) is the 95% value from Students t distribution with N-1 degrees of freedom. In this case, since N is 6, t(95) is 2.02.

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Westinghouse Non-Proprietary Class 3 7-18 TABLE 7-4 EFFECTS OF DIFFERENT SLEEVE AND TUBE DIMENSIONS TZ SLEEVES Leakage at 510 psi Tube Tube Yield and Room Sleeve Type Thickness Strength (ksi) Temperature (Inches)

(gal/hr)

Series 1 Tests b

.042 47 TZ .042 47 TZ .042 47 TZ .042 47 Series 2 Tests TZ .042 38 TZ .042 47 TZ .042 57 TZ .048 35 TZ .048 49 TZ .048 55 These sleeves contained microlok and nickel bands TABLE 7-5 EFFECTS OF DIFFERENT SLEEVE AND TUBE DIMENSIONS TS SLEEVES Tube Leakage at 510 psi and Tube Yield Sleeve Type Thickness Room Temperature Strength (ksi)

(Inches) (gal/hr) b TS .042 38 TS .042 47 TS .042 47 TS .042 57 TS .042 57 WCAP-15918-NP July 2019 Revision 3

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Westinghouse Non-Proprietary Class 3 7-19 TABLE 7-6 LEAKAGE BEFORE AND AFTER CYCLIC LOAD TESTS Leakage at 510 psi and Room Tube Tube Yield Number Sleeve Temperature Thickness Strength of Load Type Before Test After Test (Inches) (ksi) Cycles (gal/hour) (gal/hour)

TZ 0.042 57 [ 1000 TZ 0.048 49 2000 TZ 0.048 55 ]b 1000 These sleeves contained microlok and nickel bands WCAP-15918-NP July 2019 Revision 3

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Westinghouse Non-Proprietary Class 3 7-20 b

FIGURE 7-1 AXIAL LOAD/CYCLIC LOAD-TZ TEST ASSEMBLY WCAP-15918-NP July 2019 Revision 3

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Westinghouse Non-Proprietary Class 3 7-21 b

FIGURE 7-2 AXIAL LOAD TEST SET-UP WCAP-15918-NP July 2019 Revision 3

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Westinghouse Non-Proprietary Class 3 7-22 b

FIGURE 7-3 CYCLIC LOAD TEST ASSEMBLY-INTACT TUBE WCAP-15918-NP July 2019 Revision 3

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Westinghouse Non-Proprietary Class 3 7-23 b

FIGURE 7-4 CYCLIC LOAD TEST ASSEMBLY-SEVERED TUBE WCAP-15918-NP July 2019 Revision 3

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Westinghouse Non-Proprietary Class 3 7-24 b

FIGURE 7-5 TS LEAK TEST ASSEMBLY WCAP-15918-NP July 2019 Revision 3

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Westinghouse Non-Proprietary Class 3 7-25 b

FIGURE 7-6 LOCKED TUBE TEST FIXTURE WCAP-15918-NP July 2019 Revision 3

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Westinghouse Non-Proprietary Class 3 7-26 b

FIGURE 7-7 AVERAGE LEAK RATE PROJECTIONS FOR DIFFERENT PS WCAP-15918-NP July 2019 Revision 3

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Westinghouse Non-Proprietary Class 3 7-27 b

FIGURE 7-8 95% CONFIDENCE ON MEAN PROJECTIONS OF LEAK RATE WCAP-15918-NP July 2019 Revision 3

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Westinghouse Non-Proprietary Class 3 7-28 THIS PAGE INTENTIONALLY LEFT BLANK WCAP-15918-NP July 2019 Revision 3

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Westinghouse Non-Proprietary Class 3 8-1 8.0 STRUCTURAL ANALYSIS OF SLEEVE-TUBE ASSEMBLY This analysis establishes the structural adequacy of the sleeve-tube assembly. The methodology used is in accordance with the ASME Boiler and Pressure Vessel Code,Section III. The work was performed in accordance with 10 CFR 50, Appendix B and other applicable U.S. Nuclear Regulatory Commission requirements.

This analysis is provided as Appendix A of Reference 8.27. Reference 8.28 reconciles Reference 8.27 to also be applicable to the Watts Bar Unit 2 original steam generators. This analysis still contains references and data from plants that are no longer in service, but as a bounding analysis is still applicable and is left in its entirety.

8.1

SUMMARY

AND CONCLUSIONS Based on the analytical evaluation contained in this section and the mechanical test data contained in Section 7.0, it is concluded that both the TZ and TS sleeves described in this document, meet all pertinent requirements with substantial additional margins. In performing the analytical evaluation on the tube sleeves, the operating and design conditions for all of the CE and Westinghouse D and E Series operating plants with 3/4-inch Inconel 600 tubes are considered (Reference 8.2), as well as the San Onofre Nuclear Generating Station (SONGS) operating conditions in Reference 8.12. The results of this analytical evaluation are summarized in Table 8-1.

8.1.1 Design Sizing In accordance with ASME Code practice, the design requirements for tubing are covered by the specifications for the steam generator vessel. The appropriate formula for calculating the minimum required tube or sleeve thickness is found in paragraph NB-3324.1, tentative pressure thickness for cylindrical shells (Reference 8.1). The following calculation uses this formula for the tube sleeve material which is Alloy 800 material (SB-163, UNS N08800) with a specified minimum yield of 30.0 ksi and a design stress intensity of 20.0 ksi. c Where t = Minimum required wall thickness, inches WCAP-15918-NP July 2019 Revision 3

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Westinghouse Non-Proprietary Class 3 8-2 P = Design Primary Pressure, ksi (maximum value for intact tube situation)

R = Inside Radius of sleeve, in. (maximum value for tmin in Reference 8.18)

Sm = Design Stress Intensity, S.I. @ 650oF maximum design (per Reference 8.1) 8.1.2 Detailed Analysis Summary In determining the axial loads acting on the TZ sleeve at 25 inches (Figure 8-1 and Reference 8.9) there are several combinations of tube and tube support conditions which are considered. The two extreme cases for the tube condition are:

1.) The tube is intact.

2.) The tube is totally severed at the defective location.

The two extreme cases for the tube support condition are:

1.) The tube is free to move past the supports.

2.) The tube is locked in the first support and is prevented from axial motion.

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]b WCAP-15918-NP July 2019 Revision 3

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Westinghouse Non-Proprietary Class 3 8-3

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e

]c WCAP-15918-NP July 2019 Revision 3

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Westinghouse Non-Proprietary Class 3 8-4

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]c WCAP-15918-NP July 2019 Revision 3

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Westinghouse Non-Proprietary Class 3 8-5 TABLE 8-1

SUMMARY

OF SLEEVE DESIGN AND ASME CODE ANALYSIS FOR TZ AND TS SLEEVES CATEGORY RESULTS Axial Load [ ] c lb for intact tube unlocked in the supports c

during [ ] lb for severed tube unlocked in the supports 100% Steady State Operation [ ] c lb (max.) for intact tube locked in the supports

[ ] c lb for severed tube locked in the supports Tentative Sizing treqd = 0.0362 in. (per ASME Code) < tmin = 0.040 in.

% Allowable Degradation Limit 48% (per NRC Regulatory Guide 1.121, Ref. 8.3) for both CE and Westinghouse D & E plants CATEGORY ANALYSIS RESULTS ALLOWABLE (maximum stress in ksi) (per ASME Code, ksi)

General Primary Membrane Stress Stress Intensity =[ ]c Sm = 20.0 for Sleeve Material Primary Local Membrane Plus Primary Bending Stress for Sleeve Stress Intensity =[ ]c 1.5 Sm = 30.0 Material Primary Plus Secondary Stress for Stress Intensity =[ ]c 3 Sm = 60.0 Sleeve Material Fatigue of Sleeve Material U =[ ]c U = 1.0 Main Steam Line Break Stress Intensity =[ ]c 0.7 Su = 52.5 (CE plants)

Feedwater Line Break Stress Intensity =[ ]c 0.7 Su = 52.5 (Westinghouse D & E plants)

Primary Pipe Break (LOCA) Stress Intensity =[ ]c 0.7 Su = 52.5 WCAP-15918-NP July 2019 Revision 3

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Westinghouse Non-Proprietary Class 3 8-6 GENERAL MEMBRANE STRESSES SUMMARIZED

1. GENERAL PRIMARY MEMBRANE STRESS (Pm)

(per Par. NB-3221.1 of Ref. 8.1 w/ Design Primary Pressure of 2.5 ksi and Ri = [ ]c in., maximum inner radius for tmin =[ ]c in. per Reference 8.18) c

2. PRIMARY LOCAL MEMBRANE PLUS BENDING STRESS INTENSITY (PL + PB)

(per Par. NB-3221.3 of Ref. 8.1 w/Design Primary Pressure of 2.5 ksi, SOBE (seismic stress) of 5.2 ksi, and Ri of [ ]c in., maximum inner radius for tmin =[ ]c in. per Reference 8.18) c

3. PRIMARY PLUS SECONDARY STRESS INTENSITY (per paragraph NB-3222.2 of Ref. 8.1 w/ Spec. Service Pressure for Intact Tube Situation on Sleeves Inside Surface c

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Westinghouse Non-Proprietary Class 3 8-7 GENERAL MEMBRANE STRESSES SUMMARIZED (continued)

4. MAIN STEAM LINE BREAK FOR CE PLANTS c

5. FEEDWATER LINE BREAK FOR WESTINGHOUSE D & E PLANTS c

6. PRIMARY PIPE BREAK (LOCA) (assumes a severed tube) c WCAP-15918-NP July 2019 Revision 3

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Westinghouse Non-Proprietary Class 3 8-8 8.2 EVALUATION FOR ALLOWABLE SLEEVE WALL DEGRADATION USING REGULATORY GUIDE 1.121 NRC Regulatory Guide 1.121 (Reference 8.3) requires that a minimum acceptable tube (or sleeve) wall thickness be established to provide a basis for leaving a degraded tube in service.

For partial through-wall attack from any source, the requirements fall into two categories, (a) normal operation safety margins and (b) considerations related to limiting postulated accidents.

8.2.1 Normal Operation Safety Margins It is the general intent of these requirements to maintain the same factors of safety in evaluating degraded tubes as those which were contained in the original construction code, ASME Boiler and Pressure Vessel Code,Section III (Reference 8.1).

For Inconel Alloy 600 tube or Alloy 800 sleeve material the controlling safety margins from NRC Regulatory Guide 1.121 (Reference 8.3) for partial through-wall attack are:

1. Tubes with detected part through-wall cracks should not be stressed during the full range of normal reactor operation beyond the elastic range of the tube material.

2. Tubes with part through-wall cracks, wastage, or combinations of these should have a factor of safety against failure by bursting under normal operating conditions of not less than 3 at any tube location.

From References 8.2 and 8.15, the normal operating conditions for the worst case envelopment of steam generators from the CE and Westinghouse D & E plants are:

CE Plants Westinghouse D & E Primary Pressure Ppri = 2250 psi 2250 psi Secondary Pressure Psec = 790 psi (Ref. 8.15) 877 psi Differential Pressure P = Ppri - Psec = 1460 psi 1373 psi Average Pressure Pavg = 0.5 (Ppri + Psec) = 1520 psi 1564 psi Assuming the parent tube is totally severed, the sleeve is required to carry the pressure loading.

The following terms are used in this evaluation.

Ris = sleeve nominal inside radius, i.e., [ ]c in. per Reference 8.18 Syrm = min. required yield strength (per U.S. NRC Reg. Guide 1.121, Ref. 8.3)

Symin = minimum yield strength of sleeve (Sy = 23.7 ksi min. at 650°F, Ref. 8.1)

Based on the information provided in Reference 8.1, the Alloy 800 tube sleeve material (SB-163, UNS N08800) has an ultimate strength of 75.0 ksi at 650°F. The required thickness is shown below using a derivation of the formula in paragraph NB-3324.1 of Reference 8.1 with three times P as mentioned in Regulatory Guide 1.121 (Reference 8.3) and Su in place of Sm per controlling Safety Margin 2 above.

c

[ ]

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Westinghouse Non-Proprietary Class 3 8-9

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]c WCAP-15918-NP July 2019 Revision 3

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Westinghouse Non-Proprietary Class 3 8-10

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]c WCAP-15918-NP July 2019 Revision 3

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Westinghouse Non-Proprietary Class 3 8-11 8.2.2 Postulated Pipe Rupture Accidents NRC Regulatory Guide 1.121 requires the following:

The margin of safety against tube failure under postulated accidents, such as a LOCA, steam line break, or FLB concurrent with the safe shutdown earthquake (SSE), should be consistent with the margin of safety determined by the stress limits specified in NB-3225 of Section III of the ASME Boiler and Pressure Vessel Code.

The above referenced ASME Code paragraph deals with faulted conditions, where for an elastic analysis of Alloy 800 sleeves, a general membrane stress of 0.7 Su = 0.7(75.0) = 52.5 ksi is allowed. In conjunction with the NRC Regulatory Guide 1.121, the following accidents are postulated:

a. For a downcomer feedring steam generator, a FLB accident would have very little effect on steam generator internals. The FLB accident causes a significant pressure differential between the inside of the steam generator and the containment atmosphere. However, the many discharge elbows in the feedwater ring and the ring itself result in large pressure losses for the flow exiting the break. Thus, the flow at the break is limited and the associated forces acting on the steam generator internals (i.e., tubes and tube supports) is not significant when compared to other accident loads. For an economizer steam generator, a FLB accident causes large tube bending stresses near the feedwater nozzle but would have very little effect on the tube spans just above the tubesheet. For a Westinghouse economizer steam generator, a FLB accident produces a maximum differential pressure loading of 2.85 ksi (page 8-7) on the sleeve. A small axial stress could be induced in a sleeved tube if it were locked into the first tube support plate.

However, this stress would be negligible compared to the dominant hoop stress due to differential pressure

b. A LOCA accident causes large tube bending stresses in the upper tube bundle but produces only negligible compressive stresses in the region of interest. Thus, the axial loading, etc. in this evaluation applies to sleeves in the lower end of the tube bundle from the fourth support plate down to the tubesheet.

c. [

]c WCAP-15918-NP July 2019 Revision 3

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Westinghouse Non-Proprietary Class 3 8-12 The required thicknesses for a MSLB or FLB accident are shown below using the derivation of the formula in paragraph NB-3324.1 of Reference 8.1 with .7 Su in place of Sm.

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t

]c 8.3 EFFECTS OF TUBE LOCK-UP OR UNLOCKED SITUATION ON SLEEVE AXIAL LOADING Objective: Conservatively determine the maximum axial loads on the sleeve (tension and compression) during normal operation for both intact and severed tube situations.

General assumptions: (See Figures 8-2 through 8-5).

1. [

2.

3.

4.

5.

6.

]c WCAP-15918-NP July 2019 Revision 3

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Westinghouse Non-Proprietary Class 3 8-13

[

]c 8.3.1 Sleeved Tube in CE Plants, Unlocked at First Tube Support

[

]c From the diagram in Figure 8-4, the following equations are derived with the basic mechanics of materials equations in Reference 8.16.

The deflection of an axially loaded member in compression or tension, , is defined from Equation 14.6 in Reference 8.16 or: = F/K with K = AE/L where:

F = Force on the respective body, lb K = Spring constant for the respective body, lb/in A = Cross-sectional area of the respective body, in2.

E = Modulus of Elasticity of the respective body, psi L = Length of the respective body, inch The deflection or deformation of an axially loaded member due to temperature differences, , is defined from Equation 14.9 of Reference 8.16 or: = L (T - 70) where:

= Coefficient of thermal expansion of the respective body, in/in/°F T = Temperature of the respective body, °F WCAP-15918-NP July 2019 Revision 3

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Westinghouse Non-Proprietary Class 3 8-14

[

]c 8.3.2 Sleeved Tube in Westinghouse D & E Plant, Unlocked at First Tube Support

[

]c 8.3.3 Sleeved Tube in CE Plants, Locked at First Tube Support

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]c WCAP-15918-NP July 2019 Revision 3

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Westinghouse Non-Proprietary Class 3 8-15

[

]c 8.3.4 Sleeved Tube in Westinghouse D & E Plants, Locked at First Tube Support

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]c WCAP-15918-NP July 2019 Revision 3

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Westinghouse Non-Proprietary Class 3 8-16 TABLE 8-2A 25.0 INCH SLEEVE AXIAL MEMBER PHYSICAL PROPERTIES FOR CE PLANTS WITH 0.048" TUBE WALL AND EFFECTIVE LENGTH BETWEEN LOWER JOINT AND LAST UPPER JOINT OUTSIDE INSIDE EFFECTIVE SECTION CORRESPOND. YOUNG'S MEAN COEF.

COMPONENT RADIUS RADIUS LENGTH AREA Temp. MODULUS STIFFNESS THERM. EXP.

Ro Ri L A Tc E K = AE/L m (in) (in) (in) (in2) (oF) lb/in2 x 106 lb/in x 103 In/In oF x 10-6 (1) Sleeve [

(2) Lower Tube (3) Tube in Tubesheet (4) Upper Tube (5) Surrounding Tubes ]c Reference Temperatures: Primary (Hot) = 611°F (sleeve ID temperature)

Secondary = 506°F (tube OD temperature)

Normal Tubes = (2 Tpri + Tsec)/3 = 576°F NOTE:1 Nominal dimensions for sleeve from Reference 8.18.

2 m and E for Inconel 600 and 800 from Reference 8.1.

3 Nominal dimensions for tubes from Reference 8.4.

4 m for carbon moly steel from Reference 8.1.

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Westinghouse Non-Proprietary Class 3 8-17 TABLE 8-2B 25.0 INCH SLEEVE AXIAL MEMBER PHYSICAL PROPERTIES FOR CE PLANTS WITH 0.042" TUBE WALL AND EFFECTIVE LENGTH BETWEEN LOWER JOINT AND LAST UPPER JOINT OUTSIDE INSIDE EFFECTIVE SECTION CORRESPOND. YOUNG'S MEAN COEF.

COMPONENT RADIUS RADIUS LENGTH AREA Temp. MODULUS STIFFNESS THERM. EXP.

Ro Ri L A Tc E K = AE/L m (in) (in) (in) (in2) (oF) lb/in2 x 106 lb/in x 103 In/In oF x 10-6 (1) Sleeve [

(2) Lower Tube (3) Tube in Tubesheet (4) Upper Tube (5) Surrounding Tubes ]c Reference Temperatures: Primary (Hot) = 611oF (sleeve ID temperature)

Secondary = 506oF (tube OD temperature)

Normal Tubes = (2 Tpri + Tsec)/3 = 576oF NOTE:1 Nominal dimensions for sleeve from Reference 8.18.

2 m and E for Inconel 600 and 800 from Reference 8.1.

3 Nominal dimensions for tubes from Reference 8.8.

4 m for carbon moly steel from Reference 8.1.

WCAP-15918-NP July 2019 Revision 3

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Westinghouse Non-Proprietary Class 3 8-18 TABLE 8-2C 25.0 INCH SLEEVE AXIAL MEMBER PHYSICAL PROPERTIES FOR WESTINGHOUSE D3 PLANTS WITH EFFECTIVE LENGTH BETWEEN LOWER JOINT AND LAST UPPER JOINT OUTSIDE INSIDE EFFECTIVE SECTION CORRESPOND. YOUNG'S MEAN COEF.

COMPONENT RADIUS RADIUS LENGTH AREA Temp. MODULUS STIFFNESS THERM. EXP.

Ro Ri L A Tc E K = AE/L m (in) (in) (in) (in2) (oF) lb/in2 x 106 lb/in x 103 In/In oF x 10-6 (1) Sleeve [

(2) Lower Tube (3) Tube in Tubesheet (4) Upper Tube (5) Surrounding Tubes ]c Reference Temperatures: Primary (Hot) = 620oF (sleeve ID temperature)

Secondary = 526.5oF (tube OD temperature)

Normal Tubes = (2 Tpri + Tsec)/3 = 588.8oF NOTE:1 Nominal dimensions for sleeve from Reference 8.18.

2 m and E for Inconel 600 and 800 from Reference 8.1.

3 Nominal dimensions for tubes from Reference 8.9.

4 m for carbon moly steel from Reference 8.1.

WCAP-15918-NP July 2019 Revision 3

• • • This record was final approved on 8/1/2019 2:53:39 PM. (This statement was added by the PRIME system upon its validation)

Westinghouse Non-Proprietary Class 3 8-19 TABLE 8-2D 25.0 INCH SLEEVE AXIAL MEMBER PHYSICAL PROPERTIES FOR WESTINGHOUSE D4 PLANTS WITH EFFECTIVE LENGTH BETWEEN LOWER JOINT AND LAST UPPER JOINT OUTSIDE INSIDE EFFECTIVE SECTION CORRESPOND. YOUNG'S MEAN COEF.

COMPONENT RADIUS RADIUS LENGTH AREA Temp. MODULUS STIFFNESS THERM. EXP.

Ro Ri L A Tc E K = AE/L m (in) (in) (in) (in2) (oF) lb/in2 x 106 lb/in x 103 In/In oF x 10-6 (1) Sleeve [

(2) Lower Tube (3) Tube in Tubesheet (4) Upper Tube (5) Surrounding Tubes ]c Reference Temperatures: Primary (Hot) = 620oF (sleeve ID temperature)

Secondary = 526.5oF (tube OD temperature)

Normal Tubes = (2 Tpri + Tsec)/3 = 588.8oF NOTE:1 Nominal dimensions for sleeve from Reference 8.18.

2 m and E for Inconel 600 and 800 from Reference 8.1.

3 Nominal dimensions for tubes from Reference 8.9.

4 m for carbon moly steel from Reference 8.1.

WCAP-15918-NP July 2019 Revision 3

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Westinghouse Non-Proprietary Class 3 8-20 TABLE 8-2E 25.0 INCH SLEEVE AXIAL MEMBER PHYSICAL PROPERTIES FOR WESTINGHOUSE D2 PLANTS WITH EFFECTIVE LENGTH BETWEEN LOWER JOINT AND LAST UPPER JOINT OUTSIDE INSIDE EFFECTIVE SECTION CORRESPOND. YOUNG'S MEAN COEF.

COMPONENT RADIUS RADIUS LENGTH AREA Temp. MODULUS STIFFNESS THERM. EXP.

Ro Ri L A Tc E K = AE/L m (in) (in) (in) (in2) (oF) lb/in2 x 106 lb/in x 103 In/In oF x 10-6 (1) Sleeve [

(2) Lower Tube (3) Tube in Tubesheet (4) Upper Tube (5) Surrounding Tubes ]c Reference Temperatures: Primary (Hot) = 620oF (sleeve ID temperature)

Secondary = 526.5oF (tube OD temperature)

Normal Tubes = (2 Tpri + Tsec)/3 = 588.8oF NOTE:1 Nominal dimensions for sleeve from Reference 8.18.

2 m and E for Inconel 600 and 800 from Reference 8.1.

3 Nominal dimensions for tubes from Reference 8.9.

4 m for carbon moly steel from Reference 8.1.

WCAP-15918-NP July 2019 Revision 3

• • • This record was final approved on 8/1/2019 2:53:39 PM. (This statement was added by the PRIME system upon its validation)

Westinghouse Non-Proprietary Class 3 8-21 TABLE 8-2F 25.0 INCH SLEEVE AXIAL MEMBER PHYSICAL PROPERTIES FOR WESTINGHOUSE D5 PLANTS WITH EFFECTIVE LENGTH BETWEEN LOWER JOINT AND LAST UPPER JOINT OUTSIDE INSIDE EFFECTIVE SECTION CORRESPOND. YOUNG'S MEAN COEF.

COMPONENT RADIUS RADIUS LENGTH AREA Temp. MODULUS STIFFNESS THERM. EXP.

Ro Ri L A Tc E K = AE/L m (in) (in) (in) (in2) (oF) lb/in2 x 106 lb/in x 103 In/In oF x 10-6 (1) Sleeve [

(2) Lower Tube (3) Tube in Tubesheet (4) Upper Tube (5) Surrounding Tubes ]c Reference Temperatures: Primary (Hot) = 620oF (sleeve ID temperature)

Secondary = 526.5oF (tube OD temperature)

Normal Tubes = (2 Tpri + Tsec)/3 = 588.8oF NOTE: 1 Nominal dimensions for sleeve from Reference 8.18.

2 m and E for Inconel 600 and 800 from Reference 8.1.

3 Nominal dimensions for tubes from Reference 8.9.

4 m for carbon moly steel from Reference 8.1.

WCAP-15918-NP July 2019 Revision 3

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Westinghouse Non-Proprietary Class 3 8-22 TABLE 8-2G 25.0 INCH SLEEVE AXIAL MEMBER PHYSICAL PROPERTIES FOR WESTINGHOUSE E2 PLANTS WITH EFFECTIVE LENGTH BETWEEN LOWER JOINT AND LAST UPPER JOINT OUTSIDE INSIDE EFFECTIVE SECTION CORRESPOND. YOUNG'S MEAN COEF.

COMPONENT RADIUS RADIUS LENGTH AREA Temp. MODULUS STIFFNESS THERM. EXP.

Ro Ri L A Tc E K = AE/L m (in) (in) (in) (in2) (oF) lb/in2 x 106 lb/in x 103 In/In oF x 10-6 (1) Sleeve [

(2) Lower Tube (3) Tube in Tubesheet (4) Upper Tube (5) Surrounding Tubes ]c Reference Temperatures: Primary (Hot) = 620oF (sleeve ID temperature)

Secondary = 526.5oF (tube OD temperature)

Normal Tubes = (2 Tpri + Tsec)/3 = 588.8oF NOTE:1 Nominal dimensions for sleeve from Reference 8.18.

2 m and E for Inconel 600 and 800 from Reference 8.1.

3 Nominal dimensions for tubes from Reference 8.9.

4 m for carbon moly steel from Reference 8.1.

WCAP-15918-NP July 2019 Revision 3

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Westinghouse Non-Proprietary Class 3 8-23 TABLE 8-3A AXIAL THERMAL LOADS IN SLEEVE WITH TUBE UNLOCKED AND LOCKED INTO TUBE SUPPORT FOR CE PLANTS WITH 0.048" TUBE WALL Sleeve Load Sleeve Load F1 TRANSIENT Ppri Psec Tpri Tsec F1* for Locked CONDITION for Unlocked Condition (ksi) (ksi) (oF) (oF) Condition Fmax (lbs)

Fmin (lbs)

1. 100% Power [

2. 15% S.S.

3. 0% S.S.

4. Reactor Trip

5. Secondary Leak Test

]c TABLE 8-3B AXIAL THERMAL LOADS IN SLEEVE WITH TUBE UNLOCKED AND LOCKED INTO TUBE SUPPORT FOR CE PLANTS WITH 0.042 TUBE WALL Sleeve Load Sleeve Load F1 TRANSIENT Ppri Psec Tpri Tsec F1* for Locked CONDITION for Unlocked Condition (ksi) (ksi) (oF) (oF) Condition Fmax (lbs)

Fmin (lbs)

1. 100% Power [

2. 15% S.S.

3. 0% S.S.

4. Reactor Trip

5. Secondary Leak Test

]c WCAP-15918-NP July 2019 Revision 3

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Westinghouse Non-Proprietary Class 3 8-24 TABLE 8-3C AXIAL THERMAL LOADS IN SLEEVE WITH TUBE UNLOCKED AND LOCKED INTO TUBE SUPPORT FOR WESTINGHOUSE D3 PLANTS Sleeve Load Sleeve Load F1 TRANSIENT Ppri Psec Tpri Tsec F1* for Locked CONDITION for Unlocked Condition (ksi) (ksi) (oF) (oF) Condition Fmax (lbs)

Fmin (lbs)

1. 100% Power [

2. 15% S.S.

3. 0% S.S.

4. Reactor Trip

5. Feedwater Cycling

]c TABLE 8-3D AXIAL THERMAL LOADS IN SLEEVE WITH TUBE UNLOCKED AND LOCKED INTO TUBE SUPPORT FOR WESTINGHOUSE D4 PLANTS Sleeve Load Sleeve Load F1 TRANSIENT Ppri Psec Tpri Tsec F1* for Locked CONDITION for Unlocked Condition (ksi) (ksi) (oF) (oF) Condition Fmax (lbs)

Fmin (lbs)

1. 100% Power [

2. 15% S.S.

3. 0% S.S.

4. Reactor Trip

5. Feedwater Cycling

]c WCAP-15918-NP July 2019 Revision 3

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Westinghouse Non-Proprietary Class 3 8-25 TABLE 8-3E AXIAL THERMAL LOADS IN SLEEVE WITH TUBE UNLOCKED AND LOCKED INTO TUBE SUPPORT FOR WESTINGHOUSE D2 PLANTS Sleeve Load Sleeve Load F1 TRANSIENT Ppri Psec Tpri Tsec F1* for Locked CONDITION for Unlocked Condition (ksi) (ksi) (oF) (oF) Condition Fmax (lbs)

Fmin (lbs)

1. 100% Power [

2. 15% S.S.

3. 0% S.S.

4. Reactor Trip

5. Feedwater Cycling

]c TABLE 8-3F AXIAL THERMAL LOADS IN SLEEVE WITH TUBE UNLOCKED AND LOCKED INTO TUBE SUPPORT FOR WESTINGHOUSE D5 PLANTS Sleeve Load Sleeve Load F1 TRANSIENT Ppri Psec Tpri Tsec F1* for Locked CONDITION for Unlocked Condition (ksi) (ksi) (oF) (oF) Condition Fmax (lbs)

Fmin (lbs)

1. 100% Power [

2. 15% S.S.

3. 0% S.S.

4. Reactor Trip

5. Feedwater Cycling

]c WCAP-15918-NP July 2019 Revision 3

• • • This record was final approved on 8/1/2019 2:53:39 PM. (This statement was added by the PRIME system upon its validation)

Westinghouse Non-Proprietary Class 3 8-26 TABLE 8-3G AXIAL THERMAL LOADS IN SLEEVE WITH TUBE UNLOCKED AND LOCKED INTO TUBE SUPPORT FOR WESTINGHOUSE E2 PLANTS Sleeve Load Sleeve Load F1 Transient Ppri Psec Tpri Tsec F1* for Locked Condition for Unlocked Condition (ksi) (ksi) (oF) (oF) Condition Fmax (lbs)

Fmin (lbs)

1. 100% Power [

2. 15% S.S.

3. 0% S.S.

4. Reactor Trip

5. Feedwater Cycling

]c WCAP-15918-NP July 2019 Revision 3

• • • This record was final approved on 8/1/2019 2:53:39 PM. (This statement was added by the PRIME system upon its validation)

Westinghouse Non-Proprietary Class 3 8-27 8.3.5 Effect of Tube Pre-stress Prior to Sleeving

[

]c 8.3.6 Lower Sleeve Rolled Section Pushout Due to Restrained Thermal Expansion

[

]c Plant Compression Load (pounds) c CE plant with 0.048" tube thickness CE plant with 0.042" tube thickness Westinghouse D3 plant Westinghouse D4 plant Westinghouse D2 plant Westinghouse D5 plant Westinghouse E2 plant WCAP-15918-NP July 2019 Revision 3

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Westinghouse Non-Proprietary Class 3 8-28 8.4 SLEEVED TUBE VIBRATION CONSIDERATIONS The vibration behavior of a sleeved tube is evaluated as follows:

8.4.1 Effects of Increased Stiffness

[

]c 8.4.2 Effect of Severed Tube

[

]c WCAP-15918-NP July 2019 Revision 3

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Westinghouse Non-Proprietary Class 3 8-29

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]c WCAP-15918-NP July 2019 Revision 3

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Westinghouse Non-Proprietary Class 3 8-30 8.4.3 Seismic Evaluation

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]c WCAP-15918-NP July 2019 Revision 3

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Westinghouse Non-Proprietary Class 3 8-31

[

]c 8.5 EVALUATION OF SLEEVE TO TUBE EXPANSION SECTION The normal operating, design seismic, and transient conditions on the steam generator tube sleeves are used in accordance with ASME Code Section III evaluation, considering both temperature and pressure loads.

The transient conditions defined in References 8.8 and 8.23 represent the worst-case situation for a CE plant steam generator. Table 8-4A shows the grouping of these transients with the logic as follows:

• The 500 cycles between ambient (room temperature) and 0% steady state represent the 500 heatup and cooldown conditions.

• The 17,000 cycles between 15% steady state and full power are the sum of the 15,000 loading and unloading conditions and 2000 step load events.

• The 480 cycles between full power and reactor trip are a combination of 400 trip, 40 loss of flow, and 40 loss of load cycles.

• The 200 cycles for secondary leak testing.

The transient conditions defined in Reference 8.19 represent the worst-case situation for a Westinghouse D & E plant steam generator. Table 8-4B shows the grouping of these transients with the logic as follows:

• The 280 cycles between ambient (room temperature) and 0% steady state represent the 200 normal heatup and cooldown conditions and 80 loops out-of-service conditions.

• The 18,300 cycles between 15% steady state and full power are the sum of the 18,300 loading and unloading conditions.

• The 500 cycles of loading/unloading represent loading and unloading between 0%

and 15% power.

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Westinghouse Non-Proprietary Class 3 8-32

• The 400 cycles of reactor trip represent 400 upset conditions.

• The 2000 cycles of feedwater cycling represent excursions from 0% steady state.

Hydro tests are isothermal and produce negligibly small sleeve loads regarding fatigue. Further details on the results of the load cycling tests are presented in Section 7.0.

A bounding analysis which envelopes the sleeve and the tube at the expansion zone is performed in which primary plus secondary and peak stresses are evaluated. The axial and radial stresses in the sleeve due to thermal expansion differentials are conservatively calculated assuming total restraint of the sleeve/tube joint. The peak stress calculations conservatively ignore fluid film resistances and use total bulk fluid temperature differences to calculate a thermal skin stress. The actual linear temperature gradient across the sleeve wall is small and produces an insignificant secondary stress. The stress calculations assume a straight sleeve and tube with nominal dimensions. The residual strains introduced during the sleeving procedure are small, thus there is very little distortion as noted in Reference 8.4. Any non-conservatism introduced by not applying a stress intensification factor at expansion zones is covered by the other conservatisms in the modeling and loading assumptions. The major conservatisms in this analysis, relate to the treatment of the thermal conditions and the assumption that the sleeve to tube attachment points are rigid. The use of a thermal gradient across the tube/sleeve assembly wall will result in a significant reduction in the temperature differential between the sleeve and tube.

Stresses introduced during the installation of the sleeves will shake down during the first few operational cycles as noted in Reference 8.4 and are neglected in the ASME evaluations as the ASME Code does not address mechanical joints. A rolled or mechanical joint does not concentrate stresses the way a welded joint does because the two bodies are not directly bonded together. It is only interfacial pressure and friction that is used to maintain the integrity of the joint. Several cyclic tests were performed to evaluate the effect of these types of loadings on the integrity of the joint as described in Section 7.2.3. In general, the integrity of the joint was either unaffected or improved following the tests. Hence, cyclic loadings will not degrade joint integrity.

During the initial plant heatup following Alloy 800 sleeve installation, the sleeve will expand more than the parent tube. As the sleeve lengthens, it will be restrained by the upper and lower joints and the tube will be in compression. At some point during the initial heatup, the sleeve will move (with respect to the tube) and the compressive stresses will be reduced. During subsequent plant heatups there will be no relative movement between the sleeve and tube and compressive stresses on the tube will be lower than occurred during the initial heatup. A more detailed explanation of this process is contained in Section 7.2 of the report.

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Westinghouse Non-Proprietary Class 3 8-33 TABLE 8-4A TUBE SLEEVE EXPANSION SECTION - TRANSIENTS CONSIDERED FOR A CE PLANT RESTRAINED TRANSIENTS END POINTS CYCLES THERMAL P1 P2 (P1 - P2)

EXPANSION (psi) (psi) (psi)

AXIAL LOAD (lbs)

(1) Heatup/Cooldown Ambient [

0% S.S. 500 (2) Loading/Unloading 15% S.S.

(15% - 100%) 100% S.S. 17000 (3) Reactor Trip 100% S.S.

and Upset 0% S.S. 480 (4) Secondary Leak Test Test Condition Ambient 200 ]c CONDITIONS:

(a) Worst case: Tube is locked-in to first tube support.

(b) Tube is intact: Tube/sleeve restrained thermal expansion.

(c) Axial loads are from Table 8-3A.

(d) Sleeve is 25 inches long.

(e) Transient cycles are defined in References 8.8 and 8.23.

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Westinghouse Non-Proprietary Class 3 8-34 TABLE 8-4B TUBE SLEEVE EXPANSION SECTION - TRANSIENTS CONSIDERED FOR A WESTINGHOUSE D OR E PLANT RESTRAINED TRANSIENTS END POINTS CYCLES THERMAL P1 P2 (P1 - P2)

EXPANSION (psi) (psi) (psi)

AXIAL LOAD (lbs)

(1) Heatup/Cooldown Ambient [

0% S.S. 280 (2) Loading/Unloading 15% S.S.

(15% - 100%) 100% S.S. 18300 (3) Loading/Unloading 0% S.S.

(0% - 15%) 15% S.S. 500 (4) Reactor Trip 100% S.S.

and Upset 0% S.S. 400 (5) Feedwater Cycling 0% S.S.

FW Cycling 2000 ]c CONDITIONS:

(a) Worst case: Tube is locked-in to first tube support.

(b) Tube is intact: Tube/sleeve restrained thermal expansion.

(c) Axial loads are from Table 8-3C.

(d) Sleeve is 25 inches long.

(e) Transient cycles are defined in Reference 8.19.

(f) For reactor trip and upset, P1 is assumed to be a maximum of 2250 psi.

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Westinghouse Non-Proprietary Class 3 8-35 The stresses on the sleeves that occur during the installation process are not neglected in the ASME Code analysis. The stresses are treated separately. A detailed description of the installation stresses is contained in Section 7.4. As described therein, residual stresses were maintained below the yield stress of the material and were evaluated as part of the material evaluation in Section 6.0.

As described previously, axial stresses on the tube (tension) and sleeve (compression) are reduced during the initial plant heatup when the sleeve is displaced. This displacement does not occur during subsequent heatups and cooldowns and the stress on the components is less than during the first cycle.

Further, axial loads on the sleeve are calculated assuming no displacement of the sleeve relative to the tube. Hence, the axial loads calculated in the report are conservative relative to those that would occur in a steam generator. Other stresses calculated in the report for normal and faulted conditions are dependent on the primary to secondary pressure differential and are unaffected by installation stresses.

8.5.1 Analysis of Sleeve Material

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Westinghouse Non-Proprietary Class 3 8-36

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Westinghouse Non-Proprietary Class 3 8-37 TABLE 8-5A STRESSES IN SLEEVE FOR CE PLANTS WITH 0.048" TUBE WALL Stress Hoop Stress due Thermal Radial Thermal Transient due to to Sleeve/Tube Differential Skin Stress Condition Axial Load Differential Stress, thermal skin axial Temperature, (ksi) (ksi)

(ksi) (ksi)

1. Ambient [

2. 0% S.S.

3. 15% S.S.

4. 100% S.S.

5. Reactor Trip

6. Secondary Leak Test ]c TABLE 8-5B STRESSES IN SLEEVE FOR CE PLANTS WITH 0.042" TUBE WALL Stress Hoop Stress due Thermal Radial Thermal Transient due to to Sleeve/Tube Differential Skin Stress Condition Axial Load Differential Stress, thermal skin axial Temperature, (ksi) (ksi)

(ksi) (ksi)

1. Ambient [

2. 0% S.S.

4. 100% S.S.

5. Reactor Trip

6. Secondary Leak Test ]c WCAP-15918-NP July 2019 Revision 3

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Westinghouse Non-Proprietary Class 3 8-38 TABLE 8-5C STRESSES IN SLEEVE FOR WESTINGHOUSE D3 PLANTS Stress Hoop Stress due Thermal Radial Thermal Transient due to to Sleeve/Tube Differential Skin Stress Condition Axial Load Differential Stress, thermal skin axial Temperature, (ksi) (ksi)

(ksi) (ksi)

1. Ambient [

2. 0% S.S.

3. 15% S.S.

4. 100% S.S.

5. Reactor Trip

6. Feedwater Cycling ]c TABLE 8-5D STRESSES IN SLEEVE FOR WESTINGHOUSE D4 PLANTS Stress Hoop Stress due Thermal Radial Thermal Transient due to to Sleeve/Tube Differential Skin Stress Condition Axial Load Differential Stress, thermal skin axial Temperature, (ksi) (ksi)

(ksi) (ksi)

1. Ambient [

2. 0% S.S.

3. 15% S.S.

4. 100% S.S.

5. Reactor Trip

6. Feedwater Cycling ]c WCAP-15918-NP July 2019 Revision 3

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Westinghouse Non-Proprietary Class 3 8-39 TABLE 8-5E STRESSES IN SLEEVE FOR WESTINGHOUSE D2 PLANTS Stress Hoop Stress due Thermal Radial Thermal Transient due to to Sleeve/Tube Differential Skin Stress Condition Axial Load Differential Stress, thermal skin axial Temperature, (ksi) (ksi)

(ksi) (ksi)

1. Ambient [

2. 0% S.S.

3. 15% S.S.

4. 100% S.S.

5. Reactor Trip

6. Feedwater Cycling ]c TABLE 8-5F STRESSES IN SLEEVE FOR WESTINGHOUSE D5 PLANTS Stress Hoop Stress due Thermal Radial Thermal Transient due to to Sleeve/Tube Differential Skin Stress Condition Axial Load Differential Stress, thermal skin axial Temperature, (ksi) (ksi)

(ksi) (ksi)

1. Ambient [

2. 0% S.S.

3. 15% S.S.

4. 100% S.S.

5. Reactor Trip

6. Feedwater Cycling ]c WCAP-15918-NP July 2019 Revision 3

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Westinghouse Non-Proprietary Class 3 8-40 TABLE 8-5G STRESSES IN SLEEVE FOR WESTINGHOUSE E2 PLANTS Stress Hoop Stress due Thermal Radial Thermal TRANSIENT due to to Sleeve/Tube Differential Skin Stress CONDITION Axial Load Differential Stress, thermal skin axial Temperature, (ksi) (ksi)

(ksi) (ksi)

1. Ambient [

2. 0% S.S.

4. 100% S.S.

5. Reactor Trip

6. Feedwater Cycling ]c WCAP-15918-NP July 2019 Revision 3

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Westinghouse Non-Proprietary Class 3 8-41

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Westinghouse Non-Proprietary Class 3 8-42 TABLE 8-6A PRIMARY AND SECONDARY STRESSES AND STRESS INTENSITIES ON INSIDE SURFACE OF SLEEVE WITH LOCKED AND INTACT TUBE FOR CE PLANTS WITH 0.048" TUBE WALL Total Total Total Transient Axial Hoop Radial Condition Sxr Sr Sx Stresses Stresses Stresses x total total x total (ksi) (ksi) (ksi)

(ksi) (ksi) (ksi)

1. Ambient [

2. 0% S.S.

3. 15% S.S.

4. 100% S.S.

5. Reactor Trip

6. Secondary Leak Test ]c Sxr range =[ ]c ksi < 3.0 Sm = 60 ksi Sr range =[ ]c ksi Sx range =[ ]c ksi TABLE 8-6B PRIMARY AND SECONDARY STRESSES AND STRESS INTENSITIES ON INSIDE SURFACE OF SLEEVE WITH LOCKED AND INTACT TUBE FOR CE PLANTS WITH 0.042" TUBE WALL Total Total Total Transient Axial Hoop Radial Condition Sxr Sr Sx Stresses Stresses Stresses x total total x total (ksi) (ksi) (ksi)

(ksi) (ksi) (ksi)

1. Ambient [

2. 0% S.S.

3. 15% S.S.

4. 100% S.S.

5. Reactor Trip

6. Secondary Leak Test ]c Sxr range =[ ]c ksi < 3.0 Sm = 60 ksi Sr range =[ ]c ksi Sx range =[ ]c ksi WCAP-15918-NP July 2019 Revision 3

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Westinghouse Non-Proprietary Class 3 8-43 TABLE 8-6C PRIMARY AND SECONDARY STRESSES AND STRESS INTENSITIES ON INSIDE SURFACE OF SLEEVE WITH LOCKED AND INTACT TUBE FOR WESTINGHOUSE D3 PLANTS Total Total Total Transient Axial Hoop Radial Condition Sxr Sr Sx Stresses Stresses Stresses x total total x total (ksi) (ksi) (ksi)

(ksi) (ksi) (ksi)

1. Ambient [

2. 0% S.S.

3. 15% S.S.

4. 100% S.S.

5. Reactor Trip

6. Feedwater Cycling ]c Sxr range =[ ]c ksi < 3.0 Sm = 60 ksi Sr range =[ ]c ksi Sx range =[ ]c ksi TABLE 8-6D PRIMARY AND SECONDARY STRESSES AND STRESS INTENSITIES ON INSIDE SURFACE OF SLEEVE WITH LOCKED AND INTACT TUBE FOR WESTINGHOUSE D4 PLANTS Total Total Total Transient Axial Hoop Radial Condition Sxr Sr Sx Stresses Stresses Stresses x total total x total (ksi) (ksi) (ksi)

(ksi) (ksi) (ksi)

1. Ambient [

3. 15% S.S.

4. 100% S.S.

5. Reactor Trip

6. Feedwater Cycling ]c Sxr range =[ ]c ksi < 3.0 Sm = 60 ksi Sr range =[ ]c ksi Sx range =[ ]c ksi WCAP-15918-NP July 2019 Revision 3

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Westinghouse Non-Proprietary Class 3 8-44 TABLE 8-6E PRIMARY AND SECONDARY STRESSES AND STRESS INTENSITIES ON INSIDE SURFACE OF SLEEVE WITH LOCKED AND INTACT TUBE FOR WESTINGHOUSE D2 PLANTS Total Total Total Transient Axial Hoop Radial Condition Sxr Sr Sx Stresses Stresses Stresses x total total x total (ksi) (ksi) (ksi)

(ksi) (ksi) (ksi)

1. Ambient [

2. 0% S.S.

3. 15% S.S.

4. 100% S.S.

5. Reactor Trip

6. Feedwater Cycling ]c Sxr range = [ ]c ksi < 3.0 Sm = 60 ksi Sr range = [ ]c ksi Sx range = [ ]c ksi TABLE 8-6F PRIMARY AND SECONDARY STRESSES AND STRESS INTENSITIES ON INSIDE SURFACE OF SLEEVE WITH LOCKED AND INTACT TUBE FOR WESTINGHOUSE D5 PLANTS Total Total Total Transient Axial Hoop Radial Condition Sxr Sr Sx Stresses Stresses Stresses x total total x total (ksi) (ksi) (ksi)

(ksi) (ksi) (ksi)

1. Ambient [

2. 0% S.S.

3. 15% S.S.

4. 100% S.S.

5. Reactor Trip

6. Feedwater Cycling ]c Sxr range =[ ]c ksi < 3.0 Sm = 60 ksi Sr range =[ ]c ksi Sx range =[ ]c ksi WCAP-15918-NP July 2019 Revision 3

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Westinghouse Non-Proprietary Class 3 8-45 TABLE 8-6G PRIMARY AND SECONDARY STRESSES AND STRESS INTENSITIES ON INSIDE SURFACE OF SLEEVE WITH LOCKED AND INTACT TUBE FOR WESTINGHOUSE E2 PLANTS Total Total Total Transient Axial Hoop Radial Condition Sxr Sr Sx Stresses Stresses Stresses x total total x total (ksi) (ksi) (ksi)

(ksi) (ksi) (ksi)

1. Ambient [

2. 0% S.S.

3. 15% S.S.

4. 100% S.S.

5. Reactor Trip

6. Feedwater Cycling ]c Sxr range =[ ]c ksi < 3.0 Sm = 60 ksi Sr range =[ ]c ksi Sx range =[ ]c ksi WCAP-15918-NP July 2019 Revision 3

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Westinghouse Non-Proprietary Class 3 8-46

6. Fatigue Evaluation

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Westinghouse Non-Proprietary Class 3 8-47 TABLE 8-7A PEAK STRESS INTENSITY ON INSIDE SURFACE OF SLEEVE WITH LOCKED AND INTACT TUBE FOR CE PLANTS WITH 0.048" TUBE WALL Spxr Spr Spx Number Transient Condition of Cycles (ksi) (ksi) (ksi)

1. Ambient [

2. 0% S.S.

3. 15% S.S.

4. 100% S.S.

5. Reactor Trip

6. Secondary Leak Test ]c TABLE 8-7B PEAK STRESS INTENSITY ON INSIDE SURFACE OF SLEEVE WITH LOCKED AND INTACT TUBE FOR CE PLANTS WITH 0.042" TUBE WALL Spxr Spr Spx Number Transient Condition of Cycles (ksi) (ksi) (ksi)

1. Ambient [

2. 0% S.S.

3. 15% S.S.

4. 100% S.S.

5. Reactor Trip

6. Secondary Leak Test ]c WCAP-15918-NP July 2019 Revision 3

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Westinghouse Non-Proprietary Class 3 8-48 TABLE 8-7C PEAK STRESS INTENSITY ON INSIDE SURFACE OF SLEEVE WITH LOCKED AND INTACT TUBE FOR WESTINGHOUSE D3 PLANTS Spxr Spr Spx Number Transient Condition of Cycles (ksi) (ksi) (ksi)

1. Ambient [

2. 0% S.S.

3. 15% S.S.

4. 100% S.S.

5. Reactor Trip

6. Feedwater Cycling ]c TABLE 8-7D PEAK STRESS INTENSITY ON INSIDE SURFACE OF SLEEVE WITH LOCKED AND INTACT TUBE FOR WESTINGHOUSE D4 PLANTS Spxr Spr Spx Number TRANSIENT CONDITION of Cycles (ksi) (ksi) (ksi)

1. Ambient [

2. 0% S.S.

3. 15% S.S.

4. 100% S.S.

5. Reactor Trip -

6. Feedwater Cycling ]c WCAP-15918-NP July 2019 Revision 3

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Westinghouse Non-Proprietary Class 3 8-49 TABLE 8-7E PEAK STRESS INTENSITY ON INSIDE SURFACE OF SLEEVE WITH LOCKED AND INTACT TUBE FOR WESTINGHOUSE D2 PLANTS Spxr Spr Spx Number Transient Condition of Cycles (ksi) (ksi) (ksi)

1. Ambient [

2. 0% S.S.

3. 15% S.S.

4. 100% S.S.

5. Reactor Trip

6. Feedwater Cycling ]c TABLE 8-7F PEAK STRESS INTENSITY ON INSIDE SURFACE OF SLEEVE WITH LOCKED AND INTACT TUBE FOR WESTINGHOUSE D5 PLANTS Spxr Spr Spx Number Transient Condition of Cycles (ksi) (ksi) (ksi)

1. Ambient [

2. 0% S.S.

3. 15% S.S.

4. 100% S.S.

5. Reactor Trip

6. Feedwater Cycling ]c WCAP-15918-NP July 2019 Revision 3

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Westinghouse Non-Proprietary Class 3 8-50 TABLE 8-7G PEAK STRESS INTENSITY ON INSIDE SURFACE OF SLEEVE WITH LOCKED AND INTACT TUBE FOR WESTINGHOUSE E2 PLANTS Spxr Spr Spx Number Transient Condition of Cycles (ksi) (ksi) (ksi)

1. Ambient [

2. 0% S.S.

3. 15% S.S.

4. 100% S.S.

5. Reactor Trip

6. Feedwater Cycling ]c For the Spxr peak stress range, the accumulated fatigue damage is calculated as follows in Tables 8-8A through 8-8G:

TABLE 8-8A ACCUMULATED FATIGUE IN SLEEVE MATERIAL FOR SPXR PEAK STRESS RANGE FOR CE PLANTS WITH 0.048" TUBE WALL Max. Stress Intensity Min. Stress Intensity Transient SI Transient SI Sa Sa*(1) N (2) n U=

ksi ksi ksi ksi n/N Ambient [ ]c 100% S.S. [

Secondary Leak Test [ ]c 100% S.S.

0% S.S. [ ]c 100% S.S.

15% S.S. [ ]c 100% S.S. ]c (1) - Per Reference 8.1,Section III, paragraph NB-3222.4 (e) (4), the definition for Sa* is:

Sa* = Ecurve / Eactual (Sa) = 1.0755 Sa Where: Ecurve = 28.3 x 106 psi; Reference 1,Section III, Figure I-9-2 Eactual = 26.313 x 106 psi; Reference 1 for the sleeve material (2) - Reference 8.1,Section III, Figure I-9-2 Therefore, U =[ ] c < Allowable = 1.0 WCAP-15918-NP July 2019 Revision 3

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Westinghouse Non-Proprietary Class 3 8-51 TABLE 8-8B ACCUMULATED FATIGUE IN SLEEVE MATERIAL FOR SPXR PEAK STRESS RANGE FOR CE PLANTS WITH 0.042" TUBE WALL Max. Stress Intensity Min. Stress Intensity Transient SI Transient SI Sa Sa*(1) N (2) n U=

ksi ksi ksi ksi n/N Ambient [ ]c 100% S.S. [

Secondary Leak Test [ ]c 100% S.S.

0% S.S. [ ]c 100% S.S.

15% S.S. [ ]c 100% S.S. ]c Therefore, U =[ ] c < Allowable = 1.0 TABLE 8-8C ACCUMULATED FATIGUE IN SLEEVE MATERIAL FOR SPXR PEAK STRESS RANGE FOR WESTINGHOUSE D3 PLANTS Max. Stress Intensity Min. Stress Intensity Transient SI Transient SI Sa Sa*(1) N (2) n U=

ksi ksi ksi ksi n/N Feedwater Cycling [ ]c 100% S.S. [

Ambient [ ] c 100% S.S. ]c Therefore, U =[ ] c < Allowable = 1.0 TABLE 8-8D ACCUMULATED FATIGUE IN SLEEVE MATERIAL FOR SPXR PEAK STRESS RANGE FOR WESTINGHOUSE D4 PLANTS Max. Stress Intensity Min. Stress Intensity Transient SI Transient SI Sa Sa*(1) N (2) n U=

ksi ksi ksi ksi n/N Feedwater Cycling [ ] c 100% S.S. [

Ambient [ ]c 100% S.S. ]c Therefore, U =[ ] c < Allowable = 1.0 WCAP-15918-NP July 2019 Revision 3

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Westinghouse Non-Proprietary Class 3 8-52 TABLE 8-8E ACCUMULATED FATIGUE IN SLEEVE MATERIAL FOR SPXR PEAK STRESS RANGE FOR WESTINGHOUSE D2 PLANTS Max. Stress Intensity Min. Stress Intensity Transient SI Transient SI Sa Sa*(1) N (2) n U=

ksi ksi ksi ksi n/N Feedwater Cycling [ ] c 100% S.S. [

Ambient [ ]c 100% S.S. ]c Therefore, U =[ ] c < Allowable = 1.0 TABLE 8-8F ACCUMULATED FATIGUE IN SLEEVE MATERIAL FOR SPXR PEAK STRESS RANGE FOR WESTINGHOUSE D5 PLANTS Max. Stress Intensity Min. Stress Intensity Transient SI Transient SI Sa Sa*(1) N (2) n U=

ksi ksi ksi ksi n/N Feedwater Cycling [ ] c 100% S.S. [

Ambient [ ]c 100% S.S. ]c Therefore, U =[ ] c < Allowable = 1.0 TABLE 8-8G ACCUMULATED FATIGUE IN SLEEVE MATERIAL FOR SPXR PEAK STRESS RANGE FOR WESTINGHOUSE E2 PLANTS Max. Stress Intensity Min. Stress Intensity Transient SI Transient SI Sa Sa*(1) N (2) n U=

ksi ksi ksi ksi n/N Feedwater Cycling [ ] c 100% S.S. [

Ambient [ ]c 100% S.S. ]c Therefore, U =[ ] c < Allowable = 1.0 WCAP-15918-NP July 2019 Revision 3

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Westinghouse Non-Proprietary Class 3 8-53 8.6 EFFECTS OF SEVERED, UNLOCKED TUBE ON SLEEVE AXIAL LOADING

[

]c

8.7 REFERENCES

FOR SECTION 8.0 8.1 ASME Boiler and Pressure Vessel Code, Sections II and III for Nuclear Power Plant Components, 1995 Edition, No Addenda.

8.2 ABB CENP Letter Report No. CSE-96-116, Tube Sleeve History Data for 3/4 inch Steam Generator Tubes, May 07, 1996.

8.3 U.S. NRC Regulatory Guide 1.121, Bases for Plugging Degraded PWR Steam Generator Tubes.

8.4 ABB Reaktor GmbH Calculation Report No. GBRA 040 194, Sleeving of ANO2 Steam Generator Tubing (3/4") by PLUSS Sleeves with 6 x 8 mm Zero Expansions, June 10, 1997.

8.5 Mechanical Vibrations, 4th Edition, by J.P. Hartog, McGraw-Hill Book Co., New York, New York, pg. 432.

8.6 Vibration in Nuclear Heat Exchangers Due to Liquid and Two-Phase Flow, By W.J. Heilker and R.Q.

Vincent, Journal of Engineering for Power, Volume 103, pages 358-366, April 1981 (REF-96-015).

8.7 EPRI NP-1479, Effect of Out-of-Plane Denting Loads on the Structural Integrity of Steam Generator Internals, Contractor: Combustion Engineering, August 1980.

8.8 ABB CENP License Report CEN-613-P, Rev. 01, Arizona Public Service Co. Palo Verde Steam Generator Tube Repair Using Leak Tight Sleeves, January 1995.

8.9 ABB CENP Drawing No. E-SGNS-222-700, Rev. 02, I-800 Transition Zone Sleeve Installation.

8.10 ABB CENP Drawing No. E-SGNS-222-701, Rev. 02, I-800 Tube Support Sleeve Installation.

8.11 ABB CENP Report No. TR-ESE-178, Rev. 1, Palisades Steam Generator Tube/Sleeve Vibration Tests, October 05, 1977 (REF-96-003).

8.12 ABB CENP Report No. A-SONGS-9416-1168, Rev. 0 (Attachment D), Thermal-Hydraulic Analysis of the Southern California Edison San Onofre Nuclear Generating Station Unit 3 Steam Generator with Degraded Eggcrates, June 4, 1997.

8.13 ABB Reaktor GmbH Test Report No. GBRA 039927, Rev. A, 3/4" US NSSS Sleeving Summary of Test Results.

8.14 ABB CENP Drawing E-SGNS-222-702, Rev. 02, I-800 Tube Support Sleeve for CE, W D & W E Series S/G Tubes.

8.15 ABB CENP Memo No. WO97136.DS, Re-analysis of Alloy 800 Sleeve Due to a Change in Secondary Side Pressure, August 20, 1997.

8.16 Mechanical Engineering Reference Manual, Ninth Edition, by Michael R. Lindeberg, P.E., 1994, pages 14-3 through 14-4.

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Westinghouse Non-Proprietary Class 3 8-54 8.17 ABB CENP Report No. ABBCE-9416-1174, Rev. 00, Evaluation of an Alloy 800 Tube Sleeve for Application in 3/4 inch Steam Generator Tubes, October 1997.

8.18 ABB CENP Drawing No. E-SGNS-222-703, Rev. 02, I-800 Transition Zone Sleeve for CE, W D &

W E Series S/G Tubes.

8.19 ABB CENP License Report No. CEN-624-P, Rev. 00, Carolina Power & Light Shearon Harris Steam Generator Tube Repair Using Leak Tight Sleeves, July 1995.

8.20 NRC Generic Letter 95-05: Voltage - Based Repair Criteria for Westinghouse Steam Generator Tubes Affected by Outside Diameter Stress Corrosion Cracking, page 3 of Attachment 1, as applied to the Westinghouse plants.

8.21 Inconel Alloy 600 Information from Inco Alloys International, Inc. Product Information Booklet, Huntington, W. Va., 1986 (REF-00-036).

8.22 Model D4 Steam Generator Thermal and Hydraulic Design Data Report for Carolina Power & Light Company - Shearon Harris Unit 1, WTD-PE-77-22 Revision 1, November 20, 1984.

8.23 ABB CENP Report No. CENC-1272, Analytical Report for Southern California Edison San Onofre Unit 2 Steam Generator, September 1976.

8.24 Formulas for Stress and Strain, 5th Edition, by R. J. Roark and W. C. Young, McGraw-Hill Book Co.,

New York, New York, 1975.

8.25 Steam Generator Degradation Specific Management Flaw Handbook, EPRI, Palo Alto, CA:

2001. 1001191 8.26 Westinghouse Design Specification 13172-31-2, Revision 6, Project Specification for Steam Generator Assemblies for Florida Power & Light Co. St. Lucie Plant Unit 2 1978-890 Mw Extension, June 1982.

8.27 A-ABBCE-9449-1243, Revision 0, Evaluation of an Alloy 800 Tube Sleeve for Application in Combustion Engineering and Westinghouse 3/4 Inch Steam Generator Tubes, ABB Combustion Engineering, Chattanooga, TN. 2000.

8.28 LTR-CDMP-19-30, Revision 0, Evaluation of an Alloy 800 Tube Sleeve for Application in Combustion Engineering and Westinghouse 3/4 Inch Steam Generator Tubes - Reconciliation of A-ABBCE-9449-1243, REV. 0 to Watts Bar Unit 2 Model D3 OSG, Westinghouse Electric Company, June 2019.

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Westinghouse Non-Proprietary Class 3 8-55 c

FIGURE 8-1 MECHANICAL SLEEVE/TUBE ASSEMBLY WCAP-15918-NP July 2019 Revision 3

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Westinghouse Non-Proprietary Class 3 8-56 c

FIGURE 8-2 SYSTEM SCHEMATIC FOR WORST CASE CE PLANT WITH EFFECTIVE LENGTH BETWEEN LOWER JOINT AND LAST UPPER JOINT WCAP-15918-NP July 2019 Revision 3

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Westinghouse Non-Proprietary Class 3 8-57 c

FIGURE 8-3 SYSTEM SCHEMATIC FOR WESTINGHOUSE D & E PLANTS WITH EFFECTIVE LENGTH BETWEEN LOWER JOINT AND LAST UPPER JOINT WCAP-15918-NP July 2019 Revision 3

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Westinghouse Non-Proprietary Class 3 8-58 c

FIGURE 8-4 MODEL OF SLEEVE, LOWER TUBE, AND TUBE IN TUBESHEET; UNLOCKED AT TUBE SUPPORT WCAP-15918-NP July 2019 Revision 3

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Westinghouse Non-Proprietary Class 3 8-59 c

FIGURE 8-5 MODEL OF COMPOSITE MEMBER, UPPER TUBE, SURROUNDING TUBES, AND TUBESHEET; LOCKED AT TUBE SUPPORT WCAP-15918-NP July 2019 Revision 3

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Westinghouse Non-Proprietary Class 3 9-1 9.0 SLEEVE INSTALLATION VERIFICATION 9.1

SUMMARY

AND CONCLUSIONS The Westinghouse Alloy 800 sleeve installation process and sequence has been tested to ensure that the installation of a sleeve conforms to the design criteria described in Section 3. During this testing, actual steam generator conditions, such as the influence of tubes locked at tube supports, have been considered in assessing the acceptability of the various processes and the sequence in which they are performed. In addition, sleeve installation meets the requirements of ASME B&PV Code Section XI, IWA-4420.

9.2 SLEEVE-TUBE INSTALLATION SEQUENCE 9.2.1 Transition Zone Sleeve The TZ sleeve with the rolled lower joint is described in Section 4.3 and Figure 4-3. Installation is accomplished using the processes described in Section 4.5 in the following sequence:

(1) Sleeve installation and expansion (2) Sleeve lower end torque roll (3) Sleeve and tube ET examination 9.2.2 Tube Support Sleeve The TS sleeve is described in Section 4.3 and Figure 4-4. Installation is accomplished using the processes described in Section 4.5 in the following sequence:

(1) Sleeve installation and expansion of upper joint (2) Expansion of lower joint (3) Sleeve and tube ET examination 9.3 EXPANSION JOINT INTEGRITY Westinghouse has conducted a comprehensive test program, an Eddy Current Appendix H qualification and an analysis development program, as well as a corrosion test program to ensure expansion joint integrity. Tube ID conditioning tests and sleeve/tube expansion tests have been completed as part of the process verification.

9.3.1 Tube Conditioning Qualification Per the test program described in Reference 9.5.1, this process step has been removed from the sleeve installation process.

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Westinghouse Non-Proprietary Class 3 9-2 9.3.2 Expansion Qualification An important design and installation issue for the Alloy 800 sleeve is the hydraulic expansion.

There are three variables associated with the expansion: the number of expansions, the axial length of each expansion, and the diametrical extent. A finite element stress analysis was performed to study the effects of expansion length and diametrical extent. The study addressed expansion lengths from [ b Maximum installation stresses and the effective strain on the inside surface of the tube and the OD diametrical expansion as a function of sleeve expansion pressure for b expansion lengths were all considered.

The finite element stress analysis showed that the axial and hoop stresses increase rapidly with expansion pressure, with the hoop stress greater than the axial stress except for the higher expansion pressures. The radial stress, which is the stress between the sleeve and the steam generator tube, tends to be relatively constant as a function of expansion pressure. The radial stress is relatively more sensitive to expansion length than the other stress components, with a peak value at an expansion length of about a,c for all diametrical expansions.

The selection of design parameters is intended to provide the best leak resistance and the best corrosion resistance. The best leak resistance should be associated with the greatest radial stress between the sleeve and the steam generator tube. This indicates that the expansion length of a,c is the optimal length to resist leakage. The short expansion length also permits a greater number of expansions, which will also contribute to leak resistance. The number of expansions has been chosen to be a,c Leak testing was conducted for different diametrical expansions ranging from b, as described in Section 7.3.1. The test results did not identify any significant improvement in the leak rate of sleeves installed with b as compared to those with smaller diametrical expansions. The diametrical expansion is therefore targeted to be in the a,c range for improved corrosion resistance. The minimum of the range, a,c, is established as acceptable by the load and leakage tests of Section 7. The upper limit on the strain, a,c, is established by the results of the corrosion tests of Section 6.0 and the installation tolerances achievable.

Based on the above analytical study, an extensive test program was performed to qualify the expansion design. This program, as described in Section 7, considered structural and leakage limits of the design.

References 9.5.2 and 9.5.3 contain information related to one of the expansion system qualifications. This expansion system monitors the stroke of the intensifier and corresponding pressure to the expansion tool. With this system, the diametrical expansion is controlled to a,c for steam generator tubing within the range of anticipated yield strengths.

As discussed in Section 4.5.4, re-expansion of the joint can be performed should the initial expansion not reach the required minimum pressure. Failure to reach the minimum pressure would result in failing to achieve the expansion size associated with the structural integrity established in the test matrix. The re-expansion is intended to increase expansion size by increasing the applied WCAP-15918-NP July 2019 Revision 3

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Westinghouse Non-Proprietary Class 3 9-3 pressure. There would be a necessary increase in cold working due to this operation, but no more than had the proper pressure been reached during the initial pressurization. Limits on the number of re-expansions are specified in the process procedures.

9.3.3 Summary In summary, Westinghouse has conducted a comprehensive development and verification program to ensure the integrity of the expansion joint.

9.4 ROLLED JOINT INTEGRITY The rolled joint at the lower end of the Alloy 800 sleeve was developed to duplicate the rolled joint of the Alloy 800 mechanical plugs used by Westinghouse in Europe and Korea. These rolled joints have been demonstrated by testing and operating experience to be leak-tight and capable of withstanding operating conditions. The Alloy 800 mechanical plugs have operated many years with no degradation of the rolled joint in the roll transition area. Westinghouse has drawn on this successful experience in designing the lower rolled joint of the Alloy 800 sleeve.

A development program was conducted to ensure the rolled joint of the TZ sleeve was leak-tight and capable of withstanding the design loads. The sleeves were rolled into mock-ups consisting of steam generator tubes which had been rolled into blocks simulating the tubesheet. The sleeves were then tested to confirm the rolled joint was leak-tight both before and after cyclic load testing.

Tests of the rolled joint were also conducted where process parameters such as torque, tube diameter and roll location relative to the [ ]a,c were varied. A test matrix was used to verify the sleeve installation with sleeve rolling process parameter tolerances.

The test program confirmed that the rolled joint integrity is acceptable within the allowable rolling process tolerances.

As discussed in Section 4.5.5, re-rolling of the joint can be performed should the initial rolls not reach the required minimum torque value. Failure to reach the minimum torque value would result in failing to achieve the wall thinning associated with the structural integrity established in the test matrix. The re-roll operation is intended to increase the wall thinning value by increasing the torque applied. There would be a necessary increase in cold working due to this operation, but no more than had the proper torque value (and wall thinning) been reached on the initial rolling operation. Limits on the number of rolling operations are specified in the process procedures.

References 9.5.4, 9.5.5, 9.5.6, and 9.5.7 contain information concerning the qualification of the rolled joint.

9.5 REFERENCES

FOR SECTION 9.0 9.5.1 Report No. MRS-DFD-1929-SLV, Qualification of Alloy 800 Mechanical Sleeve for 0.75 x 0.048 Wall S.G. Tubes without Tube Conditioning.

9.5.2 Report No. GBRA 039-930, 3/4" US NSSS Sleeving, Volume-Controlled Hydraulic Expansion of Sleeve.

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Westinghouse Non-Proprietary Class 3 9-4 9.5.3 Report No. 00000-NOME-TR-0097, Test Report Qualification of Expansions of Alloy 800 Sleeves in .75 inch O.D. x .042/.043 inch Wall Steam Generator Tubes.

9.5.4 Report No. GBRA 039-933, 3/4" US NSSS Sleeving, Torque-Controlled Hard Rolling of Sleeve.

9.5.5 Report No. 00000-NOME-TR-0091, Test Report for the Qualification of the Alloy 800 Sleeve Rolling Operation for Combustion Engineering 0.75 inch OD x .048 inch Wall Steam Generator Tubes.

9.5.6 Report No. 00000-NOME-TR-0100, Test Report for the Qualification of the Alloy 800 Sleeve Rolling Operation for Combustion Engineering 0.75 inch OD x .042 inch Wall Steam Generator Tubes.

9.5.7 Report No. 00000-NOME-TR-0101, Test Report for the Qualification of the Alloy 800 Sleeve Rolling Operation for Westinghouse D2, D3, D4, D5 and E 0.75 Inch OD x .043 inch Steam Generator Tubes.

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Westinghouse Non-Proprietary Class 3 10-1 10.0 EFFECT OF SLEEVING ON OPERATION Multiple plant specific analyses have been performed to determine the effects of installation of varying lengths and combinations of TZ and TS sleeves. Sleeve lengths and various combinations of installed sleeves were used to evaluate the effect of sleeving on the hydraulic characteristics and heat transfer capability of steam generators. Using the head and flow characteristics of the pumps, in conjunction with the primary system hydraulic resistances, system flow rates have been calculated as a function of the number of sleeved tubes and the types of sleeves installed. Similarly, curves are generated from calculations that show the percent reduction in system flowrate as a function of newly plugged tubes (per steam generator). These curves are derived from plant specific information based on the following steam generator conditions:

Number of open tubes per steam generator Number of tubes sleeved Primary system flowrate Primary coolant temperature This information has been used to generate tables, such as Table 10-1, which provide hydraulic equivalency of plugs and installed sleeves, or the sleeve/plug ratio. Reference 10.1.1 determined a bounding equivalence ratio (ER) for the five tube sleeving cases across several plants and steam generator designs (D3-D5, E2, and CE System 80 by normalizing the specific calculations performed earlier for those plants. The purpose of Reference 10.1.1 was to determine the worst-case plant to perform the calculations for 0.042-inch-thick tube sleeve. This was done by determining the worst plant for the five tube sleeving cases. To do so it was necessary in some cases to normalize the lengths of the tube sleeves that were evaluated. Ringhals Units 3 and 4 were determined to be the limiting plant and thus the values for the ER for Ringhals 3 and 4 are provided below. However, it is important to note that Ringhals 3 and 4 have shorter tube sleeve lengths than many other plants that were evaluated, with tube sleeve lengths of LRTZ = 9.38 in. and LTSP = 7.75 in. The values in Table 10-1 provide conservative estimates of the ER that can be expected for sleeves of the lengths given. Any specific plant must evaluate individual ERs using the specific parameters of the plant in question. It is important to note that if the tube sleeve lengths for that plant are longer than the values used for Ringhals 3 and 4 the ERs could be lower. For instance, for Case 1 using the Ringhals plant parameters if the length of the sleeve is increased to 25 inches the ER decreases to 25.6.

The overall resistance to heat transfer between the primary and secondary side of the steam generator consists of primary side film resistance, the resistance to heat transfer through the tube wall, and the secondary side film resistance. Since the primary side film resistance is only a fraction of the total resistance and the change in flow rate is so small, the effect of this flow rate change on heat transfer is negligible.

When the sleeve is installed in the steam generator tube there is an annulus between the sleeve and tube except in the sleeve-tube expansion regions. Hence, there is effectively little primary to secondary heat transfer in the region where the sleeve is installed. The loss in heat transfer area associated with sleeving is small when compared to the overall length of the steam generator tube.

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Westinghouse Non-Proprietary Class 3 10-2 In summary, installation of sleeves does not substantially affect the primary system flow rate or the heat transfer capability of the steam generators.

10.1 REFERENCES

FOR SECTION 10.0 10.1.1 A-GEN-PS-0001, Revision 0, Selection of Plant/SG for Generic ER Analysis for A800 Sleeves, ABB CE Nuclear Power, April 2000.

TABLE 10-1 TYPICAL SLEEVE TO PLUG EQUIVALENCY RATIO Case TZ TS Ratio (Sleeve/Plug) 1 1 0 [

2 1 1 3 1 2 4 0 1 5 0 2 ]b WCAP-15918-NP July 2019 Revision 3

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Enclosure 4 Westinghouse Affidavit, Proprietary Information Notice, and Copyright Notice.

CNL-19-067 E4-1

Westinghouse Non-Proprietary Class 3 CAW-19-4923 Page 1 of 3 AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA:

COUNTY OF BUTLER:

(1) I, Zachary S. Harper, have been specifically delegated and authorized to apply for withholding and execute this Affidavit on behalf of Westinghouse Electric Company LLC (Westinghouse).

(2) I am requesting the proprietary portions of WCAP-15918-P, Rev. 3, be withheld from public disclosure under 10 CFR 2.390.

(3) I have personal knowledge of the criteria and procedures utilized by Westinghouse in designating information as a trade secret, privileged, or as confidential commercial or financial information.

(4) Pursuant to 10 CFR 2.390, the following is furnished for consideration by the Commission in determining whether the information sought to be withheld from public disclosure should be withheld.

(i) The information sought to be withheld from public disclosure is owned and has been held in confidence by Westinghouse and is not customarily disclosed to the public.

(ii) Public disclosure of this proprietary information is likely to cause substantial harm to the competitive position of Westinghouse because it would enhance the ability of competitors to provide similar technical evaluation justifications and licensing defense services for commercial power reactors without commensurate expenses.

Also, public disclosure of the information would enable others to use the information to meet NRC requirements for licensing documentation without purchasing the right to use the information.

Westinghouse Non-Proprietary Class 3 CAW-19-4923 Page 2 of 3 AFFIDAVIT (5) Westinghouse has policies in place to identify proprietary information. Under that system, information is held in confidence if it falls in one or more of several types, the release of which might result in the loss of an existing or potential competitive advantage, as follows:

(a) The information reveals the distinguishing aspects of a process (or component, structure, tool, method, etc.) where prevention of its use by any of Westinghouse's competitors without license from Westinghouse constitutes a competitive economic advantage over other companies.

(b) It consists of supporting data, including test data, relative to a process (or component, structure, tool, method, etc.), the application of which data secures a competitive economic advantage (e.g., by optimization or improved marketability).

(c) Its use by a competitor would reduce his expenditure of resources or improve his competitive position in the design, manufacture, shipment, installation, assurance of quality, or licensing a similar product.

(d) It reveals cost or price information, production capacities, budget levels, or commercial strategies of Westinghouse, its customers or suppliers.

(e) It reveals aspects of past, present, or future Westinghouse or customer funded development plans and programs of potential commercial value to Westinghouse.

(f) It contains patentable ideas, for which patent protection may be desirable.

(6) The attached documents are bracketed and marked to indicate the bases for withholding. The justification for withholding is indicated in both versions by means of lower case letters (a) through (f) located as a superscript immediately following the brackets enclosing each item of information being identified as proprietary or in the margin opposite such information. These lower case letters

PROPRIETARY INFORMATION NOTICE Transmitted herewith are proprietary and non-proprietary versions of a document, furnished to the NRC in connection with requests for generic and/or plant-specific review and approval.

In order to conform to the requirements of 10 CFR 2.390 of the Commissions regulations concerning the protection of proprietary information so submitted to the NRC, the information which is proprietary in the proprietary versions is contained within brackets, and where the proprietary information has been deleted in the non-proprietary versions, only the brackets remain (the information that was contained within the brackets in the proprietary versions having been deleted).

The justification for claiming the information so designated as proprietary is indicated in both versions by means of lower case letters (a) through (f) located as a superscript immediately following the brackets enclosing each item of information being identified as proprietary or in the margin opposite such information. These lower case letters refer to the types of information Westinghouse customarily holds in confidence identified in Sections (4)(ii)(a) through (4)(ii)(f) of the Affidavit accompanying this transmittal pursuant to 10 CFR 2.390(b)(1).

COPYRIGHT NOTICE The reports transmitted herewith each bear a Westinghouse copyright notice. The NRC is permitted to make the number of copies of the information contained in these reports which are necessary for its internal use in connection with generic and plant-specific reviews and approvals as well as the issuance, denial, amendment, transfer, renewal, modification, suspension, revocation, or violation of a license, permit, order, or regulation subject to the requirements of 10 CFR 2.390 regarding restrictions on public disclosure to the extent such information has been identified as proprietary by Westinghouse, copyright protection notwithstanding. With respect to the non-proprietary versions of these reports, the NRC is permitted to make the number of copies beyond those necessary for its internal use which are necessary in order to have one copy available for public viewing in the appropriate docket files in the public document room in Washington, DC and in local public document rooms as may be required by NRC regulations if the number of copies submitted is insufficient for this purpose. Copies made by the NRC must include the copyright notice in all instances and the proprietary notice if the original was identified as proprietary.