ML20080T427

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Proposed TS 3.4.5, Steam Generators & Associated Bases
ML20080T427
Person / Time
Site: South Texas STP Nuclear Operating Company icon.png
Issue date: 03/01/1995
From:
HOUSTON LIGHTING & POWER CO.
To:
Shared Package
ML19311B755 List:
References
NUDOCS 9503130311
Download: ML20080T427 (12)


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ATTACHMENT 3  ;

.i MARKED UP PAGES FOR -

PROPOSED CHANGES TO TECHNICAL SPECIFICATIONS ,

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9503130311 950301 PDR ADDCK 05000498 P PDR ,

i V-ST-IIL-AE-5026 ,

Attachment 3  !

Page 1 of 3 'f REACTOR COOLANT SYSTEM j STEAM GENERATORS SURVEILLANCE IEQUIREMENTS (Continued)

3) A tube inspection (pursuant to Specification 4.4.5.4a.8) shall be performed on each selected tube, if any selected tube does not permit the passage of the eddy current probe for a tube inspection, this shall be recorded and an adjacent tube shall be selected ed subjected to a tube 1 inspection. [
c. The tubes selected as the second and third samples g' rquirN N "able 4.4-2) during each inservice inspection may be subjected to r panni icht. mspection ,

provided:

1) The tubes selected for these samples include the tubes from those areas of the tube sheet array where tubes with imperfections were previously  !

found, and

2) The inspections include those portions of the tubes where imperfections -

were previously found. ,

d.' ' ' Inspection' and 'pluggingif defects which meeCAcceptsace Criteria'10 isiot required for Unit,1. ~' ,

The results of each sample inspection shall be classified into one of the following three categories: ,

Catecorv inspection Results C-1 Less than 5% of the total tubes inspected are degraded tubes and none ,

of the inspected tubes are defective.  !

C-2 One or more tubes, but not more than 1% of the total tubes inspected i are defective, or between 5% and 10% of the total tubes inspected are j degraded tubes.

1 C-3 More than 10% of the total tubes inspected are degraded tubes or more j than 1% of the inspected tubes are defective.

Note:In all inspections, previously degraded tubes must exhibit significant (greater than 10%)

further wall penetrations to be included in the above percentage calculations.

SOUTil TEXAS - UNITS 1 & 23/4 4-13 w -- m l

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ST-HL-AE-5026 .

I Attachment 3 i Page 2 of 3  !

REACTOR ~ COOL' ANT SYSTEM f

STEAM GENERATORS SURVEILLANCE REQUIREMENTS l(C6ntinued)~ ,

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4.4.54 fAcceptance Criterig~ l 10)! . P criteria EIFor STP~ Unit 1 onivl?for ~ sttain"tsbes,

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c tube' degradation ,

below.a. specified distance from the top-of-tubesheet can be. excluded"

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from consideration to the acceptance criteria stated lin this 'sectionKThs ~

methodology,for; determination for the FT distance1 asssil'asLthe 71ist of i tubes toihich the' PJeriteria is not app ^licable is desEribed in' detail.iri"

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the Topical ReportiBAW x10203P.' l

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SOUTHTEXAS ' -~ UNIT 1 & 2; 3/4 4-15a TbC-99W$ain ot11 l

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ST-HL-AE-5026 Attachment 3 Page 3 of 3 REACTOR COOLANT SYSTEM BASES STEAM GENERATORS (Continued)

The plant is expected to be operated in a manner such that the secondary coolant will be maintained within those chemistry limits found to result in negligible corrosion of the steam generator tubes. If the secondary coolant chemistry is not maintained within these limits, localized corrosion may likely result in stress corrosion cracking. The extent of cracking during plant operation would be limited by the limitation of steam generator tube leakage between the Reactor Coolant System and the Secondary Coolant System (primary-to- i secondary leakage = 500 gallons per day per steam generator). Cracks having a primary-to-secondary leakage less than this hmit durmg operation will have an adequate margin of safety to withstand the loads imposed during normal operation and by postulated accidents.

Operating plants have demonstrated that primary-to-secondary leakage of 500 gallons per day 3er steam generator can readily be detected by radiation monitors of steam generator 3 lowdown. Leakage in excess of this limit will require plant shutdown and an unscheduled inspection, during which the leaking tubes will be located and plugged.

Wastage-type defects are unlikely with proper chemistry treatment of the secondary coolant. However, even if a defect should develop in service, it will be found during scheduled inservice steam generator tube examinations. Plugging will be required for all tubes with imperfections exceeding the plugging limit of 40% of the tube nominal wall thickness. Steam generator tube inspections of operating plants have demonstrated the capability to reliably detect degradation that has penetrated 20% of the original tube wall thickness.

Exclusion ~of certain' areas ofiUnit 1 tubes fronico~nsideration has been analyzed'tisins an F* criterial The criteria allows service induced degradation deep within the tubesheet to~

remain in service. 6The analysis methodology determines the length of sound tubing required in the uppermost area within the tubesheet to preserve needed' structural margins for all service conditions. The remainder of the. tube, belmv the F* distance, is considered not structurally relevant and is excluded from consideration to the customary plugging criteria of 40% throughwall.' The basis for this F? criteria as well as Unit 1 -tubes that are not ' suitable' for application of this criteria is contained in Topical Report - BAWJ10203P,LThis report has

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been reviewed by Houston Lighting & Power for application to STP Unit 1.

Whenever the results of any steam generator tubing inservice inspection fall into Category C-3, these results will be promptly reported to the Commission in a Special Report pursuant to SpeciGcation 6.9.2 withm 30 days and prior to resumption of plant operation.

Such cases will be considered by the Commission on a case-by-case basis and may result in a requirement for analysis, laboratory examinations, tests, additional cddy-current inspection, and revision of the Technical SpeciGeations, if necessary.

3/4.4.6 REACTOR COOLANT SYSTEM LEAKAGE P 3/4.4.6.1 LEAKAGE DETECTION SYSTEMS <

The RCS Leakage Detection Systems required by this speciGcation are provided to monitor and detect leakage from the reactor coolant pressure boundary. These Detection Systems are consistent wnh the recommendations of Regulatory Guide 1.45, " Reactor Coolant i Pressure Boundary Leakage Detection Systems," May 1973.

SOUTil TEXAS - UNITS 1 & 2 B 3/4 4-3 m.e-.

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ATTACHMENT 4 i l W E-Series F* Qualification Report BAW-10203P, Proprietary l

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AFFIDAVIT OF JAMM H. TAYLOR ~

e A.- . My name is James H. Taylor. 'I am Manager of Licensing Services for B&W Nuclear Technologies (BWNT), and as such I am authorized to execute this Affidavit.

~B. I am familiar 'with the criteria applied by BWNT to determine whether certain information :

of BWNT is proprietary and I am familiar with the procedures established within BWNT tot ensure the proper application of these criteria.

C. In determining whether a BWNT document'is to be classified as proprietary information,'an.

initial determination is made by the Unit Manager, who is responsible for originating the document, as to whether it falls within the criteria set forth in Paragraph D hereof. - If the information falls within any one of these criteria, it is classified as proprietary by the -

originating Unit Manager. This initial determination is reviewed by the cognizant Section_-

Manager. If the document is designated as proprietary, it is reviewed again by Licensing ,

personnel and other management within BWNT as designated by the Manager of Licensing:

Services to assure that the regulatory requirements of 10 CFR Section 2.790 are met.

!- D. The following information is provided to demonstrate that the provisions of 10 CFR Section -

2.790 of the Commission's regulations have been considered:

(i) The information has been held in confidence by BWNT. Copies of the document are clearly identi5ed as proprietary. In addition, whenever BWNT transmits the information to a customer, customer's agent, potential customer or regulatory si;ency, the transmittal requests the recipient to hold the information as

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proprietary. Also, in order to strictly limit any potential or actual customer s use-of proprietary information, the following provision is included in all proposals s submitted by BWNT, and an applicable version of the proprietary provision is -

included in all of BWNT's contracts:

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AFFIDIVIT OF JAMFS 'H. T YLOR (Cont'd.))

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" Purchaser may retain Company'.s proposal for use in connection with any

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contract resulting therefrom, and, for that purpose, make such copies -

thereof as may be necessary.' ' Any proprietary information concerning Company's or its Supplier's products'or manufacturing processes which is so designated by Company or its Suppliers and disclosed to Purchaser

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incident to the performance of such contract shall remain the ' property of .

Company or its Suppliers and is disclosed in confidence, and Purchaser i shall not publish or otherwise disclose it to others without the written

-approval of Company, and no rights, implied or otherwise~, are granted to produce or have produced any products or to practice or cause to be practiced any manufacturing processes covered thereby.

Notwithstanding the above, Purchaser may provide the NRC or any other regulatory agency with any such proprietary information as the NRC or such other agency.may require; provided, however, that Purchaser shall-

' first give Company written notice of such proposed' disclosure and -

Company shall have the right to' amend such proprietary information so as to make it non-proprietary. In the c.ent that Company cannot amend such proprietary information, Purchaser shall prior to disclosing such information, use its best efforts to obtain a commitment from NRC or such -

other agency to have such information withheld from public inspection.

Company shall be given the right to participate in pursuit of such ~

confidential treatment,"

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AFFIDAVIT OF JAMES H. TAYLOR (Cont'd.) i f

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.(ii) The following criteria are customarily applied by BWNT in a rational decision j process to determine whether the information should be classified as proprietary.

Information may be classified as proprietary if one or more of the following criteria are met:  !

a.- Information reveals cost or price information, commercial strategies, . j production capabilities, or budget levels of BWNT, its customers or j suppliers. {

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b. The information reveals data or material concerning BWNT research or  !

development plans or programs of present or potential competitive f

advantage to BWNT. .!

c. The use of the information by a competitor would decrease his  !

t expenditures, in time or resources, in designing, producing or marketing a :

j similar product. j

d. The information consists of test data or other similar data concerning a i process, method or component, the application of which results in a competitive advantage to BWNT. l
e. The information reveals special aspects of a process, method, component , l or the like, the exclusive use of which results in a competitive advantage to l BWNT. l l
f. The information contains ideas for which patent protection may be sought. _

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, , 1 I AFFIDAVIT OF JAMFR Hi TiYLOR (Cont'd.)I t t

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' The document (s) listed on Exhibit "A", which is attached hereto and made a part  !

- hereof, has been evaluated in accordance with normal BWNT procedures with . :i

. respect to classification and has been found to contain information which falls' ~

within one or more of the criteria enumerated above. Exhibit "B", which is ,

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. nttached hereto and made a part hereof, specifically identifies the' criteria L  :;

t applicable to the document (s) listed in Exhibit "A".' , q i

(iii) The document (s) listed in Exhibit "A", which has been made available to the 1 United States Nuclear Regulatory Commission was made available in confidence with a request that the document (s) and the information contained therein be.  !

withheld from public disclosure.

(iv) The information is not available in the open literature and to the best of our j knowledge is not kr.own by Combustion Engineering, EXXON, General Electric,  !

Westinghouse or other current <x potential domestic or foreign competitors of 1 BWNT. '[

i (v) Specific information with regard to whether public' disclosure of the information is l likely to cause harm to the competitive position of BWNT, taking into account the value of the information to BWNT; the amount of effort or money expended by l

BWNT developing the information; and the case or difficulty with which the j information could be properly duplicated by others is given in Exhibit "B". .!

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E. I have personally reviewed the document (s) listed on Exhibit "A" and have found that it is-g considered proprietary by BWNT because it contains information which falls within one or - ]

I more of the criteria enumerated in Paragraph D, and it is information which is customarily - j held in confidence and protected as proprietary information by BWNT. This report j l

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' AFFIDAVIT OF JAMES H. TAYLOR (Cont'd.)  ;

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t comprises information utilized by BWNT in its business which afford BWNT an opportunity .

to obtain a competitive advar.tage over those who may wish to know or use the information contained in the document (s). ] ,

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/ JAMES H. TAYLO l State of Virginia)

) SS. Lynchburg  ;

City of Lynchburg)  ;

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-James H. Taylor, being duly sworn, on his oath deposes and says that he is the person who subscribed his name to the foregoing statement, and that the matters and facts set forth in the . -

statement are true. ,

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MES H. TAYLO '

Subscribed and syorn before me this Mday of J4r branu 1995.

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mC< b bmOe Notary Public in and for the City i of Lynchburg, State of Virginia. I My Commiss; a npix5JW31,ISA l

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EXHIBITS A & B i

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P EXHIBIT A i

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1. BWNT Topical Report BAW-10203P, "E E-Series F* Qualification Report",  :

February 1995.  ;

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The above listed document contains information which is considered Proprietary in accordance i with Criteria c and d of the attached affidavit.  !

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1 ATTACHMENT 5 l W E-Series F* Qualification Report BAW-10203, Non-Proprietary I

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