ML20091C146

Proposed Tech Specs 4.4.5 Re Steam Generator Tube Plugging

ML20091C146
Person / Time
Site:	Arkansas Nuclear
Issue date:	03/30/1992
From:	ENTERGY OPERATIONS, INC.
To:
Shared Package
ML19354F199	List: 2CAN039204, Application for Amend to License NPF-6,revising TS 4.4.5 to Allow Installation of Tube Sleeves as Alternative to Plugging Defective SG Tubes.Encl Rept 51-1212539-00 Withheld ML20091C146
References
NUDOCS 9204030072
Download: ML20091C146 (11)

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1 PROPOSED ANO-2 TECTINICAL SPECIFICATION CilANGE E

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REACTOR COOLANT ___SYSTEN EURVEILLANCE REQUIE MENTS (Cgntinggd) 4.4.5.4 Atsanianco criteria

a. As us6d in this Specification

1. Tubing _or Tubo means that portion of the tube or sleeve "hich

-forms the primary system to secondary system pressure boundary.

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2. Imperfection means an exception to the dimensionr. finish or contour of a tube from that required by fabrication drawings or specifications. Eddy-current testing indications below 20% of the nominal tube wall thickness, if detectablo, may be considered as imperfections.

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3. Deeradation means a servico-induced cracking, wastago, wear or general corrosion occurring on either inside or outsido of a tube.

4. Derraded Tubo means a tubo containing imperfections 220% of the nominal wall thickness caused by degradation.

5.1 Derradating means the percentage of the tube wall thickness affected or removed by degradation.

6. Defect means an imperfection of such severity that it exceeds the plugging or, repair limit.

A tubo containing a defect is defectivo.

7. Pluecine or Repair Limit means the imperfection depth at or beyond which the tube shall be. removed from service by plugging or repaired by sleoving because it may becomo unserviceable prior to the next inspection and is equal to 40% of the nominal tube wall thickness.

8. Unterviceable describes the condition of a tube if 'it leaks t

-or contains a defect largo enough to affect its structural integrity in the event of an Operating Basis Earthquake, a loss-of-coolant accident,- or a steam line or foodwater line break as specified in 4.4.5.3.c, above.

9. Tube Insocction means an-inspection of the steam generator

. tubo from the point of entry (hot leg side) completely around the U-bend to the top support of the cold leg.

. ARKANSAS:- UNIT 2 3/4 4-9

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RilACT0R C001. ANT, SYST[.H 0

I EMElEAKL.KLQ!BEEUS lR98tillugd) 10.

I'teservic.t_ltspntion means an inspect ion of the full length of each tube in each utcam generator performed by eddy current techniques prior to service to establish a bannline condition of the tebing. This inspection shall be performed af ter the field hydrostatic test and prior to initial p0WER OPERA10N using the equipnnt and techniques expected to be used during subsequeit inservice inspections.

b. The stnam generator shall be deter iptRADbi'. af ter completing the corresponding actions (piug or t all tubes exceeding the plugging or repair limit and all tuu.

containing through-wall cracks) required by Tablo 4.4-2.

Defective tubes may be repaired in accordance with B6V Topical Report DAW-2045pA 00 as sup'plemented by the information provided in B5W Report 51 12125'39-00, DWNS Kinetic Sleevn Design-Application to ANO Unit 2".

4.4.5.5 Ecp.g.Lth

a. l'o11owing each inservice inspection of steam generator tubes the number of tubes plugged or sleeved in each steam generator shall bn reported to the Cor.nission within 15 days,

b. The complete results of the steam generator tube inservico inspection shall be reported on an annual basin for the pe;riod in which the inspection was completed.

This inport shall includo:

1. Number and extent of tubes inspected.

2. I.ocation and percent of wall-thickness penetration for each indication of an imperfection.

3. Identification of tubes plugged or sleeved.

c. Results of steam generator tube inspections which fall into Category C-3 shall be reported in a Special Report pursuant to Specification 6.9.2 as denoted by Table 4.4-2.

Notification of the Commission will be mado prior to resumption of plant operation. The written Special Report shall provide a description of investigations conducted to determine cause of the tubo degradation and corrective nasures taken to prevent recurrence.

ARKANSAS - UNIT 2 3/4 4-10 Amendment. No. H,

r TABLE 4.4-2 STEAM GENERATOR TUBE INSPECTION IST SAMPLE INSPECTION ENU SAMPLE INSPECTION l

3ED SAMPLE INSPECTION Samole Size Result Actien_ Recuired Result Action Recuired i

Result i

Action Recuired A minimum of C-1 None N/A N/A N/A N/A 5 Tubes per S.G.

C-2 Plug or sleeva defec-C-1 None N/A N/A tive tubes and inspect additional 25 tubes in Flug or sleeve defec-C-1 None this S.G.

C-2 tive tubes and inspect C-2 Plug or sleeve additional 45 tubes in defective tubes this S.G.

Perform action for 0-3 C-3 result of first scenle Perform action for C-3 C-3 result of first N/A N/A I

Sarnic C-3 Inspect all tubes in All other this S.G., plug or S.G.s are None N/A N/A sleeve defective tubes C-1 and inspect 2S tubes in each other S.G.

Some S.G.s Perform action for N/A N/A C-2 but no C-2 result of second

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l additional sample Special Report S.G. are to NRC per C-3 l

l Specification 6.9.2 l

Additional Inspect all tubes in S.G. is C-3 each S. G. and plug or sleeve defective tubes. Special N/A N/A Report to NRC per l

Spec. 6.9.2.

S=3

% Where N is the number of steam generators in the unit, and n is the number of steam generators inspected E

l during an inspection ARKANSAS - UNIT 2 3/4 4-12 Amendment No. FJ,

• REAGIDS.CO.0MNT SYSTEM I

RAEES Wantage + type defectn are unlikely with proper chemist ry trentetnt of the secondary coolant.

However, even if a defect should develop in service, it will be found during scheduled inservice steam generator tubes examinations.

Plugging or sleeving will be required for all tuben with imperloctions exceeding the plugging repair limit as defined in Survollianco Requirement r

4.4.5.4.a.

Defectivo es may be repaired by sleeving in accordance with the B&W Topical koport 8AW 2045PA-00 na supplemented by the information provided in D&W Report $1 1212539-00, "BWNS Kicetic Sleeve Design-Application to ANO Unit 2".

Steam generator tubo inspections of operating plants have demonstrated the cnpability to rollably detect degradation that has penetrated 207. of the tube wall thickness.

For sleeved tubes, the adequacy of the system that is used for periodic inservice inspection will be ve,11dsted.

Additionally..upgradod testitig motbods will be evaluated and appropriately impicmented as botter methods are developed and validated for commerical use, j

Whenever the results of any stnam generator tubing inservice inspection fall into Category.C-3 certain results 9111 be reported in a Special Report to the Commission pursuant to Specification 6.9.2 as denoted by Table 4.2-2.

Notification of the Commission will be mado prior to resumption of plant operation.

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

3/4.4.6 REACIDR COOLANT SYSIEM LEAKAGI 3/4.4.6.1 LEAKAGE DETECTION _ SYSTEMS The RCS leakage detection systems required by this specification are providad to monitor and detect leakage from_the Reactor Coolant pressure Boundary. These detection systems are consistent with the recommendations

-of Regulatory Guide 1.45, " Reactor Coolant Pressure Boundary Leakago Detection Systems"_May 1973.

2/4.4.6.2 REACTOR C00LANY SYSTEM LEAKAGE Industry experienca has shown that while a limited amount of leakage is expected from the RCS, the unidentified portion of this Inakage can be

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reduced to a threshold valun of less than 1 GPH.

This threshold valun is sufficiently low to ensure early detection of additional Icakage.

The 10 GPM IDENTIFIED LEAKAGE limitation provides allowances for a limited amount of leakage from known sources whose presence will not interfere with the detection of UNIDENTIFIED LEAKAGE by the leakago detection systems, The Surveillance Requirements for RCS Pressure Isolation Valves provido added assurance of valvo integrity thereby reducing the probability of gross valve failure and consequent intersystem LOCA.

Leakage from the RCS Pressure Isolation Valves is IDENTIFIED LEAKAGE and will be considered as a portion of the allowed limit.

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ARKANSAS - UNIT 2 B 3/4 4-3 Amendment No. 9J.

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i Aff.1 DAVIT OF' JAMES H. TAYLOR A.

My name is James H. Taylor.

I am Manager of Licensing Servicet in the B&W Nuclear Service Company (BWhS), which'is a part of B&W Nuclear Technologies (BWNT), and as such I am authorized to execute this. Affidavit.

B.

I am familiar with the criteria applied by B&W to determine whether certain information of B&W is-proprietary and I am I

familiar with the procedures established within B&W, particularly the Nuclear Services Company, to ensure the proper application of these criteria.

4 C.

In determining whethr.r a B&W document is to be classified as proprietary information, an initial determination is node by the Unit Manager, who is responsible for originating the document, as to whether it falls within the criteria set forth in Paragraph D horeof.

If the information falls within any one of these criteria, it is classified as proprietary by the originating Unit-Manager.

This in.~tial 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 BWNS 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 c.f the Commission's regulations have been-considered:

(i)

The-information has been held in confidence by B&W.

Copies-of the document are clearly identified as proprietary.

In addition, whenever B&W transmits the

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

information to a customer, customer's agent, potential customer or regulatory agency, the transmittal requeste the recipient to hold the information as proprietary.

Also, in order to sPrictly limit any potential or act al customer's use of proprietary information, the following provision is included in all proposals submitted by B&W, and an applicable version of the proprietary provision is included in all of B&W's contracts:

" Purchaser may retain Company's proposal for use in connection with any 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 incident to the performance of such contract shall rems 3n the roperty of Company or its Suppliers and is disclosed in confi$ence, and Purchaser 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 providefthe 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 firct 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 event that Company Cdnnot amend such proprietary information, Purchaser 2

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

shall, prior to disclosing such information, use its best efforts to obtain a commitment from NRC or such other agancy to have such information withheld from public inspection.

Company shall be given the right to participate in-pursuit of such confidential treatment."

(ii)

The following criteria are customarily applied by_B&W in a rational decision process to determine whether the information should be classified as proprietary.

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

Information reveals cost or price information, a.

commercial strategies, production capabilities, or-budget levels of B&W, its customors or suppliers, b.

The information reveals data or material concerning B&W research or development plans or programs of present or potential competitive advantage to B&W.

c.

The use of the information b" a competitor would decrease his expenditures, in time or resources, in designing, producing or marketing a similar product.

d.

The information consists of test data or other similar data concerning a process, method or component, the application cf which results in a competitive. advantage to B&W.

e.

The information reveals special aspects of a process, method, component or the like, the exclusive use of which results in a competitive advantage to B&W.

3

t AFFIDAVIT OF JAMES H. TAYLOB (Cont'd.)

f.

The information contains ideas for which patent protection may be sought.

The document (s) listed on Exhibit "A",

which is attached hereto and made a part hereof, has been evaluated in accordance with normal B&W procedures with 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 attached hereto and made a part hereof, specifically identifies the criteria applicable to the document (s) listed in Exhibit "A".

(iii)

The document (s) listed in Exhibit "A", which has been made available to the United States Nuclear Regulatory Commission was made availabla in confidence with a request that the document (s) and the information containcd therein be withheld from public disclosure.

(iv)

The information is not available in the open literature

-d and to the best of our knowleoge is not known by Combustion Engineering, EXXON, General Electric, Westinghouse or other current or potential domestic or foreign competitors of B&W.

(v)

Specific information with regard to whether public disclosure of the information is likely to cause harm to the competitive position of B&W, taking into account the value of the information to B&W; the amount of effort or money expended by B&W developing the information; and the ease or difficulty with which the information could be properly duplicated by others is given in Exhibit "B".

E.

I have personally reviewed the document (s) listed on Exhibit "A"

and have found that it is considered proprietary by B&U because it contains information which falls within one or more of the 1

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• AFFIDAVIT OF JAMES H. TAYI48 (Cont'd. )

criteria enumerated in Paragraph D, and it is information which is customarily held in confidence and protected as proprietary information by D&W.

This report comprises information utilized by B&W in its business which afford B&W an opportunity to obtain a competitive advantage over those who may wish to know or use the information contained in the document (s).

f f0 L, 82d$(l$"

n JAMES H. TAYLOR State of Virginia)

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SS. Lynchburg City of Lynchburg)

James H. Taylor, being duly sworn, on his cath deposes and says

-that ho 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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7 JAMLSH.TAYgdR l

Subscribed and sworn before me this 0 7"' day of IUntolo 1992.

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'0D ur<C~ ('L,(5m Sc-sa' n

Notary Public in and for the City L

of Lynchburg, State of Virginia.

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