ML20247M968

Proposed Tech Specs,Revising Tech Spec Section 4.3 to Allow Plant Steam Generator Tubes to Be Repaired Through Installation of Welded Sleeve

ML20247M968
Person / Time
Site:	Zion  File:ZionSolutions icon.png
Issue date:	06/02/1989
From:	COMMONWEALTH EDISON CO.
To:
Shared Package
ML19311A784	List: ML20247M964 ML20247M968
References
0163T, 163T, NUDOCS 8906050204
Download: ML20247M968 (15)

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ATIACB15tiI_2 Z1Gl_HUCLEAR PO!!ER STATIQ1 PROPOEED._I5CIR11 CAL EEECIFICATION AliENDMENTJIMDIX_A EECTION 4J (e

EZACTOR_CQDLANT SYSTEM REIEf_RESCElETION OF PROPOSED AMENDMENT AND TECHNICAL ~JUSTIFICAIIDti F.

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AU AQiMEN U description and Justification _nf Proposed Amendment The Zion Technical Specifications currently. allow a steam generator tube to be repaired through the installation of a Combustion Engineering (CE) welded sleeve or a Westinghouse Electric (WE) mechanical sleeve. These options were approved in the referenced letters. This proposed snendment will allow the sleeving process to be performed through the utilization of the Bechtel-KWU Alliance. welded sleeve process. The Bechtel-KWU. Alliance sleeving process _is l fully. described in their Topical Report, BKAT-01-P, Revision 1, February 1989, l Repair of Defective Steam Generator Tubes by Sleeving, contained in Attachment 4 to this letter. This Topical Report is currently under review by the NRC Staff as part of the NRC topical report review program.

The Bechtel-KWU Alliance welded sleeve process produces a repaired steam generator tube with an appropriate level of integrity. The background

'information supporting this statement is provided in Topical Peport BKAT-01-P, Revision 1.

The Bechtel-KWU Alliance sleeve is manufactured from thermally-treated Alloy 690. The sleeve is expanded in the tube and welded at both ends. Either a fillet weld or overlap weld is used at the upper joint of the sleeve. The length of the sleeve depends on the area of the defect and the location of the steam generator tube. The upper weld is always made above the tubesheet. The steam generator tubes to be sleeved are the tubes where tube degradation in the tubesheet and just above the tubesheet has exceeded the plugging or repair limit of 40%.

After-the sleeve is installed, s. nondestructive examinations are performed to confirm the quality of the welds, verify correct installation of the sleeve,

. examine the areas affected by the repair process, and obtain baseline data for future inservice inspection. These examinations are performed by ultrasonic examination, eddy current testing, and visual inspection as applicable.

To maintain sufficient tube integrity, allowable levels of tube wall degradation referred to as plugging limits are estab1E+5ed. This determination was performed in accordance with NRC Regulatory Guide 1.121.

Tubes which have eddy current indications of degradation in excess of the limits must be repaired or plugged. The information provided in BKAT-01-P, Revision 1 defines the portion of the tube and the sleeve for which indication of wall degradation must be evaluated. This information can be summarized as follows:

1) Indications of degradation in the entire length of the sleeve must be evaluated against the sleeve plugging limit.

2) The tube plugging limit continues to apply to the area of the tube at and above the bottom of the upper weld joint.

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3) Indication of tube degradation of any type including a complete '

guillotine break in'the tube between the bottom of the upper weld joint and top of the lower weld joint does not require i that the tube be removed from service. ]

l The design of the Bechtel-KWU Alliance sleeve, material, inspection and installation procedures, test and analyses were developed to the applicable ASME Boller and Pressure Vessel codes. The design, fabrication, installation, and testing of the sleeving process conform to all current applicable regulatory requirements. Extensive analyses and tests have verified the structural adequacy of the sleeved tube and have demonstrated that the system flowrate and the required heat removal capability of the affected steam generator are not compromised after sleeve installation. The j.

analyses were performed in accordance with the guidelines of Section III of the ASME Boller and Pressure Vessel Code for Class 1 components. The analyses performed were stress and fatigue, flow induced vibration, effects due to tubesheet convexity, _ thermal effects of the sludge pile, buckling, and hydraulic analyses. The test program includes both corrosion and structural tests.

The installed sleeve is considered as a structural member of the reactor coolant pressure boundary, meeting all loading conditions associated with accidents and normal plant operations including start-up, hot standby, and anticipated transients.

The installation of a sleeve into a tube results in an additional flow restriction within the primary system with an associated increase in presuure drop across the steam generator. The effect of this ficw l restriction on plant operation is evaluated in the same manner that tube plugging effects are analyzed. BKAT-01-P, Revision 1 identifies the reduction in primary coolant flow caused by the projected sleeving under normal operating conditions and identifies the number of sleeves which result in a flow reduction equivalent to one plugged tube.

l BKAT-01-P, Revision I also provides as assessment of the impact of sleeving on both LOCA and non-LOCA transients. These analyses are not adversely impacted by the maximum anticipated sleeving level.

In summary, the Bechtel-KNU Alliance welded sleeve process, in conjunction with the plugging criteria summarized in this attachment, will provide a primary system boundary equivalent to that of an original steam generator.

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,l ATTACIDENT 3 .i

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ZIN. MUELEAILEQt.ER._SIAILM f  :!

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ERDEDSED_TECIIMIEAL_ SPECIFICATION

'AMBiDHEMI AEFIEDlX A SECIL@ 4.3 I i

f REACIDiLC00LANT SYSTEN '!

1 EVALUATION OF SIGNIFICANT HAZARDS CONSIDER &Il0H H i

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L EVALUATION OF SIGNIFICANT HAZARDS CONSIDERATION

.'ERQEQSED_ GAHEES TO ZION TECHNICAb iSEEElflEAHD14 APPENDIX A'- SECTION 4.3

' .EEACTOR COOLANT SYSTEM 1r.

DESCRIPTION ~OF AMENDMENT REQUES*[

An amendment.to the Zion Facility Operating License is proposed to allow the

. ;usefof the Bechtel-KWU Alliance welded sleeve process to repair defective steam generator tubes. '

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' BACKGRQUND-10 CFR 50.92 states that a proposed swendment will involve a no significant hazards consideration'if the proposed snendment does nott i

(1) Involve a significant increase in the probability or consequences lof an accident previously~ evaluated; or

'( 2 ) . Create the possibility of a new or different kind of accident from.any accident'previously evaluated; or

..(3) Involve a significant reduction in a margin of safety.

The discussion below addresses each of these three criteria and demonstrates

'that the proposed amendment involves a no significant hazards consideration.

HASIS FOR NO SIGNIFICANT HAZARDS CONSIDERATION DETERMINATION

-Does'the proposed. amendment .

(1) Involve a significant increase in the probability or consequences of an accident previously evaluated; or (2) 1 Create the possibility of a new or different kind of accident from any accident previously evaluated; or (3) Involve a significant reduction in a margin of safety?

1 RIS QSSION - ITEM II

- The creation of the option to utilize the Bechtel-KWU Alliance welded sleeve process.to repair a defective steam generator tube has no effect on either the

. probability or' consequences of any accident previously evaluated. As discussed in BKAT-01-P, Revision 1 and Attachment 2, the integrity of the steam generator tubes will be equivalent to that of an original tube, or a tube; sleeved by!the NRC-approved CE or HE processes. The continued integrity of.the sleeves will be verified by the inspection program required as a result of this change.

01637t8 f.

Thus, since the structural integrity of the tubes will not be adversely affected by this change, there is no increase in the probability of any accident previously evaluated. Specifically, the probability of a t i eam generator tube rupture will be unaltered.

In addition, the steam generator will remain capable of performing its required heat transfer function. The information provided in Section 4.3.5 of BKAT-01-P, Revision 1 demonstrates that the sleeve-induced primary flow reduction resulting from the use of a Bechtel-KWU Alliance sleeve is comparable to the currently approved WE or CE processes. As a result, the choice to install a Bechtel-KWU Alliance sleeve, as opposed to a WE or CE sleeve, will have no significant effect on the steam generator's heat transfer ability.

The sleeving process will allow a repaired steam generator tube to remain in service, rather than completely blocking the tube's flow with plugs. Thus, the act of placing a sleeve in a steam generator tube actually results in a more efficient steam generator relative to plugging the tube.

l Based upon the above discussion, the consequences of any accident previously evaluated will be unaf fected because the heat transfer capability of the steam generators will not be significantly altered.

DISCURSION - ITEM #2 As discussed above, both the structural integrity and the heat transfer capability of Zion steam generators will not be significantly affected by the use of the Bechtel-KWU Alliance welded sleeve process instead of the WE or CE sleeve processes. In addition, the steam generator tube sleeves do not interact with any other of Zion's systems. The ability of Zion's safety systems to perform their function will not be altered. Thus, there is no potential for a new or different kind of accident due to the use of the Bechtel-KWU sleeving process to repair Zion steam generators.

DISCUSSION - ITEM 13 The heat transfer capabilities of Zion's steam generators will not be significantly altered through the utilization of Bechtel-KWU Alliance welded sleeves as opposed to the currently approved WE or CE sleeves. In general, the sleeving process, whether the Bechtel-KWU Alliance, WE, or CE processes are utilized, results in a more efficient steam generator when compared to the plugging alternative.

As discussed above and in BKAT-01-P, Revision 1 the structural integrity of the steam generator tubes will be unaltered. Use of the Bechtel-KWU Alliance, WE, or CE sleeving processes will produce a primary system boundary with the appropriate integrity.

Since both the structural integrity and the heat transfer capability of Zion's steam generators will not be significantly altered by the choice of sleeving processes, the margin of safety will not be affected.

Therefore, since the application for amendment satisfies the criteria specified in 10 CFR 50.92, Commonwealth Edison Company has made a determination that the application involves no significant hazards consideration.

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ATIACIMENI_i DEAI:01-Pu BEVISION 1 APJLIL, 1989 PROPRIETARY VERSION IDEICAL_REPOILT: REEAXILQF_ DEFECTIVE STEAM GENERATOR RJBES BY SLEgyllig l

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i, AFFIDAVIT STATE OF MARYLAND )

) u ss q MONTGOMERY COUNTY )

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F Diethelm Knoedler, being first duly sworn, says:

1. I am President of Universal Testing Laboratories. Universal  !

Testing Laboratories is the owner of information contained in a document entitled " Topical Report: Repair of Defective Steam Generator Tubes by Sleeving" dated February 1989, which Universal Testing Laboratories seeks to have withheld from public disclosure.

2. I.am making this Affidavit pursuant to the provisions of the Nuclear Regulatory Commission's rules and regulations, including )

10.CFR 2.790. 1

'I have personal knowledge of the criteria and procedures 3.

utilized by Universal Testing Laboratories in determining and designating information as a trade secret or privileged or confidential commercial or financial information.

Under that system, information is customarily designated confidential and held in confidence if the release of that information might result in the loss of an existing or potential competitive advantage. Information which falls in one or more of the following categories is designated confidential:

a. Information which reveals the distinguishing aspects of a process (or component, structure, tool, method, i etc.) where prevention of its use by a competitor without license from Universal Testing Laboratories constitutes a competitive economic advantage over other companies.

b. Information in the form 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. Information which, if available to a competitor would reduce his expenditure or resources or improve his I. competitive position in the design, manufacture, shipment installation, assurance of quality, or licensing a similar product.

d. Information concerning or relating to price, production capacities, budget levels, or commercial strategies of Universal Testing Laboratories, its customers or suppliers.

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e. Information which reveals aspects of past, present, or future Universal Testing Laboratories or customer i funded development plans and programs of potential ccmaercial value to Universal Testing Laboratories. L

f. Information which contains patentable ideas or for j which patent protection may be desirable. <

g. Information relating to an invention.

4. The document " Topical Report: Repair of Defective Steam Generator Tubes by Sleeving" is marked " Proprietary" and is transmitted to the Nuclear Regulatory Commission in confidence.

5. The document " Topical Report: Repair of Defective Steam ,

Generator Tubes by Sleeving" contains confidential commercial information consisting of test data or other similar data concerning a process, method or component, the application of which results in a substantial competitive advantage to Universal Testing Laboratories.

6. The document " Topical Report: Repair of Defective Steam Generator Tubes by Sleeving", as well as the information which it describes has been held in confidence by Universal Testing Laboratories and has becn disclosed only after each proposed recipient of the information has executed an appropriate agreement if such agreement has been deemed necessary.

7. The information contained in the document " Topical Report:

Repair of Defective Steam Generator Tubes by Sleeving" is not available in public sources and can not be properly acquired without the execution of an appropriate agreement maintaining the proprietary nature of the information from Universal Testing Laboratories.

8. Public disclosure of the document and the information contained therein is likely to cause substantial harm to the competitive position of Universal Testing Laboratories because:

a. The information contained in the document consists of the design, manufacturing, installation and testing relating to the repair of steam generator tubes by sleeving, the application of which provides a competitive advantage to Universal Testing Laboratories in the nuclear marketplace.

Development of this information by Universal Testing Laboratories involved a substantial investment of ef for i and money.

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b. The information required significant effort and expense to obtain the licensing approvals necessary for application  :

of the information.

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c. The information contained in the document cannot be otherwise be duplicated by others without a substantial investment of effort and money by them.

d. In order to acquire such information, another party would also incur considerable expense and inconvenience in developing the design, manufacturing and test procedures relating to the information contained in the document.

e. The availability of such information to others would enable them to modify or create products without incurring significant research, development, engineering, manufacturing, licensing, quality assurance and other costs incurred by Universal Testing Laboratories.

f. The disclosure of the information may enable such parties to provide such services while avoiding the forgoing costs thereby significantly impairing the position of Universal Testing Laboratories in the nuclear marketplace.

9. Because of both the substantial investment of effort and money by Universal Testing Laboratory in conceiving and developing the information described in the document " Topical Report

Repair of Defective Steam Generator Tubes by Sleeving" I

and Universal Testing Laboratories' expectation that this information will substantially enhance its competitive position in the nuclear industry, Universal Testing Laboratories has a l rati'nal basis for holding this information in confidence.

t Further the Affiant sayeth not. I f'c/tfcdL,. Q5--

Diethelm R60edler j Subscribed and sworn to before me this /2' Wday of EhhE6 . , 1989.

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' Notary Public My Commission expires: O,la / NO Mt Commi: mon Unsa un gy i

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