RA-22-0280, Supplement to License Amendment Request to Adopt Technical Specifications Task Force (TSTF) Traveler TSTF-577, Revised Frequencies for Steam Generator Tube Inspections

Supplement to License Amendment Request to Adopt Technical Specifications Task Force (TSTF) Traveler TSTF-577, Revised Frequencies for Steam Generator Tube Inspections

ML22277A399
Person / Time
Site:	Robinson
Issue date:	10/04/2022
From:	Flippin N Duke Energy Progress
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
RA-22-0280
Download: ML22277A399 (28)

Text

Nicole L. Flippin H. B. Robinson Steam Electric Plant Unit 2 Site Vice President Duke Energy 3581 West Entrance Road Hartsville, SC 29550 O: 843 951 1701 F: 843 951 1319 Nicole.Flippin@Duke-Energy.com Serial: RA-22-0280 10 CFR 50.90 October 4, 2022 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 H.B. Robinson Steam Electric Plant, Unit No. 2 Docket No. 50-261 Renewed License No. DPR-23

Subject:

Supplement to License Amendment Request to Adopt Technical Specifications Task Force (TSTF) Traveler TSTF-577, Revised Frequencies for Steam Generator Tube Inspections By letter dated December 9, 2021 (Agencywide Document Access and Management System (ADAMS) Accession No. ML21343A047), as supplemented by letters dated January 6, 2022 (ADAMS Accession No. ML22006A240), April 28, 2022 (ADAMS Accession No. ML22118A336), and July 28, 2022 (ADAMS Accession No. ML22209A156), Duke Energy Progress, LLC (Duke Energy) requested an amendment to the H.B. Robinson Steam Electric Plant, Unit No. 2 (HBRSEP2) Technical Specifications (TS). The proposed amendment would adopt Technical Specifications Task Force (TSTF) Traveler TSTF-577, Revision 1, Revised Frequencies for Steam Generator Tube Inspections. Additionally, Duke Energy proposed a steam generator tube inspection period of 72 effective full power months (EFPM) for the HBRSEP2 inspection period that began December 8, 2020.

On September 14, 2022, Duke Energy and the U.S. Nuclear Regulatory Commission (NRC) held a public meeting regarding the proposed amendment. Based on those discussions, Duke Energy is supplementing the license amendment request to revise TS 5.5.9.c, which contains provisions for steam generator tube plugging criteria. Specifically, Duke Energy proposes to remove the time-based component of the steam generator tube plugging criteria, as well as revise the 47% nominal tube wall thickness to 40%. This additional aspect of the proposed change is a variation from TSTF Traveler TSTF-577, Revision 1. The Enclosure to this submittal provides a revision to the original license amendment request dated December 9, 2021.

provides the supplemental information. Attachment 2 provides a revised markup of the TS pages. This markup supersedes the TS markup provided as an attachment to the April 28, 2022 letter, entirely. Attachment 3 provides revised (clean) TS pages that reflect the proposed change. The information contained within this letter and its enclosures does not change the No Significant Hazards Consideration provided in the original license amendment request submittal.

( ~ DUKE ENERGYi

U.S. Nuclear Regulatory Commission RA-22-0280 Page 2 There are no regulatory commitments made in this submittal.

In accordance with 10 CFR 50.91, Duke Energy is notifying the State of South Carolina of the supplement to this LAR by transmitting a copy of this letter and enclosure to the designated State Official.

If there are any questions or if additional information is needed, please contact Mr. Ryan Treadway, Director - Nuclear Fleet Licensing at 980-373-5873.

I declare under penalty of perjury that the foregoing is true and correct. Executed on October 4, 2022.

Sincerely, Nicole L. Flippin Site Vice President

Enclosure:

Revised License Amendment Request Attachments: 1.

2.

3.

Supplemental Information Revised Technical Specifications Markup Revised (Clean) Technical Specifications Pages

U.S. Nuclear Regulatory Commission RA-22-0280 Page 3 cc (with Enclosure and Attachments):

L. Dudes, USNRC Region II - Regional Administrator J. Zeiler, USNRC Senior Resident Inspector - RNP L. Haeg, NRR Project Manager A. Nair, Director, Division of Environmental Response (SC)

A. Wilson, Attorney General (SC)

L. Garner, Manager, Radioactive and Infectious Waste Management (SC)

RA-22-0280 Enclosure Enclosure Revised License Amendment Request

[4 pages follow this cover page]

RA-22-0280 Enclosure The following contains a revision to the original license amendment request to adopt TSTF-577 (ADAMS Accession No. ML21343A047) to reflect a supplemental aspect of the proposed change.

Changes are identified by a vertical line (bar) in the right-hand margin of the affected page.

ENCLOSURE DESCRIPTION AND ASSESSMENT

1.

DESCRIPTION Duke Energy Progress, LLC (Duke Energy) requests adoption of TSTF-577, "Revised Frequencies for Steam Generator Tube Inspections," which is an approved change to the Standard Technical Specifications (STS), into the H.B. Robinson Steam Electric Plant, Unit No.

2 (HBRSEP2) Technical Specifications (TS). The TS related to steam generator (SG) tube inspections and reporting are revised based on operating history.

2.

ASSESSMENT 2.1 Applicability of Safety Evaluation Duke Energy has reviewed the safety evaluation for TSTF-577 provided to the Technical Specifications Task Force in a letter dated April 14, 2021. This review included a review of the NRC staffs evaluation, as well as the information provided in TSTF-577. As described herein, Duke Energy has concluded that the justifications presented in TSTF-577 and the safety evaluation prepared by the NRC staff are applicable to HBRSEP2 and justify this amendment for the incorporation of the changes to the HBRSEP2 TS.

The current SG TS requirements are based on TSTF-510, "Revision to Steam Generator Program Inspection Frequencies and Tube Sample Selection." HBRSEP2 is a single unit site.

The Unit No. 2 SGs have Alloy 600 thermally treated (Alloy 600TT) tubes.

The initial inspection period described in the SG Program, paragraph d.2, began December 8, 2020. Duke Energy will submit a SG Tube Inspection Report meeting the revised TS 5.6.8 requirements within 30 days after implementation of the license amendment.

2.2 Variations Duke Energy is proposing the following variations from the TS changes described in TSTF-577 or the applicable parts of the NRC staffs safety evaluation:

1. The HBRSEP2 TS utilize different numbering than the Standard Technical Specifications on which TSTF-577 was based. Specifically, the NUREG-1431 STS for Westinghouse plants uses TS 5.6.7 for the Steam Generator Tube Inspection Report TS and HBRSEP2 uses TS 5.6.8. This difference is administrative and does not affect the applicability of TSTF-577 to the HBRSEP2 TS.

RA-22-0280 Enclosure

2. Duke Energy is proposing a HBRSEP2 SG tube inspection period of 72 effective full power months (EFPM) for the inspection period that began December 8, 2020. This is a variation because HBRSEP2 has not previously performed a SG inspection with enhanced probes. However, for all future HBRSEP SG tube inspections, enhanced probes will be utilized in accordance with TSTF-577. None of the HBRSEP2 SG tubes have ever experienced cracking other than in regions that are exempt from inspection by alternate repair criteria.

The justification for this technical variation from TSTF-577 is provided in Attachment 3 and reflects discussions between Duke Energy and the NRC staff regarding the proposed amendment from a public meeting on June 24, 2021 (ADAMS Accession No. ML21182A220).

3. Duke Energy is proposing to revise TS 5.5.9.c to remove the time-based component of the SG tube plugging criteria and modify the 47% nominal tube wall thickness to a value of 40%. This is a variation because the SG tube plugging criteria in the SG Program TS is not modified by TSTF-577.

The justification for this technical variation from TSTF-577 is provided in Attachment 1 of Duke Energy letter RA-22-0280, dated October 4, 2022.

The HBRSEP2 SG Program TS currently contains a provision for an alternate tube plugging criteria. The description of the alternate tube plugging criteria in the proposed change are equivalent to the descriptions in the current TS.

3.0 REGULATORY ANALYSIS

3.1 No Significant Hazards Consideration Analysis Duke Energy Progress, LLC (Duke Energy) requests adoption of TSTF-577, "Revised Frequencies for Steam Generator Tube Inspections," which is an approved change to the Standard Technical Specifications (STS), into the H.B. Robinson Steam Electric Plant, Unit No.

2 (HBRSEP2) Technical Specifications (TS). The TS related to steam generator (SG) tube inspections and reporting are revised based on operating history. Duke Energy is proposing a HBRSEP2 SG tube inspection period of 72 effective full power months (EFPM) for the inspection period that began December 8, 2020, which is a variation from the TS changes described in TSTF-577 because 100% of the SG tubes have not been inspected with enhanced probes.

Duke Energy has evaluated if a significant hazards consideration is involved with the proposed amendment 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 consequences of an accident previously evaluated?

Response: No The proposed change revises the inspection frequencies for SG tube inspections and associated reporting requirements. The SG inspections are conducted as part of the SG Program to ensure and demonstrate that performance criteria for tube structural integrity

RA-22-0280 Enclosure and accident leakage integrity are met. These performance criteria are consistent with the plant design and licensing basis. With the proposed changes to the inspection frequencies, the SG Program must still demonstrate that the performance criteria are met. As a result, the probability of any accident previously evaluated is not significantly increased and the consequences of any accident previously evaluated are not significantly increased.

Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

2.

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

Response: No The proposed change revises the inspection frequencies for SG tube inspections and associated reporting requirements. The proposed change does not alter the design function or operation of the SGs or the ability of an SG to perform the design function.

The SG tubes continue to be required to meet the SG Program performance criteria.

The proposed change does not create the possibility of a new or different kind of accident due to credible new failure mechanisms, malfunctions, or accident initiators that are not considered in the design and licensing bases.

Therefore, the proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

3.

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

Response: No The proposed change revises the inspection frequencies for SG tube inspections and associated reporting requirements. The proposed change does not change any of the controlling values of parameters used to avoid exceeding regulatory or licensing limits.

The proposed change does not affect a design basis or safety limit, or any controlling value for a parameter established in the Updated Final Safety Analysis Report (UFSAR) or the license.

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

Based on the above, Duke Energy concludes that the proposed change presents no 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.

3.2 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.

RA-22-0280 Enclosure

4.0 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 a 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.

RA-22-0280 Supplemental Information

[5 pages follow this cover page]

RA-22-0280 By letter dated December 9, 2021 (Agencywide Document Access and Management System (ADAMS) Accession No. ML21343A047), as supplemented by letters dated January 6, 2022 (ADAMS Accession No. ML22006A240), April 28, 2022 (ADAMS Accession No. ML22118A336), and July 28, 2022 (ADAMS Accession No. ML22209A156), Duke Energy Progress, LLC (Duke Energy) requested an amendment to the H.B. Robinson Steam Electric Plant, Unit No. 2 (HBRSEP2) Technical Specifications (TS). The proposed amendment would adopt Technical Specifications Task Force (TSTF) Traveler TSTF-577, Revision 1, Revised Frequencies for Steam Generator Tube Inspections. Additionally, Duke Energy proposed a steam generator tube inspection period of 72 effective full power months (EFPM) for the HBRSEP2 inspection period that began December 8, 2020.

Duke Energy proposes to supplement the proposed amendment with additional changes to TS 5.5.9, Steam Generator (SG) Program. Specifically, the additional aspects of the proposed change would revise TS 5.5.9.c, which contains provisions for steam generator tube plugging criteria, to remove the time-based component of the steam generator tube plugging criteria.

The proposed change would also modify the 47% nominal tube wall thickness to a value of 40%.

Current Technical Specifications Requirements The existing HBRSEP TS 5.5.9.c states the following, in part:

Provisions for SG tube plugging criteria. Tubes found by inservice inspection to contain flaws with a depth equal to or exceeding the following criteria shall be plugged: 47% of the nominal tube wall thickness if the next inspection interval of that tube is 12 months, and a 2% reduction in the plugging criteria for each 12 month period until the next inspection of the tube.

Reason for the Proposed Change For B SG tube R3C5, the TS 5.5.9.c projected plugging limit criteria will be exceeded prior to HBRSEP2 Refuel 35 (November 2026). Specifically, after applying the site-specific 2% per year reduction to the 47% plugging criteria, the 38% through-wall (TW) indication for tube R3C5 exceeds the calculated 72-month criteria of 37% TW. The projection from the last SG tube inspection in December 2020 is represented as follows:

Time (from December 2020)

TS Plugging Limit 0-12 months (2020-2021) 47%

12-24 months (2021-2022) 45%

Refuel 33 24-36 months (2022-2023) 43%

36-48 months (2023-2024) 41%

Refuel 34 48-60 months (2024-2025) 39%

60-72 months (2025-2026) 37%

Refuel 35

RA-22-0280 Description of the Proposed Change The SG tube plugging criteria is revised to remove the time-based component of the SG tube plugging criteria and modify the 47% nominal tube wall thickness to a value of 40%.

Specifically, TS 5.5.9.c is revised as follows:

Provisions for SG tube plugging criteria. Tubes found by inservice inspection to contain flaws with a depth equal to or exceeding the following criteria shall be plugged: 47%

40% of the nominal tube wall thickness if the next inspection interval of that tube is 12 months, and a 2% reduction in the plugging criteria for each 12 month period until the next inspection of the tube shall be plugged.

The proposed change presented above is appropriately described as a variation from TSTF Traveler TSTF-577, Revision 1 in the Enclosure of this submittal.

Technical Evaluation The time-based reduction component of the SG tube plugging criteria (i.e., 2% reduction in the plugging criteria for each 12 month period) was added to the HBRSEP2 TS upon the issuance of Amendment No. 44 on November 17, 1979 (ADAMS Accession No. ML020500754) and the requirement was carried through to HBRSEP2s full conversion to Improved Standard Technical Specifications upon issuance of Amendment No. 176 on October 24, 1997 (ADAMS Accession Nos. ML020560172, ML14175A922, and ML14175A924). From issuance of Amendment No. 44 and until 1984, HBRSEP had 600 mill-annealed SG tubes. Operating experience has shown that mill-annealed Alloy 600 is susceptible to various forms of degradation in the steam generator operating environment. One such type of degradation affecting such tubes is wastage, which is general corrosion caused by chemical attack from acid phosphate residues in areas of low water flow. Wastage is a form of generalized corrosion in which metal is more or less uniformly removed over an area of macroscopic dimensions. Tube wastage (frequently called thinning) was first observed in nuclear SGs when these units were being treated with sodium phosphate. Affected areas were typically found at the top of sludge piles where wet and dry zones could concentrate corrosive chemicals. The 2% reduction in plugging limit per 12 month period was added to HBRSEP2 TS to provide a tube wall thinning allowance between inspections due to chemical wastage.

In 1984, the three SGs at HBRSEP2 were replaced with Westinghouse model 44F SGs having 600 thermally-treated (TT) tubes. This SG model remains in service at HBRSEP2 today. A thinning allowance or time-based reduction component of the SG tube plugging criteria in TS is no longer necessary for maintaining SG tube integrity and for satisfying the regulatory requirements of Title 10 of the Code of Federal Regulations (10 CFR) paragraph 50.36(c)(5),

Administrative controls for the following reasons.

First, tube degradation from chemical wastage at HBRSEP2 no longer occurs because of the change from sodium phosphate water chemistry to all-volatile water treatment (AVT) based on the use of ammonia and hydrazine. This change in chemistry for the secondary coolant at the time of SG replacement was pursued to minimize corrosion.

Furthermore, the tube degradation from chemical wastage that had occurred in the 600 mill-annealed SG tubes prior to SG replacement at HBRSEP2 is no longer a concern because of the 600 TT tube material and its heat treatment. The first major advance in limiting the corrosion

RA-22-0280 susceptibility of the improved 600 TT SG tubes was the use of a thermal treatment process to improve the tubes microstructure and thereby its corrosion resistance.

In addition to the more advanced 600 TT tubing material and chemistry changes, several other design improvements were associated with the HBRSEP2 SG replacement to increase the tubes resistance to degradation. The NRC staff acknowledged several of these design improvements from the HBRSEP2 SG replacement in its Safety Evaluation Report (SER) dated November 1983 (NUREG-1004; ADAMS Accession No. ML14175A907). Specifically, the NRC highlighted in the SER modifications such as a flow distribution baffle, improved internal blowdown design, tube expansion in tubesheet, offset feedwater distribution, quatrefoil tube support plates, tube lane blocking device, and access ports and stated the following regarding these modifications:

Staff evaluation of these modifications indicates that these design features should provide better flow distribution, provide additional tube bundle access, and minimize the potential for secondary side corrosion. (emphasis)

The Safety Evaluation Report further states:

(1) the design modifications and material changes in the replacement steam generators will reduce the potential for corrosion degradation, (2) the procedures and controls to be used in the repair/replacement program are adequate to reduce the potential for corrosion degradation of the reassembled primary and secondary coolant systems during layup and subsequent operation, and (3) there is reasonable assurance that the removed portions of the steam generators will not degrade by corrosion during the long term. (emphasis)

The NRC staff concluded that:

the steam generator repair/replacement program is acceptable from the corrosion aspect and the secondary water chemistry monitoring and control program meets the requirements of GDC-14. In addition the staff concludes thatchanges in secondary system design, water chemistry, and operation appear to be the effective solutions to steam generator problems previously encountered at HBR-2.

In addition to the proposed removal of a 2% thinning allowance from HBRSEP2 TS 5.5.9.c, Duke Energy is also proposing the industry standard depth-based plugging limit of 40% of the initial tube wall thickness as the new HBRSEP2 SG tube plugging criterion. Regarding this criterion, direct precedent exists from other nuclear units with replacement SGs installed. Like HBRSEP2, Turkey Point Units 3 and 4 have three Westinghouse replacement model 44F SGs, and each SG contains 3,214 thermally treated Alloy 600 tubes. The tube dimensions for HBRSEP2 and Turkey Point, Units 3 and 4 are identical with a nominal outside diameter of 0.875 inches and a nominal wall thickness of 0.050 inches. The NRC stated in the Safety Evaluation Report for the replacement of the HBRSEP2 SGs (NUREG-1004; ADAMS Accession No. ML14175A907) that the program proposed for HBRSEP2:

is essentially identical to the steam generator repairs completedfor Turkey Point Units 3 and 4

RA-22-0280 A review of the existing Turkey Point Units 3 and 4 TS (ML052790649) indicates that there is no time-based reduction component of the SG tube plugging criteria. Rather, Turkey Point adopted the standard 40% criterion into TS in March 1982 (ADAMS Accession No. ML013340228), prior to its SG replacements in April 1982 (Unit 3) and May 1983 (Unit 4). HBRSEP2 already had a TS for the inservice inspection of SG tubes prior to the 1984 SG replacements. Based on the similarities in SG type, tube type, and scope of replacement projects discussed above, Duke Energy concludes 40% of the nominal tube wall thickness plugging criterion is reasonable for application to the HBRSEP2 SG tubes and for satisfying the structural integrity criterion in order to maintain SG tube integrity.

Furthermore, the 40% criterion has been standard in plant TS since the 1970s. The TSTF-449, Steam Generator Tube Integrity, Traveler, which has been approved by the NRC staff for adoption into plant TS, states in the background section, for example:

The criteria governing structural integrity of SG tubes were developed in the 1970s and assumed uniform wall thinning. This led to the establishment of a through wall SG tube repair criteria (e.g., 40 percent) that has historically been incorporated into most pressurized water reactor (PWR) Technical Specifications and has been applied, in the absence of other repair criteria, to all forms of SG tube degradation where sizing techniques are available. Since the basis of the through wall depth criterion was 360° wastage, it is generally considered to be conservative for other mechanisms of SG tube degradation.

The Model Safety Evaluation for TSTF-449, prepared by the NRC staff, acknowledges the standard 40% criterion when evaluating the structural integrity criterion for SG tube integrity:

The NRC staff has evaluated this proposed [structural integrity] criterion for consistency with the safety factors embodied in the current licensing basis, specifically, the safety factors embodied in the TS tube repair criterion. The tube repair criterion typically specified in plant TSs is 40 percent of the initial tube wall thickness. This criterion is typically applicable to all tubing flaws found by inspection, except for certain flaw types at certain locations for which less restrictive repair criterion may be applicable (as specified in the TSs)

Given that the HBRSEP2 replacement (existing) SGs are a standard Westinghouse model 44F design with 600 TT tubes, Duke Energy concludes that the industry 40% criterion in TS applies to HBRSEP2.

Lastly, for Westinghouse plants throughout the nuclear industry, the TS contain a through wall SG tube criterion of 40% consistent with Standard Technical Specifications (STS), without a time-based reduction component or thinning allowance between inspections. Callaway is the only other plant observed by Duke Energy to maintain a value other than 40% for the depth-based criterion in TS. By letter dated October 1, 1996 (ADAMS Accession No. ML021640202),

the NRC staff issued a license amendment to Callaway accepting its repair of SG tubes using laser welded tubesheet sleeves and a reduction from 48% to 40% through wall for the plugging limit. Within the Safety Evaluation for that license amendment, the NRC staff stated:

In accordance with the guidance of NUREG-1431, Standard Technical Specifications for Westinghouse Plants, the licensee is reducing the tube plugging/repair limit from 48 percent to 40 percent through wall of nominal tube wall thickness (including the 20 percent NDE uncertainty).

RA-22-0280 The proposed change for HBRSEP2 to reduce the tube plugging limit from 47% to 40% would align the TS with other Westinghouse plants and with STS.

RA-22-0280 Revised Technical Specifications Markup

[7 pages follow this cover page]

Programs and Manuals 5.5 5.5 Programs and Manuals (continued) 5.5.9 HBRSEP 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:

r==--i 11

~

a.

Provisions for condition monitoring assessments. Condition monitoring assessment means an evaluation of the "as found" condition of the tubing with respect to the performance criteria for structural integrity and accident induced leakage. The "as found" condition refers to the condition of the tubing during an SG inspection outage, as determined from the inservice inspection results or by other means, prior to the plugging of tubes.

Condition monitoring assessments shall be conducted during each outage during which the SG tubes are inspected or plugged 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

~ rsG7 operating conditions (including startup, operation in the power range, ~

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

2. Accident induced leakage performance criterion: The primary to secondary accident induced leakage rate for any design basis accident, other than a SG tube rupture, shall not exceed the leakage rate assumed in the accident analysis in terms of total leakage rate for all SGs and leakage rate for an individual SG. Leakage is not to exceed 150 gallons per day per SG.

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

(continued) 5.0-12 Amendment No. ~

Programs and Manuals 5.5 5.5 Programs and Manuals (continued)

HBRSEP 5.0-13 Amendment No. 235 5.5.9 Steam Generator (SG) Program (continued)

c.

Provisions for SG tube plugging criteria. Tubes found by inservice inspection to contain flaws with a depth equal to or exceeding the following criteria shall be plugged: 47% of the nominal tube wall thickness if the next inspection interval of that tube is 12 months, and a 2% reduction in the plugging criteria for each 12 month period until the next inspection of the tube.

The following alternate tube plugging criteria shall be applied as an alternative to the preceding criteria:

Tubes with service-induced flaws located greater than 18.11 inches below the top of the tubesheet do not require plugging. Tubes with service-induced flaws located in the portion of the tube from the top of the tubesheet to 18.11 inches below the top of the tubesheet shall be plugged upon detection.

d.

Provisions for SG tube inspections. Periodic SG tube inspections shall be performed. The number and portions of the tubes inspected and methods of inspection shall be performed with the objective of detecting flaws of any type (e.g., volumetric flaws, axial and circumferential cracks) that may be present along the length of the tube, from the tube-to-tubesheet weld at the tube inlet to the tube-to-tubesheet weld at the tube outlet and that may satisfy the applicable tube plugging criteria. The tube-to-tubesheet weld is not part of the tube. In addition to meeting the requirements of d.1, d.2, and d.3 below, the inspection scope, inspection methods, and inspection intervals shall be such as to ensure that SG tube integrity is maintained until the next SG inspection. 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 48 effective full power months or at least every other refueling outage (whichever results in more frequent inspections). In addition, the minimum number of tubes inspected at each scheduled inspection shall be the number of tubes In all SGs divided by the number of SG inspection outages scheduled in each Inspection period as defined in a, b, and c below. 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 INSERT6 INSERT 1 INSERT 2

Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.9 Steam Generator (SG) Program (continued) the applisable tube plugging sriteria, the rninirnurn nurnber of losations inspested 1Nith sush a sapable inspestion teshnique during the rernainder of the inspestion period rnay be prorated. The frastion of losations to be inspested for this potential type or degradation at this losation at the end of the inspestion period shall be no less than the ratio of the nurnber of tirnes the SG is ssheduled to be inspested in the inspestion period after the deterrnination that a ne1N forrn of degradation sould potentially be ossurring at this losation di1,1ided by the total nurnber of tirnes the SG is ssheduled to be inspested in the inspestion period. Eash inspestion period defined belo1.*.1 rnay be e:><-tended up to a eff.estive full po1Ner rnonths to inslude a SG inspestion outage in an inspestion period and the subsequent inspestion period begins at the sonslusion of the insluded SG inspestion outage.

a) After the first refueling outage following SG installation, inspest 100~~ of the tubes during the ne~d 120 effestive full power rnonths. This sonstitutes the first inspestion period; b) During the nmd 9e eff.esti1,e full power rnonths, inspest 100% of the tubes. This sonstitutes the sesond inspestion period; and s) During the rernaining lif.e of the SGs, inspest 100% of the tubes e1,er;1 72 effesti1,e full power rnonths. This sonstitutes the th."""ir"""'"d""""a"""n"""'"d __

subsequent inspestion periods.

INSERT 3

3.

lbe at the next I If crack indications are found in any portion of a SG tube not e>EGluded aeeYe, then the next inspection for each affected and potentially affected SG ~

the degradation mechanism that caused the crack INSERT 4 indication sh 5.5.10 HBRSEP refueling outage (whishever results in rnore frequent inspestions). If I

definitive information, such as from examination of a pulled tube, diagnostic non-destructive testing, or engineering evaluation indicates that a crack-like indication is not associated with a crack(s), then the indication need not be treated as a crack.

e.

Provisions for monitoring operational primary to secondary LEAKAGE.

Secondary Water Chemistry Program This program provides controls for monitoring secondary water chemistry to inhibit SG tube degradation. The program shall include:

a.

Identification of critical parameters, their sampling frequency, sampling points, and control band limits; (continued) 5.0-14 Amendment No. ~

Reporting Requirements 5.6 5.6 Reporting Requirements (continued) 5.6.7 5.6.8 INSERT 5 Tendon Surveillance Report

a.

Notification of a pending sample tendon test, along with detailed acceptance criteria, shall be submitted to the NRC at least two months prior to the actual test.

b.

A report containing the sample tendon test evaluation shall be submitted to the NRC within six months of conducting the test.

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

The soope of inspestions performed on eaoh SG.

Degradation meohanisms f.ound.

NondestrustiYe e>mmination teohniques utilii!ed for eaoh degradation meohanism.

4 Looation, orientation (if linear), and measured sii!es (if aYailable) of seFYioe induoed indioations.

e-:

Number of tubes plugged during the inspeotion outage for eaoh asti*,e degradation meohanism.

f:.

The number and peroentage of tubes plugged to date, and the effesti*,e plugging peroentage in eaoh steam generator.

§-:-

The results of oondition monitoring, inoluding the results of tube pulls and in situ testing.

R-:-

The primary to seoondary leakage rate obseFYed in eaoh SG (if it is not prastioal to assign the leakage to an indiYidual SG, the entire primary to seoondary leal'iage should be oonseFYatiYely assumed to be from one SG) during the oyole preoeding the inspestion that is the subjest of the report, h-The oaloulated aooident induoed leal'iage rate from the portion of the tubes belm-.* 18.11 inohes from the top of the tubesheet f.or the most limiting aooident in the most limiting SG. In addition, if the oaloulated aooident induoed leal'iage rate from the most limiting aooident is less than 1.87 times the ma:1Eimum operational primary to seoondary leal'iage rate, the report should desoribe how it was determined, and HBRSEP Unit No. 2 5.0-28 Amendment No. ~

Reporting Requirements 5.6 5.6 Reporting Requirements (continued) 5.6.8 Steam Generator Tube Inspection Report (continued)

HBRSEP Unit No. 2 The results of monitoring for tube axial displacement (slippage). If slippage is discovered, the implications of the discovery and corrective action shall be provided.

5.0-28a Amendment No. 224

INSERT 1 except for any portions of the tube that are exempt from inspection by alternate repair criteria, INSERT 2 After the first refueling outage following SG installation, inspect 100% of the tubes in each SG at least every 54 effective full power months, which defines the inspection period. If none of the SG tubes have ever experienced cracking other than in regions that are exempt from inspection by alternate repair criteria and the SG inspection was performed with enhanced probes, the inspection period may be extended to 72 effective full power months. Additionally, the inspection period that began December 8, 2020 may be 72 effective full power months without prior performance of a SG inspection using enhanced probes. Enhanced probes have a capability to detect flaws of any type equivalent to or better than array probe technology. The enhanced probes shall be used from the tube-to-tubesheet weld at the tube inlet to the tube-to-tubesheet weld at the tube outlet except any portions of the tube that are exempt from inspection by alternate repair criteria. If there are regions where enhanced probes cannot be used, the tube inspection techniques shall be capable of detecting all forms of existing and potential degradation in that region.

INSERT 3 excluding any region that is exempt from inspection by alternate repair criteria INSERT 4

, but may be deferred to the following refueling outage if the 100% inspection of all SGs was performed with enhanced probes as described in paragraph d.2 INSERT 5

a. The scope of inspections performed on each SG;

b. The nondestructive examination techniques utilized for tubes with increased degradation susceptibility;

c. For each degradation mechanism found:

1. The nondestructive examination techniques utilized;

2. The location, orientation (if linear), measured size (if available), and voltage response for each indication. For tube wear at support structures less than 20 percent through-wall, only the total number of indications needs to be reported;

3. A description of the condition monitoring assessment and results, including the margin to the tube integrity performance criteria and comparison with the margin predicted to exist at the inspection by the previous forward-looking tube integrity assessment; and

4. The number of tubes plugged during the inspection outage.

d. An analysis summary of the tube integrity conditions predicted to exist at the next scheduled inspection (the forward-looking tube integrity assessment) relative to the applicable performance criteria, including the analysis methodology, inputs, and results;

e. The number and percentage of tubes plugged to date, and the effective plugging percentage in each SG;

f. The results of any SG secondary side inspections;

g. The primary to secondary leakage rate observed in each SG (if it is not practical to assign the leakage to an individual SG, the entire primary to secondary leakage should be conservatively assumed to be from one SG) during the cycle preceding the inspection that is the subject of the report;

h. The calculated accident induced leakage rate from the portion of the tubes below 18.11 inches from the top of the tubesheet for the most limiting accident in the most limiting SG. In addition, if the calculated accident induced leakage rate from the most limiting accident is less than 1.87 times the maximum operational primary to secondary leakage rate, the report should describe how it was determined; and INSERT 6 Provisions for SG tube plugging criteria. Tubes found by inservice inspection to contain flaws with a depth equal to or exceeding 40% of the nominal tube wall thickness shall be plugged.

RA-22-0280 Revised (Clean) Technical Specifications Pages

[5 pages follow this cover page]

Programs and Manuals 5.5 5.5 Programs and Manuals (continued)

(continued)

HBRSEP 5.0-12 Amendment No. XXX 5.5.9 Steam Generator (SG) Program An SG Program shall be established and implemented to ensure that SG tube integrity is maintained. In addition, the SG 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 an SG inspection outage, as determined from the inservice inspection results or by other means, prior to the plugging of tubes.

Condition monitoring assessments shall be conducted during each outage during which the SG tubes are inspected or plugged 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 SG tubes shall retain structural integrity over the full range of normal operating conditions (including startup, operation in the power range, hot standby, and cool down) and all anticipated transients included in the design specification, and design basis accidents. This includes retaining a safety factor of 3.0 against burst under normal steady state full power operation primary-to-secondary pressure differential and a safety factor of 1.4 against burst applied to the design basis accident primary-to-secondary pressure differentials. Apart from the above requirements, additional loading conditions associated with the design basis accidents, or combination of accidents in accordance with the design and licensing basis, shall also be evaluated to determine if the associated loads contribute significantly to burst or collapse. In the assessment of tube integrity, those loads that do significantly affect burst or collapse shall be determined and assessed in combination with the loads due to pressure with a safety factor of 1.2 on the combined primary loads and 1.0 on axial secondary loads.

2. Accident induced leakage performance criterion: The primary to secondary accident induced leakage rate for any design basis accident, other than a SG tube rupture, shall not exceed the leakage rate assumed in the accident analysis in terms of total leakage rate for all SGs and leakage rate for an individual SG. Leakage is not to exceed 150 gallons per day per SG.

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

Programs and Manuals 5.5 5.5 Programs and Manuals (continued)

HBRSEP 5.0-13 Amendment No. XXX 5.5.9 Steam Generator (SG) Program (continued)

c.

Provisions for SG tube plugging criteria. Tubes found by inservice inspection to contain flaws with a depth equal to or exceeding 40% of the nominal tube wall thickness shall be plugged.

The following alternate tube plugging criteria shall be applied as an alternative to the preceding criteria:

Tubes with service-induced flaws located greater than 18.11 inches below the top of the tubesheet do not require plugging. Tubes with service-induced flaws located in the portion of the tube from the top of the tubesheet to 18.11 inches below the top of the tubesheet shall be plugged upon detection.

d.

Provisions for SG tube inspections. Periodic SG tube inspections shall be performed. The number and portions of the tubes inspected and methods of inspection shall be performed with the objective of detecting flaws of any type (e.g., volumetric flaws, axial and circumferential cracks) that may be present along the length of the tube, from the tube-to-tubesheet weld at the tube inlet to the tube-to-tubesheet weld at the tube outlet except for any portions of the tube that are exempt from inspection by alternate repair criteria, and that may satisfy the applicable tube plugging criteria. The tube-to-tubesheet weld is not part of the tube. In addition to meeting the requirements of d.1, d.2, and d.3 below, the inspection scope, inspection methods, and inspection intervals shall be such as to ensure that SG tube integrity is maintained until the next SG inspection. 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 100% of the tubes in each SG at least every 54 effective full power months, which defines the inspection period. If none of the SG tubes have ever experienced cracking other than in regions that are exempt from inspection by alternate repair criteria and the SG inspection was performed with enhanced probes, the inspection period may be extended to 72 effective full power months. Additionally, the inspection

Programs and Manuals 5.5 5.5 Programs and Manuals (continued)

HBRSEP 5.0-14 Amendment No. XXX 5.5.9 Steam Generator (SG) Program (continued) period that began December 8, 2020 may be 72 effective full power months without prior performance of a SG inspection using enhanced probes. Enhanced probes have a capability to detect flaws of any type equivalent to or better than array probe technology. The enhanced probes shall be used from the tube-to-tubesheet weld at the tube inlet to the tube-to-tubesheet weld at the tube outlet except any portions of the tube that are exempt from inspection by alternate repair criteria. If there are regions where enhanced probes cannot be used, the tube inspection techniques shall be capable of detecting all forms of existing and potential degradation in that region.

3.

If crack indications are found in any portion of a SG tube excluding any region that is exempt from inspection by alternate repair criteria, then the next inspection for each affected and potentially affected SG for the degradation mechanism that caused the crack indication shall be at the next refueling outage, but may be deferred to the following refueling outage if the 100% inspection of all SGs was performed with enhanced probes as described in paragraph d.2. If definitive information, such as from examination of a pulled tube, diagnostic non-destructive testing, or engineering evaluation indicates that a crack-like indication is not associated with a crack(s), then the indication need not be treated as a crack.

e.

Provisions for monitoring operational primary to secondary LEAKAGE.

5.5.10 Secondary Water Chemistry Program This program provides controls for monitoring secondary water chemistry to inhibit SG tube degradation. The program shall include:

a.

Identification of critical parameters, their sampling frequency, sampling points, and control band limits;

Reporting Requirements 5.6 5.6 Reporting Requirements (continued)

(continued)

HBRSEP Unit No. 2 5.0-28 Amendment No. XXX 5.6.7 Tendon Surveillance Report

a.

Notification of a pending sample tendon test, along with detailed acceptance criteria, shall be submitted to the NRC at least two months prior to the actual test.

b.

A report containing the sample tendon test evaluation shall be submitted to the NRC within six months of conducting the test.

5.6.8 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 5.5.9, Steam Generator (SG) Program. The report shall include:

a.

The scope of inspections performed on each SG;

b.

The nondestructive examination techniques utilized for tubes with increased degradation susceptibility;

c.

For each degradation mechanism found:

1. The nondestructive examination techniques utilized;

2. The location, orientation (if linear), measured size (if available), and voltage response for each indication. For tube wear at support structures less than 20 percent through-wall, only the total number of indications needs to be reported;

3. A description of the condition monitoring assessment and results, including the margin to the tube integrity performance criteria and comparison with the margin predicted to exist at the inspection by the previous forward-looking tube integrity assessment; and

4. The number of tubes plugged during the inspection outage.

d.

An analysis summary of the tube integrity conditions predicted to exist at the next scheduled inspection (the forward-looking tube integrity assessment) relative to the applicable performance criteria, including the analysis methodology, inputs, and results;

e.

The number and percentage of tubes plugged to date, and the effective plugging percentage in each SG;

f.

The results of any SG secondary side inspections;

Reporting Requirements 5.6 5.0 ADMINISTRATIVE CONTROLS 5.6 Reporting Requirements (continued)

HBRSEP Unit No. 2 5.0-28a Amendment No. XXX 5.6.8 Steam Generator Tube Inspection Report (continued)

g.

The primary to secondary leakage rate observed in each SG (if it is not practical to assign the leakage to an individual SG, the entire primary to secondary leakage should be conservatively assumed to be from one SG) during the cycle preceding the inspection that is the subject of this report;

h.

The calculated accident induced leakage rate from the portion of the tubes below 18.11 inches from the top of the tubesheet for the most limiting accident in the most limiting SG. In addition, if the calculated accident induced leakage rate from the most limiting accident is less than 1.87 times the maximum operational primary to secondary leakage rate, the report should describe how it was determined; and

i.

The results of monitoring for tube axial displacement (slippage). If slippage is discovered, the implications of the discovery and corrective action shall be provided.