RNP-RA/07-0023, Response to NRC Request for Additional Information Pertaining to Proposed Technical Specifications Changes Regarding Steam Generator Tube Repair Criteria

Response to NRC Request for Additional Information Pertaining to Proposed Technical Specifications Changes Regarding Steam Generator Tube Repair Criteria

ML070800588
Person / Time
Site:	Robinson
Issue date:	03/13/2007
From:	Lucas J Progress Energy Carolinas, Progress Energy Co
To:	Document Control Desk, NRC/NRR/ADRO
References
RNP-RA/07-0023
Download: ML070800588 (15)

Text

10 CFR 50.90 Progress Energy Serial: RNP-RA/07-0023 MAR ,, 2007 United States Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO. 2 DOCKET NO. 50-261/LICENSE NO. DPR-23 RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION PERTAINING TO PROPOSED TECHNICAL SPECIFICATIONS CHANGES REGARDING STEAM GENERATOR TUBE REPAIR CRITERIA Ladies and Gentlemen:

In a letter dated January 19, 2007, Carolina Power and Light Company, also known as Progress Energy Carolinas, Inc. (PEC), requested NRC review and approval of changes to modify the Technical Specifications (TS) requirements related to steam generator tube alternate repair criteria for H. B. Robinson SteamElectric Plant (HBRSEP), Unit No. 2. An NRC request for additional information (RAI) pertaining to this amendment request was received by electronic mail transmission dated February 8, 2007.

Attachment I provides an Affirmation in accordance with the provisions of 10 CFR 50.30(b).

Attachment II provides the response to the NRC RAI for this license amendment request. Note that a portion of Attachment II is marked "Proprietary." It is requested that these pages be withheld from public disclosure in accordance with 10 CFR 2.390, as described in the request provided in Attachment V.

Attachment III provides revised edited TS pages. Attachment IV provides the revised TS pages.

In accordance with 10 CFR 50.91, a copy of this application is being provided to the State of South Carolina.

If you have any questions concerning this matter, please contact Mr. C. T. Baucom at (843) 857-1253.

Sincerely, JanF. ucas Manager- Support Services- Nuclear Progress Energy Carolinas, Inc.

Robinson Nuclear Plant g 66 3581 West Entrance Road Hartsville, SC 29550

United States Nuclear Regulatory Commission Serial: RNP-RA/07-0023 Page 2 of 2 JFL/cac Attachments: I. Affirmation II. Response to NRC Request for Additional Information Pertaining to Proposed Technical Specifications Changes Regarding Steam Generator Tube Repair Criteria III. Revised Edited Technical Specifications Pages IV. Revised Technical Specifications Pages V. Westinghouse Affidavit Regarding Proprietary Information c: Mr. T. P. O'Kelley, Director, Bureau of Radiological Health (SC)

Mr. H. J. Porter, Director, Division of Radioactive Waste Management (SC)

Dr. W. D. Travers, NRC, Region II Mr. C. P. Patel, NRC, NRR NRC Resident Inspector, HBRSEP Attorney General (SC)

United States Nuclear Regulatory Commission Attachment I to Serial: RNP-RA/07-0023 Page 1 of 1 AFFIRMATION The information contained in letter RNP-RA/07-0023 is true and correct to the best of my information, knowledge and belief; and the sources of my information are officers, employees, contractors, and agents of Carolina Power and Light Company, also known as Progress Energy Carolinas, Inc. I declare under penalty of perjury that the foregoing is true and correct.

Executed On: 4O 9 K V'kA/M3I A Ernest J. Kapbdufos, fr.

Plant General Manager, HBRSEP, Unit No. 2

United States Nuclear Regulatory Commission Attachment III to Serial: RNP-RA/07-0023 3 pages (including this page)

H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO. 2 REVISED EDITED TECHNICAL SPECIFICATIONS PAGES

The following alternate tube repair criteria may be applied as an alternative to the preceding criteria, until the end of Operating Cycle 25:

Flaws found in the portion of the tube below 17 inches from the top of the tubesheet do not require plugging. Tubes with flaws identified in the portion of the tube from the top of the tubesheet to 17 inches below the top of the tubesheet shall be plugged upon detection.

Hrograms ann rlanuals 55 5.5 Programs and Manuals 5 5.-9 Steam Generator (SG) Program (continued) I

2. Accident induced leakage performance criterion: The primary to secondary accident induced leakage rate for any desigcn basis accident, other than a )G tube rupture, shall not exceed the leakage rate assunied in the accident analYsis in terms of total leakage rate for all SGs and (until the en d leakage rate for an individual SG. Leakage is not to of Operating excee[d 7 gallons per day per S%

Cycle 25 the required 3. The operational LEAKAGE performance criterion is specified in LCO 3.4.13, "RCS Operational LEAKAGE" inspection length extend s c. Provisions fon SC tube repair criteria. Tubes found by 17 inches bel ow inservice inspection to contain flaws with a depth equal to the top of th e or exceeding thle following criteria shall be plugged: 47% of tubesheet on the nominal tube wall thickness if tile next inspection the tube hot interval of that tube is 12 months. and a 2% reduction in the leg side to 17 repair criteria for each 12 month period until the next inches below inspection of the tube.

the top of th e d. Provisions for SG tube inspections.l Periodic SG tube tubesheet on inspections;shall be performed. The number and portions of the tube cold the tubes inspected and methods of inspection shall be leg side) 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 outletv and tihat may satisfy the applicable tube repair 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, t'le inspection scope. inspection methods, and inspection intervals shall be such as to ensure that SG tube integrity is maintained until the next SG inspection. An assessment of degradation 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.i of the tubes in each SG during the first refuel ing outage fol l owing SG replacement.

2. inspect 100% of the tubes at sequential periods of 120.

90. and. thereafter. 60 effective full power months. The first sequential period shall be considered to begin after the first inservice inspection of the SGs. In (continued)

HBRSEP Unit No. 2 5-0-13 Amlendment No.

Report1 ng Requi rements 5_6 6 Reporting Requi1 renments, (continued) 5.6.6 Post Accident Honitoring (PAM) instrumentation Report When a report is required by Condition B or H of LCO 3-3.3. "Post Accident Monitoring (PAM) Instrumentation," a report shall be submitted within the following 14 days. The report shall outline the preplanned alternate method of monitoring, the cause of the inoperability. and the plans and schedule for restoring the instrumentation channels of the Function to OPERABLE status.

5.6.7 Tendon Surveillance Report

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

b. A report containing the sample tendon test evaluation shall be submittedi 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 clays after the initial entry into NODE 4 following completion of an inspection performed in accordance with the Specification 5.5.9. Steanm Generator (SG)

Program. The report shall include:

a. The scope of inspections performed on each SG.

b. Active degradation mechanisms found.

c. Nondestructive examination techniques utilized for each degradation nmechanism.

d_ Location. orientation (if linear), and measured sizes (if available) of service induced indications.

e. Number of tubes plugged during the inspection outage for each active degradation mechanism.

f. Total number and percentage of tubes plugged to date.

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

<Insert new requirements h. and i.>

h. The number of indications including location, size. and orientation, and whether the indications initiated in the primary or secondary side of the tube for each indication detected in the upper 17 inches of the tubesheet region of the tube.

The operational cycle primary to secondary leakage rate observed in each SG during the cycle preceding the tube inspection that is the subject of this report and the corresponding HBRSEP UH calculated accident leakage from the lower 4.81 inches of the tube for the most-limiting accuenlL inl gLle MIOL-IIIlimiIng 3G. 11 Lrle cdlcufdLeU dcciuenlL iedKdge rd~e lor any steam generator is less than two times the total observed operational primary to secondary leakage rate. the report should describe how it was determined.

United States Nuclear Regulatory Commission Attachment IV to Serial: RNP-RA/07-0023 3 pages (including this page)

H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO. 2 REVISED TECHNICAL SPECIFICATIONS PAGES

Programs and Manuals 5.5 5,5 Programs and Hanuals 5-5-9 Steam Generator (SG) Program (cont i nued) 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 75 gallons per day per SG-

3. The operational LEAKAGE performance criterion is specified in LCO 3.4-13, "RCS Operational LEAKI-AE."

c. Provisions for SG tube repair criteria. Tubes found by inservice inspection to contain flaws with a depth equal to or, eNceeding the follotingi criteria shall be plugged: 47% of the nominal tube wall thicknes s if the next inspection interval of that tube is 12 months, and a 2. red ction in the repair criteria for each 12 month period until the next inspection of the tube.

The following alternate tube repair criteria may be applied as an alternative to the preceding criteria, until the end of Operating Cycle 25:

Flaws found in the portion of the tube below 17 inches from the top of the tubesheet do not require plugging- Tubes with flaws identified in the portion of the tube from the top of the tubesheet to 17 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 (eg_, 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 (until the end of Operating Cycle 25 the required inspection length extends 17 inches below the top of the tubesheet on the tube hot leg side to 17 inches below the top of the tubesheet on the tube cold leg side). and that may satisfy the applicable tube repair criteria- The tube-to-tubesheet weld is not part of the tube.

in addition to meeting the requirements of d.l. d-2, and [.3 below, the inspection scope, inspection methods. and (continued)

HBRSEP Unit No- 2 5_- 0-1:3 Amlendment No.

Report ing Requi rements 5_6 5.6 Reporting Requirements (continuMed) 556,7 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- Active degradation mechanisms found.

c. Nondestructive examination techniques utilized for each degradation mechanism.

d. Location, orientation (if linear), and measured sizes (if available) of service induced indications.

e. Number of tubes plugged during the inspection outage for each active degradation mechanism.

f. Total number and percentage of tubes plugged to date.

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

h. The number of indications including location, size, and orientation, and whether the indications initiated in the primary or secondary side of the tube for each indication detected in the upper 17 inches of the tubesheet region of the tube.

i. The operational cycle primary to secondary leakage rate observed in each SG during the cycle preceding the tube inspection that is the subject of this report and the corresponding calculated accident leakage from the lower 4.81 inches of the tube for the most-limiting accident in the most-limiting SG. If the calculated accident leakage rate for any steam generator is less than two times the total observed operational primary to secondary leakage rate, the report should describe how it was determined.

HBRSEP Unit No. 2 5.0-28 Amendment No.

United States Nuclear Regulatory Commission Attachment V to Serial: RNP-RA/07-0023 6 pages (including this page)

H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO. 2 WESTINGHOUSE AFFIDAVIT REGARDING PROPRIETARY INFORMATION

CA W-07-2250 AFFIDAVIT COMMON WEALTH OF PENNSYLVANIA.

ss COUNTY OF ALLEGIHENY:

Actbrc mn the undersigned authority, personally appeared B. F. Maurer, who, behig by me duly sworn according to law,, deposes and ays that he is authorized to execute this Affidavil on behalf of Westiinghouse Electric Company ILLC (Westinghouse), and that the averments of Fact sei forth in this Affidavit are Inte and correct to the best of his knowledge, information, and beIlief:

B. F. MIaurer, Acting Manager Regulatory Compliance and Plant Licensing Sworn to and subscribed befbre me this 2 61h day of Fcbruajy, 2007 Notary Public COt 0'J 'EALrI't COF PENNSYLVANIA S!3a I Madrid, Notart Putt c ii ,Ateghany County Nly-riiar n io~ Jan. 29J,20111

2 CA W-07-2 250 (I) I am Acting Manager, Regulatory Compliance and Plant Iicensing, in Nuclear Services, Westinghouse Electric Company LLC (Westinghouse), and as such, I hIvc been specifically delegated the function of reviewing the proprietary informationm :oughw to he withheld from public disclosure in connection with nuclear power plant licensing and rule making proceedings. and aml authorized to apply for its withholding on behalf of Westinghoue.

(2) I am making this AM1fidavit in conformance with the provisions of 1(0 CFR Section 2.390 of the Corrumission's reguluations and in conjunction with the Westinghlouse "Application for Withholding" accompanying this Affidavit.

(3) I have personal knowledge of the criteria and procedures utilized by Westinghouse in designating information as a trade secret, privileged or as confidential commercial or financial information.

(4) Purtsuant to the provisions of pI*ragraph (b)(4) of Section 2,390 of the Conimission's regulations, the tboloowing is firnishcd tfr consideration by the Commission in determining whether the information sought t e withheld from public disclosure shoul1d be withheld, (i) The infonrmation sought to be withheld from public disclosure is owned and haks been held in confidence by Westinghouse.

(ii) The information is of a type customarily held in confidence by Westinghouse and not customarily disclosei to the public. Wesfinghoutse has o rational ba-sis for determining the types of informnalion customarily held in confidence by it and, in that connection, utilizes a system to determine when and whether to hold certain types of information in confidence. The application of that system and the substance of that system constitutes Westingh usc policy and provides the rational basis required.

Under that system, information is held in confidence if it falls in.one or more of several types, the release of which might result in the loss of an existing or potential competitive advantage, as follows:

(a) The information reveals the distinguishing aspects ofa process (or component, structure, fool, method, etc.) where prevention of its use by any of Westinghou xs's competitors without, license from Westinghouse constitutes a competitive economic advantage ovcr other companies.

3 CA W-07-2250 (b) It consists ofsupporting data, incliudhflg lest da'-, relative to a process (or component, structure, tool. method, ee4.), the application of which data secures a competitive economnic advantage,.eg., by optimizalion or improved marketability.

(c) Its use by a competitor would reduce his expenditure of resources or improve his competitive position in the design, manufacture, shipment, installation, assurance orquality, or licensing a similar product-(d) R reveals cost or price information, production capacities, budget levels, or conmerc ia. strategics or Westinghouse, ius customers or suppliers.

(e) ft reveaals aspects of past, present, or future Westinghouse or customer funded development plans and programs of potential commercial value to Westinghouse.

(f) It contains pateniable idea,;. Fbr which paent protection may be desirable.

There are sound policy reasons behind the Westinghouse system which include the folblowing:

(a) The use of'such information by Westinghouse gives Westinghouse a. competitive advantage over its competitors. It is, therefbre, withheld from disclosure to protect the Westinghouse competitive position.

(b) It is information that is marketable in many ways. The extent to which such information is available to competitors diminishes the Westinghouse ability to sell products and services involvi.ng the use of the infbrnation.

(c) Use by our competitor would put We-stinghouse at a coinmetitive disadvantage by reducing his expenditilre of resources al our expense.

(d) Each componrent of proprietary information pertinent to a particular competitive advantage is potentially as valuable as the total competitive advantage. if competitors acquire components of proprietary intbrmation, any one component

4 CAW-07-2250 may be the key to the erntire puzzle, [hereby depriving Westinghouse of a competitive advantage.

(e) Unrestricled disclosure would jeopardize the position of prominence o1f Westinghouse in the world market, and thereby give a market advantage to the competition of those countries.

(Q) The Westinghouse capacity to invest corporate assets in research and development depends upon the success in obtaining and maintaiining a competitive advantage.

(iii) The information is being transmitted to the Commission in confidence and, under the provisions of 10 CFR Section 2.390, it is to be received in confidence by the Comm ission.

(iv) The information sought to be protected is not available in public sources or availablc information has not been previously employed in the saone original manner or method to the best of our knowledge and belief.

(v) The proprictury information sought to be withheld in this submittal is thamt which is appropriately marked in LTM-CDME-07-39 P-Attachment, "Response to NRC Dr)aft Requ est for Additional Information on Steam Generator Alternate Repair Criteria ( 17 Inch Inspection Distance) for J.B. Robinson Unit 2," dated February 26, 2007 (Proprietary), for submittal to the Commission, being transmitted by Progress Energy Application Tor Withholding Proprietary Information from Public Disclosure to the Document Control Desk. The proprietary information as submitted for use by Westinghouse for FIB. Robinson Unit 2 is expected to be applicable to other licensee submittals in support of implementing a limited inspection of the t.ub joint within the tubcshect region of the steam generators and is provided in response to a NRC request for additional inforniation on WCAP-1 6627-P, "Stealn Generator Alternate Repair Criteria for Tube Portion Within the'P ubesheet at l+1B. Robinson Unit 2," dated August 2006.

This information is part. of that which will enable Westinghouse to:

5 CAW-07-2254)

(a) Provide document-ation of the anal)ý.ses, inethods. and testing for the irnpleientation of an alternate repair criteria for the portion if the tubes within the tubesheet of the

.LEIt. Robinson Unit 2 steam ingenerators.

(b) As*ist the customers in the licensinj and NRC appnrval of the Technical Specification changes associated with the alternate repair criteria.

Further this information has substantial commercial value as follows:

(a) Westinghouse plans to sell the use of similar information to its customers for the purposes of meeting NR.C requirements for licensing documentation.

(it) Westinghouse can sell support and detknse of the technology, to its customers in the licensing process, Public disclosure of this proprietary intfrmation is likely to cause substantial harm to the comnpetitive position of Westinghouse because it would enhance the ability of compe,titors to provide similar calculation, evaluation and licensing defense services for coIMnercial power reactors without comnmiensurate expenses. Also, public disclosure of Ihe information would enable others to use the information to tnee NRC requirements for licensiig documentation without purchasing the right to use the information.

The development of the technology described in part by the inlbrmation is the result of applying the results of many years of experience in an intensive Westinghouse effort and the expenditure of a considerable sum of money.

In order for competitors of Westintghousc to duplicate this information, similar technical programs would have to be pcr-ltrmed and a signiticant manpower effort, having the requisite talent and experience, would have to be expended.

Further the deponent sayeth not.