RS-06-140, Response to Request for Additional Information to Support NRC Approval of a License Amendment Related to Technical Specification 5.5.9, Steam Generator (SG) Tube Surveillance Program, for Use During the Unit 2 Refueling..

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Response to Request for Additional Information to Support NRC Approval of a License Amendment Related to Technical Specification 5.5.9, Steam Generator (SG) Tube Surveillance Program, for Use During the Unit 2 Refueling..
ML062710559
Person / Time
Site: Braidwood  Constellation icon.png
Issue date: 09/28/2006
From: Benyak D
Exelon Generation Co, Exelon Nuclear
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
RS-06-140
Download: ML062710559 (16)
v • d • e


Text

10 CFR 50-90 RS-06-140 September 28, 2006 U . S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001 Braidwood Station, Units 1 and 2 Facility Operating License Nos. NPF-72 and NPF-77 NRC Docket Nos. 50-456 and 50-457

Subject:

Response to Request for Additional Information to Support NRC Approval of a License Amendment Related to Technical Specification 5 .5 .9, "Steam Generator (SG) Tube Surveillance Program," for Use During the Unit 2 Refueling Outage 12 and Subsequent Operating Cycle References : (1) Letter from J. A. Bauer (Exelon Generation Company, LLC) to U. S.

NRC, "Application for Technical Specification Improvement Regarding Steam Generator Tube Integrity," dated November 18, 2005 (2) Letter from S. J. Campbell (NRC) to C. M. Crane (Exelon Generation Company, LLC), "Byron Station, Unit Nos. 1 and 2, and Braidwood Station, Unit Nos . 1 and 2 - Request for Additional Information Related to Technical Specification Improvement Regarding Steam Generator Tube Integrity," dated August 4, 2006 Letter from D. M. Benyak (Exelon Generation Company, LLC) to U . S . NRC, "Response to Request for Additional Information Regarding Application for Steam Generator Tube Integrity Technical Specification," dated August 18, 2006 In Reference 1, Exelon Generation Company, LLC (EGC) requested an amendment to Appendix A Technical Specifications (TS), of Facility Operating License Nos . NPF-72, NPF-77, NPF-37, and NPF-66 for Braidwood Station, Units 1 and 2, and Byron Station, Units 1 and 2, respectively . The proposed changes were requested to revise the TS requirements related to steam generator tube integrity. The proposed change was consistent with the NRC-approved Revision 4 to Technical Specification Task Force (TSTF) Standard Technical Specification Change Traveler, TSTF-449, "Steam Generator Tube integrity," with two exceptions . EGC proposed to revise the TSTF-449 version of TS 5.5.9, "Steam Generator (SG) Tube Surveillance Program," to exclude the portion of the tube below 17 inches from the top of the hot leg tubesheet in the Braidwood Station, Unit 2, and Byron Station, Unit 2, steam generators . This proposed

September 28, 2006 U.S. Nuclear Regulatory Commission Page 2 license amendment request, in effect, redefines the Braidwood Station, Unit 2, and Byron Station, Unit 2, primary pressure boundary from the hot leg tube end weld to 17 inches below the top of the hot leg tubesheet This change is supported by Westinghouse Electric Company, LLC, LTR-CDME-05-32, "Limited Inspection of the Steam Generator Tube Portion Within the Tubesheet at Byron 2 and Braidwood 2,"

Revision 2, dated August 2005, which was previously submitted to the NRC in Reference 1 . EGC also proposed to delete Westinghouse laser welded sleeves as a steam generator tube repair method.

In the course of their review, the NRC requested that additional information be provided to support the requested change as documented in Reference 2. EGC provided that information in Reference 3.

On September 20, 2006, a teleconference was held between staff members of EGC and the NRC to discuss the review status of the subject amendment request. All technical issues associated with permanent approval of the "17-inch limited tubesheet inspection criteria" have not been fully resolved ; therefore, EGC is requesting a one-cycle partial approval of the subject amendment request (i .e., Reference 1) to use the "17-inch limited tubesheet inspection criteria," as described above, during the Braidwood Station, Unit 2, Refueling Outage 12 and subsequent operating cycle. Approval of the original license amendment request (i .e., Reference 1) remains pending.

The "17-inch limited tubesheet inspection criteria" for one cycle at Braidwood Station, Unit 2 is fully supported by the information previously submitted in References 1 and 3.

Note that the NRC has previously granted similar amendments, on a one-cycle basis for Braidwood Station, Unit 2, Refueling Outage 11 and subsequent operating cycle, in Amendment 135, dated April 25, 2005 ; and for Byron Station, Unit 2, Refueling Outage 12 and subsequent operating cycle, in Amendment 145, dated September 19, 2005 .

In addition, the following two regulatory commitments are being made :

1 . During Braidwood Station, Unit 2, Refueling Outage 12 and subsequent operating cycle, no steam generator tube sleeves that have a connecting joint below 17 inches from the top of the hot leg tubesheet will be installed.

2. During Braidwood Station, Unit 2, Refueling Outage 12, the 17-inch limited tubesheet inspection sampling scope will be performed in accordance with the requirements contained in Westinghouse letter, LTR-CDME-05-32 . provides a "List of Commitments" which reflects the commitments made above . includes the marked-up TS pages reflecting the one-cycle use of the "17-inch limited tubesheet inspection criteria" for Braidwood Station, Unit 2, Refueling Outage 12 and subsequent operating cycle. A brief description of the changes is given below.

TS 5.5 .9.b.3.ii : An editorial change was made for grammatical correctness .

September 28, 2006 U.S. Nuclear Regulatory Commission Page 3

" TS 5 .1905: Deleted . The 17-inch limited tubesheet inspection sampling scope will be performed in accordance with the requirements contained in Westinghouse letter, LTR-CDME-05-32, as documented in Attachment 1 .

" TS 5.5.9.e .6: The applicable time period for the Unit 2 tubesheet Plugging or Repair Limit acceptance criteria was changed to Refueling Outage 12 and subsequent operating cycle.

" TS 5.5.9.e.8 : The applicable time period for the Unit 2 Tube Inspection acceptance criteria exclusion was changed to Refueling Outage 12 and subsequent operating cycle.

" TS 5 .5.9.e.12 : Deleted . The definitions of "Bulge" and "Overexpansion" are deleted as these terms were used in TS 5.5 .9.b.5, which was deleted as noted above .

Attachment 3 includes the associated typed TS pages .

Please note that the license for Braidwood Station, Unit 1, is affected only due to the fact that Unit 1 and Unit 2 use common Technical Specifications .

The Braidwood Station, Unit 2, Refueling 12 is scheduled to begin in mid-October 2006 ;

therefore, EGC respectfully requests that the one-cycle "17-inch limited tubesheet inspection criteria," be approved by October 15, 2006. The amendment will be implemented prior to entry into Mode 4 upon startup following Refueling Outage 12.

The information provided in this letter does not affect the supporting analysis for the original license amendment request as described in Reference 1 . No other information contained in the Reference 1 letter is affected by this additional information .

The No Significant Hazards Consideration and the Environmental Consideration provided in Attachment 1 of Reference 1 are not affected by this additional information .

In accordance with 10 CFR 50.91(b), "State consultation," EGC is providing the State of Illinois with a copy of this letter and its attachments to the designated State Official .

H you have any questions about this letter, please contact J . A. Bauer at (630) 657-2801 .

I declare under penalty of perjury that the foregoing is true and correct . Executed on the 28th day of September 2006.

Respectfully, Darin M. Benyak Manager - Licensing  : List of Commitments  : Revised Markup of Technical Specifications Pages for Braidwood Station : Revised Typed Technical Specifications Pages for Braidwood Station

ATTACHMENT 1 Response to Request for Additional Information to Support NRC Approval of a License Amendment Related to Technical Specification 5.5.9, "Steam Generator (SG) Tube Surveillance Program,"

for Use During the Braidwood Station, Unit 2, Refueling Outage 12 and Subsequent Operating Cycle List of Commitments The following table identifies commitments made in this document . Any other actions discussed in the submittal represent intended or planned actions. They are described to the NRC for the NRC's information and are not regulatory commitments.

COMMITTED COMMITMENT TYPE COMMITMENT DATE OR ONE-TIME ACTION Programmatic "OUTAGE" (Yes/No) (Yes/No)

During Braidwood Station, Unit 2, Refueling Upon Yes No Outage 12 and the subsequent operating cycle, Implementation no steam generator tube sleeves that have a connecting joint below 17 inches from the top of hot the leg tubesheet will be installed .

During Braidwood Station, Unit 2, Refueling Upon Yes No Outage 12, the 17-inch limited tubesheet Implementation inspection sampling scope will be performed in accordance with the requirements contained in Westingh ouse letter, LTR-CDME-05-32 .

ATTACHMENT 2 BRAIDWOOD STATION UNITS 1 AND 2 Docket Nos. STN 50-456 and STN 50-457 License Nos. NPF-72 and NPF-77 Response to Request for Additional Information to Support NRC Approval of a License Amendment Related to Technical Specification 5.5 .9, "Steam Generator (SG) Tube Surveillance Program,"

for Use During the Braidwood Station, Unit 2, Refueling Outage 12 and Subsequent Operating Cycle Revised Markup of Technical Specifications Pages 5.5-8 5.5-9 5.5-12 5.5-13 51-14

Programs and Manuals 5 .5 5 .5 Programs and Manuals 5 .5 .9 Steam Generator (SG) Tube Surveillance Program (continued)

2. The first sample of tubes selected for each inservice inspection (subsequent to the preservice inspection) of each SG shall include :

All tubes that previously had detectable tube wall penetrations > 20% that have not been plugged or sleeved in the affected area, and all tubes that previously had detectable sleeve wall penetrations that have not been plugged, ii . Tubes in those areas where experience has indicated potential problems, iii . A tube inspection (pursuant to Specification 5 .5 .9 .e .8) shall be performed on each selected tube . If any selected tube does not permit the passage of the eddy current probe for a tube inspection, this shall be recorded and an adjacent tube shall be selected and subjected to a tube inspection ;

3. The tubes selected as the second and third samples (if required by Table 5 .5 .9-2) during each inservice inspection may be subjected to a partial tube inspection provided :

The tubes selected for these samples include the tubes from those areas of the tube sheet array where tubes with imperfections were previously found, and 0 . The inspections include those portions of the tubes where imperfections were previously found ;

BRAIDWOOD - UNITS I & 2 5 .5 - 8 Amendment

Programs and Manuals 5 .5 5 .5 Programs and Manuals 5 .5 .9 Steam Generator (SG) Tube Surveillance Program (continued)

4. A random sample of n 20% of the total number of laser welded sleeves and ~! 20% of the total number of Tungsten Inert Gas (TIG) welded sleeves installed shall be inspected for axial and circumferential indications at the end of each cycle . In the event that an imperfection exceeding the repair limit is detected, an additional 20% of the unsampled sleeves shall be inspected and if an imperfection exceeding the repair limit is detected in the second sample, all remaining sleeves shall be inspected . These inservice inspections will include the entire sleeve, the tube at the heat treated area, and the tube-to-sleeve joints . The inservice inspection for the sleeves is required on all types of sleeves installed in the SGs to demonstrate acceptable structural integrij ,

during R,,-fueling age A. a 201 TAW-,,

s I of all inserv e tubes from thletop ot the hot esf-Pt ~o 17 i hes be] of the t A , al I spected by obe . 'This

,ample - , ill in a 20', ninimu h Ee pci- al ation gJs and ove-~xpans fro,~ the too the iiet leg to ~esheet below he to t .~5(?sheet .

c. tion Results Classification The results of each sample inspection shall be classified into one of the following three categories :

____________________________NOTE-__________________________

Previously degraded tubes or sleeves must exhibit significant (> 10% of wall thickness) further wall penetrations to be included in the percentage calculations .

C~ategory Inspection Results C-1 < 5% of the total tubes inspected are degraded tubes and none of the inspected tubes are defective .

C-2 One or more tubes, but <_ 1% of the total tubes inspected are defective, or ~! 5% and <_ 10% of the total tubes inspected are degraded tubes .

C-3 > 10% of the total tubes inspected are degraded tubes or > 1% of the inspected tubes are defective .

BRAIDWOOD - UNITS 1 & 2 5 .5 - 9 Amendment llws"

Programs and Manuals 5 .5 5 .5 Programs and Manuals 5 .5 .9 Steam Generator (SG) Tube Surveillance Program (continued)

Acceptance Criteria Imperfection means an exception to the dimensions, finish or contour of a tube or sleeve from that required by fabrication drawings or specifications .

Eddy current testing indications < 20% of the nominal tube or sleeve wall thickness, if detectable, may be considered as imperfections ;

2. Degradation means a service induced cracking, wastage, wear or general corrosion occurring on either inside or outside of a tube or sleeve ;

Degraded Tub means a tube or sleeve containing unrepaired imperfections ~! 20% of the nominal tube or sleeve wall thickness caused by degradation ;

4.  % Degradation means the percentage of the tube or sleeve wall thickness affected or removed by degradation ;

Defect means an imperfection of such severity that it exceeds the plugging or repair limit . A tube or sleeve containing an unrepaired defect is defective ;

Plugging or Repair Limit means the imperfection depth at or beyond which the tube shall be removed from service by plugging or repaired by sleeving in the affected area . The plugging or repair limit imperfection depth for the tubing is equal to 40% of the nominal wall thickness . The plugging limit imperfection depth for laser welded sleeves is equal to 38 .7% of the nominal wall thickness . The plugging limit imperfection depth for TIG welded sleeves is equal to 32% of the nominal wall thickness .

For Unit 2 during Refueling Outag6,IJ and the subsequent operating cycle, this definition does not apply to degradation identified in the portion of the tube below 17 inches from the top of the hot leg tubesheet . Degradation found in the portion of the tube below 17 inches from the top of the hot leg tubesheet does not require plugging or repair .

For Unit 2 during Refueling Outage' 1 and the subsequent operating cycle, degradation identified in the portion of the tube from the top of the hot leg tubesheet to 17 inches below the top of the tubesheet shall be plugged or repaired upon detection ;

BRAIDWOOD - UNITS I & 2 5 .5 - 12 Amendment

Programs and Manuals 5 .5 5 .5 Programs and Manuals 5 .5 .9 Steam Generator (SG) Tube Surveillance Program (continued)

7. Unserviceable describes the condition of a tube if it leaks or contains a defect large enough to affect its structural integrity in the event of an OBE, COCA, or a steam line or feedwater line break as specified in Specification 5 .5 .9 .d .4 ;

Tube Inspection means an inspection of the SG tube from the point of entry (hot leg side) completely around the U-bend to the top support of the cold leg .

For a tube that has been repaired by sleeving, the tube inspection shall include the sleeved portion of the tube .

For Unit 2 during Refueling Outage - 0. and the subsequent operating cycle, the portion of the tube below 17 inches from the top of the hot leg tubesheet is excluded ;

Preservice Inspection means an inspection of the full length of each tube in each SG performed by eddy current techniques prior to service to establish a baseline condition of the tubing . This inspection shall be performed prior to initial MODE I operation using the equipment and techniques expected to be used during subsequent inservice inspections ;

10 . Tube Repair refers to a process that reestablishes tube serviceability . Acceptable tube repairs will be performed by the following processes :

i . Laser welded sleeving as described in a Westinghouse Technical Report and subject to the limitations and restrictions as approved by the NRC, or ii . TIG welded sleeving as described in ABB Combustion Engineering Inc ., Technical Reports :

Licensing Report CEN-621-P, Revision 00, "Commonwealth Edison Byron and Braidwood Unit 1 and 2 Steam Generators Tube Repair Using Leak Tight Sleeves, FINAL REPORT," April 1995 ; and licensing Report CEN-627-P, Operating Performance of the ABB CENO Steam Generator Tube Sleeve for Use at Commonwealth Edison Byron and Braidwood Units I and 2," January 1996 ; subject to the limitations and restrictions as noted by the NRC Staff .

BRAIDWOOD - UNITS 1 & 2 5 .5 - 13 Amendment

Programs and Manuals 5 .5 5 .5 Programs and Manuals 5 .5 .9 Steam Generator (SG) Tube Surveillance Program (continued)

Tube repair includes the removal of plugs that were previously installed as a corrective or preventative measure . A tube inspection per Specification 5 .5 .9 .e .8 is required prior to returning previously plugged tubes to service ;

11 . The SG shall be determined OPERABLE after completing the corresponding actions (plug or repair in the affected area all tubes exceeding the plycing or repair limit) required by Table 5 .5 .9-For Unit 2 duriog Refuel ir',,q Oi,tage 11 aiid -ffc-'

,--,ubsequerj, (-,, perat$Qg cycle :

Bulp refers Q a tut diameter deviatidi within the tkev2et of 18 volts o greater as meas~x°-~,d by bobbin coil pilkbe ; and Q ,j oiaxRa n refers ` :o a Jiameter at i on

,within the eet of 1 .5 mils or create as measured b n coil prose .

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 :

Identification of a sampling schedule for the critical variables and control points for these variables ;

b. Identification of the procedures used to measure the values of the critical variables ;

C. Identification of process sampling points, which shall include monitoring the discharge of the condensate pumps for evidence of condenser inleakage ;

d. Procedures for the recording and management of data ;

Procedures defining corrective actions for all off control point chemistry conditions ; and A procedure identifying the authority responsible for the interpretation of the data and the sequence and timing of administrative events, which is required to initiate corrective action .

BRAIDWOOD - UNITS I & 2 5 .5 - 14 Amendment

ATTACHMENT 3 BRAIDWOOD STATION UNITS 1 AND 2 Docket Nos. STN 50-456 and STN 50-457 License Nos. NPF-72 and NPF-77 Response to Request for Additional information to Support NRC Approval of a License Amendment Related to Technical Specification 5.5.9, "Steam Generator (SG) Tube Surveillance Program,"

for Use During the Braidwood Station, Unit 2, Refueling Outage 12 and Subsequent Operating Cycle Revised Typed Technical Specifications Pages 5.5-8 5.5-9 5 .5-112 5 .5-13 5 .5-14

Programs and Manuals 5 .5 5 .5 Programs and Manuals 5 .5 .9 Steam Generator (SG) Tube Surveillance Program (continued)

2. The first sample of tubes selected for each inservice inspection (subsequent to the preservice inspection) of each SG shall include :

All tubes that previously had detectable tube wall penetrations > 20% that have not been plugged or sleeved in the affected area, and all tubes that previously had detectable sleeve wall penetrations that have not been plugged, ii . Tubes in those areas where experience has indicated potential problems, iii . A tube inspection (pursuant to Specification 5 .5 .9 .e .8) shall be performed on each selected tube . If any selected tube does not permit the passage of the eddy current probe for a tube inspection, this shall be recorded and an adjacent tube shall be selected and subjected to a tube inspection ;

3. The tubes selected as the second and third samples (if required by Table 5 .5 .9-2) during each inservice inspection may be subjected to a partial tube inspection provided :

i . The tubes selected for these samples include the tubes from those areas of the tube sheet array where tubes with imperfections were previously found, and The inspections include those portions of the tubes where imperfections were previously found ;

and BRAIDWOOD - UNITS 1 & 2 5 .5 - 8 Amendment xxx

Programs and Manuals 5 .5 5 .5 Programs and Manuals 5 .5 .9 Steam Generator (SG) Tube Surveillance Program (continued)

4. A random sample of >_ 20% of the total number of laser welded sleeves and >_ 20% of the total number of Tungsten Inert Gas (TIG) welded sleeves installed shall be inspected for axial and circumferential indications at the end of each cycle . In the event that an imperfection exceeding the repair limit is detected, an additional 20% of the unsampled sleeves shall be inspected and if an imperfection exceeding the repair limit is detected in the second sample, all remaining sleeves shall be inspected . These inservice inspections will include the entire sleeve, the tube at the heat treated area, and the tube-to-sleeve joints . The inservice inspection for the sleeves is required on all types of sleeves installed in the SGs to demonstrate acceptable structural integrity .
c. Inspection Results Classification The results of each sample inspection shall be classified into one of the following three categories :

NOTE---------------------------

Previously degraded tubes or sleeves must exhibit significant (> 10% of wall thickness) further wall penetrations to be included in the percentage calculations .

Category Inspection Results C-1 < 5% of the total tubes inspected are degraded tubes and none of the inspected tubes are defective .

C-2 One or more tubes, but <_ 1% of the total tubes inspected are defective, or >_ 5% and <_ 10% of the total tubes inspected are degraded tubes .

C-3 > 10% of the total tubes inspected are degraded tubes or > 1% of the inspected tubes are defective .

BRAIDWOOD - UNITS 1 & 2 5 .5 - 9 Amendment xxx

Programs and Manuals 5 .5 5 .5 Programs and Manuals 5 .5 .9 Steam Generator (SG) Tube Surveillance Program (continued)

e. Acceptance Criteria
1. Imperfection means an exception to the dimensions, finish or contour of a tube or sleeve from that required by fabrication drawings or specifications .

Eddy current testing indications < 20% of the nominal tube or sleeve wall thickness, if detectable, may be considered as imperfections ;

2. Degradation means a service induced cracking, wastage wear or general corrosion occurring on either inside or outside of a tube or sleeve ;
3. Degraded Tub means a tube or sleeve containing unrepaired imperfections ! 20% of the nominal tube or sleeve wall thickness caused by degradation ;

% Degradation means the percentage of the tube or sleeve wall thickness affected or removed by degradation ;

5. Defect means an imperfection of such severity that it exceeds the plugging or repair limit . A tube or sleeve containing an unrepaired defect is defective ;

Plugging or Repair Limit means the imperfection depth at or beyond which the tube shall be removed from service by plugging or repaired by sleeving in the affected area . The plugging or repair limit imperfection depth for the tubing is equal to 40% of the nominal wall thickness . The plugging limit imperfection depth for laser welded sleeves is equal to 38 .7% of the nominal wall thickness . The plugging limit imperfection depth for TIG welded sleeves is equal to 32% of the nominal wall thickness .

For Unit 2 during Refueling Outage 12 and the subsequent operating cycle, this definition does not apply to degradation identified in the portion of the tube below 17 inches from the top of the hot leg tubesheet . Degradation found in the portion of the tube below 17 inches from the top of the hot leg tubesheet does not require plugging or repair .

For Unit 2 during Refueling Outage 12 and the subsequent operating cycle, degradation identified in the portion of the tube from the top of the hot leg tubesheet to 17 inches below the top of the tubesheet shall be plugged or repaired upon detection ;

BRAIDWOOD - UNITS 1 & 2 5 .5 - 12 Amendment xxx

Programs and Manuals 5 .5 5 .5 Programs and Manuals 5 .5 .9 Steam Generator (SG) Tube Surveillance Program (continued)

7. Unserviceable describes the condition of a tube if it leaks or contains a defect large enough to affect its structural integrity in the event of an OBE, LOCH, or a steam line or feedwater line break as specified in Specification 5 .5 .9 .4 .4 ;

Tube Inspection means an inspection of the SG tube from the point of entry (hot leg side) completely around the U-bend to the top support of the cold leg .

For a tube that has been repaired by sleeving, the tube inspection shall include the sleeved portion of the tube .

For Unit 2 during Refueling Outage 12 and the subsequent operating cycle, the portion of the tube below 17 inches from the top of the hot leg tubesheet is excluded ;

9. Preservice Inspection means an inspection of the full length of each tube in each SG performed by eddy current techniques prior to service to establish a baseline condition of the tubing . This inspection shall be performed prior to initial MODE I operation using the equipment and techniques expected to be used during subsequent inservice inspections ;

10 . Tube Repair refers to a process that reestablishes tube serviceability . Acceptable tube repairs will be performed by the following processes :

Laser welded sleeving as described in a Westinghouse Technical Report and subject to the limitations and restrictions as approved by the NRC, or ii . TIG welded sleeving as described in ABB Combustion Engineering Inc ., Technical Reports :

Licensing Report CEN-621-P, Revision 00, "Commonwealth Edison Byron and Braidwood Unit 1 and 2 Steam Generators Tube Repair Using Leak Tight Sleeves, FINAL REPORT," April 1995 ; and Licensing Report CEN-627-P, Operating Performance of the ABB CENO Steam Generator Tube Sleeve for Use at Commonwealth Edison Byron and Braidwood Units 1 and 2," January 1996 ; subject to the limitations and restrictions as noted by the NRC Staff .

BRAIDWOOD - UNITS 1 & 2 5 .5 - 13 Amendment xxx

Programs and Manuals 5 .5 5 .5 Programs and Manuals 5 .5 .9 Steam Generator (SG) Tube Surveillance Program (continued)

Tube repair includes the removal of plugs that were previously installed as a corrective or preventative measure . A tube inspection per Specification 5 .5 .9 .e .8 is required prior to returning previously plugged tubes to service ; and 11 . The SG shall be determined OPERABLE after completing the corresponding actions (plug or repair in the affected area all tubes exceeding the plugging or repair limit) required by Table 5 .5 .9-2 .

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 a sampling schedule for the critical variables and control points for these variables ;

Identification of the procedures used to measure the values of the critical variables ;

C. Identification of process sampling points, which shall include monitoring the discharge of the condensate pumps for evidence of condenser inleakage ;

d. Procedures for the recording and management of data ;
e. Procedures defining corrective actions for all off control point chemistry conditions ; and A procedure identifying the authority responsible for the interpretation of the data and the sequence and timing of administrative events, which is required to initiate corrective action .

BRAIDWOOD - UNITS 1 & 2 5 .5 - 14 Amendment xxx

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