ML13308A387

Calvert Cliffs, Units 1 and 2, Application for Technical Specification Improvement to Adopt TSTF-510-A, Revision 2, Revision to Steam Generator Program Inspection Frequencies and Tube Sample Selection.

ML13308A387
Person / Time
Site:	Calvert Cliffs
Issue date:	10/31/2013
From:	Gellrich G H Calvert Cliffs, Constellation Energy Group, EDF Group
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
Download: ML13308A387 (21)

Text

George H. Gellrich Calvert Cliffs Nuclear Power Plant, LLCSite Vice President 1650 Calvert Cliffs ParkwayLusby, Maryland 20657410.495.5200 410.495.3500 FaxCENG.a joint venture of0 Constellaion Enemy* 64FeDFCALVERT CLIFFSNUCLEAR POWER PLANTOctober 31, 2013U. S. Nuclear Regulatory Commission Washington, DC 20555ATTENTION:

Document Control Desk

SUBJECT:

Calvert Cliffs Nuclear Power PlantUnit Nos. 1 & 2; Docket Nos. 50-317 & 50-318Application for Technical Specification Improvement to Adopt TSTF-510-A, Revision 2, "Revision to Steam Generator Program Inspection Frequencies andTube Sample Selection" In accordance with 10 CFR 50.90, Calvert Cliffs Nuclear Power Plant, LLC is submitting a request for anamendment to the Technical Specifications for Calvert Cliffs Nuclear Power Plant (Calvert Cliffs) Units Iand 2. The proposed amendment would modify the Technical Specification requirements regarding steamgenerator tube inspections and reporting as described in Technical Specification Task Force(TSTF)-510-A, Revision 2, "Revision to Steam Generator Program Inspection Frequencies and TubeSample Selection."

The changes are consistent with Nuclear Regulatory Commission-approved industry TSTF StandardTechnical Specification Change Traveler, TSTF-5 10-A, Revision

2. The availability of this Technical Specification improvement was announced in the Federal Register on October 27, 2011 (76 FR 66763) aspart of the consolidated line item improvement process.Attachment (1) provides a description and assessment of the proposed changes.

Attachment (2) providesthe existing Technical Specification pages marked up to show the proposed changes.

Attachment (3)provides the existing Technical Specification Bases pages marked up to show the proposed changes.Calvert Cliffs Nuclear Power Plant requests approval of the proposed license amendment by October 31,2014 with the amendment being implemented within 60 days.In accordance with 10 CFR 50.91, a copy of this application, with attachments, is being provided to thedesignated Maryland Official.

There are no regulatory commitments contained in this letter.

Document Control DeskOctober 31, 2013Page 2Should you have questions regarding this matter, please contact Mr. Douglas E. Lauver at(410) 495-5219.

I declare under penalty of perjury that the foregoing is true and correct.

Executed on October 31, 2013.Very truly yours,GHG/PSF/bjd Attachments:

(1)(2)(3)Description and Assessment of Proposed ChangesMarked up Technical Specification PagesMarked up Technical Specification Bases Pagescc: N. S. Morgan, NRCW. M. Dean, NRCResident Inspector, NRCS. Gray, DNR ATTACHMENT (1)DESCRIPTION AND ASSESSMENT OF PROPOSED CHANGESTABLE OF CONTENTS1.0 DESCRIPTION

2.0 ASSESSMENT

3.0 REGULATORY ANALYSIS4.0 ENVIRONMENTAL EVALUATION

5.0 REFERENCES

Calvert Cliffs Nuclear Power Plant, LLCOctober 31, 2013 ATTACHMENT (1)DESCRIPTION AND ASSESSMENT OF PROPOSED CHANGES1.0 DESCRIPTION This letter is a request for an amendment to Renewed Operating Licenses DPR-53 and DPR-69 forCalvert Cliffs Nuclear Power Plant (Calvert Cliffs),

Unit Nos. 1 and 2. The proposed change revisesTechnical Specification (TS) 5.5.9, "Steam Generator (SG) Program,"

and TS 5.6.9, "Steam Generator Tube Inspection Report."

The proposed changes are needed to address implementation issues associated with the inspection

periods, and address other administrative changes and clarifications.

For consistency, additional administrative changes are being made to TS 3.4.18, "Steam Generator (SG) Tube Integrity."

This change is consistent with Technical Specification Task Force (TSTF) change traveler TSTF-5 10-A,Revision 2, "Revision to Steam Generator Program Inspection Frequencies and Tube Sample Selection."

The availability of this TS improvement was announced in the Federal Register on October 27, 2011(76 FR 66763) as part of the Consolidated Line Item Improvement Process (CLIIP).2.0 ASSESSMENT 2.1 Applicability of Published Safety Evaluation Calvert Cliffs has reviewed TSTF-5 10-A, Revision 2, "Revision to Steam Generator Program Inspection Frequencies and Tube Sample Selection" and the model safety evaluation dated October 19, 2011(ADAMS Accession No. ML 112101513).

As described in the subsequent paragraphs, Calvert Cliffs hasconcluded that the justifications presented in TSTF-5 10-A, Revision 2 and the model safety evaluation prepared by the Nuclear Regulatory Commission (NRC) staff are applicable to Calvert Cliffs Unit Nos. 1and 2 and justify this amendment for the incorporation of the changes to the Calvert Cliffs TSs.2.2 Optional Change and Variations Calvert Cliffs is not proposing any technical variations or deviations from the TS changes described inTSTF-510-A, Revision 2 or the applicable parts of the NRC staffs model safety evaluation datedOctober 19, 2011. However, Calvert Cliffs is proposing the following administrative variations.

1. The proposed change corrects an administrative inconsistency in TSTF-510-A, Revision 2,paragraph d.2 of TS 5.6.9, "Steam Generator Tube Inspection Report."

In Section 2.0, "Proposed Change,"

TSTF-5 10-A, Revision 2, states that references to "tube repair criteria" in Paragraph dare revised to "tube plugging

[or repair] criteria."

However, in the following sentence in Paragraph d.2, this change was inadvertently omitted (see below)."If a degradation assessment indicates the potential for a type of degradation to occur at a locationnot previously inspected with a technique capable of detecting this type of degradation at thislocation and that may satisfy the applicable tube repair criteria, the minimum number of locations inspected with such a capable inspection technique during the remainder of the inspection periodmay be prorated" (emphasis added).The underlined phrase should state "tube plugging

[or repair] criteria" consistent with the otherchanges made in TSTF-510-A, Revision

2. Calvert Cliffs does not have approved tube repaircriteria.

Therefore, Calvert Cliffs is revising the phrase to "tube plugging criteria."

This change isadministrative and should not result in this application being removed from the Consolidated LineItem Improvement Process.This administrative error was identified in a February 2012 NRC/TSTF meeting and documented inReference

1. The NRC accepted the error resolution in Reference 2.I ATTACHMENT (1)DESCRIPTION AND ASSESSMENT OF PROPOSED CHANGES2. Calvert Cliffs uses different numbering than the Improved Standard Technical Specifications inone instance.

The Steam Generator Tube Inspection Report is TS 5.6.9 in the Calvert Cliffs TS. Itis numbered TS 5.6.6 in the Improved Standard Technical Specifications.

This change isadministrative and should not result in this application being removed from the Consolidated LineItem Improvement Process.3.0 REGULATORY ANALYSIS3.1 No Significant Hazards Consideration Calvert Cliffs Nuclear Power Plant Unit Nos. 1 and 2 requests adoption of an approved change to thestandard technical specifications into the plant specific Technical Specifications (TSs), to revise TS 5.5.9,"Steam Generator Program",

TS 5.6.9, "Steam Generator Tube Inspection Report",

and TS 3.4.18,"Steam Generator (SG) Tube Integrity" to address inspection periods and other administrative changesand clarifications.

This proposed change has been evaluated against the standards in 10 CFR 50.92 and has been determined to involve no significant hazards considerations, in that operation of the facility in accordance with theproposed amendment would not:1. Involve a significant increase in the probability or consequences of an accident previously evaluated; orNo.The proposed change revises the Steam Generator (SG) Program to modify the frequency ofverification of SG tube integrity and SG tube sample selection.

A steam generator tube rupture event(SGTR) is one of the design basis accidents that are analyzed as part of a plant's licensing basis. Theproposed SG tube inspection frequency and sample selection criteria will continue to ensure that theSG tubes are inspected such that the probability of a SGTR is not increased.

The consequences of aSGTR are bounded by the conservative assumptions in the design basis accident analysis.

Theproposed change will not cause the consequences of a SGTR to exceed these assumptions.

Therefore, operation of the facility in accordance with the proposed amendment does not involve asignificant increase in the probability or consequences of an accident previously evaluated.

2. Create the possibility of a new or different type of accident from any accident previously evaluated; orNo.The proposed changes to the SG Program will not introduce any adverse changes to the plant designbasis or postulated accidents resulting from potential tube degradation.

The proposed change doesnot affect the design of the SGs or their method of operation.

In addition, the proposed change doesnot impact any other plant system or component.

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

3. Involve a significant reduction in a margin of safety.No.2 ATTACHMENT (1)DESCRIPTION AND ASSESSMENT OF PROPOSED CHANGESThe SG tubes in pressurized water reactors are an integral part of the reactor coolant pressureboundary and, as such, are relied upon to maintain the primary system's pressure and inventory.

Aspart of the reactor coolant pressure

boundary, the SG tubes are unique in that they are also reliedupon as a heat transfer surface between the primary and secondary systems such that residual heatcan be removed from the primary system. In addition, the SG tubes also isolate the radioactive fission products in the primary coolant from the secondary system. In summary, the safety functionof a SG is maintained by ensuring the integrity of its tubes.Steam generator tube integrity is a function of the design, environment, and the physical condition ofthe tube. The proposed change does not affect tube design or operating environment.

The proposedchange will continue to require monitoring of the physical condition of the SG tubes such that therewill not be a reduction in the margin of safety compared to the current requirements.

Therefore, the proposed amendment would not involve a significant reduction in a margin of safety.Based on the above, Calvert Cliffs concludes that the proposed amendment does not involve a significant hazards consideration under the standards set forth in 10 CFR 50.92(c) and, accordingly, a finding of "nosignificant hazards consideration" is justified.

4.0 ENVIRONMENTAL EVALUATION The proposed change would change a requirement with respect to installation or use of a facilitycomponent located within the restricted area, as defined in 10 CFR Part 20, and would change aninspection or surveillance requirement.

However, the proposed change does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of anyeffluent that may be released

offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure.

Accordingly, the proposed change meets the eligibility criterion forcategorical exclusion set forth in 10 CFR 51.22(c)(9).

Therefore, pursuant to 10 CFR 51.22 (b), noenvironmental impact statement or environmental assessment need be prepared in conjunction with theproposed change.

5.0 REFERENCES

1. Letter from the Technical Specification Task Force to Document Control Desk (NRC), datedMarch 28, 2012, Correction to TSTF-5 10-A, Revision 2, "Revision to Steam Generator ProgramInspection Frequencies and Tube Sample Selection"

2. Letter from A. J. Mendiola (NRC) to Technical Specification Task Force, dated June 17, 2013,NRC Staff Response to TSTF letter Dated March 28, 2012, Regarding Correction to TSTF-5 10,Revision 2, "Revision to Steam Generator Program Inspection Frequencies and Tube SampleSelection" 3

ATTACHMENT (2)MARKED UP TECHNICAL SPECIFICATION PAGESCalvert Cliffs Nuclear Power Plant, LLCOctober 31, 2013 SG Tube Integrity 3.4.183.4 REACTOR COOLANI SYSTEM (RCS)3.4.1q Steam Generator (SG) Tube Integrity I.CO 3.4.18SG tube integrity shall be maintained.

AND GAll SG tubes satisfying the tubiplugged in accordance with the.criteria shall be)team Generator Program.APPLICABILITY:

MODES 1, 2, 3, and 4.ACT I.ONS---------------------

.-- ...-- ------------. .NOTES -------------------------------------

Separate Condition entry is allowed for each SG tube.CONDITION I REQUIRED ACTION COMPLETION TIMEA. One or more SG tubessatisfyirng the tubecriLeria andrniot plugged inaccordance with theSteam Generator P rog ram.A. 1ANDA.2Verify tube integrity of the affectedtube(s) is maintained until the nextrefueling outage or SGtube inspection.

Plug the affectedtube(s) in accordance with the SteamGenerator Program.7 daysPrior toentering MODE 4following thenext refueling outage or SGtube inspection CALVERI CLIFFS -UNIT ICA[.VERT CLIFFS -UNIT 23.4.18-1Amendment No. 278Amendment No. 255 SG Tube Integrity 3.4.18ACTIONSCONDITION REQUIRED ACTION COMPLETION TIMEB. Required Action and B.1 Be in MODE 3. 6 hour6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />sassociated Completion lime of Condition A ANDnot met.B.2 Be in MODE 5. 36 hour4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />sORSG tube integrity notmaintained.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.18.1 Verify SG tube integrity in accordance with In accordance the Steam Generator Program.

with the SteamGenerator ProgramSR 3.4.18.2 Verify that each ispected SG tube that Prior tosatisfies the tube criteria is entering MODE 4plugged in accordance with the Steam following a SGGenerator Program.

tube inspection Amendment No. 278Amendment No. 255CALVERI CLIFFS -UNII 1CAI.VERT CLIFFS -UNIT 23.4.18-2 Programs and Manuals5.55.5 Programs and Manualsa. Testing frequencies applicable to the ASME Code for Operation and Maintenance of Nuclear Power Plants (ASME OM Code) andapplicable Addenda as follows:ASME OM Code andapplicable Addendaterminology forinservice testingactivities Required Frequencies for performing inservice testing activities WeeklyMonthlyQuarterly or every3 monthsSemiannually orevery 6 monthsEvery 9 monthsYearly or annuallyBiennially or every2 yearsAt least once perAt least once per7 days31 daysAt least once per 92 daysAtAtAtleastleastleastonceonceonceperperper184276366daysdaysdaysAt least once per 731 daysb. The provisions of SR 3.0.2 are applicable to the aboverequired Frequencies and to other normal and accelerated Frequencies specified as 2 years or less in the Inservice Testing Program for performing inservice testing activities;

c. The provisions of SR 3.0.3 are applicable to inservice testing activities; andd. Nothing in the ASME OM Code shall be construed to supersede the requirements of any Technical Specification.

Steam Generator (SG) ProQram5.5.9A Steam Generator Program shall be established and implemented toensure that SG tube integrity is maintained.

In addition, theSteam Generator Program shall include the following CALVERT CLIFFS -UNIT 1CALVERT CLIFFS -UNIT 25.5-7Amendment No. 294Amendment No. 270 Programs and Manuals5.55.5 Programs and Manualsa. 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 inducedleakage.

The "as found" condition refers to the condition ofthe tubing during an SG inspection outage, as determined fromthe inservice inspection results or by other means, prior tothe plugging of tubes. Condition monitoring assessments shall be conducted during each outage during which the SGtubes are inspected or plugged to confirm that theperformance criteria are being met.b. Performance criteria for SG tube integrity.

Steam generator tube integrity shall be maintained by meeting the performance criteria for tube structural integrity, accident inducedleakage, and operational LEAKAGE.1. Structural integrity performance criterion:

All in-service steam generator tubes shall retain structural integrity over the full range of normal operating conditions (including

startup, ion in the powerrange, hot standby, and cool d n all antici atedtransients included in the design specificati

_ nddesign basis accidents.

This includes retaining asafety factor of 3.0 against burst under normal steady-state full power operation primary-to-secondary pressuredifferential and a safety factor of 1.4 against burstapplied to the design basis accident primary-to-secondary pressure differentials.

Apart from the aboverequirements, additional loading conditions associated with the design basis accidents, or combination ofaccidents in accordance with the design and licensing basis, shall also be evaluated to determine if theassociated loads contribute significantly to burst orcollapse.

In the assessment of tube integrity, thoseloads that do significantly affect burst or collapseshall be determined and assessed in combination with theloads due to pressure with a safety factor of 1.2 on thecombined primary loads and 1.0 on axial secondary loads.CALVERT CLIFFS -UNIT 1 5.5-8 Amendment No. 278CALVERT CLIFFS -UNIT 2 Amendment No. 255 Programs and Manuals5.55.5 Programs and Manuals2. Accident induced leakage performance criterion:

Theprimary to secondary accident induced leakage rate forany design basis accident, other than a SG tube rupture,shall not exceed the leakage rate assumed in theaccident analysis in terms of total leakage rate for allSGs and leakage rate for an individual SG. Leakage isnot to exceed 100 gpd per SG.3. The operational LEAKAGE performance criterion isspecified in .13 "RCS Operational LEAKAGE."

c. Provisions for SG tube criteria.

Tubes found byinservice inspection to contain flaws with a depth equal toor exceeding 40% of the nominal tube wall thickness shall beplugged.d. Provisions for SG tube inspections.

Periodic SG tubeinspections shall be performed.

The number and portions ofthe tubes inspected and methods of inspection shall beperformed 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 thetube-to-tubesheet weld at the tube inlet to the tube-to-tubesheet weld at the tube outlet, and that may satisfy theapplicable tube criteria.

The tube-to-tubesheet weldis not part of the tube. In addition to meeting therequirements of d.1, d.2, and d.3 below, the inspection scope, inspection

methods, and inspection intervals shall besuch as to ensure that SG tube integrity is maintained untilthe next SG inspection.

A degradatio shallformed to dettermi~nne'-t'he typeand lýdiuo" flaws towhich the tubes may be susceptible and, based on thisassessment, to determine which inspection methods need to beemployed and at what locations.

1. Inspect 100% of the tubes in each SG during t e firstrefueling outage following SGCALVERT CLIFFS -UNIT 1 5.5-9 Amendment No. 278CALVERT CLIFFS -UNIT 2 Amendment No. 255 Insert 5.5.9After the first refueling outage following SG installation, inspect each SG at least every 72 effective fullpower months or at least every third refueling outage (whichever results in more frequent inspections).

Inaddition, the minimum number of tubes inspected at each scheduled inspection shall be the number oftubes in all SGs divided by the number of SG inspection outages scheduled in each inspection period asdefined in a, b, c, and d below. If a degradation assessment indicates the potential for a type ofdegradation to occur at a location not previously inspected with a technique capable of detecting this typeof degradation at this location and that may satisfy the applicable tube plugging

criteria, the minimumnumber of locations inspected with such a capable inspection technique during the remainder of theinspection period may be prorated.

The fraction of locations to be inspected for this potential type ofdegradation at this location at the end of the inspection period shall be no less than the ratio of the numberof times the SG is scheduled to be inspected in the inspection period after the determination that a newform of degradation could potentially be occurring at this location divided by the total number of timesthe SG is schedule to be inspected in the inspection period. Each inspection period defined below may beextended up to 3 effective full power months to include a SG inspection outage in an inspection periodand the subsequent inspection period begins at the conclusion of the included SG inspection outage.a) After the first refueling outage following SG installation, inspect 100% of the tubes during thenext 144 effective full power months. This constitutes the first inspection period;b) During the next 120 effective full power months, inspect 100 % of the tubes. This constitutes thesecond inspection period;c) During the next 96 effective full power months, inspection 100% of the tubes. This constitutes the third inspection period; andd) During the remaining life of the SGs, inspection 100% of the tubes every 72 effective full powermonths. This constitutes the fourth and subsequent inspection periods.

Programs and Manuals5.55.5 Programs and Manuals,m n t s T h eJ J ----f s --m -e n i a /l O p e i o s a lthee t5bs 4 the_ri e lirg tehtagn 72a e3. If crack indications are found in any SG tube, then thenext inspection for each SG for the degradation

, ,cl o 7A mechanism that caused the crack indication shall notob,. /exceed 24 effective full power months or one refueling CL-Ce_ Jouta ge (whichever

• i- !s-4ee ). If definitive information, fsuch as fromeaination of a pulled tube, diansir ,~1-[¥ 'r, o q_ u , non-destructive testing , or engineering evaluation x x ._ w , v e , n d i c a t e s t h a t a c r a c k -l i k e i n d i c a t i o n i s n o t a s s o c i a t e d~with a crack(s),

then the indication need not be treatedas a crack.e. Provisions for monitoring operational primary to secondary LEAKAGE.5.5.10 Secondary Water Chemistr~y ProciramThis program provides controls for monitoring secondary waterchemistry to inhibit steam generator tube degradation and lowpressure turbine disc stress corrosion cracking.

The programshall include:a. Identification of a sampling schedule for the criticalvariables and control points for these variables;

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

c. Identification of process sampling points which shall includemonitoring the discharge of the condensate pumps for evidenceof condenser in leakage;CALVERT CLIFFS -UNIT 1 5.5-10 Amendment No. 278CALVERT CLIFFS -UNIT 2 Amendment No. 255 Reporting Requirements 5.65.6 Reporting Requirements

a. The sceof inspections performed on each SG,b. gradation mechanisms found,c. Nondestructive examination techniques utilized for eachdegradation mechanism,

d. Location, orientation (if linear),

and measured sizes (ifavailable) of service induced indications,

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

g. The resuls o condition monitoring, inc uding the results oftube pulls and in-situ testing,CALVERT CLIFFS -UNIT 1CALVERT CLIFFS -UNIT 25.6-7Amendment No. 297Amendment No. 273 ATTACHMENT (3)MARKED UP TECHNICAL SPECIFICATION BASES PAGESCalvert Cliffs Nuclear Power Plant, LLCOctober 31, 2013 SG Tube Integrity B 3.4.18BASESLCO The LCO requires that SG tube integrity be maintainnee eLCO also requires that all SG tubes that satisfy the criteria be plugged in accordance with the Steam Generator During SG inspection, any inspected tube that satisfies the Ste m Generator Program criteria is removed fromservic by plugging.

If a tube was determined to satisfythe criteria but was not plugged, the tube may stillhave tube integrity.

In the context of this Specification, a SG tube is definedas the entire length of the tube, including the tube wall,between the tube-to-tubesheet weld at the tube inlet and thetube-to-tubesheet weld at the tube outlet. The tube-to-tubesheet weld is not considered part of the tube.A SG tube has tube integrity when it satisfies the SGperformance criteria.

The SG performance criteria aredefined in Specification 5.5.9, and describe acceptable SGtube performance.

The Steam Generator Program also providesthe evaluation process for determining conformance with theSG performance criteria.

There are three SG performance criteria:

structural integrity, accident induced leakage, and operational LEAKAGE.

Failure to meet any one of these criteria isconsidered failure to meet the LCO.The structural integrity performance criterion provides amargin of safety against tube burst or collapse under normaland accident conditions, and ensures structural integrity ofthe SG tubes under all anticipated transients included inthe design specification.

Tube burst is defined as, "Thegross structural failure of the tube wall. The condition typically corresponds to an unstable opening displacement (e.g., opening area increased in response to constantpressure) accompanied by ductile (plastic) tearing of thetube material at the ends of the degradation."

Tubecollapse is defined as, "For the load displacement curve fora given structure, collapse occurs at the top of the loadversus displacement curve where the slope of the curvebecomes zero." The structural integrity performance CALVERT CLIFFS -UNITS 1 & 2B 3.4.18-3Revision 41 SG Tube Integrity B 3.4.18BASESa main steam line break. If this amount of LEAKAGE is dueto more than one crack, the cracks are very small, and theabove assumption is conservative.

APPLICABILITY Steam generator tube integrity is challenged when thepressure differential across the tubes is large. Largedifferential pressures across SG tubes can only beexperienced in MODE 1, 2, 3, or 4.Reactor Coolant System conditions are far less challenging in MODES 5 and 6 than during MODES 1, 2, 3, and 4. InMODES 5 and 6, primary to secondary differential pressure islow, resulting in lower stresses and reduced potential forLEAKAGE.ACTIONS The ACTIONS are modified by a Note clarifying that theConditions may be entered independently for each SG tube.This is acceptable because the Required Actions provideappropriate compensatory actions for each affected SG tube.Complying with the Required Actions may allow for continued operation, and subsequent affected SG tubes are governed bysubsequent Condition entry and application of associated Required Actions.A.1 and A.2Condition A applies if it is discovered that one or more SGtubes examined in an inservice inspection satisfy the tubecriteria but were not plugged in accordance with theSteam Generator Program as required by SR 3.4.18.2.

Anevaluation of SG tube integrity of the affected tube(s) mustV- .c be made. Steam generator tube integrity is based on meetinghe SG performance criteria described in the Steam Generator Program.

T e S rGcriteria define limits on SG tubedegradation that allow for flaw growth between inspections while still providing assurance that the SG performance criteria will continue to be met. In order to determine ifa SG tube that should have been plugged has tube integrity, an evaluation must be completed that demonstrates that theSG performance criteria will continue to be met until thenext refueling outage or SG tube inspection.

The tubeintegrity determination is based on the estimated condition of the tube at the time the situation is discovered and theestimated growth of the degradation prior to the next SGCALVERT CLIFFS -UNITS 1 & 2B 3.4.18-5Revision 41 SG Tube Integrity B 3.4.18BASESis to ensure that the SG performance criteria have been metfor the previous operating period.The Steam Generator Program determine e scope of theinspection and the methods used to de rmine whether thetubes contain flaws satisfying the tube C criteria.

Inspection scope (i.e., which tubes or areas of tubingwithin the SG are to be inspected) is a function of existingand potential degradation locations.

The Steam Generator Program also specifies the inspection methods to be used tofind potential degradation.

Inspection methods are afunction of degradation morphology, non-destructive examination technique capabilities, and inspection locations.

The Steam Generator Program defines the Frequency

.ofSR 3.4.18.1.

The Frequency is determined by the operational assessment and other limits in the SG examination guidelines (Reference 6). The Steam Generator Program uses information on existing degradation and growth rates to determine aninspection Frequency that provides reasonable assurance thatthe tubing will meet the SG performance criteria at the nextscheduled inspection.

In addition, Specification 5.5.9contains prescriptive requirements concerning inspection intervals to provide added assurance that the SG performance criteria will be met between scheduled inspections.

SR 3.4.18.2During an SG inspection, any inspected tube that satisfies the Steam Generator Program criteria is removed fromservice by plugging.

The tube criteria delineated inV\35 Specification 5.5.9 are intended to ensure that tubes for continued service satisfy the SG performance criteria with allowance for error in the flaw size and for future flaw growth. In addition, thetube-j.e~ptt-r

criteria, in conjunction with other elements ofthe Steam Generator

Program, ensure that the SG performance criteria will continue to be met util the next inspection ofthe subject tube(s).

Reference 1 provides guidance forperforming operational assessment to verify that the tubesremaining in service will continue to meet the SGperformance criteria.

CALVERT CLIFFS -UNITS 1 & 2B 3.4. 18-7Revision 41 Insert B 3.4.18If crack indications are found in any SG tube, the maximum inspection interval for all affected andpotentially affected SGs is restricted by Specification 5.5.9 until subsequent inspections supportextending the inspection interval.

SG Tube Integrity BASESB 3.4.18The Frequency of prior to MODE 4 following a SGinspection ensures that the uvillance has been completed and all tubes meeting the<;;criteria are plugged priorto subjecting the SG tubes to significant primary tosecondary pressure differential.

REFERENCES

1. NEI 97-06, Steam Generator Program Guidelines

2. 10 CFR Part 50, Appendix A, GDC 193. 10 CFR 50.674. ASME Boiler and Pressure Vessel Code,Section III,Subsection NB5. Draft Regulatory Guide 1.121, Basis for PluggingDegraded Steam Generator Tubes, August 19766. EPRI, Pressurized Water Reactor Steam Generator Examination Guidelines

7. Regulatory Guide 1.183, Alternative Radiological SourceTerms for Evaluating Design Basis Accidents at NuclearPower Reactors, July 2000CALVERT CLIFFS -UNITS 1 & 2B 3.4. 18-8Revision 41