ML24130A203

Proposed License Amendment Request Application to Revise Technical Specifications to Adopt TSTF-577, Revised Frequencies for Steam Generator Tube Inspections Supplemental Information

ML24130A203
Person / Time
Site:	Surry
Issue date:	05/09/2024
From:	James Holloway Virginia Electric & Power Co (VEPCO)
To:	Office of Nuclear Reactor Regulation, Document Control Desk
References
24-001A
Download: ML24130A203 (1)

Text

May 9, 2024 VIRGINIA ELECTRIC AND POWER COMPANY RICHMOND, VIRGINIA 23261 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555-0001 VIRGINIA ELECTRIC AND POWER COMPANY SURRY POWER STATION UNITS 1 AND 2 PROPOSED LICENSE AMENDMENT REQUEST 10 CFR 50.90 Serial No.:

24-001A NRA/GDM:

RO Docket Nos.:

50-280 50-281 License Nos.: DPR-32 DPR-37 APPLICATION TO REVISE TECHNICAL SPECIFICATIONS TO ADOPT TSTF-577, "REVISED FREQUENCIES FOR STEAM GENERA TOR TUBE INSPECTIONS" SUPPLEMENTAL INFORMATION By letter dated February 19, 2024 (ADAMS Accession No. ML24051A178), Virginia Electric and Power Company (Dominion Energy Virginia) submitted a request for an amendment to the Technical Specifications (TS) for Surry Power Station (SPS) Units 1 and 2 to adopt TSTF-577, "Revised Frequencies for Steam Generator Tube Inspections,"

which is an NRG approved change to the Standard Technical Specifications (STS).

Subsequent to the submittal, a clarification call was held with the NRG on April 19, 2024 to discuss the proposed SPS TS changes. Specifically, the NRG reviewer noted there were two proposed changes included in TSTF-577 for plants that have steam generators (SGs) with Alloy 600 Thermally Treated (TT) tubes that had not been included in the SPS License Amendment Request (LAR). The two administrative changes replace redundant plant specific TS wording associated with alternate tube plugging/repair criteria with more general wording. The intent of these two changes is to preclude repeating the same technical information in several locations in the TS by simply including general references to the previously stated criteria. Since the SPS SGs have Alloy 600TT tubes, those two changes should have been included in the SPS LAR.

At the conclusion of the call, Dominion Energy Virginia agreed to supplement the LAR by providing revised marked-up and typed TS pages that include the two additional TS changes as provided in TSTF-577 for plants with steam generators that have Alloy 600TT tubes. provides the revised, marked-up TS pages to include the two additional TS changes, and Attachment 2 provides the revised (clean) TS pages.

The two administrative TS changes associated with this letter are indicated by double revision bars in the right hand margin of the revised TS pages included in Attachment 2.

Serial No. 24-001A Docket Nos. 50-280/281 Page 2 of 3 Since the two additional TS changes provided in this letter are administrative in nature, they do not affect the conclusions of the no significant hazards consideration determination or the environmental assessment included in the February 19, 2024 LAR.

If you should have any questions regarding this submittal, please contact Mr. Gary D.

Miller at (804) 273-2771.

Respectfully, James E. Holloway Vice President - Nuclear Engineering and Fleet Support Commitments contained in this correspondence: None Attachments: 1. Revised Proposed Technical Specifications Changes (Mark-Up)

2. Revised Technical Specifications (Clean) Pages COMMONWEAL TH OF VIRGINIA

)

)

COUNTY OF HENRICO

)

The foregoing document was acknowledged before me, in and for the County and Commonwealth aforesaid, today by Mr. James E. Holloway, who is Vice President - Nuclear Engineering and Fleet Support, of Virginia Electric and Power Company. He has affirmed before me that he is duly authorized to execute and file the foregoing document in behalf of that company, and that the statements in the document are true to the best of his knowledge and belief.

Acknowledged before me this 9 ~ day of Ma.'{

, 2024.

My Commission Expires:

J<An1Aa*n1 3 \\ 1 -z.o-z.B.

KATHRYN HILL BARRET NOTARY PUBLIC COMMONWEALTH OF VIRGINIA MY COMMISSION EXl'IRES JANUARY 31, 2021 otary Public

cc:

U.S. Nuclear Regulatory Commission - Region II Marquis One Tower 245 Peachtree Center Ave., NE Suite 1200 Atlanta, GA 30303-1257 NRG Senior Resident Inspector Surry Power Station Mr. L. John Klos NRG Project Manager - Surry U.S. Nuclear Regulatory Commission One White Flint North Mail Stop 09 E-3 11555 Rockville Pike Rockville, MD 20852-2738 Mr. G. Edward Miller NRC Senior Project Manager - North Anna U.S. Nuclear Regulatory Commission One White Flint North Mail Stop 09 E-3 11555 Rockville Pike Rockville, MD 20852-2738 State Health Commissioner Virginia Department of Health James Madison Building - 7th floor 109 Governor Street Suite 730 Richmond, VA 23219 Serial No.24-001 A Docket Nos. 50-280/281 Page 3 of 3 Serial No. 24-001A Docket Nos. 50-280/281 REVISED PROPOSED TECHNICAL SPECIFICATIONS CHANGES (MARK-UP)

Virginia Electric and Power Company (Dominion Energy Virginia)

Surry Power Station Units 1 and 2

TS 6.4-11 Q. Steam Generator (SG) Program -

A Sleam GeRefitl&f Program shall be established and implemented to ensure that SG AnSG 4 integrity is maintained. In addition, the St-eam-Geftemtef Program shall include

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~ollowing

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I. Provisions for condition monitoring assessments. Condition monitoring assessment means an evaluation of the "as found" condition of the tubing with respect to the perfonnance 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. Condilion 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.

2. Pedormance 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 LEAK.AGE.

~

a. Structural integrity performance criterion: All in-service ste6ffl geneflltef 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), all anticipated transients included in the design specification, and,r' 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 bur~t 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 colJapse shall be detennined 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.

b. Accident induced leakage perfonnance criterion: The primary to secondary accident induced leakage rate for any design basis accident, other than a SG tube rupture, shall not exceed the ieakage 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 I gpm for all SG.

Amendment Nos. 278, 278

TS 6.4-12

c. The operational LEAKAGE performance criterion is specified in TS 3.1.C and 4.13, "RCS Operational LEAKAGE."

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

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

,I" the 40% depth-based criteria:

a. Tubes with service-induced flaws located greater than 17.89 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 17.89 inches below the top of the tubesheet shall be plugged UJ?On detection.

4. Provisions for SG tube inspections. Periodic SO tube inspections shall be performed. The number and portions o( 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 and that may satisfy the applicable tube ter than 17,g9 inehes belev, the tap ef,V the h1~eskee1 are ex

. The tube-to-tubesheet weld is not part of the tube.

to meeting the requirements of 4.a, 4.b, and 4.c below, the inspection scope mspection methods, and inspection intervals shall be such as to ensure that S be integrity is maintained until the next SG inspection.

A degradation assess ent shall be performed to determine the type and location of,r flaws to which t tubes may be susceptible and, based on this assessment, to determine whic inspection m~thods need to be employed and at what locations.

a. Inspect 00% of the tubes in each SO during the first refueling outage foll

,r' except for any p011ions of the tube that are exempt from inspection by alternate repair criteria, Amendment Nos. 278, 278

INSERT 1 TS 6.4-13 Ailer the fust Jefuelieg outage fellowiag SG installatio~

least C¥ery 48 effective full i,ewer mofl-ths er at leeat 8\\1ery other t=efuelmg oatege (w-hiehever results ie. more ft:eEtUent inspeeHe~ In-additioe, the.,r m:iBmmm eumber of tube&--iBSpeeted at eeeh seheEluled iespeetieB-tJWlil be the lftlfflber of mhes iB ell SGo di*liee<<:l by the aameer of SG i:e:ofeeti0E. outages ieheduletl in eaeh i:w;peet:iea-,erioe es defiaed iB. b.1, h.~, 8:fld b.3 oolew.- If.a legault~tioa asses91BeBt iadieates the poteatiel fer e type e~~ogmclatien to eeeur at a leeeti8fl Bet preYie tiag this ype ef degi=edatiea et this leeeti:oe Oft6 that may satisfy _the OJ'IH:ieable tub&

Jhiggie.g eriter-ia, the miBimum ~

er ef leeatieaB mspeeteEi with saeh a mpehle mspeetieB teelmique during the remaiBEler of the iespeetieaperiod may

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roted. The fmetiea of loeetiOBS to be iBBpeetee-fe~

legffteali0B et this loeatioB at the eBQ of the ie:Speetiea-peried shall,be no-less Bftft the fftbe ef the BUBlber ef times the SG is sebeduled to he ieopeetcd-in-th&

mpeetion-peFioel after the-determinetieB that o BOW ferm of degmeatiOR eollk!

~eteooelly be eeeurriBg et this leeotion divieed by th&-tetal-B~

~o~ iespeeted ill the lllBf)eetie& i,erioa Eaeh iuspeetioa peFioEl iefmed-bclew may be eMeftded ut> te ~ fieetwe full power moati.to iBelade a

~G iB&peetioB etttege ia an mspeetioa peried &Bel the !RH>sequeet iBspeetioB

?erioEl hegins et the-e&.&elusioe of the ieeludee SG isspeetien &l:rtage.

I. Mer the fifst refeeliag outage folle'V'triBg SG iestellatiea, iaspeet lOOIVe-4 the tub~ duriug the ll8!Et 120 effeetir,e full Jlow<< moaths. This eeBStitutes

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me lll'SI H1Speef:ieft pmou;

2. ])ering tlre B83Et 96 effeetir;e full pewer meaths, HHJIJSet 100% of the ftl&e8:

'£ms eenstitu~ee theseeoed iBspeetiea period; eBEl

3. Dttrmg the-rem&iBiag life ef the SGs, Hllff)eet 100%4 the rubes every 72 effeetive fttH pew*er menths. This eoe5~ihttes the tlffl:d BB~

iaspeetiea perieds-:

• h. approved by Amendment Nos. 299 and 299, the inspection of Surry Unit 2 SOB t may be deferred, on a one-time basis, from the Suny Unit 2 spring 2020 refueling outage (S2R29) to the Suny Unit 2 2021 fall refueling outage (S2R30).

Amendment Nos. 299 eed 299

INSERT 1 Serial No. 24-001A Docket Nos. 50-280/281 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.

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.*

5.

excluding any region that is exempt from inspection by alternate repair criteria, TS 6.4-13a

c.

If crack indications are found in the portions of the SG tube not eKeluded aeo*+'e, then the next inspection for each affected and potentially affected SG for the,r-degradation mechanism that caused the crack indication shall net e*eeea 24 efreeti't'e fell power months or one refueling ou freqtieet iespeetioas). If definitive information pulled tube, diagnostic non-destructive ting, or engineering evalua

• n indicates that a crack-like indication is ot associated with a crack(s), then the be at the next onal primary to secondary LEAKAGE.

but may be defe1Ted to the following refueling outage if the I 00% inspection of all SGs was perfmmed with enhanced probes as described in paragraph 6.4.Q.4.b.

Amendment Nos. 278, 278

TS 6.6-3

b. Deleted

3. Stearn Generator Tube Inspection Report A report shall be submitted within 180 days after Tavg exceeds 200°F following completion of an inspection performed in accordance with the Specification 6.4.Q, Steam Generator (SG) Program. The report shall include:

a. The scope of inspections performed on each SG,

a. Degffl811:tioft m:eehaftisms fauml,

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e. Noneestraetive e*IHHiaation teehntques utili"ted fOf eaeh aegradatioH mechanism,

a. LoeaaOH, arieHhtlioH (if liHelif), ttHd measttred siEes (if ft',11ttl11:ble) 5f serYiee iBdtteed iHdieatio~,

e. NtuHber of tttbes plugged duriH:g the inspeetioa outage f& eaeh aegradatioft meelum-ism,

f.

The nttmber 11:H:d pereeatage of tubes plugged ta aate, aHd the effeetive pluggiBg perecfltage iH eaek steftffl geftereter.

g. The results of eoHclitioR moHitariRg, ineluding the resttlts of tl:lBe pttlls ftftd ift site tesliBg, 11ft:

ltl-1 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 which is the subject of the report, i Amendment Nos. 295, 295

INSERT 2 Serial No. 24-001A Docket Nos. 50-280/281

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;

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TS6.6-3a The cakulamd accident jnduced LBAKAOE nte from the portion of lhe tubes,,(

below 17.89 jncbes from the top of the tube.sheet for the most limiting accident In the most limiting SO. In addition, If lhe calculated accident induced LBAKAOB rate from the most limiting accident ~s less than 1.80 times the maximum operational primary to secondary LEAKAGE rate, the report should

• dcscn'be bow it was determined;-~

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[}---=it-The results of the monitoring for tube axial displacement (slippage). If slippage,f is discovered, the implications of the discovery and correctJve acdon shall be provided.

Amendment Nos. 278 1 278 Serial No. 24-001A Docket Nos. 50-280/281 REVISED TECHNICAL SPECIFICATIONS (CLEAN) PAGES Virginia Electric and Power Company (Dominion Energy Virginia)

Surry Power Station Units 1 and 2

TS6.4-11 Q. 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:

1. 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.

2. 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.

a. 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),

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. Apa11 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.

b. 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 I gpm for all SG.

Amendment Nos.

TS 6.4-12

c. The operational LEAKAGE performance criterion is specified in TS 3.1.C and 4.13, "RCS Operational LEAKAGE."

3. 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 may be applied as an alternative to the 40% depth-based criteria:

a. Tubes with service-induced flaws located greater than 17.89 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 17.89 inches below the top of the tubesheet shall be plugged upon detection.

4. 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 4.a, 4.b, and 4.c 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.

a. Inspect I 00% of the tubes in each SG during the first refueling outage following SG installation.

Amendment Nos.

TS 6.4-13

b.

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. 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.*

c.

If crack indications are found in the portions of the 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 6.4.Q.4.b. 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.

5. Provisions for monitoring operational primary to secondary LEAKAGE.

As approved by Amendment Nos. 299 and 299, the inspection of Surry Unit 2 SG B may be deferred, on a one-time basis, from the Surry Unit 2 spring 2020 refueling outage (S2R29) to the Surry Unit 2 2021 fall refueling outage (S2R30).

Amendment Nos.

TS 6.6-3

b. De]eted

3. Steam Generator Tube Inspection Report A report shall be submitted within 180 days after T avg exceeds 200°F following completion of an inspection performed in accordance with the Specification 6.4.Q, 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 availab]e ), 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) re]ative 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; Amendment Nos.

TS 6.6-3a

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 which is the subject of the report;

h. The calculated accident induced LEAKAGE rate from the portion of the tubes below 17.89 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 1.80 times the maximum operational primary to secondary LEAKAGE rate, the report should describe how it was determined; and

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

Amendment Nos.