ML20206T265
| ML20206T265 | |
| Person / Time | |
|---|---|
| Site: | Arkansas Nuclear  |
| Issue date: | 05/14/1999 |
| From: | ENTERGY OPERATIONS, INC. |
| To: | |
| Shared Package | |
| ML20137P387 | List: |
| References | |
| NUDOCS 9905240105 | |
| Download: ML20206T265 (20) | |
Text
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PROPOSED TECHNICAL SPECIFICATION CHANGES 1
1 9905240105 990514 PDR ADOCK 05000313 P
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Th3 first eksplo in2psetien during acch inscrvica in p2ction (subsequent to the baseline inspection) of each steam generator shall include:
1.
All nonplugged tubes that previously had detectable wall penetrations (>20%), except tubes in which the wall penetration has been spanned by a sleeve, and 2.
At least 50% of the tubes inspected shall be in those areas where experience has indicated potential problems, except where specific groups are inspected per Specification 4.18.3.a.3.
A tube inspection (pursuant-to Specification 4.18.5.a.9) 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.
Tubes in the following groups may be excluded from the first random sample if all tubes in a group in both steam generators are inspected. The inspection may be concentrated on those portions of the tubes where imperfections were previously found. No credit will be taken for these tubes in meeting minimum sample size requirements. Where only a portion of the tube is inspected, the remainder of the tube will be subjected to the random inspection.
(1)
Group A-1:
Tubes within one, two or three rows of the open inspection lane.
(2)
Group A-2: Unplugged tubes with sleeves installed.
(3)
Group A-3: Tubes in the wedge-shaped group on either side of the lane region (Group A-1) as defined by Figure 4.18.1.
4.
Implementation of the upper tubesheet ODIGA alternate repair criteria requires a 100% bobbin coil inspection of the non-plugged and non-sleeved tubes, spanning the defined region of the upper tubesheet, during all subsequent SG inspection intervals pursuant to 4.18.4. The results of this examination may be excluded from the first random sample. The defined region begins one inch above the upper tubesheet secondary face and ends at the nearest tube roll transition. ODIGA indications detected by the bobbin coil probe shall be characterized using rotating coil probes in j
accordance with topical report BAN-10235P, Revision O.
b.
All tubes which have been repaired using the reroll process will have the new roll area inspected during the inservice inspection.
c.
The second and third sample inspections during each inservice inspection as required by Table 4.18-2 may be less than a full tube inspection by concentrating the inspection on those areas of the tube sheet array and on those portions of the tubes where tubes with imperfections were previously found, i
Amendment No. 34,M,M,M6 110j1
I Ths rsoulto of coch camplo insp2ctien chall ba clacoified into one of the following three categories:
Category Inspection Results C-1 Less than 5% of the total tubes inspected are degraded tubes and none of the inspected tubes are defective.
C-2 One or more tubes, but not more than 1% of the total tubes inspected, are defective, or between 5% and 10% of the total tubes inspected are degraded tubes.
C-3 More than 10% of the total tubes inspected are degraded tubes or more than 1% of the inspected tubes are defective.
NOTES:
(1)
In all inspections, except as specified in 4.18.3.c,
~
previously degraded tubes whose degradations have not been spanned by a sleeve must exhibit significant (>10%) further wall penetrations to be included in the above percentage calculations.
(2)
Where special inspections are performed pursuant to 4.18.3.a.3, defective or degraded tubes found as a result of the inspection shall be included in determining the Inspection Results Category for that special inspection but need not be included in determining the Inspection Results Category for the general steam generator inspection.
(3)
Where special inspections are performed pursuant to 4.18.3.b, defective or degraded tube indications found in the new roll area as a result of the inspection and any indications found above the new roll area, are not included in the determination for the inspection results category of a general steam generator inspection.
I i
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Amendment No. M,M,M,M6,M4,MO 110k
o, l
4.18.4 Inep,ctirn Interynin
.The
' equi-< 3 inservice inspections of steam generstor tubes shall be perfo.
following frequencies:
a.
Inspection shall be. performed during the first st.s
'itdown.
Subsequent. inservice inspections shall be i
perfor.. c intervals of not less than 10 nor more than 24 l
calendar months ' after the previous' inspection.
If the results of
'two consecutive inspections for a given group
- of tubes following service under all volatile treatment (AVT) conditions fall into the.C-1 category or.if two consecutive inspections demonstrate that previously observed degradation has not continued and no additional degradation has occurred,.the inspection interval for that group may be extended to a maximum of 40 months.
j b.
If the results of the inservice inspection of a steam generator performed in accordance.with Table 4.18-2 at 40-month intervals
'for's given group
- of tubes fall in Category C-3, subsequent inservice inspections shall be performed at intervals of not less than 10 nor more than 20 calendar months after the previous inspection. The increase in inspection frequency shall apply j
until a subsequent inspection meets the conditions specified in j
4.18.4.a and the. interval'can be extended to 40 months.
- Additional unscheduled inservice inspections sh'all be performed on c.
each steam generator in accordance with the first sample inspection specified in Table 4.18-2 during the shutdown subsequent to any of the.following conditions:
.l.
Primary-to-secondary leakage in excess of the limits of Specification 3.1.6.3.b (Inservice inspection not required if leaks originate from tube-to-tubesheet welds).
If the l
leaking tube is from either Group A-1 or A-3 as defined in Specification 4.18.3.a.3, all of the tubes in the affected group in this steam generator may be inspected in lieu of the first sample inspection specified in Table 4.18-2.
If the degradation mechanism which caused the leak is limited to a specific portion of the tube length, the inspection per this
-paragraph may be limited to the affected portion of the tube length.
If the results of this inspection fall into the C-3 category, all of the tubes in the same group in the other steam generator will also be similarly inspected.
1 If the leaking tube has been repaired by the reroll process and j
is leaking in the new roll area, all of the tubes in the steam generator that have been repaired by the zeroll process will have 1
the new roll area inspected.
If the results of this inspection fall into the C-3 category, all of the tubes with zerolled areas in the other steam generator will also be sindlarly inspected.
This inspection will be in lieu of the first sample inspection specified in Table 4.18-2.
2.:
A seismic occurrence greater than the operating Basis Earthquake, 3.-
A loss-of-coolant accident requiring actuation of the engineered safeguards, or 4.
A main steam line or feedwater line break.
- A group of tubes meansa (a) All tubes inspected pursuant to 4.18.3.a.3, or
.(b)
All tubes in a steam generator less those inspected pursuant to 4.18.3.a.3.
' Amendment No. 44,M,M,M6,H4,MG 1101
n.
e;'i=
4.18.5 Acceptenes criterin
-a..
As used in this specifications
- 1.
' Tubing or Tube means that portion of the tube or sleeve which forms the primary system to secondary system pressure boundary. -
2.-
Imperfection means an exception-to the dimensions, finish or contour of a tube from that required by fabrication drawings
'or specifications. Eddy current testing indications below 20% of the nominal tube wall thickness, if detectable, may be considered as' imperfections.
3.
- Degradation means a service-induced cracking, wastage, wear l
or general corrosion occurring'on either the inside or outside of-a tube.
D 4.-
Degraded Tube means;a tube containing imperfections 2 20%_of l
Lthe. nominal _ wall thickness caused by degradation, except where.all. degradation has been spanned by the installation of a sleeve.
5.-
% Degradation means the percentage of the tube wall thickness affected or removed by degradation.
6.
Defect means an imperfection of such severity that it exceeds the plugging limit except where the imperfection has been spanned by the installation of a sleeve. A tube containing a defect in its pressure boundary is defective.
7.
Pluquing Limit means.the imperfection depth at or beyond 40% of the nominal tube wall thickness for which the tube shall be sleeved, rerolled, or removed from service because it may become unserviceable prior.to the next inspection. This does not apply to ODIGA indications within the defined region of the upper tubesheet..These imperfections shall be assessed for continued plant operation in accordance with topical report RAN-10235P, Revision 0.
The reroll repair process will only be used to repair tubes with defects in the upper tubesheet area. The reroll repair process will be performed only once per steam generator tube using a 1 inch roll length. _The new roll area must be free of detectable degradation in order-for the repair to be considered acceptable.
The reroll repair process is described in the topical report, RAN-10232P, Revision 00.
8.
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 Operating Basis Earthquake, a loss-
- of-coolant accident, or a steam line or feedwater line break as specified in Specification 4.18.4.c.
9._
Tube Inspection means an inspection of the steam generator tube from the point of' entry completely to the point of exit.
For tubes that have been_ repaired by the reroll process within the upper tubesheet, that portion of the tube above the new roll can be excluded from future periodic inspection requirements because it is no-longer part of the pressure boundary once the repair roll'is installed.
t b.-
The steam generator shall be determined operable after completing the corresponding actions (plug, reroll, or sleeve all tubes
- exceeding.the plugging limit and all tubes containing through-wall cracks) _ required by Table 4.18-2.
Amendment No.[34,M,MA44,M4AGO Illom
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4.18.6 Reports Following each inservice inspection of steam generator tubes, the complete results of the inspection shall be reported to the NRC.
This report, to be submitted within 90 days of inspection completion, shall includes l
a.
Number and extent of tubes inspected; b.
Location and percent of wall-thickness penetration for each indication of an imperfections c.
Identification of tubes plugged and tubes sleeved; d.
Number of tubes repaired by rerolling and number of indications detected in the new roll area of the repaired tubes; and e.
Summary of the condition monitoring and the operational assessment results when applying the upper tubesheet ODIGA alternate repair criteria.
This report shall be in addition to a Special Report (per Specification 6.12.5.d) required for the results of steam generator tube inspections which fall'into Category C-3 as denoted in Table 4.18-2.
The Commission shall be notified of the results of steam generator tube inspections which fall into Category C-3 prior to resumption of plant operation. The written Special Report shall provide a description of investigations conducted to determine cause of the tube degradation and corrective measures taken to prevent recurrence.
l Amendtrwd No. 24,44,86,40s,434, 110m1 440,400,444
m o,
e Btnan The surveillance requirements-for inspection of the steam generator tubes ensure that the structural ~ integrity of this portion of the RCS will be maintained. LThe program for inservice inspection of steam generator tubes is
. based on a modification of Regulatory' Guide 1.83, Revision 1.
Inservice inspection of steam generator tubing is essential in order to maintain surveillance of the conditions of the tubes in the event that there is evidence.of mechanical damage or progressive degradation due to design, i manufacturing errors, or inservice conditions that lead to corrosion.
~ > Inservice-inspection of steam generator tubing also provides a means of characterizing the. nature and cause of any tube degradation so that corrective measures can be taken.
.In general, steam generator tubes that are degraded beyond the repair limit can either be plugged, sleeved, or rerolled. ' The steam generator (SG) tubes that are plugged are removed from service by the installation of plugs at both ends of the associated tube and thus completely removing the tube from service. When the upper.tubesheet outer diameter intergranular attack
'(ODIGA) alternate repair' criteria is applied, imperfections found within~the defined region of'the upper tubesheet may be left in service under the guidelines of. topical report BAW-10235P, Revision 0.. The defined region begins one inch above the upper tubesheet secondary. face and ends at the nearest tube ro11' transition.
Following a SG inspoction, an operational-assessment is performed to ensure primary-to-secondary leak rates will be maintained within the assumptions of the accident analysis.
. Degraded steam generator. tubes can'also be repaired by the installation of sleeves which span the area of degradation and serve as a replacement pressure boundary for the degraded portion of the tube, thus permitting the tube to remain in service.
Degraded steam generator tubes can also be repaired by the rerolling of the tube'in the upper tubesheet-to create a new roll area and pressure boundary for the. tube.
The zerolling methodology establishes a new pressure boundary below the degradation, thus permitting the tube to remain in service. The degraded-_ tube above the:new roll area can be excluded from future periodic inspection requirements because it is no longer part of the pressure boundary once-the repair roll is installed in the upper tubesheet. The rerolling repair process will only be used to repair defects in the upper tubesheet in
-accordance with BAW-10232P, Revision 00.
.All tubes.which have been repaired using the reroll process will have the new roll area inspected during future inservice inspections.
Defective or degraded tube indications found in the new roll and any indications found in the original roll need not be included in determining the Inspection Results i
Category for the generator inspection..
j The reroll repair-process will'only be used to repair. tubes with defects in Lthe upper tubesheet area..The. reroll repair process will be performed only once per steam generator tube using a 1 inch roll length. 'Thus, multiple applications of.the reroll process to any individual tube is not-acceptable.
.The new roll' area must be free of detectable degradation in order for the repair to be considered acceptable. After'the new roll area is initially ademned acceptable, future degradation in the new roll area will be analyzed to determine if the tube is defective and needs to be removed from service.
~The reroll repair process is described.in the topical report, BAW-10232P, Revision 00..
Amendment No. 24,44,48,408,444, -
.-110n 472,400,494
' d._ $.
MARKUP OF CURRENT ANO-1 TECHNICAL SPECIFICATIONS (FORINFO ONLY) i l
l Legend Strike-through Deleted Text
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Double Underline =
Added Text Shaded Text being deleted from current page and being moved to another
=
Boxed Text being added to current page from another page
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.g.
'first camplo insp2ction during each inservico inepaction a.
Th2 (subsequent to the baseline inspection) of each steam generator shall include:
1.
All nonplugged tubes that previously had detectable wall penetrations (>20%), except tubes in which the wall penetration has been spanned by a sleeve, and 2.
At least 50% of the tubes inspected shall be in those areas where experience has indicated potential probleum, except where specific groups are inspected per Specification 4.18.3.a.3.
A tube inspection (pursuant to specification 4.18.5.n.9) 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.
Tubes in the following groups may be excluded from the first random sample if all tubes in a group in both steam generators are inspected. The inspection may be concentrated on those portions of the tubes where imperfections were previously found. No credit will be taken for these tubes in meeting minimum sample size requirements. Where only a portion of the tube is inspected, the remainder of the tube will be subjected to the random inspeccion.
(1)
Group A-1: Tubes within one, two or three rows.of the~open inspection lane.
l (2)
Group A-2: Unplugged tubes with sleeves installed.
l (3)
Group A-3:
Tubes in the wedge-shaped group on either side of the lane region (Group A-1) as
' defined by Figure 4.18.1.
4.
T=nlementation of the unner tubasheet ODIGA alternate renhir criteria reauires a 100% bobbin coil inanection of the son-nluaaed and non-sleeved tubes, scannina the defined reaion of t ie unner tubesheet, durina all subsesuant SG insnection intervals t'ursuant t2 4..8.4.
The results of t.11s aw==4 r ation may be excludec,from l
t se fLrst ra W = s== le.
The definec. reaion beains one lg @
j t se unner tubesheet secondarv f ace ard anda at the nearer 1_1ggg roll transition. ODIGA indications catected by the bobbin _E221 I
orobe shall be characterized usina rotatina co:.1 nrobes ig gccordance with tonical reDort RAN-10235P, Revnsion O.
b.
All tubes which have been repaired using the reroll process wilJ have the new roll area inspected during the inservice inspection.
I c.
The second and third sample inspections during each inservice inspection as required by Table 4.18-2 may be less.than a ful.
l tube inspection by concentrating the inspection on those areas of the tube sheet array and on these portions of the tubes where ttubes with imperfections were previously found.
Amendment No. 44,41,44, H4 110jl t:
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'perfarmed M nltcchMic cted!! tub 2!? If 9 any ) selected.itube? does ? not$
- permitithij pss.sagel;o f {theisddy[ded F and tant adj acent1 tube !L
! inspection hi[this S sha11E be5 reco r lselectedi;andisubjectedjtolaitubefinspectionh 7Eih!$!M Ms e M N b 3s[9?l
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' ca d The f second> and third sample ' inspections during each inservice > ',L n' ' "
\\ [(;
jO inspection as required by Table 4.18-2 may be less than,a full;[f
>l)'
?
l tube inspect'.on by concentrating.thel inspection'on those tress of,,
D
,,the tube sheet array,and on those portions of the tubes,where',,,1 '
o u,,
c tubes;with imperfections were previously found.,
L;,'
s
,,g y,,
The results of each sample inspection shall be classified into one of the following three categories:
Category Inspection Results C-1 Less than 5% of the total tubes inspected are degraded tubes and none of the inspected tubes are defective.
C-2 One or more tubes, but not more than 1% of the total tubes inspected, are defective, or between 5% and 10% of the total tubes inspected are degraded tubes.
1 C-3 More than 10% of the total j
tubes inspected are degraded 1
tubes or more than 1% of the inspected tubes are defective.
NOTES:
(1)
In all inspections, except as specified in 4.18.3.c, previously degraded tubes whose degradations have not been spanned by a sleeve must exhibit significant (>10%) further wall penetrations to be included in the above percentage calculations.
1 Amendment No. M,4+,M,M6,H4,M9 110k J
(2)
Where special inspections are performed pursuant to 4.18.3.a.3, defective or degraded tubes found as a result of the inspection shall be included in determining the Inspection Results Category for that special inspection but need not be included in determining the Inspection Results Category for the general steam generator inspection.
]
(3)
Where special inspections are performed pursuant to 4.18.3.b, defective or degraded tube indications found in the new roll area as a result of the inspection and any indications found above the new roll area, are not included in the determination for the inspection results category of a general steam generator inspection.
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The above-required inservice inspections of steam generator. tubes shall be performed at the following frequencies:
a.
The baseline inspection shalllbe performed during the first refueling shutdown.
Subsequent inservice inspections shall be performed at intervals of not less than 10 nor more than 24 calendar months after the previous inspection. If the results of two consecutive inspections for a given group
- of tubes following service under all volatile treatment (AVT) conditions fall into the C-1 category or if two consecutive inspections demonstrate that previously observed degradation has not continued and no additional degradation has occurred, the inspection interval for that group may be extended to a maximum of 40 months.
b.
If the results of the inservice inspection of a steam generator performed in accordance with Table 4.18-2 at 40-month intervals for a given group
- of tubes fall in category C-3, subsequent
' inservice inspections shall be performed at intervals of not less than 10 nor more than 20 calendar months after the previous inspection. The increase in inspection frequency shall apply until a subsequent inspection meets the conditions specified in 4.18.4.a and the interval can be extended to 40 months.
c.
Additional unscheduled inservice inspections shall be performed on each steam generator in accordance with the firet sample inspection specified in Table 4.18-2 during the shutdown subsequent to any of the following conditions:
1.
Primary-to-secondary leakage in excess of the limits of Specification 3.1.6.3.b (Inservice inspection not required if leaks originate from tube-to-tubesheet weldsl.
If the l
1eaking tube is from either Group A-1 or A-3 as defined in Specification 4.18.3.a.3, all of the tubes in the affected group in this steam generator may be inspected in lieu of l
the first sample inspection specified in Table 4.18-2.
If the degradation mechanism which caused the leak is limited to a i
specific' portion of the tube length, the inspection per this paragraph may be limited to the affected portion of the tube length.
If the results of this inspection fall into the C-3 category, all of the tubes in the same group in the other steam generator will also be similarly-inspected.
Amendment No. 44,M,M,M4,M4,MO 1101
O If the leaking tube has been repaired by the reroll process and is leaking in the new-roll area, all of the tubes in the steam generator that have been repaired by the reroll process will have the new roll area inspected.
If the results of this inspection fall into-the C-3 category, all of the tubes with rerolled areas in the other steam generator will also be similarly inspected.
This inspection will be'in lieu of the first sample inspection specified in Table 4.18-2.
2.
A seismic occurrence greater than the operating Basis Earthquake, 3.-
A loss-of-coolant accident requiring actuation of the engineered safeguards, or.
l 4.
A main steam line or feedwater line break.
l
- A group of tubes means: (a) All tubes inspected pursuant to 4.18.3.a.3, or-(b) All tubes in a steam generator less.these inspected pursuant to 4.18.3.a.3.
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4.18.5 Acceptance criteria a.
As used in this specification:
1.
Tubing or Tube means that portion of the tube or sleeve which forms the primary systeta to secondary system pressure J
boundary.
2.
Imperfection means an exception to the dimensions, finish or contour of a tube from that required by fabrication drawings or specifications.
Eddy current testing indications below 20% of the nominal tube wall thickness, if detectable, may be i
I considered as imperfections.
3.
Degradation means a service-induced cracking, wastage, wear or general corrosion occurring on either the inside or outside of a tube.
4.
Degraded Tube means a tube containing imperfections y; 20% of l
the nominal wall thickness caused by degradation, except where all degradation has been spanned by the installation of a sleeve.
5.
% Degradation means the percentage of the tube wall thickness affected or removed by degradation.
6.
Defect means an imperfection of such severity that it exceeds the plugging limit except where the imperfection has been spanned by the installation of a sleeve. A tube containing a defect in its pressure boundary is defective.
7.
Plugging Limit means the imperfection depth at or beyond 40% of the nominal tube wall thickness for which the tube shall be :::t:::t t: :::vi;;;hility by the in:t:11:.ti;n ;f : sleeveg, rerolled, or removed from service because it may become unserviceable prior to the next inspection t it i: : ; :1 t:
Of th; n :.in:1 tub w:14-
~
a thich::::. This does not acolv to the ODIGA indications within the defined reaion of the nocer tubesheet.
"hese imperfections shall be assessed for cont:.nued clant operat:.on in accordance with tonical report BAN-10235P, Revision O.
Amendment No. H,44,M,4M,4M,MG 110m
<q.
a The reroll repair process will only be used to repair tubes with defects in the upper tubesheet area. The reroll repair process will be perfo'rmed only once per steam generator tube using a 1 J
j inch roll length. The new roll area must be free of detectable degradation in order for the repair to be considered acceptable.
I The reroll repair process is described in the topical report, I
BAN-10232P, Revision 00.
8.
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 Operating Basis Earthquake, a loss-of-coolant accident, or a steam line or feedwater line break as specified in Specification 4.18.4.c.
9.
Tube Inspection means an inspection of the steam generator tube from the point of entry completely to the point of exit.
For tubes that have been repaired by the reroll process within the upper tubesheet, that portion of the tube above the new roll can be excluded from future periodic inspection requirements because it is no longer part of the pressure boundary once the repair roll is installed.
b.
The steam generator shall be determined operable after completing the corresponding actions (plug, reroll, or sleeve all tubes exceeding the plugging limit and all tubes containing through-wall cracks) required by Table 4.18-2.
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The steam generator shall be determined operable after completing the corresponding actions (plug, reroll, or sleeve all tubes exceeding the plugging limit and all tubes containing through-wall cracks) required by Table 4.18-2 with th: f:11:uing 2
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Tch:: with ::t:: di-t:: interg::nul:: tt :k indi : tion: within
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- n...e 4.18.6 Reports Following each inservice inspection of steam generator tubes, the complete results of the inspection shall be reported to the NRC.
This report, to be submitted within 46-20. days of inspection completion, shall include:
l a.
Number and extent of tubes inspected; Amendment No. G4,44,44,444,444, 110ml 449,444,494
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b.
Location and percent of wall-thickness penetration for each indication of an imperfection; c.
Identification of tubes plugged and tubes sleeved;-end d.
Number of tubes repaired by rerolling and number of indications detected in the new roll area of the repaired tubes; and e.
Sn---rv of the condition monitorina and the operational assessment results when acolvina the unoer tubesheet ODIGA alternate recair criteria.
This report shall be in addition to a Special Report (per Specification 6.12.5.d) required for the results of steam generator tube inspections which fall into Category C-3 as denoted in Table 4.18-2.
The Commission shall be notified of the results of steam generator tube inspections which fall into Category C-3 prior to resumption of plant cperation. The written Special Report shall provide a description of investigations conducted to determine cause of the tube degradation and corrective measures taken to prevent recurrence.
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e d.? (Number ~of tubes repaired.by" rerolling"and number ofindications" detected in the"new roll
,,, inrea of the repaired tubes.
- This ' report shalllbe In" addition ~ to a Special Report (per Specification 6.12.5A)' rsquired for;thelresults of,
steam generator tube inspections which fsN into Category C-3 as denoted in Table 4.18-20The.L.i Commission'shall be notified of the results of steam generator tube inspections.which fallinto Categoryf C-3 prior to resumption of plant operation.3 The wntten Specul Report shall provide"a. description of 9 ~
' investigations' conducted to determine cause'of the tube degradation and ' orrectiv' lm' ssures taken to.
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prevent recurrence.
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a Bases The surveillance requirements for inspection of the steam generator tubes ensure that the structural integrity of this portion of the RCS will be maintained The program forinservice inspection of steam generator tubes is based on a modification of Regulatory Guide 1.83, Revision 1. Inservice inspection of steam generator tubing is essential in order to maintain surveillance of the conditions of the tubes in the event that there is evidence of mechanical damage or progressive degradation due to design, manufacturing errors, orinservice con &tions that lead to corrosion. Inservice inspection of steam generator tubing also provides a means of characterizing the nature and cause of any tube degradation so that corrective measures can be taken.
in aaneral. sSteam generator tubes that are degraded beyond the repair limit can either be plugged, sleeved, or rerolled The steam generatorIEfd, tubes that are plugged are removed from service by the installation of plugs at both ends of the associated tube and thus completely removing the tube from service. When the unoer tt,besheet otiter cliameter interaranular attack (ODIGA) alternate repair criter:.a is appl:.ed, : moerfections found within the defined rea:.on of the uoner tubesheet nav be left :.n service under the auidelines of tootcal report BAW-10235P, Rev:.sion 0.
The defined reaion beains one inch above the unoer tubosheet secondary face and ends at the nearest tube roll transition.
Follow:.no a SG inspection, an operational assessment
.s performed to ensure crimarv-to-secondary leak rates w:.ll be mainta:.ned within the assumotions of the accident analysis.
Degraded steam generator tubes can also be repaired by the installation of sleeves which span the area of degradation and serve as a replacement pressure boundary for the degraded portion of the tube, thus permitting the tube to remain in service.
Degraded steam generator tubes can also be repaired by the rerolling of the tube in the upper tubesheet to create a new roll area and pressure boundary for the tube. The rerolling methodology establishes a new pressure boundary below the degradation, thus permitting the tube to remain in service. The degraded tube above the new roll area can be excluded from future periodic inspection requirements because it is no longer part of the pressure boundary once the repair roll is installed in the upper tubesheet. The rerolhng repair process will only be used to repair defects in the upper tubesheet in accordance with BAW-10232P, Revision 00.
All tubes which have been repaired using the reroll process will have the new roll area inspected during future inservice inspechons. Defecdve or degraded tube indications found in the new roll and any in& cations found in die original roll need not be included in determining the inspection Results Category for the generatorinspection.
The reroll repair process will only be used to repair tubes with defects in the upper tubesheet area. The reroll repair process will be performed only once per steam generator tube using a 1 inch roll length.
Thus, multiple applications of the reroll process to any individual tube is not acceptable. The new roll area must be free of detectable degradation in order for the repair to be considered acceptable. After the new roll area is initially deemed acceptable, future degradation in the new roll area will be analyzed Amendment No. 34,44,86,406,448, 110n 473,490,494 l
]
J to determine if the tube is defedive and needs to be removed from service. The reroll repair process is described in the topical report, BAW-10232P, Revision 00.
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ATTACHMENT 2 IQ lCAN059901 BAW-10235P MANAGEMENT PROGRAM FOR VOLUMETRIC OUTER DIAMETER INTERGRANULAR ATTACK IN THE TUBESHEETS OF ONCE-THROUGH STEAM GENERATORS FTIPROPRIETARY Prepared by:
Framatome Technolonies. Inc.
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ATTACHMENT 3 10 ICAN059901 Framatome Affidavit for Proprietary Nature of BAW-10235P MANAGEMENT PROGRAM FOR VOLUMETRIC OUTER DIAMETER INTERGRANULAR ATTACK IN TEE TUBESHEETS OF ONCE-THROUGH STEAM GENERATORS l
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- AFFIDAVIT OF JOSEPH J. KELLY A.
My name is Joseph J.. Kelly. I am Manager of B&W Owners Group Services for Framatome Technologies, Inc. (FTI), and as such, I am authorized to execute this Affidavit.
B.
I am familiar with the criteria applied by FTI to determine whether certain information of FTI is proprietary and I am familiar with the procedures established within FTI to ensure the proper application of these criteria.
C.
In determining whether an FTI ' document is to be classified as proprietary information, an initial determination is made by the Unit Manager, who is responsible for originating the document, as to whether it falls within the criteria set forth in Paragraph D hereof. If the information falls within any one of these criteria, it is classified as proprietary by the originating Unit Manager. This initial determination is reviewed by the cognizant Section Manager. If the document is designated as proprietary, it is reviewed again by me to assure that the regulatory requirements of 10 CFR Section 2.790 are met.
D.
The following information is provided to deraonstrate that the provisions of 10 CFR Section 2.790 of the Commission's regulations have been considered:
(i)
The information has been held in confidence by Ffl. Copies of the document are clearly identified as proprietary.- In addition, whenever FTI transmits the information to a customer, customer's agent, potential customer or regulatory agency, the transmittal requests the recipient to hold the information as proprietary. Also, in order to strictly limit any potential or actual customer's use I
of proprietary information, the substance of the following provision is included in 1
all agreements entered into by FTI, and an equivalent version of the proprietary provision is included in all of FTfs proposals:
1 I
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.e s AFFIDAVIT OF JOSEPH J. KELLY (Cont'd.)
"Any proprietary information concerning Company's or,its Supplier's products or manufacturing processes which is so designated by Company or its Suppliers and disclosed to Purchaser incident to the performance of such contract shar remain the property ofCompany or its Suppliers and is disclosed in confidence, and Purchaser shall not publish or otherwise disclose it to others without the written approval of Company, and no rights, implied or otherwise, are granted to produce or have produced any products or to practice or.' cause to be practiced any manufacturing processes covered thereby.
Notwithstanding the above, Purchaser may provide the NRC or any other regulatory agency with any such proprietary information as the NRC or such other agency may require; provided, however, that Purchaser shall first give Company written notice of such proposed disclosure and Company shall have the right to amend such proprietary information so as to make it non-proprietary. In the event that Company cannot amend such proprietary information, Purchaser shall prior to disclosing such information, use its best efforts to obtain a commitment from NRC or such other agency to have such information withheld from public inspection.
' Company shall be given the right to_ participate in pursuit of such confidential treatment."
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3,3
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AFFIDAVIT OF JOSEPH J. KELLY (Cont'd.) -
p (ii) -
' The following criteria are customarily applied by FTI in a rational decision process
- to determine whether the information should be classified as' proprietary.
Information may be classi6ed as proprietary ifone or more of the following criteria are met:
a.
Information reveals cost or price information, commercial strategics, production capabilities, or budget levels of FTI, its customers or suppliers.'
I
~ b.
The informa: ion reveals data or material concerning FTI research or development plans or programs of present or potential competitive advantage to FTI.
c.
The 'use of the information by a competitor would decrease' his expenditures, in tir.ie or resources, in designing, producing or marketing a similar product.
. d.
The information consists of test data or other similar data concerning a process, method'or component, the application of which results in a competitive advantage to FTI.-
e.
The information reveals special aspects of a process, method, component or the like, the exclusive use of which results in a competitive advantage to FTI.
- f.
The information contains ideas for which patent protection may be sought.
3
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's*
AFFIDAVIT OF JOSEPH J. KELLX (Cont'd.)
The document (s) listed on Exhibit "A", which is attached hereto and ma& a part hereof, has been evaluated in accordance with normal FTI procedures with respect to classification and has been found to contain information which falls within one or more of the criteria enumerated above. Exhibit "B", which is attached hereto and made a part hereof, specifically identifies the criteria applicable to the document (s) listed in Exhibit "A".
(iii)
The document (s) listed in Exhibit "A", which has been made available to the United States Nuclear Regulatory Commission was made available in confidence with a request that the document (s) and the information contained therein be withheld from public disclosure.
j (iv)
The information is not available in the open literature and to the best of our knowledge is not known by Combustion Engineering, EXXON, General Electric, Westinghouse or other current or potential domestic or foreign competitors of FT.
(v)
Specific information with regard to whether public disclosure of the information is likely to cause harm to the competitive position of FTI, taking into account the value of the information to FTI; the amount of effort or money expended by FTI developing the information; and the case or difficulty with which the information could be properly duplicated by others is given in Exhibit "B".
1 E.
I have personally reviewed the document (s) listed on Exhibit "A" and have found that it is
[
~ considered proprietary by FTI because it contains information which falls within one or more
(
of the criteria enumerated in Paragraph D, and it is information which is customarily held in confidence 'and protected as proprietary information by FTI. This report comprises l
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AFFIDAVIT OF JOSEPH J. KELLY (Cont'd.)
Information' utilized by FTI in its business which afford FTI an opportunity to obtain a competitive advantage over those who may wish to know or use the information contained in the document (s).
l l
/x OS EP J.
LLY State of Virginia)
)-
SS. Lynchburg City ofLynchburg)
Joseph J. Kelly, being duly sworn, on his oath deposes and says that he is the person who subscribed his name to the foregoing statement, and that the matters and facts set forth in the statement are true.
j fkno)l i
(
05EP4 J.
LY Subscribed and sworn before me this )4A ay of 7Lu< ~ 1999.
d a
b.Mw Notary Public in and for the City ofLynchburg, State of Virginia.
My Commission Expires. d4 31/F/9 I sJ 5
e...
EXHIBITS A & B EXHIBIT A Topical Report BAW-10235P, " Management Program for Volumetric Outer Diameter Intergranular Attack in the Tubesheets of Once-Through Steam Generators," May 1999.
EXHIBIT B, The above listed document contains information which is considered Proprietary in accordance i.
with Criteria b, c, d, and e of the attached affidavit.