Beaver Valley, Unit 1 - License Application No. 322 Regarding … · 2012. 11. 19. · L-04-009 Page 2 2. One copy of WCAP-15919-NP, "Steam Generator Tube Repair for Westinghouse

FENOC Beaver Valley Power StationRoute 168110 % PO. Box4

FirstEnergy Nuclear Operating Company Shippingport PA 15077-0004

L. WJillian Pearce 724-682-5234Site Vice President Far: 724-643-8069

January 27, 2004L-04-009

U. S. Nuclear Regulatory CommissionAttention: Document Control DeskWashington, DC 20555-0001

Subject: Beaver Valley Power Station, Unit No. 1Docket No. 50-334, License No. DPR-66License Amendment Request No. 322Steam Generator Tube Repair Using Alloy 800 Sleeves

Pursuant to 10 CFR 50.90, FirstEnergy Nuclear Operating Company (FENOC) requestsan amendment to the above license for Beaver Valley Power Station (BVPS) Unit No. 1in the form of changes to the Technical Specifications. The proposed amendment willallow steam generator tube repair using Alloy 800 sleeves.

The FENOC evaluation of the proposed changes are presented in the Enclosure. Theproposed Technical Specification changes are presented in Attachment A. Attachment Bprovides the proposed information-only changes to the Technical Specification Bases thatreflect the proposed license amendment. Attachment C identifies the commitments madein this submittal.

The Beaver Valley review committees have reviewed the changes. The changes weredetermined to be safe and do not involve a significant hazard consideration as defined in10 CFR 50.92 based on the attached safety evaluation and no significant hazardevaluation.

FENOC requests approval of the proposed amendment by September 30, 2004, in orderto support implementation of the proposed changes for the next BVPS Unit 1 refuelingoutage in the fall of 2004. Once approved, the amendment shall be implemented within60 days.

Enclosed are:

1. One copy of WCAP-15919-P, "Steam Generator Tube Repair for WestinghouseDesigned Plants with 7/8 Inch Inconel 600 Tubes Using Leak Limiting Alloy 800Sleeves" (Proprietary) dated August 2003.

Beaver Valley Power Station, Unit No. 1License Amendment Request No. 322L-04-009Page 2

2. One copy of WCAP-15919-NP, "Steam Generator Tube Repair for WestinghouseDesigned Plants with 7/8 Inch Inconel 600 Tubes Using Leak Limiting Alloy 800Sleeves" (Nonproprietary) dated August 2003.

Also enclosed are a Westinghouse authorization letter, CAW-03-1750, accompanyingaffidavit, Proprietary Information Notice, and Copyright Notice.

As Item 1 contains information proprietary to Westinghouse Electric Company LLC, it issupported by an affidavit signed by Westinghouse, the owner of the information. Theaffidavit sets forth the basis on which the information may be withheld from publicdisclosure by the Commission and addresses with specificity the considerations listed inparagraph (b) (4) of Section 2.790 of the Commission's' regulations.

Accordingly, it is respectfully requested that the information which is proprietary toWestinghouse be withheld from public disclosure in accordance with 10 CFR Section2.790 of the Commission's regulations.

Correspondence with respect to the copyright or proprietary aspects of the items listedabove or the supporting Westinghouse Affidavit should reference CAW-03-1750 andshould be addressed to J. S. Galembush, Acting Manager, Regulatory Compliance andPlant Licensing, Westinghouse Electric Company LLC, P.O. Box 355, Pittsburgh,Pennsylvania 15230-0355.

If there are any questions concerning this license amendment request, please contactMr. Larry R. Freeland, Manager, Regulatory Affairs/Performance Improvement at724-682-5284.

I declare under penalty of perjury that the foregoing is true and correct. Executed onJanuary p1 , 2004.

Sincerely,

'aw lePearce

Beaver Valley Power Station, Unit No. License Amendment Request No. 322L-04-009Page 3

Enclosures:* FENOC Evaluation of the Proposed Change.* Westinghouse authorization letter, CAW-03-1750, dated December 5, 2003* Proprietary Information Notice* Copyright Notice

Attachments:A. Proposed Technical Specification Changes (mark-ups)B. Proposed Changes to Technical Specification Bases (Information only)C. List of Regulatory CommitmentsD. WCAP- 15919-NP, Revision 00 (Non-Proprietary)E. WCAP-15919-P, Revision 00 (Proprietary)

c: Mr. T. G. Colburn, NRR Senior Project ManagerMr. P. C. Cataldo, NRC Sr. Resident InspectorMr. H. J. Miller, NRC Region I AdministratorMr. D. A. Allard, Director BRP/DEP (w/o Attachment E)Mr. L. E. Ryan (BRP/DEP) (w/o Attachment E)

t

ENCLOSURE

Beaver Valley Power Station, Unit No. 1License Amendment Request No. 322

FENOC Evaluation of the Proposed Change

Subject: Application for Amendment of Technical Specification 3/4.4.5 to Allow SteamGenerator Tube Repair Using Alloy 800 Sleeves.

Table of Contents

Section Title Page

1.0 DESCRIPTION ................................ 1

2.0 PROPOSED CHANGES ................................ 1

3.0 BACKGROUND ................................ 2

4.0 TECHNICAL ANALYSIS ................................. 3

5.0 REGULATORY SAFETY ANALYSIS ................................ 13

5.1 No Significant Hazards Consideration .................... ............ 13

5.2 Applicable Regulatory Requirements/Criteria ................................ 16

6.0 ENVIRONMENTAL CONSIDERATION ................................ 17

7.0 REFERENCES ................................ 18

AttachmentsNumber Title

A Proposed Technical Specification Changes

B Proposed Technical Specification Bases Changes

C Commitment Summary

D WCAP -15919-NP, Revision 00 (Non-Proprietary)

E WCAP -15919-P, Revision 00 (Proprietary)

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Beaver Valley Power Station Unit No. 1License Amendment Request No. 322

1.0 DESCRIPTION

FirstEnergy Nuclear Operating Company (FENOC) requests to amend OperatingLicense DPR-66 for Beaver Valley Power Station (BVPS) Unit No. 1. The proposedamendment would revise Technical Specification 3.4.5, "Steam Generators," to allowrepair of steam generator tubes by utilizing leak limiting Alloy 800 leak limitingsleeves.

2.0 PROPOSED CHANGE

The proposed amendment would revise Technical Specification 3.4.5 to allow repair ofsteam generator tubes by installation of leak limiting Alloy 800 leak limiting sleeves.The leak limiting Alloy 800 sleeves were developed by Westinghouse Electric LLC(Westinghouse). The technique to use leak limiting Alloy 800 sleeves to repairdegraded steam generator tubes is described in Westinghouse WCAP-15919-NP,Revision 00, "Steam Generator Tube Repair for Westinghouse Designed Plants with 7/8Inch Inconel 600 Tubes Using Leak Limiting Alloy 800 Sleeves," dated August 2003(nonproprietary) contained in Attachment D and WCAP-15919-P, Revision 00, "SteamGenerator' Tube Repair for Westinghouse Designed Plants with 7/8 Inch Inconel 600Tubes Using Leak Limiting Alloy 800 Sleeves," dated August 2003 (proprietary),contained in Attachment E. These reports detail the analyses and testing performed toverify the adequacy of Alloy 800 sleeves for installation in a steam generator tube anddemonstrate sleeving to be an acceptable repair technique.

The proposed Technical Specification change, which is submitted for NuclearRegulatory Commission (NRC) review and approval, is provided in Attachment A.FirstEnergy Nuclear Operating Company is proposing to modify the BVPS Unit No. 1Technical Specifications to revise Surveillance Requirements (SRs) 4.4.5.4.a.6 and4.4.5.4.a.9. These two SRs currently describes plugging and repair criteria whichallows for Westinghouse laser welded sleeves and the former ABB CombustionEngineering tungsten inert gas (TIG) welded sleeves. These SRs are proposed to berevised to also list Westinghouse Alloy 800 leak limiting sleeves as an additionallyacceptable sleeve method. The proposed ability to utilize Westinghouse Alloy 800 leaklimiting sleeves is only being requested for Cycle 17 of BVPS Unit No. 1 and willinclude a note indicating that Alloy 800 sleeves are only applicable to Cycle 17. SR4.4.5.4.a.6 will also include a note indicating that tubes repaired with Alloy 800 leaklimiting sleeves will be plugged on detection of any service induced imperfection,degradation or defect in the sleeve or in the pressure boundary portion of the originaltube wall in the leak limiting sleeve/tube assembly as defined in Technical Specification4.4.5.4. SR 4.4.5.2.b.3 is being revised to require an inspection of all inservice Alloy800 sleeves using a plus point coil or equivalent technique during each refueling outage.

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The changes proposed to the Technical Specification Bases are provided in AttachmentB. The proposed Technical Specification Bases changes do not require NRC approval.The Beaver Valley Power Station Technical Specification Bases Control Programcontrols the review, approval and implementation of Technical Specification Baseschanges. The Technical Specification Bases changes are provided for information only.

Attachment C provides a list of commitments associated with this License AmendmentRequest (LAR).

The proposed change to the Technical Specifications and Technical Specification Baseshave been prepared electronically. Deletions are shown with a strike-through andinsertions are shown double-underlined. This presentation allows the reviewer toreadily identify the information that has been deleted and added.

To meet format requirements the Index, Technical Specifications and Bases pages willbe revised and repaginated as necessary to reflect the changes being proposed by thisLAR.

3.0 BACKGROUND

Pressurized water reactor steam generators (SGs) have experienced tube degradationrelated to corrosion phenomena such as wastage, pitting, intergranular attack, stresscorrosion cracking and crevice corrosion along with other phenomena such as dentingand vibration wear. Tubes that experience excessive degradation reduce the integrity ofthe primary to secondary pressure boundary. These tubes are considered defective andmust be repaired or removed from service by plugging. The installation of steamgenerator tube plugs removes the heat transfer surface of the plugged tube from serviceand leads to a reduction in the primary coolant flow available for core cooling. Sleevingis a steam generator tube repair method which was previously incorporated into theBeaver Valley Unit I Technical Specifications by Amendments 176 and 208. Theseamendments permitted the use of the Westinghouse laser welded sleeves and the formerABB Combustion Engineering tungsten inert gas (TIG) welded sleeves. Sleevingtechnology has been enhanced with the introduction of the Westinghouse leak limitingAlloy 800 sleeves. The option to use this sleeving method is requested to provide anadditional option for use in maintaining the operability of the steam generator.

FENOC is planning to replace the BVPS Unit No.1 steam generators in the refuelingfollowing Cycle 17. The proposed changes are only being requested for Cycle 17 toallow for the use of Alloy 800 sleeves if needed to maintain the BVPS Unit No. 1 steamgenerators within the analyzed plugging limits.

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Beaver Valley Power Station Unit No. ILicense Amendment Request No. 322

4.0 TECHNICAL ANALYSIS

The proposed changes revise the Technical Specifications SRs 4.4.5.4.a.6, 4.4.5.4.a.9and 4.4.5.2.b.3 to permit the installation of leak limiting Alloy 800 sleeves developed byWestinghouse to repair SG tubes at Beaver Valley Unit No. 1. Westinghouse providestwo types of leak limiting Alloy 800 sleeves. The first type of sleeve spans thetransition zone (TZ) of the parent SG tube at the top of the tubesheet and is called a TZsleeve. The TZ sleeve is hydraulically expanded into the SG tube at the upper end andis hard rolled into the SG tube within the SG tubesheet. The length of the TZ sleevespermits the sleeve to span the degraded SG tube section at the top of the tubesheet. Thesecond type of sleeve spans degraded areas of the SG tube at a Tube Support Plate(TSP) elevation or in a free span section and is called a tube support (TS) sleeve. TheTS sleeve is hydraulically expanded into the SG tube near each end of the sleeve.

There are two distinct advantages associated with the leak limiting Alloy 800 sleevescompared to other sleeve designs. First, no welding, brazing, or heat treatment isrequired during sleeve installation. Secondly, the strain within the tube is low, therebyreducing the likelihood of future degradation due to stress-influenced mechanisms.Although the Alloy 800 sleeves may allow slight leakage past the sleeve (assuming theparent SG tube is leaking), the sleeve is designed to maintain normal operation andpostulated post-accident leakage to be extremely small compared to the TechnicalSpecification primary-to-secondary leakage limits.

The SG tube with the installed sleeve meets the structural requirements of SG tubes thatare not degraded. Even in the event of the severance of the SG tube, the sleeve willprovide the required structural support and acceptable primary-to-secondary leakage fornormal operating and accident conditions. Extensive analyses and testing have beenperformed on the sleeve and repair joints to demonstrate that the design and licensingcriteria are met.

Analysis was performed by Westinghouse for SG tube repair in Westinghouse designedplants with 7/8 inch Outside Diameter (OD) Inconel 600 tubes of varying wall thicknessand addresses a combination of one TZ sleeve and/or up to two TS sleeves that could beinstalled in a single SG tube. Acceptable sleeve locations covered by the analysis are inthe SG tube straight legs from the top of the tubesheet up to the upper most tube supportplant region. WCAP-15919-P, Revision 00, provides a detailed description of thedesign, installation, and testing associated with the leak limiting Alloy 800 sleeves.

In addition to the analysis and test programs discussed in WCAP-15919-P, Revision 00,a significant number of Alloy 800 sleeves have been in operation for a number of years

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with no service induced degradation or significant leakage. No degradation of theinstalled sleeves or SG tubes in the area of the expansions has been identified.

The principal accident associated with the proposed changes is the Steam GeneratorTube Rupture (SGTR) event. The consequences associated with a SGTR event arediscussed in BVPS Unit No. I Updated Final Safety Analysis Report (UFSAR) Section14.2.4, "Steam Generator Tube Rupture." The SGTR event is a breach of the barrierbetween the reactor coolant system and the main steam system. The integrity of thisbarrier is significant from the standpoint of radiological safety in that a leaking SG tubeallows the transfer of reactor coolant into the main steam system. In the event of aSGTR, radioactivity contained in the reactor coolant mixes with water in the shell sideof the affected SG. This radioactivity is transported by steam to the turbine and then tothe condenser, or directly to the condenser via the turbine bypass valves, or directly tothe atmosphere via the atmospheric dump/relief valves, main steam safety valves, or theauxiliary feedwater pump turbine exhaust. Non-condensable radioactive gases in thecondenser are removed by the condenser air removal system and discharged to the plantvent. The use of leak limiting Alloy 800 sleeves allows the repair of degraded SG tubessuch that the function and integrity of the SG tube is maintained. Therefore the SGTRaccident is not affected by the use of leak limiting Alloy 800 sleeves.

The consequences of a hypothetical failure of a leak limiting Alloy 800 sleeve and/orthe associated SG tube would be bounded by the current SGTR analysis. Due to theslight reduction in the inside diameter of the SG tube caused by the sleeve wallthickness, primary coolant release rates through a ruptured parent tube would be slightlyless than assumed for the SGTR analysis and, therefore, would result in lower totalprimary fluid mass release to the secondary system. A Main Steam Line Break (MSLB)or Feedwater Line Break (FLB) will not cause a SGTR since the sleeves are analyzedfor a design basis accident differential pressure greater than that predicted in the BVPSsafety analysis. The impact of sleeving on SG performance, heat transfer, and flowrestriction is minimal and/or insignificant compared to plugging. The proposed BVPSUnit No. 1 Technical Specification changes to allow the use of leak limiting Alloy 800sleeves do not adversely impact any other previously evaluated design basis accident.

Evaluation of the proposed leak limiting Alloy 800 sleeves indicates no detrimentaleffects on the sleeve or sleeved tube assembly from reactor system flow, primarycoolant chemistry, secondary coolant chemistry, thermal conditions or transients, orother pressure conditions that may be experienced at BVPS Unit No. 1. Any leakage,which is assumed but not expected, experienced during normal operation and post-accident conditions is extremely small relative to the primary-to-secondary operationalleakage limits in the Technical Specifications and the BVPS Unit No. 1 accidentinduced MSLB leak limit. Data and calculation methodology concerning the reduction

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in primary coolant flow rate and sleeve-to-plug equivalency ratios is contained inSection 10 of WCAP-15919-P, Revision 00. Table 1 of this Attachment provides acomparison of loading conditions assumed in WCAP-15919-P, Revision 00, withrespect to corresponding BVPS Unit No. 1 operating and accident values. The valuesassumed in WCAP-15919-P, Revision 00, are either equivalent or more conservativethan BVPS Unit No. 1 plant specific values.

Table 1

LOADING CONDITIONS COMPARISON

Beaver Valley WCAP-15919-PUnit 1

T-Hot (Primary) Inlet Actual -607 F 594 FDesign 650 F 650 F

T-Steam (Secondary) Actual >509 F 467.5 FDesign 560 F 550 F

Primary-to-secondary AT Actual <98 F 126.5 F

Primary Pressure Actual 2250 psia 2250 psiaDesign 2500 psia 2500 psia

Secondary Pressure Actual -800 psia 700 psiaDesign 1100 psia 1130 psia

Normal Operating Actual <1490 psi 1550 psiPrimary-to-secondary AP

MSLB S2405 psi 2650 psiFLB <2650 psi

Primary-to-secondary APLOCA <l 100 psi 1130 psi

Secondary-to-Primary AP

WCAP-15919-P, Revision 00, describes the specific qualifications of leak limitingAlloy 800 sleeves. The summary of the results from WCAP-15919-P, Revision 00, isdiscussed below.

Sleeve Installation Requirements

The sleeves will be installed in accordance with the processes provided by the vendorand described in the associated reports which address sleeve design, qualification,installation methods, non-destructive examination and ALARA considerations. TheWestinghouse leak limiting Alloy 800 sleeving process is described in WestinghouseWCAP-15919-NP, Revision 00, "Steam Generator Tube Repair for Westinghouse

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Designed Plants with 7/8 Inch Inconel 600 Tubes Using Leak Limiting Alloy 800Sleeves," dated August 2003 (nonproprietary) contained in Attachment D of this letterand WCAP-15919-P, Revision 00, "Steam Generator Tube Repair for WestinghouseDesigned Plants with 7/8 Inch Inconel 600 Tubes Using Leak Limiting Alloy 800Sleeves," dated August 2003 (proprietary), contained in Attachment E of this letter.

A plant specific document that specifies the allowable location of tube eddy currenttesting indications in order to perform a successful sleeve installation in accordancewith WCAP-15919-P requirements will be established upon implementation of theamendment which approves the proposed Technical Specification changes supportingtube repair by leak limiting Alloy 800 sleeves. This document will be utilized todetermine that a tube is an acceptable sleeving candidate. Tubes with indicationsoutside of the acceptable locations would not be sleeved.

To prepare for sleeve installation, the current installation process requires the insidesurface of the parent SG tube to be cleaned with a high speed buffing tool. After theparent SG tube is cleaned, the sleeve is inserted in the parent tube and positioned at thedesired location. Sleeve expansion equipment is used to provide the required structuralfit-up of the sleeve by making the required number of hydraulic expansion joints withthe parent tube. The expansion equipment is controlled and monitored to ensure properdiametrical expansion. For the TZ sleeve, a hard roll is performed with sleeve rollingequipment in the lower part of the sleeve to expand the sleeve into contact with the SGtube within the SG tubesheet. The torque of the rolling equipment is monitored andcontrolled to ensure an acceptable joint. After installation, all sleeve-tube jointsundergo initial eddy current test acceptance and baseline inspection of 100 percent ofthe installed sleeves.

General Structural Assessment

The Alloy 800 tubing, from which the sleeves are fabricated, is procured to therequirements of the American Society of Mechanical Engineers (ASME) Boiler andPressure Vessel Code, Section II, Part B, SB-163, NiFeCr Alloy, Unified NumberingSystem N08800, and Section III, Subsection NB-2000. Alloy 800 is incorporated inASME Code Case N-21 and is considered acceptable for use by Regulatory Guide 1.85,"Materials Code Case Acceptability ASME Section III, Division 1," Revision 24, datedJuly 1986. Additionally, supplemental requirements more tightly controllingparameters within the limits allowed by the ASME specification are imposed.

Fatigue and stress analysis of the sleeved tube assemblies have been completed inaccordance with the requirements of Section III of the ASME Boiler and PressureVessel Code and NRC Regulatory Guide (RG) 1.121, "Bases for Plugging Degraded

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PWR Steam Generator Tubes," August, 1976. SG tubes with installed Alloy 800sleeves meet the structural integrity requirements of tubes that are not degraded. Evenin the event of the severance of the SG tube in the region behind the sleeve, the sleevewill provide the required structural support and acceptable leakage between the primaryand secondary systems for normal operating and accident conditions. The selecteddesign criteria for the sleeves ensure that all design and licensing requirements areconsidered. Extensive testing and analysis have been performed on the sleeve andsleeve-to-tube joints to demonstrate that these design criteria are met.

Mechanical testing has been performed to support the analyses prepared using ASMECode stress allowable values. Corrosion testing of sleeve-tube assemblies has beenperformed in Belgium (Laborelec Laboratories) and the U.S. (Westinghouse) withsatisfactory results. These results, when analyzed in conjunction with corrosion testresults from the tungsten inert gas-welded sleeve program, confirm the adequacy of thesleeve joint design. The Alloy 800 sleeve material showed no signs of degradationunder high temperature and pressure conditions in a caustic environment, while thesleeve-tube specimens maintained primary side pressure and exhibited no leakagethroughout the duration of the test program. Earlier design variations of this sleeve-tubeassembly (larger diametrical hydraulic expansion or varying number ofexpansions/configurations) were used at KORI I (South Korea) and Tihange 3(Belgium) steam generators. The current design configuration is in service or recentlyin service at Angra I (Brazil), KRSKO (Slovenia), Ringhals 4 (Sweden), Tihange 2(Belgium), Ulchin 1 & 2 (South Korea), and Calvert Cliffs 1 and 2 (United States)steam generators.

RG 1.121, along with Electric Power Research Institute (EPRI) Technical Report10001191, "Steam Generator Degradation Specific Management Flaw Handbook,"dated 2001, which adds margin to account for the configuration of a long axial crack,are used to develop the structural limit of the sleeve should sleeve wall degradationoccur as described in Section 8.2 of WCAP-15919-P. Leak limiting Alloy 800 sleevesare shown (by test and analysis) to retain burst strength in excess of three times thenormal operating pressure differential at end of operating cycle conditions. No creditfor the presence of the parent SG tube behind the sleeve was assumed for the minimumwall burst evaluation for the Alloy 800 sleeve. Bounding normal operating, designseismic, and transient loading conditions on the SG tube sleeves were used for thestructural analysis of the sleeves and are summarized in Section 8.5 of WCAP-15919-P.The loading conditions assumed in WCAP-15919-P as supplemented by Westinghousecalculation CN-SGDA-04-4 bound the loading conditions listed in BV UFSAR Table4.1-10.

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The RG 1.121 bounding structural limit for leak limiting Alloy 800 sleeves is 45 percentthrough-wall detailed in Section 8.2.1 of WCAP-15919-P, Revision 00, which is basedon normal operating conditions for the worst case envelopment of SG conditions forWestinghouse Model 44, 44F, and 51 steam generators.

The eddy current inspection method used has a documented qualification, per AppendixH of EPRI Technical Report TR-107569-V1R5, "PWR Steam Generator ExaminationGuidelines: Revision 5, Volume 1: Requirements," dated September 1997, of the Alloy800 sleeve for 3/4 (0.750) inch tubing. An equivalency assessment was performed toestablish that the essential variables developed for the eddy current examination of theAlloy 800 sleeve for a 3/4 (0.750) inch tube can be applied to a 7/8 (0.875) inch tube.

Corrosion Assessment

Historically, Alloy 800 has been used successfully for SG tubes, tube plugs, and sleevesprimarily in Western Europe. Over 200,000 Alloy 800 tubes have been used for up to19 years with only minimal tube failures (thinning/wastage, wear). No evidence ofprimary or secondary side stress corrosion cracking has been identified in any Alloy 800tube. Over 5,300 Alloy 800 sleeves of the leak limiting type design have been used in10 nuclear plants worldwide of which none have identified any service induced stresscorrosion cracking in the sleeved tube assembly to-date. Accelerated corrosion testingof Alloy 800 sleeve-tube assemblies has been performed in simulated primary andsecondary side SG environments and the Alloy 800 sleeves showed no signs of crackingin both the primary and secondary side tests. The specific details of Alloy 800 sleevecorrosion performance are contained in Section 6 of WCAP-15919-P, Revision 00.

Mechanical Integrity Assessment

Mechanical testing of Alloy 800 sleeve-tube assemblies was performed using mock-upSG tubes. The tests determined axial load, collapse pressure, burst pressure, leak rates,wear, and thermal cycling capability. The demonstrated load capacity of the assembliesprovides an adequate safety factor for normal operating and postulated accidentconditions. The load capacity of the upper and lower sleeve joints is sufficient towithstand thermally induced stresses and displacements resulting from the temperaturedifferential between the sleeve and the SG tube and pressure induced stresses resultingfrom normal operating and post-accident conditions. The burst and collapse pressuresof the sleeve provide margin over the limiting pressure differential. The mechanicaltesting demonstrated that the installed sleeve will withstand the cyclic loading resultingfrom power changes in the plant and other transients. The loading conditions developedin Section 8 of WCAP-15919-P were used to develop the conditions for the mechanicaltests described in Section 7 of WCAP-15919-P. The temperature and pressure

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differentials described in Section 8 of WCAP-15919-P are conservative with respect toBVPS Unit No. 1 operating and accident conditions.

Leak Rate Assessment

Although the Alloy 800 sleeve to SG tube joint is not required to be leak tight,conservative leak rate tests have been performed to provide the basis for leak ratecalculations considering normal operating and accident conditions. The Alloy 800 TZand TS sleeve leakage characteristics were evaluated at shutdown, normal operating,and accident temperatures so that all possible plant conditions would be enveloped bythe test results. Based on a conservative sleeve leak rate determined from the sleeveleak rate tests and excluding calculated leakage from alternate plugging criteria ineffect, over 11,000 TZ sleeves or 4000 TS sleeves could be installed and still meet theBVPS Unit No. 1 Technical Specification 3.4.6.2, "RCS Operational Leakage," leakagelimits of 150 gallons per day primary to secondary leakage for a single SG. UnderMSLB and FLB accident conditions, over 30,000 TS or TZ sleeves could be installedwithout exceeding the 1.0 gallon per minute post-accident leakage limit in the affectedsteam generator. Details of the leakage assessment are contained in Section 7 ofWCAP-15919-P.

FENOC will conservatively assume all installed sleeves will leak for post-accidentleakage calculations. The leak rate for each sleeve will be based on the upper 95percent confidence limit on the mean value of leakage for appropriate temperature andpressure conditions. The total sleeve leak rate will be combined with the total amountof leakage from all other sources (i.e. Alternate Repair Criteria (ARC) and nonalternaterepair criteria indications) for comparison against the limit on accident induced leakageas specified in the UFSAR for the MSLB radiological consequences analysis. This totalcalculated accident induced leakage will be reported in the 90-day report required byNRC Generic Letter 95-05, Attachment 1, Section 6.b.

Sleeve Inspections

Post-installation

As required by EPRI Technical Report 1003138, post-installation (pre-service)examination will be performed on the full length of 100 percent of leak limiting Alloy800 sleeve/tube assemblies using Plus Point probes or an equivalent EPRI Appendix Hqualified technique, if available. This examination will establish in-service inspectionbaseline data and initial installation acceptance data on the primary pressure boundaryof the sleeve/SG tube assembly repair.

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In-service Inspection

Alloy 800 sleeves are not expected to be in operation exceeding one cycle and, hence,no inservice inspection is expected. However, should inservice inspection be needed,examination will be performed on the full length of 100 percent of the leak limitingAlloy 800 sleeve/tube assemblies (i.e., the sleeve-to-tube joint) using Plus Point probesor an equivalent EPRI Appendix H qualified technique, if available. This inspectionfrequency exceeds the 20 percent sampling requirement of Section 3.4.1 of EPRITechnical Report 1003138 and therefore is conservative with respect to current industryrequirements.

Plugging Requirements for Tubes With Alloy 800 Sleeves

To ensure that a defect in the pressure boundary of a sleeve does not adversely impactthe leakage integrity of the sleeve, a sleeved tube will be plugged if an imperfection isdetected in any portion of the sleeve. In addition, to ensure that a defect in the pressureboundary of a sleeve does not adversely impact the structural integrity of the sleeve, asleeved tube will be plugged if an imperfection is detected in the pressure boundaryportion of the original tube wall in the leak limiting sleeve/tube assembly (i.e., at thesleeve-tube joint(s)). Imperfections that are detected in the non-pressure boundaryportion of the original parent tube wall associated with a sleeve do not impact thepressure boundary of the sleeve/tube assembly and do not impact the structural integrityof the sleeve.

Effects of Sleeving on Operation

The effects of sleeve installation on SG heat removal capability and reactor coolantsystem flow rate are discussed in Section 10 of WCAP-15919-P, which in summarystates that the installation of the sleeves does not substantially affect the primary systemflow rate or the heat transfer capability of the SGs. The typical hydraulic equivalencyof plugs and installed sleeves, called the sleeve/plug ratio or sleeve to plug equivalencyratio, is contained in Table 10-1 of WCAP-15919-P for different configurations of TZsleeves and TS sleeves in 7/8 inch OD SG tubes. The Table 10-1 sleeve/plug ratiovalues are an approximation only based on assumed operating parameters and sleevetypes for SGs with 7/8 inch tubes and some variations in the sleeve/plug ratio will occurbased on operating parameters and SG conditions. FENOC will use the sleeve/plugratio values contained in Table 10-1 of WCAP-15919-P to determine the equivalent SGplugging due to installed leak limiting Alloy 800 sleeves, unless more appropriatevalues become available. The total SG plugging level for each SG will be determinedby adding the equivalent SG plugging percentage due to installed leak limiting Alloy

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800 sleeves to the percent of SG tubes plugged. The total SG plugging level must bemaintained less than the limit allowed by accident analyses of record.

Alloy 800 was designed for SG tubing as an alternative to Alloy 600 and is comprisedof the same three major metallurgical components (nickel, iron, chrome) as Alloys 600and 690. It has been in use in SGs for many years in European nuclear plants and hasperformed well in a primary chemistry environment similar to BVPS Unit No. 1.Therefore, Alloy 800 is compatible with the primary chemistry regime used at BVPSUnit No. 1 and no changes to this regime are necessary.

Relationship between TS Sleeves and TSP ARC

For sleeves installed at Tube Support Plate (TSP) locations, TSP Outside DiameterStress Corrosion Cracking (ODSCC) ARC will no longer apply to the sleeved TSPintersections. No Technical Specification change is necessary to clarify this relationshipfor sleeved tubes because the sleeve will remove the TSP ODSCC ARC indicationsfrom service.

Severe Accident Considerations

Severe accidents can lead to high primary pressure of 2500 psi and high primarytemperature between 1200'F and 1500'F. At severe accident conditions, pressure tendsto loosen the tube joint and temperature tends to tighten it. As the temperature reaches1500'F, both the sleeve and tube yield at steam line break pressures. Because the sleevematerial is specified to have a low yield stress (30 ksi minimum and controlledmaximum), the sleeve will yield at a lower temperature (or pressure) than the tube,thereby tending to tighten the tube joint. At 1500'F, the ultimate stress of the sleevematerial is comparable to that of the SG tube and the integrity of the sleeve repair iscommensurate with the integrity of the inservice SG tubes. Therefore, under severeaccident conditions, sleeving is expected to have no impact on the plant risk.

Conclusion

Based on past usage, extensive testing, and analysis, the leak limiting Alloy 800 sleevesprovide satisfactory repair of defective SG tubes. Design criteria were established basedon the requirements of the ASME Code and RG 1.121.

Precedent

The NRC has previously approved the use of leak limiting Alloy 800 sleeves for theWatts Bar Nuclear Plant Unit 1 in License Amendment No. 44 to Facility Operating

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i~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~


License No. NPF-90, "Watts Bar Nuclear Plant, Unit 1 - Issuance of Amendment forSteam Generator Tube Repair (TAC No. MB6976)," dated August 15, 2003 (ADAMS #ML032300143), and for the Calvert Cliffs plant in License Amendment No. 231 toFacility Operating License No. DPR-53 and Amendment No. 207 to Facility OperatingLicense No. DPR-69, "Calvert Cliffs Nuclear Power Plant, Unit Nos. 1 and 2 - Issuanceof Amendment RE: Steam Generator Tube Repair Using Leak Limiting Alloy 800Sleeves (TAC Nos. MA4278 and MA4279)," dated September 1, 1999 (ADAMS #MLI010520103).

Calvert Cliffs applied the technique in ABB-Combustion Engineering Report CEN-633-P, Revision 3, "Steam Generator Tube Repair for Combustion Engineering DesignedPlants with 3/4 - .048" Wall Inconel 600 Tubes Using Leak Limiting Alloy 800Sleeves," dated October 1998 (ABB-Combustion Engineering proprietary) as the basisfor the acceptability of the leak limiting Alloy 800 sleeve. Watts Bar applied thetechnique in Westinghouse WCAP-15918-P, Revision 0, (CEN-633-P, Revision 05-P),"Steam Generator Tube Repair for Combustion Engineering and WestinghouseDesigned Plant with 3/4 Inch Inconel 600 tubes Using Leak Limiting Alloy 800Sleeves," dated November 2002 (proprietary) as the basis for the acceptability of theleak limiting Alloy 800 sleeve.

Revision 3 of the CEN-633-P report addressed the specific 3/4 inch O.D. 0.048 inchwall thickness SG tube size contained in the Calvert Cliffs Combustion EngineeringSGs. Since 1998, the CEN-633-P, Revision 3, report was revised to include additionaltesting and analysis, to incorporate other industry comments, to reflect the purchase ofABB-Combustion Engineering by Westinghouse, and to include evaluation for SG tuberepair for Westinghouse designed plants with 3/4 inch O.D. Inconel 600 tubes.Westinghouse WCAP-15918-P, Revision 0, (CEN-633-P, Revision 05-P), "SteamGenerator Tube Repair for Combustion Engineering and Westinghouse Designed Plantwith 3/4 Inch Inconel 600 tubes Using Leak Limiting Alloy 800 Sleeves," datedNovember 2002 (proprietary) provides the basis for SG tube repair using leak limitingAlloy 800 sleeves for Westinghouse plants with 3/4 inch Inconel 600 tubes.

The Westinghouse WCAP-15918-P, Revision 00, (CEN-633-P, Revision 05-P), reporthas been updated to address Westinghouse plants with 7/8 inch O.D. Inconel 600 tubesin Westinghouse WCAP-15919-P, Revision 00, "Steam Generator Tube Repair forWestinghouse Designed Plants with 7/8 Inch Inconel 600 Tubes Using Leak LimitingAlloy 800 Sleeves," dated August 2003 (proprietary). The FENOC request for approvalto use leak limiting Alloy 800 sleeves is based on Westinghouse WCAP-15919-P,Revision 00.

Page 12


A similar request for NRC approval to use leak limiting Alloy 800 sleeves has beenmade based on WCAP-15918-P, Revision 00, (CEN-633-P, Revision 05-P), by TXUGeneration Company LP (TXU Energy) for Comanche Peak Steam Electric Station inthe letter CPSES-200301190, "Comanche Peak Steam Electric Station (CPSES), DocketNos. 50-445 and 50-446, License Amendment Request (LAR) 03-03, Revision toTechnical Specification 5.5.9, Steam Generator Repair Using Leak Limiting Alloy 800Sleeves," dated July 21, 2003 (ADAMS # ML032120445).

A similar request for NRC approval to use leak limiting Alloy 800 sleeves has beenmade based on WCAP-15919-P, Revision 00, by Pacific Gas & Electric Company(PG&E) for Diablo Canyon Power Plant Units 1 and 2, PG&E letter DCL-03-132,Diablo Canyon Power Plant Units 1 and 2 Docket Nos. 50-275 and 50-323, LicenseAmendment Request (AR) 03-15, "Steam Generator Tube Repair Using LeakLimiting Alloy 800 Sleeves" and Revision to Technical Specification Table 5.5.9.-2,"Steam Generator Tube Inspection" dated October 22, 2003 (ADAMS # 033010563).

5.0 REGULATORY SAFETY ANALYSIS

FirstEnergy Nuclear Operating Company (FENOC) is proposing to modify the BeaverValley Power Station (BVPS) Unit I Technical Specification to revise SurveillanceRequirement (SR) 4.4.5.4.a.6 and SR 4.4.5.4.a.9. These two SRs currently describeplugging and repair criteria which allows for Westinghouse laser welded sleeves and theformer ABB Combustion Engineering tungsten inert gas (TIG) welded sleeves. TheseSRs are proposed to be revised to also list Westinghouse Alloy 800 leak limiting sleevesas an additionally acceptable sleeve method. The proposed ability to utilizeWestinghouse Alloy 800 leak limiting sleeves is only being requested for Cycle 17 ofBVPS Unit No. 1 and will include a note indicating that Alloy 800 sleeves are onlyapplicable to Cycle 17. SR 4.4.5.4.a.6 will also include a note indicating that tubesrepaired with Alloy 800 leak limiting sleeves will be plugged on detection of anyservice induced imperfection, degradation or defect in the sleeve or in the pressureboundary portion of the original tube wall in the leak limiting sleeve/tube assembly. SR4.4.5.2.b.3 is proposed to be revised to require an inspection of all inservice Alloy 800sleeves during each refueling outage.

5.1 No Significant Hazards Consideration

FENOC has evaluated whether or not a significant hazards consideration is involvedwith the proposed amendments by focusing on the three standards set forth inIOCFR50.92, "Issuance of amendment," as discussed below:

Page 13


1. Does the proposed change involve a significant increase in the probability orconsequences of an accident previously evaluated?

No.

The leak limiting Alloy 800 sleeves are designed using the applicable AmericanSociety of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code and,therefore, meet the design objectives of the original steam generator (SG) tubing.The applied stresses and fatigue usage for the sleeves are bounded by the limitsestablished in the ASME Code. Mechanical testing has shown that the structuralstrength of sleeves under normal, upset, emergency, and faulted conditions providesmargin to the acceptance limits. These acceptance limits bound the most limiting(three times normal operating pressure differential) burst margin recommended byNRC Regulatory Guide 1.121, "Bases for Plugging Degraded PWR Steam GeneratorTubes." Burst testing of sleeve-tube assemblies has confirmed the analytical resultsand demonstrated that no unacceptable levels of primary-to-secondary leakage areexpected during any plant condition.

The leak limiting Alloy 800 sleeve depth-based structural limit is determined usingNRC guidance and the pressure stress equation of ASME Code, Section III withadditional margin added to account for the configuration of long axial cracks. AnAlloy 800 sleeved tube will be plugged on detection of an imperfection in the sleeveor in the pressure boundary portion of the original tube wall in the leak limitingsleeve/tube assembly.

Evaluation of the repaired SG tube testing and analysis indicates no detrimentaleffects on the leak limiting Alloy 800 sleeve or sleeved tube assembly from reactorsystem flow, primary or secondary coolant chemistries, thermal conditions ortransients, or pressure conditions as may be experienced at Beaver Valley PowerStation (BVPS) Unit 1. Corrosion testing and historical performance of sleeve-tubeassemblies indicates no evidence of sleeve or tube corrosion considered detrimentalunder anticipated service conditions.

The implementation of the proposed change has no significant effect on either theconfiguration of the plant or the manner in which it is operated. The consequences ofa hypothetical failure of the leak limiting Alloy 800 sleeve-tube assembly is boundedby the current SG tube rupture (SGTR) analysis described in the BVPS Unit No. IUpdated Final Safety Analysis Report. Due to the slight reduction in the insidediameter caused by the sleeve wall thickness, primary coolant release rates through'the parent tube would be slightly less than assumed for the SGTR analysis andtherefore, would result in lower total primary fluid mass release to the secondary

Page 14


system. A main steam line break or feedwater line break will not cause a SGTRsince the sleeves are analyzed for a maximum accident differential pressure greaterthan that predicted in the BVPS Unit No. 1 safety analysis. The sleeve-tubeassembly leakage during plant operation would be minimal and is well within theallowable Technical Specification leakage limits.

Therefore, the proposed change does not involve a significant increase in theprobability or consequences of an accident previously evaluated.

2. Does the proposed change create the possibility of a new or different kind ofaccident from any accident previously evaluated?

No.

The leak limiting Alloy 800 sleeves are designed using the applicable ASME Codeas guidance, and therefore meet the objectives of the original SG tubing. As a result,the functions of the SG will not be significantly affected by the installation of theproposed sleeve. The proposed sleeves do not interact with any other plant systems.Any accident as a result of potential tube or sleeve degradation in the repairedportion of the tube is bounded by the existing SGTR accident analysis. Thecontinued integrity of the installed sleeve-tube assembly is periodically verified bythe Technical Specification requirements and a sleeved tube will be plugged ondetection of an imperfection in the sleeve or in the pressure boundary portion of theoriginal tube wall in the leak limiting sleeve/tube assembly.

Implementation of the proposed change has no significant effect on either theconfiguration of the plant, or the manner in which it is operated.

Therefore, the proposed change does not create the possibility of a new or differentaccident from any accident previously evaluated.

3. Does the proposed change involve a significant reduction in a margin of safety?

No.

The repair of degraded SG tubes with leak limiting Alloy 800 sleeves restores thestructural integrity of the degraded tube under normal operating and postulatedaccident conditions. The reduction in core cooling margin due to the addition ofAlloy 800 sleeves is not significant because the cumulative effect of all repaired(sleeved) and plugged tubes will continue to be less than the currently allowed corecooling margin threshold established by the total steam generator tube plugging

Page 15


level. The design safety factors utilized for the sleeves are consistent with the safetyfactors in the ASME Boiler and Pressure Vessel Code used in the original SGdesign. The sleeve and portions of the installed sleeve-tube assembly that representthe reactor coolant pressure boundary will be monitored and a sleeved tube will beplugged on detection of an imperfection in the sleeve or in the pressure boundaryportion of the original tube wall in the leak limiting sleeve/tube assembly. Use ofthe previously identified design criteria and design verification testing assures thatthe margin to safety is not significantly different from the original SG tubes.

Therefore, the proposed change does not involve a significant reduction in a marginof safety.

Based on the above, FENOC concludes that the proposed amendments present nosignificant hazards consideration under the standards set forth in 10CFR50.92(c), and,accordingly, a finding of "no significant hazards consideration" is justified.

5.2 Applicable Regulatory Requirements/Criteria

Title 10 of the Code of Federal Regulations Part 50 (10 CFR 50), Appendix A, "GeneralDesign Criterion (GDC)," Criterion 14, Reactor Coolant Pressure Boundary, containsrequirements applicable to SG tubes since they are part of the reactor coolant pressureboundary. GDC 14 requires that the reactor coolant pressure boundary be designed,fabricated, erected, and tested in order to have an extremely low probability of abnormalleakage, of rapidly propagating failure, and of gross failure. The repair of the existingreactor coolant pressure boundary is performed in accordance with Section XI of ASMEBoiler and Pressure Vessel Code, which refers to Section III of the ASME Code. Theoriginal SG tubes are designed in accordance with Section III of the ASME Code (1965edition through Summer 1967 addenda). The design criteria for the leak limitingsleeves were established to meet the loading condition and stress requirements ofSection III of the ASME Code (1995 edition, no addenda), which is consistent with thesection of the ASME Code that applies to the original SG tubes.

10 CFR 50, Appendix B, "Quality Assurance Criteria for Nuclear Power Plants andFuel Reprocessing Plants," requires a quality assurance program for the design,fabrication, construction, and operation of structures, systems, and components innuclear power plants. The requirements of Appendix B apply to all activities affectingthe safety-related functions of those structures, systems, and components. The activitiesinclude designing, purchasing, fabricating, handling, shipping, storing, cleaning,erecting, installing, inspecting, testing, operating, maintaining, repairing, refueling, andmodifying safety-related structures, systems and components. The leak limiting sleeves

Page 16


are considered safety-related components and therefore will be required to meet theAppendix B requirements.

Regulatory Guide (RG) 1.121 provides guidance for determining the minimum wallthickness at which a SG tube should be plugged. The RG 1.121 performance criteriarecommend that the margin of safety against SGTR under normal operating conditionsshould not be less than 3 at any tube location where defects have been detected. Themargin of safety against tube failures under postulated accident conditions should beconsistent with the margin of safety determined by the stress limits specified in theASME Code. The RG 1.121 requirements were used to develop the structural limit ofleak limiting Alloy 800 sleeve should sleeve wall degradation occur. In addition, thefatigue and stress analysis of the sleeved tube assemblies have been completed inaccordance with the requirements of RG 1.121.

Based on past usage, extensive testing and analysis, the leak limiting Alloy 800 sleevesprovide satisfactory repair of degraded SG tubes. Qualified nondestructive examinationtechniques will be used to perform necessary sleeve and parent SG tube inspections fordefect detection, and to verify proper installation of the repair sleeve.

In conclusion, based on the considerations discussed above, (1) there is reasonableassurance that the health and safety of the public will not be endangered by operation inthe proposed manner, (2) such activities will be conducted in compliance with theCommission's regulations, and (3) the issuance of the amendment will not be inimicalto the common defense and security or to the health and safety of the public.

6.0 ENVIRONMENTAL CONSIDERATION

A review has determined that the proposed amendment would change a requirementwith respect to installation or use of a facility component located within the restrictedarea, as defined in 10CFR20, or would change an inspection or surveillancerequirement. However, the proposed amendment does not involve (i) a significanthazards consideration, (ii) a significant change in the types or significant increase in theamounts of any effluent that may be released offsite, or (iii) a significant increase inindividual or cumulative occupational radiation exposure. Accordingly, the proposedamendment meets the eligibility criterion for categorical exclusion set forth in10CFR51.22(c)(9). Therefore, pursuant to 10CFR51.22(b), no environmental impactstatement or environmental assessment need be prepared in connection with theproposed amendment.

Page 17

I


7.0 REFERENCES

1. Westinghouse Electric LLC WCAP-15919-P, Revision 00, "Steam Generator TubeRepair for Westinghouse Designed Plants with 7/8 Inch Inconel 600 Tubes UsingLeak Limiting Alloy 800 Sleeves," dated August 2003 (proprietary).

2. Westinghouse Electric LLC WCAP-15919-NP, Revision 00, "Steam Generator TubeRepair for Westinghouse Designed Plants with 7/8 Inch Inconel 600 Tubes UsingLeak Limiting Alloy 800 Sleeves," dated August 2003 (nonproprietary).

3. American Society of Mechanical Engineers (ASME) Boiler and Pressure VesselCode, Section II, Part B, SB-163, NiFeCr Alloy UNS N08800, and Section III,Subsection NB-2000.

4. Regulatory Guide 1.85, "Materials Code Case Acceptability ASME Section III,Division 1," Revision 24, dated July 1986.

5. Regulatory Guide 1.121, "Bases for Plugging Degraded PWR Steam GeneratorTubes," dated August, 1976.

6. EPRI Technical Report 10001191, "Steam Generator Degradation SpecificManagement Flaw Handbook," dated 2001.

7. EPRI Technical Report TR-107569-VIR5, "PWR Steam Generator ExaminationGuidelines: Revision 5, Volume 1: Requirements," dated September, 1997.

8. EPRI Technical Report 1003138, "Pressurized Water Reactor Steam GeneratorExamination Guidelines: Revision 6, Requirements," dated October, 2002.

9. ABB-Combustion Engineering Report CEN-633-P, Revision 3, "Steam GeneratorTube Repair for Combustion Engineering Designed Plants with 3/4" - .048" WallInconel 600 Tubes Using Leak Limiting Alloy 800 Sleeves," dated October 1998(proprietary).

10.Westinghouse Electric LLC WCAP-15918-P, Revision 00, (CEN-633-P, Revision05-P), "Steam Generator Tube Repair for Combustion Engineering andWestinghouse Designed Plant with 3 Inch Inconel 600 tubes Using Leak LimitingAlloy 800 Sleeves," dated November 2002 (proprietary).

1. Westinghouse Electric LLC WCAP-14797, Revision 1, "Generic W* Tube PluggingCriteria for 51 Series Steam Generator Tubesheet Region WEXTEX Expansions,"dated February 1997 (proprietary).

Page 18


12. Westinghouse Electric LLC WCAP-14798, Revision 1, "Generic W* Tube PluggingCriteria for 51 Series Steam Generator Tubesheet Region WEXTEX Expansions,"dated February 1997 (nonproprietary).

13.License Amendment No. 231 to Facility Operating License No. DPR-53 andAmendment No. 207 to Facility Operating License No. DPR-69, "Calvert CliffsNuclear Power Plant, Unit Nos. 1 and 2 - Issuance of Amendment RE: SteamGenerator Tube Repair Using Leak Limiting Alloy 800 Sleeves (TAC Nos. MA4278and MA4279)," dated September 1, 1999 (ADAMS # ML010520103).

14.Tennessee Valley Authority letter "Watts Bar Nuclear Plant (WBN) - Unit 1 -Proposed License Amendment Request Change No. WBN-S-02-16 - SteamGenerator Tube Repair Sleeve," dated December 13, 2002 (ADAMS #ML023520628).

15.TXU Generation Company LP (TXU Energy) letter CPSES-200301190, "ComanchePeak Steam Electric Station (CPSES), Docket Nos. 50-445 and 50-446, LicenseAmendment Request (LAR) 03-03, Revision to Technical Specification 5.5.9, SteamGenerator Repair Using Leak Limiting Alloy 800 Sleeves," dated July 21, 2003(ADAMS # ML032120445).

16.Pacific Gas & Electric Company (PG&E) letter DCL-03-132, "Diablo CanyonPower Plant Units 1 and 2 Docket Nos. 50-275 and 50-323, License AmendmentRequest (LAR) 03-15, "Steam Generator Tube Repair Using Leak Limiting Alloy800 Sleeves and Revision to Technical Specification Table 5.5.9.-2, "SteamGenerator (SG) Tube Inspection". dated October 22, 2003 (ADAMS #ML033010563).

17. Beaver Valley Power Station Unit No. I Updated Final Safety Analysis Report.

Page 19

W estinghouse Westinghouse Electric CompanyNuclear ServicesP.O. Box 355Pittsburgh Pennsylvania 15230-0355USA

U.S. Nuclear Regulatory Commission Direct tel: (412) 374-5036Document Control Desk Directfax: (412) 3744011Washington, DC 20555-0001 e-mail: [email protected]

Our ref: CAW-03-1750

December 5, 2003

APPLICATION FOR WITHHOLDING PROPRIETARYINFORMATION FROM PUBLIC DISCLOSURE

Subject: WCAP-15919-P, "Steam Generator Tube Repair for Westinghouse Designed Plants with7/8 Inch Inconel 600 Tubes Using Leak Limiting Alloy 800 Sleeves" (Proprietary)

The proprietary information for which withholding is being requested in the above-referenced report isfurther identified in Affidavit CAW-03-1750 signed by the owner of the proprietary information,Westinghouse Electric Company LLC. The affidavit, which accompanies this letter, sets forth the basison which the information may be withheld from public disclosure by the Commission and addresses withspecificity the considerations listed in paragraph (b)(4) of 10 CFR Section 2.790 of the Commission'sregulations.

Accordingly, this letter authorizes the utilization of the accompanying affidavit by First Energy NuclearOperating Company.

Correspondence with respect to the proprietary aspects of the application for withholding or theWestinghouse affidavit should reference this letter, CAW-03-1750, and should be addressed toJ. S. Galembush, Acting Manager, Regulatory Compliance and Plant Licensing, Westinghouse ElectricCompany LLC, P.O. Box 355, Pittsburgh, Pennsylvania 15230-0355.

Very truly yours,

J. S. u , Acting ManagerRegulatory Compliance and Plant Licensing

Enclosures

cc: D. HollandB. BenneyE. Peyton

A BNFL Group company

CAW-03-1750

bcc: J. S. Galembush (ECE 4-7A) ILR. Bastien, IL, IA (Nivelles, Belgium)C. Brinkman, IL, IA (Westinghouse Electric Co., 12300 Twinbrook Parkway, Suite 330, Rockville, MD 20852)RCPL Administrative Aide (ECE 4-7A) I L, IA (letter and affidavit only)R. J. Sterdis, Waltz MillE. A. Dzenis, ECE 4-3G. W. Whiteman, ECE-410CR. F. Keating, Waltz MillW. K. Cullen, Waltz MillN. B. Closky, ECE 4-3

A BNFL Group company

CAW-03-1 750

AFFIDAVIT

COMMONWEALTH OF PENNSYLVANIA:

ss

COUNTY OF ALLEGHENY:

Before me, the undersigned authority, personally appeared H. A. Sepp, who, being by me duly

sworn according to law, deposes and says that he is authorized to execute this Affidavit on behalf of

Westinghouse Electric Company LLC (Westinghouse), and that the averments of fact set forth in this

Affidavit are true and correct to the best of his knowledge, information, and belief:

c24/H. A. Sepp, Manager

Regulatory Compliance and Plant Licensing

Sworn to and subscribed

before me this L day

of Z 2003

A,71/Notary Public

I.~ '';*i; L-;;';'j;;NotarW SealSharon L oro Noary c

7#~ ~ ~ ~ ~~~~~~Mnov~ to.o -no Cou *n,0XyMY Ccrss ores ma y 292 007

o *rn', Member. Pensqvaia Assodation of Ntaies

2 CAW-03-1750

(1) I am Manager, Regulatory Compliance and Plant Licensing, in Nuclear Services, Westinghouse

Electric Company LLC (Westinghouse), and as such, I have been specifically delegated the

function of reviewing the proprietary information sought to be withheld from public disclosure in

connection with nuclear power plant licensing and rule making proceedings, and am authorized to

apply for its withholding on behalf of Westinghouse.

(2) 1 am making this Affidavit in conformance with the provisions of 10 CFR Section 2.790 of the

Commission's regulations and in conjunction with the Westinghouse "Application for

Withholding" accompanying this Affidavit.

(3) I have personal knowledge of the criteria and procedures utilized by Westinghouse in designating

information as a trade secret, privileged or as confidential commercial or financial information.

(4) Pursuant to the provisions of paragraph (b)(4) of Section 2.790 of the Commission's regulations,

the following is furnished for consideration by the Commission in determining whether the

information sought to be withheld from public disclosure should be withheld.

(i) The information sought to be withheld from public disclosure is owned and has been held

in confidence by Westinghouse.

(ii) The information is of a type customarily held in confidence by Westinghouse and not

customarily disclosed to the public. Westinghouse has a rational basis for determining

the types of information customarily held in confidence by it and, in that connection,

utilizes a system to determine when and whether to hold certain types of information in

confidence. The application of that system and the substance of that system constitutes

Westinghouse policy and provides the rational basis required.

Under that system, information is held in confidence if it falls in one or more of several

types, the release of which might result in the loss of an existing or potential competitive

advantage, as follows:

(a) The information reveals the distinguishing aspects of a process (or component,

structure, tool, method, etc.) where prevention of its use by any of

Westinghouse's competitors without license from Westinghouse constitutes a

competitive economic advantage over other companies.

3 CAW-03-1750

(b) It consists of supporting data, including test data, relative to a process (or

component, structure, tool, method, etc.), the application of which data secures a

competitive economic advantage, e.g., by optimization or improved

marketability.

(c) Its use by a competitor would reduce his expenditure of resources or improve his

competitive position in the design, manufacture, shipment, installation, assurance

of quality, or licensing a similar product.

(d) It reveals cost or price information, production capacities, budget levels, or

commercial strategies of Westinghouse, its customers or suppliers.

(e) It reveals aspects of past, present, or future Westinghouse or customer funded

development plans and programs of potential commercial value to Westinghouse.

(f) It contains patentable ideas, for which patent protection may be desirable.

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

following:

(a) The use of such information by Westinghouse gives Westinghouse a competitive

advantage over its competitors. It is, therefore, withheld from disclosure to

protect the Westinghouse competitive position.

(b) It is information that is marketable in many ways. The extent to which such

information is available to competitors diminishes the Westinghouse ability to

sell products and services involving the use of the information.

(c) Use by our competitor would put Westinghouse at a competitive disadvantage by

reducing his expenditure of resources at our expense.

(d) Each component of proprietary information pertinent to a particular competitive

advantage is potentially as valuable as the total competitive advantage. If

competitors acquire components of proprietary information, any one component

4 CAW-03-1 750

may be the key to the entire puzzle, thereby depriving Westinghouse of a

competitive advantage.

(e) Unrestricted disclosure would jeopardize the position of prominence of

Westinghouse in the world market, and thereby give a market advantage to the

competition of those countries.

(f) The Westinghouse capacity to invest corporate assets in research and

development depends upon the success in obtaining and maintaining a

competitive advantage.

(iii) The information is being transmitted to the Commission in confidence and, under the

provisions of 10 CFR Section 2.790, it is to be received in confidence by the

Commission.

(iv) The information sought to be protected is not available in public sources or available

information has not been previously employed in the same original manner or method to

the best of our knowledge and belief.

(v) The proprietary information sought to be withheld in this submittal is that which is

appropriately marked in WCAP-I5919-P, "Steam Generator Tube Repair for

Westinghouse Designed Plants with 7/8 Inch Inconel 600 Tubes Using Leak Limiting

Alloy 800 Sleeves" (Proprietary) dated August 2003. The information is provided in

support of a submittal to the Commission, being transmitted by FirstEnergy Nuclear

Operating Company letter (FENOC-03-223) and Application for Withholding Proprietary

Information from Public Disclosure, to the Document Control Desk. The proprietary

information as submitted for use by Westinghouse for Beaver Valley Unit I is expected

to be applicable for other licensee submittals in support of the installation of Alloy 800

sleeves that span the degraded sections of the original steam generator tubes.

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

(a) Discuss the design features of the Alloy 800 sleeve.

5 CAW-03- 1750

(b) Document the acceptability of installing Alloy 800 sleeves for the repair of the hot or

cold leg of the Beaver Valley Unit I steam generator tubes.

(c) Discuss analysis and testing programs used in support of the development of the

Alloy 800 sleeves.

Further this information has substantial commercial value as follows:

(a) Westinghouse plans to sell the use of similar information to its customers for

purposes of meeting NRC requirements for licensing documentation.

(b) Westinghouse can sell support and defense of this information to its customers in

the licensing process.

(c) The information requested to be withheld reveals the distinguishing aspects of a

methodology which was developed by Westinghouse.

Public disclosure of this proprietary information is likely to cause substantial harm to the

competitive position of Westinghouse because it would enhance the ability of

competitors to provide similar licensing support documentation and licensing defense

services for commercial power reactors without commensurate expenses. Also, public

disclosure of the information would enable others to use the information to meet NRC

requirements for licensing documentation without purchasing the right to use the

information.

The development of the technology described in part by the information is the result of

applying the results of many years of experience in an intensive Westinghouse effort and

the expenditure of a considerable sum of money.

In order for competitors of Westinghouse to duplicate this information, similar technical

programs would have to be performed and a significant manpower effort, having the

requisite talent and experience, would have to be expended.

Further the deponent sayeth not.

PROPRIETARY INFORMATION NOTICE

Transmitted herewith are proprietary and/or non-proprietary versions of documents furnished to the NRCin connection with requests for generic and/or plant-specific review and approval.

In order to conform to the requirements of 10 CFR 2.790 of the Commission's regulations concerning theprotection of proprietary information so submitted to the NRC, the information which is proprietary in theproprietary versions is contained within brackets, and where the proprietary information has been deletedin the non-proprietary versions, only the brackets remain (the information that was contained within thebrackets in the proprietary versions having been deleted). The justification for claiming the informationso designated as proprietary is indicated in both versions by means of lower case letters (a) through (f)located as a superscript immediately following the brackets enclosing each item of information beingidentified as proprietary or in the margin opposite such information. These lower case letters refer to thetypes of information Westinghouse customarily holds in confidence identified in Sections (4)(ii)(a)through (4)(ii)(f) of the affidavit accompanying this transmittal pursuant to 10 CFR 2.790(b)(1).

COPYRIGHT NOTICE

The reports transmitted herewith each bear a Westinghouse copyright notice. The NRC is permitted tomake the number of copies of the information contained in these reports which are necessary for itsinternal use in connection with generic and plant-specific reviews and approvals as well as the issuance,denial, amendment, transfer, renewal, modification, suspension, revocation, or violation of a license,permit, order, or regulation subject to the requirements of 10 CFR 2.790 regarding restrictions on publicdisclosure to the extent such information has been identified as proprietary by Westinghouse, copyrightprotection notwithstanding. With respect to the non-proprietary versions of these reports, the NRC ispermitted to make the number of copies beyond those necessary for its internal use which are necessary inorder to have one copy available for public viewing in the appropriate docket files in the public documentroom in Washington, DC and in local public document rooms as may be required by NRC regulations ifthe number of copies submitted is insufficient for this purpose. Copies made by the NRC must includethe copyright notice in all instances and the proprietary notice if the original was identified as proprietary.

Attachment A


Proposed Technical Specification Changes

The following are the affected pages:

3/4 4-9

3/4 4-lOb

3/4 4-1Oc

i

REACTOR COOLANT SYSTEM

SURVEILLANCE REQUIREMENTS (Continued)

2. Tubes in those areas where experience has indicatedpotential problems, and

3. Except for Alloy 800 leak-limitingsleeves, at least 3percent of the total number of sleeved tubes in allthree steam generators. A sample size less than 3percent is acceptable provided all the sleeved tubesin the steam generator(s) examined during therefueling outage are inspected. AllJinservice Alloy800 -sleeves sh thebefuni -- ln-cth

3 x ~ 1 g a p x s p ~ n t c j J r e a ui va l n t ui a i e dhtechr refurn ehelin Theseinspections will include both the tube and the sleeve,and

4. A tube inspection pursuant to Specification4.4.5.4.a.8. If any selected tube does not permit thepassage of the eddy current probe for a tube or sleeveinspection, this shall be recorded and an adjacenttube shall be selected and subjected to a tubeinspection.

5. Indications left in service as a result of applicationof the tube support plate voltage-based repaircriteria (4.4.5.4.a.10) shall be inspected by bobbincoil probe during all future refueling outages.

c. The tubes selected as the second and third samples (ifrequired by Table 4.4-2) during each inservice inspectionmay be subjected to a partial tube inspection provided:

1. The tubes selected for these samples include the tubesfrom those areas of the tube sheet array where tubeswith imperfections were previously found, and

2. The inspections include those portions of the tubeswhere imperfections were previously found.

d. Implementation of the steam generator tube-to-tube supportplate repair criteria requires a 100-percent bobbin coilinspection for hot-leg and cold-leg tube support plateintersections down to the lowest cold-leg tube supportplate with known outside diameter stress corrosion cracking(ODSCC) indications. The determination of the lowest cold-leg tube support plate intersections having ODSCCindications shall be based on the performance of at least a20-percent random sampling of tubes inspected over theirfull length.

The results of each sample inspection shall be classified into one ofthe following three categories:

BEAVER VALLEY - UNIT 1 3/4 4-9 Amendment No. 479-

DPR-66REACTOR COOLANT SYSTEM


6. Plugging or Repair Limit means the imperfection depth at orbeyond which the tube shall be removed from service byplugging or repaired by sleeving in the affected areabecause it may become unserviceable prior to the nextinspection. The plugging or repair limit imperfectiondepths are specified in percentage of nominal wall thicknessas follows:

a) Original tube wall 40%

This definition does not apply to tube support plateintersections for which the voltage-based repair criteriaare being applied. Refer to 4.4.5.4.a.10 for the repairlimit applicable to these intersections.

b) ABB Combustion Engineering TIG weldedsleeve wall 32%

c) Westinghouse laser welded sleeve wall 25%

d) Westi ouse Alloy 800 leak iting a sleeve*: Plugondetection of any srie induced iPerfction.degradation or efect in t (a) Ileeado bIpressre bsadry oortion of the original tubewllin the sleeve/tube ass blyi.e. the sleeve-to-tube joint).

7. Unserviceable describes the condition of a tube if it leaksor contains a defect large enough to affect its structuralintegrity in the event of an Operating Basis Earthquake, aloss-of-coolant accident, or a steamline or feedwater linebreak as specified in 4.4.5.3.c, above.

8. Tube Inspection means an inspection of the steam generatortube from the point of entry (hot-leg side) completelyaround the U-bend to the top support to the cold-leg.

9. Tube Repair refers to sleeving which is used to maintain atube in-service or return a tube to service. This includesthe removal of plugs that were installed as a corrective orpreventive measure. The following sleeve designs have beenfound acceptable:

a) ABB Combustion Engineering TIG Welded Sleeves, CEN-629-P,Revision 02 and CEN-629-P Addendum 1.

b) Westinghouse laser welded sleeves, WCAP-13483, Revision 1.

.i p.PicahLe only to Ce 17.|

BEAVER VALLEY - UNIT 3/4 4-10b Amendment No. 2-1-

REACTOR COOLANT SYSTEM


Westinghouse Alloy 800 sleeves, WCAP-15919-P IRevision 00. *

10. Tube Support Plate Plugging Limit is used for thedisposition of an alloy 600 steam generator tube forcontinued service that is experiencing predominantlyaxially oriented' outside diameter stress corrosioncracking confined within the thickness of the tubesupport plates. At tube support plate intersections,the plugging (repair) limit is based on maintainingsteam generator tube serviceability as describedbelow:

a) Steam generator tubes, whose degradation isattributed to outside diameter stress corrosioncracking within the bounds of the tube supportplate with bobbin voltages less than or equal to2.0 volts will be allowed to remain in service.

b) Steam generator tubes, whose degradation isattributed to outside diameter stress corrosioncracking within the bounds of the tube supportplate with a bobbin voltage greater than 2.0volts will be repaired or plugged, except asnoted in 4.4.5.4.a.10.c below.

c) Steam generator tubes, with indications ofpotential degradation attributed to outsidediameter stress corrosion cracking within thebounds of the tube support plate with a bobbinvoltage greater than 2.0 volts but less than orequal to the upper voltage repair limit(l) mayremain in service if a rotating pancake coil oracceptable alternative inspection does notdetect degradation. Steam generator tubes, withindications of outside diameter stress corrosioncracking degradation with a bobbin voltagegreater than the upper voltage repair limit(l)will be plugged or repaired.

d) If an unscheduled mid-cycle inspection isperformed, the following mid-cycle repair limitsapply instead of the limits identified in4.4.5.4.a.10.a, 4.4.5.4.a.10.b, and4.4.5.4.a.10.c.

* Appicable only ts Cycle 17.

(1) The upper voltage repair limit is calculated according to themethodology in Generic Letter 95-05 as supplemented.

BEAVER VALLEY - UNIT 1 3/4 4-10c Amendment No. 29

Attachment B


Proposed Technical Specification Bases Changes

Technical Specification Bases changes are provided for information only.

The following is the only affected page:

B 3/4 4-2

DPR-66REACTOR COOLANT SYSTEM

BASES

3/4.4.5 STEAM GENERATORS (Continued)

ProIidedforInformation Only.

operation would be limited by the limitation of steam generator tubeleakage between the Primary Coolant System and the Secondary CoolantSystem (primary-to-secondary LEAKAGE = 150 gallons per day per steamgenerator). Axial cracks having a primary-to-secondary LEAKAGE lessthan this limit during operation will have an adequate margin ofsafety to withstand the loads imposed during normal operation and bypostulated accidents. Operating plants have demonstrated thatprimary-to-secondary LEAKAGE of 150 gallons per day per steamgenerator can readily be detected. Leakage in excess of this limitwill require plant shutdown and an unscheduled inspection, duringwhich the leaking tubes will be located and plugged or repaired bysleeving. The technical bases for sleeving are described in theapproved vendor reports listed in Surveillance Requirement4.4.5.4.a.9.

Wastage-type defects are unlikely with the all volatile treatment(AVT) of secondary coolant. However, even if a defect of similartype should develop in service, it will be found during scheduledinservice steam generator tube examinations. Plugging or repair willbe required of all tubes with imperfections exceeding the plugging orrepair limit. Degraded steam generator tubes may be repaired by theinstallation of sleeves which span the degraded tube section. Asteam generator tube with a sleeve installed meets the structuralrequirements of tubes which are not degraded, therefore, the sleeveis considered a part of the tube. The surveillance requirementsidentify those sleeving methodologies approved for use. o IAlloy 800 sleeves. if an installed sleeve is found to have through Iwall penetration greater than or equal to the plugging limit, thetube must be plugged. The plugging limit for the sleeve is derivedfrom R.G. 1.121 analysis which utilizes a 20 percent allowance foreddy current uncertainty in determining the depth of tube wallpenetration and additional degradation growth. Steam generator tubeinspections of operating plants have demonstrated the capability toreliably detect degradation that has penetrated 20 percent of theoriginal tube wall thickness. All tubes wdithA11N 80 sleeveswillbe oluraed un detection of any service induced imerfection.deiradation or defect in the sl /or the px.surjeyundarv ofthe orinal tube wall in the sleeve/tube assembly (i.e., the sleeve-to-tube oint)

The voltage-based repair limits of these surveillance requirements(SR) implement the guidance in Generic Letter (GL) 95-05 and areapplicable only to Westinghouse-designed steam generators (SGs) withoutside diameter stress corrosion cracking (ODSCC) located at thetube-to-tube support plate intersections. The voltage-based repairlimits are not applicable to other forms of SG tube degradation norare they applicable to ODSCC that occurs at other locations withinthe SG. Additionally, the repair criteria apply only to indicationswhere the degradation mechanism is dominantly axial ODSCC with

BEAVER VALLEY - UNIT 1 B 3/4 4-2a Amendment No. Ale

Attachment C


Commitment Summary

i

The following list identifies those actions committed to by FirstEnergy Nuclear OperatingCompany (FENOC) for Beaver Valley Power Station (BVPS), Unit No. 1 in this document.Any other actions discussed in the submittal represent intended or planned actions by BeaverValley. These other actions are described only as information and are not regulatorycommitments. Please notify Mr. Larry R. Freeland, Manager, Regulatory Affairs/PerformanceImprovement, at Beaver Valley on (724) 682-5284 of any questions regarding this document orassociated regulatory commitments.

Commitment

The sleeves will be installed in accordance with theprocesses provided by the vendor and described in theassociated reports which address sleeve design,qualification, installation methods, non-destructiveexamination and ALARA considerations.

A plant specific document that specifies the allowablelocation of tube eddy current testing indications inorder to perform a successful sleeve installation will beestablished in accordance with WCAP-15919-Prequirements. This document will be utilized todetermine that a tube is an acceptable sleevingcandidate.

Due Date

Process to address thiscommitment will be in place uponimplementation of the amendmentwhich approves the proposedTechnical Specification changessupporting tube repair by leaklimiting Alloy 800 sleeves.


Attachment CCommitment SummaryPage 2

Commitment Due Date

FENOC will conservatively assume all installedsleeves will leak for post-accident leakage calculations.The leak rate for each sleeve will be based on the upper95 percent confidence limit on the mean value ofleakage for appropriate temperature and pressureconditions. The total sleeve leak rate will be combinedwith the total amount of leakage from all other sources(i.e. alternate repair criteria and non-alternate repaircriteria indications) for comparison against the limit onaccident induced leakage as specified in the UFSARfor the MSLB radiological consequences analysis.This total calculated accident induced leakage will bereported in the 90-day report required by NRC GenericLetter 95-05, Attachment 1, Section 6.b.

As required by EPRI Technical Report 1003138, post-installation (pre-service) examination will beperformed on the full length of 100 percent of leaklimiting Alloy 800 sleeve/tube assemblies using PlusPoint rotating coil or an equivalent EPRI TechnicalReport 1003138 Appendix H technique if one becomesavailable. This examination will establish in-serviceinspection baseline data and initial installationacceptance data on the primary pressure boundary ofthe sleeve/SG tube assembly repair.

FENOC will use the sleeve/plug ratio values containedin Table 10-1 of WCAP-15919-P to determine theequivalent SG plugging due to installed leak limitingAlloy 800 sleeves, unless more appropriate valuesbecome available. The total SG plugging level for eachSG will be determined by adding the equivalent SGplugging percentage due to installed leak limiting Alloy800 sleeves to the percent of SG tubes plugged.




The above commitments are only applicable to Cycle 17.

Attachment D


Westinghouse WCAP-15919-NP, Revision 00,"Steam Generator Tube Repair for Westinghouse Designed Plants

With 7/8 Inch Inconel 600 Tubes Using Leak Limiting Alloy 800 Sleeves"

Note: The attached WCAP is Westinghouse non-proprietary.

I

Attachment E


Westinghouse WCAP-15919-P, Revision 00,"Steam Generator Tube Repair for Westinghouse Designed Plants

With 7/8 Inch Inconel 600 Tubes Using Leak Limiting Alloy 800 Sleeves"

�M

Note: The attached WCAP is Westinghouse proprietary.

Documents

Beaver Valley, Unit 1 - License Application No. 322 Regarding … · 2012. 11. 19. · L-04-009 Page 2 2. One copy of WCAP-15919-NP, "Steam Generator Tube Repair for Westinghouse