southern california brian katz edison · dear sir or madam: southern california edison (sce)...

SOUTHERN CALIFORNIA Brian Katz

- EDISON Vice President

An EDISON INTERNATIONALV Company

Withhold from Public Disclosure Under 10 CFR 2.390 (b) (4)May 1, 2006

U.S. Nuclear Regulatory CommissionAttn: Document Control DeskWashington, DC 20555

Subject: San Onofre Nuclear Generating Station, Units 2 and 3Docket Nos. 50-361 and 50-362Response to Request For Additional Information and Submittal ofSupplement I to Proposed Change Number NPF-10/15-565License Amendment Request, "Proposed Technical SpecificationChange, Define the Extent of the Required Tube Inspections andRepair Criteria Within the Tubesheet Region of the SteamGenerators"

References:

1. Letter from Brian Katz (SCE) to Document Control Desk (NRC) Dated November', 2005, Subject: San Onofre Nuclear Generating Station, Units 2 and 3, DocketNos. 50-361 and 50-362, Proposed Change Number NPF-10/15-565, LicenseAmendment Request, "Proposed Technical Specification Change, Define theExtent of the Required Tube Inspections and Repair Criteria Within theTubesheet Region of the Steam Generators."

2. Letter from N. Kalyanam (NRC) to Richard M. Rosenblum (SCE) Dated March23, 2006, Subject: San Onofre Nuclear Generating Station, Units 2 and 3 -Request for Additional Information on the Proposed C* Amendment for SteamGenerator Tube Inspection and Repair in the Tubesheet (TAC NOS. MC8850end MC8851)

Dear Sir or Madam:

Southern California Edison (SCE) submitted Reference (1) on November 3, 2005 torequest license amendments for San Onofre Units 2 and 3. Those proposedamendments revise Technical Specification (TS) Section 5.5.2.11 to modify thedefinitions of steam generator tube "Repair Limit" and "Tube Inspection." The purposeof these changes is to define the extent of the required tube inspections and repaircriteria within the tubesheet regions. On March 23, 2006 the NRC provided SCE aRequest for Additional Information (RAI), Reference (2), to facilitate NRC Staff review ofReference (1). This letter provides the additional information and an associatedsupplement to the proposed amendment.

Withhold From Public Disclosure Under 10 CFR 2.390 (b) (4)P.O. Box 128San Clemente, CA 9 2 67 4 o01 2 WVhen Separated from the Proprietary Enclosure949-368-9275 (Enclosure 4), this Document is DecontrolledFax 949-368-9881

Docurrient Control Desk -2- May 1, 2006

This submittal uses more conservative tube pull-out forces. This necessitates changesto the proposed tubesheet region inspection depths as follows:

* Change in the hot leg, from 10.4 to 10.6 inches* Change in the cold leg, from 10.7 to 11.0 inches

These changes are provided in Enclosure (3); Supplement 1 to Reference (1). Thesupplement provides modifications to Reference (1) Technical Specification changepages that provide consistency with Enclosure (4).

Enclosure (4) is a proprietary copy of the responses to the NRC RAI. It isWestinghouse Document Number LTR-CDME-06-27-P, Revision 0, dated April 2006,titled "Responses to NRC Request for Additional Information on License AmendmenlRequest for Proposed Technical Specification Change Regarding Repair Criteria andInspection Depth for Steam Generator Tubes within the Tubesheet Region, SouthernCalifornia Edison San Onofre Nuclear Generating Station, Units 2 and 3, DocketNos. 50-361 and 50-362."

Enclosure (5) is a nonproprietary copy of the response document. Enclosure (6) isWestinghouse authorization letter CAW-06-2133 with accompanying affidavit,Proprietary Information Notice, and Copyright Notice.

The affidavit 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 2.390 of the Commission's regulations. Accordingly, it isrespectfully requested that the information which is proprietary to Westinghouse bewithheld from public disclosure in accordance with 10 CFR Section 2.390 of theCommission's regulations. Correspondence with respect to the copyright or proprietaryaspects of Enclosures (4) and (6) should be addressed to B. F. Maurer, Manager,Regulatory Compliance and Plant Licensing, Westinghouse Electric Company LLC,P.O. Box 355, Pittsburgh, Pennsylvania15230-0355.

Should you have any questions, or require additional information, please contactMr. Jack Rainsberry at (949) 368-7420.

Sincerely,

Document Control Desk -3- May 1, 2006

Enclosures

1. Notarized affidavit, Unit 2

2. Notarized affidavit, Unit 3

3. Supplement 1 to the Proposed License Amendment Request, Proposed ChangeNumber NPF-1 0/15-565, with attachments A - F (modifications to TechnicalSpecification change pages).

4. Proprietary copy of the response document, Westinghouse Document NumberLTR-CDME-06-27-P, Revision 0, dated April 2006, titled "Responses to NRCRequest for Additional Information on License Amendment Request for Proposed'Technical Specification Change Regarding Repair Criteria and Inspection Depth'for Steam Generator Tubes within the Tubesheet Region Southern CaliforniaEdison San Onofre Nuclear Generating Station, Units 2 and 3, Docket Nos. 5()-.361 and 50-362."

5. Nonproprietary copy of the response document, Westinghouse DocumentNumber LTR-CDME-06-27-NP, Revision 0, dated April 2006, titled "Responses-to NRC Request for Additional Information on License Amendment Request forProposed Technical Specification Change Regarding Repair Criteria andInspection Depth for Steam Generator Tubes within the Tubesheet RegionSouthern California Edison San Onofre Nuclear Generating Station, Units 2 arid:3, Docket Nos. 50-361 and 50-362."

6. 'Westinghouse Application for Withholding Proprietary Information from PublicDisclosure with Affidavit

cc: 13. S. Mallett, Regional Administrator, NRC Region IVN. Kalyanam, NRC Project Manager, San Onofre Units 2 and 3C. C. Osterholtz, NRC Senior Resident Inspector, San Onofre Units 2 and 3S. Y. Hsu, California Department of Health Services, Radiologic Health Branch

Enclosure 1

UNITED STATES OF AMERICANUCLEAR REGULATORY COMMISSION

Application of SOUTHERN CALIFORNIAEDISON COMPANY, ET AL. for a Class 103License to Acquire, Possess, and Usea Utilization Facility as Part ofUnit No. 2 of the San Onofre NuclearGenerating Station)

)))))

Docket No. 50-361Supplement 1 toAmendment ApplicationNo. 238

SOUTHERN CALIFORNIA EDISON COMPANY, ET AL. pursuant to 10 CFR 50.90,

hereby submit Supplement 1 to Amendment Application No. 238. This amendment

application consists of Supplement 1 to Proposed Change No. NPF-10-565 to Facility

Operaiing License NPF-10. Proposed Change No. NPF-10-565 is a request to revise

Facility Operating License NPF-10 to define the extent of the required steam generator

tube inspections and repair criteria within the tubesheet regions.

State cf CaliforniaCounty of San Diego

Brian Katz, Vice Presid&rtf

Subscribed and sworn to iFafd* before me on this S day of

by Yt- v\ &¾zpersonally known to me or-proved to me one bais of satisfactory pidonce to be theperson who appeared before me.

E'AW 54. WAM LQdCfNotary Public

01ato i 16}23105

IAm Dieo Ca~ouCE"Ma"W0O24

Enclosure 2

UNITED STATES OF AMERICANUCLEAR REGULATORY COMMISSION

Application of SOUTHERN CALIFORNIAEDISON COMPANY, ET AL. for a Class 103License to Acquire, Possess, and Usea Utilization Facility as Part ofUnit No. 3 of the San Onofre NuclearGenerating Station)

)))))

Docket No. 50-362Supplement 1 toAmendment ApplicationNo. 222

SOUTHERN CALIFORNIA EDISON COMPANY, ET AL. pursuant to 10 CFR 50.90,

hereby submit Supplement 1 to Amendment Application No. 222. This amendment

application consists of Supplement 1 to Proposed Change No. NPF-15-565 to Facility

Operating License NPF-15. Proposed Change No. NPF-15-565 is a request to revise

Facility Operating License NPF-15 to define the extent of the required steam generator

tube inspections and repair criteria within the tubesheet regions.

State of CaliforniaCounty of San Diego

1121A.CA

Brian Katz, Vice PresidenF

Subscribed and sworn to (et-affkmiebefore me on this I 5f day of

) . SO() C( ,

by 12 5Ian Kitpersonally known to me oF pFOved-to-me-on-the-basis-of-satisfactory-evidenre to be theperson who appeared before me.

(0�uj�� - 11'� aw e = =

Notary Public i II - -- 20ACK

Enclosure (3)

Supplement 1 to the Proposed License Amendment Request, Proposed ChangeNumber NPF-1 0/15-565, with attachments A - F (modifications to Technical

Specification change pages)

LICENSEE'S EVALUATION

DESCRIPTION FOR PROPOSED CHANGE NPF-10/15-565 SUPPLEMENT 1PROPOSED TECHNICAL SPECIFICATION CHANGE,

DEFINE THE EXTENT OF THE REQUIRED TUBE INSPECTIONS ANDREPAIR CRITERIA WITHIN THE TUBESHEET REGION

OF THE STEAM GENERATORSSan Onofre Nuclear Generating Station Units 2 and 3

ORIGINAL PCN-565 PROPOSED TECHNICAL SPECIFICATION CHANGE(highlight for additions, strikeout for deletions)

Unit 2: see Attachment AUnit 3: see Attachment B

PC1N-565 SUPPLEMENT 1 PROPOSED TECHNICAL SPECIFICATIONCHANGE REVISIONS(highlight for additions, strikeout for deletions)

Unit 2: see Attachment C (To replace similar pages in PCN-565.)Unit 3: see Attachment D (To replace similar pages in PCN-565.)

PCN-565 SUPPLEMENT 1 PROPOSED TECHNICAL SPECIFICATIONS(with changes)

Unit 2: see Attachment E (To replace similar pages in PCN-565.)Unit 3: see Attachment F (To replace similar pages in PCN-565.)

1.0 INTRODUCTION

This supplement uses more conservative tube pull-out forces. This necessitateschanges to the proposed tubesheet region inspection depths identified in PCN-565 as follows:

Change in the hot leg, from 10.4 to 10.6 inchesChange in the cold leg, from 10.7 to 11.0 inches

2.0 PROPOSED CHANGE

This supplement to PCN-565 provides revised proposed Technical Specificationchange pages that reflect the above described inspection depths and provideconsistency with the SCE responses to the NRC request for additional information(RAI).

3.0 REGULATORY SAFETY ANALYSIS

The no significant hazards consideration and Environmental Considerationprovided with PCN-565 both remain bounding.

2

Attachment A

(Original PCN-565 Pages)

SONGS Unit 2

Procedures, Programs, and Manuals5.5

5.5 Procedures, Programs, and Manuals (continued)

5.5.2.11 Steam Generator (SG) Tube Surveillance Program (continued)

e) Imperfection - An exception to the dimensions,finish, or contour of a tube from that required byfabrication drawings or specifications. Eddy-current testing indications below 20% of thenominal tube wall thickness, if detectable, may beconsidered as imperfections;

f) Repair Limit - The imperfection depth at or beyondwhich the tube shall be removed from service orrepaired and iJ equal to 44% of the nominal tubewall thickness., Sleeves shall be removed fromservice upon detection of service-induceddegradation of the sleeve material or any portionof the sleeve-to-tube weld.

For tubes that have not been repaired (sleeved):Deqradation detected below the bottom of the hotleq expansion transition or hot leq top of thetubesheet. whichever is higher. shall be removedfrom service or repaired on detection. Degradationdetected below the bottom of the cold leqexpansion transition or cold leg top of thetubesheet, whichever is higher, shall be removedfrom service or repaired on detection.

This Repair Limit is not applicable in the portionof the tubing within the hotleg tubesheet asfollows:

For tubes that have not been repaired:Greater than 10.4 inches below the bottom ofthe hot leg expansion transition or top ofthe hot leg tubesheet, whichever is lower.

For tubes that have been repaired: Below thebottom of the pressure retaining portion ofthe parent tube in contact with the sleeve(the lower joint that is formed byhard-rollinq) or greater than 10.4 incheshplnw thp hnt.tnm of thp hot lpo expansiontransition, whichever is lower.

(continued)

SAN ONOFRE--UNIT 2 5.0-18 Amendment No. +89


(continued)5.5 Procedures, Programs, and Manuals


g) Preservice Inspection - An inspection of the fulllength of each tube in each SG performed by eddy-current techniques prior to service to establish abaseline condition of the tubing. This inspectionshall be performed prior to initial MODE 1operating using the equipment and techniquesexpected to be used during subsequent inserviceinspections. These examinations may be performedprior to steam generator installation. Similarly,for tube repair by sleeving, an inspection of thefull length of the pressure boundary portion ofthe sleeved area shall be performed by eddycurrent techniques prior to service. Thisincludes pressure retaining portions of the parenttube in contact with the sleeve, the sleeve-1:o-tube weld, and the pressure retaining portion ofthe sleeve.

h) Tube Inspection - An inspection of the SG tubefrom the point of entry (hot leg side) eampltl-Cyaround tie U bend to the top support of the 4oldleg excluding the portion of the tube within-tlhetubesheet (TS) below 5 inches from the secon h-ryface of the TS.*10.4 inches below the bottom ofthe hot leg expansion transition or hot leq i:op ofthe tubesheet, whichever is lower, completelyaround the U-bend to 10.7 inches below the bottomof the cold leq expansion transition or cold legtop of the tubesheet, whichever is lower.

i) Unserviceable - The condition of a tube if it:leaks or contains a defect large enough to affectits structural integrity in the event of anOperational Basis Earthquake, a loss-of-coolantaccident, or a steam line of feedwater line breakaccident as specified in Specification 5.5.2.11.e.

Unit 2, Cycle 12 operation only.* Th-: exclusion is for

(continued)

SAN ONOFRE--UNIT 2 5.0-18a Amendment No. 4434

Attachment B

(Original PCN-565 Pages)

SONGS Unit 3





f) Repair Limit - The imperfection depth at or beyondwhich the tube shall be removed from service orrepaired and iq equal to 44% of the nominal tubewall thickness., Sleeves shall be removed fromservice upon detection of service-induceddegradation of the sleeve material or any portionof the sleeve-to-tube weld.

For tubes that have not been repaired (sleeved):Degradation detected below the bottom of the hotleg expansion transition or hot leq top of thetubesheet, whichever is higher, shall be removedfrom service or repaired on detection. Degradationdetected below the bottom of the cold legexpansion transition or cold leg top of thetubesheet, whichever is higher, shall be removedfrom service or repaired on detection.


For tubes that have not been repaired:Greater than 10.4 inches below the bottom ofthe hot leg expansion transition or toD ofthe hot leg tubesheet, whichever is lower.

For tubes that have been repaired: Bel:w thebottom of the pressure retaining portiDn ofthe parent tube in contact with the sleeve(the lower joint that is formed byhard-rollinq) or greater than 10.4 incheshplnw thp hnttom nf the hot lea expansiontransition, whichever is lower.

(continued)

SAN ONOFRE--UNIT 3 5.0-18 Amendment No. +84




g) Preservice Inspection - An inspection of the fulllength of each tube in each SG performed by eddy-current techniques prior to service to establish abaseline condition of the tubing. This inspectionshall be performed prior to initial MODE Ioperating using the equipment and techniquesexpected to be used during subsequent inserviceinspections. These examinations may be performedprior to steam generator installation. Similarly,for tube repair by sleeving, an inspection of thefull length of the pressure boundary portion ofthe sleeved area shall be performed by eddycurrent techniques prior to service. Thisincludes pressure retaining portions of the parenttube in contact with the sleeve, the sleeve-to-tube weld, and the pressure retaining portion ofthe sleeve.

h) Tube Inspection - An inspection of the SG tubefrom the point of entry (hot leg side) eompl-t-elyaround the U bond to the top support of tleg excluding the portion of the tube within-Shetubesheet (TS) below 5 inches from the seconddryface of the TS.*10.4 inches below the bottom ofthe hot leq expansion transition or hot leci top ofthe tubesheet, whichever is lower, completelyaround the U-bend to 10.7 inches below the bottomof the cold leq expansion transition or cold legtop of the tubesheet, whichever is lower.

i) Unserviceable - The condition of a tube if itleaks or contains a defect large enough to affectits structural integrity in the event of anOperational Basis Earthquake, a loss-of-coolantaccident, or a steam line of feedwater line breakaccident as specified in Specification 5.5.2.1l.e.

This exclusion is for Unit 3, CyAlA 11 operation only.

(continued)

SAN ONOFRE--UNIT 3 5.0-18a Amendment No. 1890

Attachment C

(PCN-565 Supplement 1 Proposed Pages)

(Redline and Strikeout)

SONGS Unit 2





f) Repair Limit - The imperfection depth at or beyondwhich the tube shall be removed from service orrepaired and is equal to 44% of the nominal tubewall thickness. Sleeves shall be removed fromservice upon detection of service-induceddegradation of the sleeve material or any portionof the sleeve-to-tube weld.

For tubes that have not been repaired (sleeved):Deqradation detected below the bottom of the hotlea expansion transition or hot lea top of tietubesheet. whichever is hicher. shall be removedfrom service or repaired on detection. Degraiationdetected below the bottom of the cold leaexpansion transition or cold lea too of thetubesheet. whichever is hicher. shall be remDvedfrom service or repaired on detection.


For tubes that have not been repaired:Greater than 10.6 inches below the bottom ofthe hot lea expansion transition or too ofthe hot leg tubesheet, whichever is lower.

For tubes that have been repaired: Below thebottom of the pressure retaining portion ofthe parent tube in contact with the sleeve(the lower joint that is formed byhard-rollinq) or greater than 10.6 inchesbelow the bottom of the hot lea expansiontransition, whichever is lower.

(continued)

SAN ONOFRE--UNIT 2 5.0-18 Amendment No.




g) Preservice Inspection - An inspection of the fulllength of each tube in each SG performed by eddy-current techniques prior to service to establish abaseline condition of the tubing. This inspectionshall be performed prior to initial MODE 1operating using the equipment and techniquesexpected to be used during subsequent inserviceinspections. These examinations may be performedprior to steam generator installation. Similarly,for tube repair by sleeving, an inspection of thefull length of the pressure boundary portion ofthe sleeved area shall be performed by eddycurrent techniques prior to service. Thisincludes pressure retaining portions of the parenttube in contact with the sleeve, the sleeve-to-tube weld, and the pressure retaining portion ofthe sleeve.

h) Tube Inspection - An inspection of the SG tulyefrom 10.4 inches below the bottom of the hot-heg

expasiontransition or hot leg top of thceb .L. . L - -L _ L

tube~shct, whichever is lower, completely arguedthe U bend to 10.7 inches below the bottom oF-theold leg expaniontransition or eold le tor-o~

the tubesheet. whichever is lever.For a tube with no portion of a sleeve extendingbelow (a) 10.6 inches from the bottom of the hotleq expansion transition or the top of thetubesheet (whichever is lower) or (b) 11.0 inchesfrom the bottom of the cold leg expansiontransition or the top of the tubesheet (whicheveris lower), a tube inspection means an inspectionof the steam generator tube from 10.6 inches belowthe bottom of the hot leq expansion transition ortop of the tubesheet (whichever is lower)completely around the U-bend to 11.0 inches belowthe bottom of the cold leq expansion transition ortop of the tubesheet (whichever is lower).

(continued)

SAN ONOFRE--UNIT 2 5.0-18a Amendment No.




For all other tubes, a tube inspection means aninspection from the bottom of the sleevecompletely around the U-bend to either (a) 10.6inches below the bottom of the hot leq expansiontransition or the top of the tubesheet (whicheveris lower) or (b) 11.0 inches below the bottor ofthe cold leq expansion transition or the top ofthe tubesheet (whichever is lower), asappropriate.

i) Unserviceable - The condition of a tube if itleaks or contains a defect large enough to affectits structural integrity in the event of anOperational Basis Earthquake, a loss-of-coolantaccident, or a steam line of feedwater line breakaccident as specified in Specification 5.5.2,11.e.

(continued)

SAN ONOFRE--UNIT 2 5.0-18b Amendment No.

Attachment D


(Redline and Strikeout)

SONGS Unit 3





f) Repair Limit - The imperfection depth at or beyondwhich the tube shall be removed from service orrepaired and is equal to 44% of the nominal tubewall thickness. Sleeves shall be removed fromservice upon detection of service-induceddegradation of the sleeve material or any portionof the sleeve-to-tube weld.

For tubes that have not been repaired (sleeved):Deqradation detected below the bottom of the hotleq expansion transition or hot leq top of thetubesheet, whichever is hiqher, shall be removedfrom service or repaired on detection. Degradationdetected below the bottom of the cold lecexpansion transition or cold leq top of thetubesheet, whichever is hicher, shall be removedfrom service or repaired on detection.


For tubes that have not been repaired:Greater than 10.6 inches below the bottom ofthe hot lec expansion transition or tog ofthe hot leg tubesheet, whichever is lower.

For tubes that have been repaired: Below thebottom of the pressure retaining portion ofthe parent tube in contact with the sleeve(the lower joint that is formed byhard-rollinq) or greater than 10.6 inchesbelow the bottom of the hot lec expansiontransition, whichever is lower.

(continued)





g) Preservice Inspection - An inspection of the fulllength of each tube in each SG performed by eddy-current techniques prior to service to establish abaseline condition of the tubing. This inspectionshall be performed prior to initial MODE 1operating using the equipment and techniquesexpected to be used during subsequent inserviceinspections. These examinations may be performedprior to steam generator installation. Similarly,for tube repair by sleeving, an inspection of thefull length of the pressure boundary portion ofthe sleeved area shall be performed by eddycurrent techniques prior to service. Thisincludes pressure retaining portions of the parenttube in contact with the sleeve, the sleeve-to-tube weld, and the pressure retaining portion ofthe sleeve.

h) Tube Inspection - An inspection of the SC tuIbefrom 10.4 inches below the bottom of the hot-1-eUexpans-i~ transition or hot leg top of thetubesheet, whichever is lower, completely argoft+the U bend to 10.7 inehes below thC bdttomC oF thecold leg expansion transition or cold leg top -fthe tubesheet. whichever is lower.For a tube with no portion of a sleeve extendinqbelow (a) 10.6 inches from the bottom of the hotleg expansion transition or the top of thetubesheet (whichever is lower) or (b) 11.0 inchesfrom the bottom of the cold leq expansiontransition or the top of the tubesheet (whicheveris lower), a tube inspection means an inspectionof the steam generator tube from 10.6 inches belowthe bottom of the hot leq expansion transition ortop of the tubesheet (whichever is lower)completely around the U-bend to 11.0 inches belowthe bottom of the cold leg expansion transition ortop of the tubesheet (whichever is lower).

(continued)





For all other tubes, a tube inspection means aninspection from the bottom of the sleevecompletely around the U-bend to either (a) 10.6inches below the bottom of the hot leq expansiontransition or the top of the tubesheet (whicheveris lower) or (b) 11.0 inches below the bottori ofthe cold leq expansion transition or the top ofthe tubesheet (whichever is lower), asappropriate.

i) Unserviceable - The condition of a tube if itleaks or contains a defect large enough to affectits structural integrity in the event of anOperational Basis Earthquake, a loss-of-coolantaccident, or a steam line of feedwater line breakaccident as specified in Specification 5.5.2..11.e.

(continued)

SAN ONOFRE--UNIT 3 5.0-18b Amendment No.

Attachment E


SONGS Unit 2





f) Repair Limit - The imperfection depth at or beyondwhich the tube shall be removed from service orrepaired and is equal to 44% of the nominal *ubewall thickness. Sleeves shall be removed fromservice upon detection of service-induceddegradation of the sleeve material or any portionof the sleeve-to-tube weld.

For tubes that have not been repaired (sleeved):Degradation detected below the bottom of the hotleg expansion transition or hot leg top of thetubesheet, whichever is higher, shall be removedfrom service or repaired on detection. Degradationdetected below the bottom of the cold legexpansion transition or cold leg top of thetubesheet, whichever is higher, shall be removedfrom service or repaired on detection.


For tubes that have not been repaired:Greater than 10.6 inches below the bot:om ofthe hot leg expansion transition or top ofthe hot leg tubesheet, whichever is lower.

For tubes that have been repaired: Below thebottom of the pressure retaining portion ofthe parent tube in contact with the sleeve(the lower joint that is formed byhard-rolling) or greater than 10.6 inchesbelow the bottom of the hot leg expansiontransition, whichever is lower.

(continued)




5.5.2.11 Steam Generator

g)

(SG) Tube Surveillance Program (continued)

Preservice Inspection - An inspection of the fulllength of each tube in each SG performed by eddy-current techniques prior to service to establish abaseline condition of the tubing. This inspectionshall be performed prior to initial MODE 1operating using the equipment and techniquesexpected to be used during subsequent inserviceinspections. These examinations may be performedprior to steam generator installation. Similarly,for tube repair by sleeving, an inspection o- thefull length of the pressure boundary portion ofthe sleeved area shall be performed by eddycurrent techniques prior to service. Thisincludes pressure retaining portions of the parenttube in contact with the sleeve, the sleeve-to-tube weld, and the pressure retaining portion ofthe sleeve.

h) Tube Inspection - For a tube with no portion of asleeve extending below (a) 10.6 inches from thebottom of the hot leg expansion transition or thetop of the tubesheet (whichever is lower) or (b)11.0 inches from the bottom of the cold legexpansion transition or the top of the tubesheet(whichever is lower), a tube inspection means aninspection of the steam generator tube from :10.6inches below the bottom of the hot leg expansiontransition or top of the tubesheet (whichever islower) completely around the U-bend to 11.0 -inchesbelow the bottom of the cold leg expansiontransition or top of the tubesheet (whichever islower).

For all other tubes, a tube inspection means aninspection from the bottom of the sleevecompletely around the U-bend to either (a) 10.6inches below the bottom of the hot leg expansiontransition or the top of the tubesheet (whicheveris lower) or (b) 11.0 inches below the bottom ofthe cold leg expansion transition or the top ofthe tubesheet (whichever is lower), asappropriate.

i) Unserviceable - The condition of a tube if itleaks or contains a defect large enough to affectits structural integrity in the event of anOperational Basis Earthquake, a loss-of-coolantaccident, or a steam line of feedwater line breakaccident as specified in Specification 5.5.2.11.e.

(continued)


Attachment F


SONGS Unit 3




e) Imperfection - An exception to the dimensions,finish, or contour of a tube from that required byfabrication drawings or specifications. Eddy-current testing indications below 20% of thenominal tube wall thickness, if detectable, nay beconsidered as imperfections;

f) Repair Limit - The imperfection depth at or beyondwhich the tube shall be removed from service orrepaired and is equal to 44% of the nominal l:ubewall thickness. Sleeves shall be removed fromservice upon detection of service-induceddegradation of the sleeve material or any portionof the sleeve-to-tube weld.

For tubes that have not been repaired (sleeved):Degradation detected below the bottom of the hotleg expansion transition or hot leg top of thetubesheet, whichever is higher, shall be removedfrom service or repaired on detection. Degradationdetected below the bottom of the cold legexpansion transition or cold leg top of thetubesheet, whichever is higher, shall be removedfrom service or repaired on detection.


For tubes that have not been repaired:Greater than 10.6 inches below the bottom ofthe hot leg expansion transition or top ofthe hot leg tubesheet, whichever is lower.

For tubes that have been repaired: Below thebottom of the pressure retaining portion ofthe parent tube in contact with the sleeve(the lower joint that is formed byhard-rolling) or greater than 10.6 inchesbelow the bottom of the hot leg expansiontransition, whichever is lower.

(continued)





g) Preservice Inspection - An inspection of the fulllength of each tube in each SG performed by eddy-current techniques prior to service to establish abaseline condition of the tubing. This inspectionshall be performed prior to initial MODE 1operating using the equipment and techniquesexpected to be used during subsequent inserviceinspections. These examinations may be performedprior to steam generator installation. Similarly,for tube repair by sleeving, an inspection of thefull length of the pressure boundary portion ofthe sleeved area shall be performed by eddycurrent techniques prior to service. Thisincludes pressure retaining portions of the parenttube in contact with the sleeve, the sleeve-1:o-tube weld, and the pressure retaining portion ofthe sleeve.

h) Tube Inspection - For a tube with no portion of asleeve extending below (a) 10.6 inches from thebottom of the hot leg expansion transition or thetop of the tubesheet (whichever is lower) or (b)11.0 inches from the bottom of the cold legexpansion transition or the top of the tubesheet(whichever is lower), a tube inspection means aninspection of the steam generator tube from :10.6inches below the bottom of the hot leg expansiontransition or top of the tubesheet (whichever islower) completely around the U-bend to 11.0 inchesbelow the bottom of the cold leg expansiontransition or top of the tubesheet (whichever islower).

For all other tubes, a tube inspection means aninspection from the bottom of the sleevecompletely around the U-bend to either (a) 10.6inches below the bottom of the hot leg expansiontransition or the top of the tubesheet (whicheveris lower) or (b) 11.0 inches below the bottori ofthe cold leg expansion transition or the top ofthe tubesheet (whichever is lower), asappropriate.

i) Unserviceable - The condition of a tube if itleaks or contains a defect large enough to affectits structural integrity in the event of anOperational Basis Earthquake, a loss-of-coolantaccident, or a steam line of feedwater line breakaccident as specified in Specification 5.5.2..11.e.

(continued)


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