ML041320470
| ML041320470 | |
| Person / Time | |
|---|---|
| Site: | Kewaunee  |
| Issue date: | 05/03/2004 |
| From: | Coutu T Nuclear Management Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| NRC-04-053 | |
| Download: ML041320470 (31) | |
Text
tN Excellence_
Committed to Nuclear Kewaunee Nuclear Power Plant Operated by Nuclear Management Company, LLC May 3, 2004 NRC-04-053 10 CFR 50.90 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555 KEWAUNEE NUCLEAR POWER PLANT DOCKET 50-305 LICENSE NO. DPR-43 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION RELATED TO LICENSE AMENDMENT REQUEST 199 "STEAM GENERATOR EDDY CURRENT INSPECTION FREQUENCY EXTENSION" TO THE KEWAUNEE NUCLEAR POWER PLANT TECHNICAL SPECIFICATIONS
References:
- 1) Letter from Thomas Coutu (NMC) to Document Control Desk (NRC), "License Amendment Request 199, Steam Generator Eddy Current Inspection Frequency Extension to the Kewaunee Nuclear Power Plant Technical Specifications", dated October 8, 2003.
- 2) Letter from John G. Lamb (NRC) to Thomas Coutu (NMC),
Kewaunee Nuclear Power Plant, "Request For Additional Information For Proposed Amendment Request, Steam Generator Eddy Current Inspection Frequency Extension (TAC NO.
MC-1049)", dated January 26, 2004.
- 3) Letter from Thomas Coutu (NMC) to Document Control Desk (NRC), "Response To Request For Additional Information Related To License Amendment Request to the Kewaunee Nuclear Power Plant Technical Specifications", dated February 27, 2004.
- 4) Letter from John G. Lamb (NRC) to Thomas Coutu (NMC),
Kewaunee Nuclear Power Plant, "Request For Additional Information For Proposed Amendment Request, Steam Generator Eddy Current Inspection Frequency Extension (TAC NO.
MC1 049)", dated April 6, 2004.
N490 Highway 42
- Kewaunee, Wisconsin 54216-9511 Telephone: 920.388.2560 A 0
Document Control Desk Page 2 In Reference 4, the Nuclear Regulatory Commission (NRC) staff requested additional information concerning the Nuclear Management Company, LLC (NMC) request to modify Technical Specification (TS) Section 4.2.b.3.a, "Inspection Frequency", which would revise the Steam Generator (SG) inspection interval requirements for the Kewaunee Nuclear Power Plant (KNPP) to allow a 40-month inspection interval after one SG inspection (Reference 1). This letter is NMC's response to the NRC's request for additional information (RAI). to this letter contains the questions the NRC staff requested. Enclosure 2 to this letter contains the questions the NRC staff requested with NMC's response.
As the response does not alter the conclusions reached in NMC's Reference 1 submittal; the safety analysis, significant hazards determination, and the environmental considerations statements contained in Reference 1 are still applicable and support the changes contained herein. Also, this submittal contains no new commitments.
NMC requests approval of the license amendment request in accordance with the date contained in Reference 1. If you have any questions concerning this submittal please contact Mr. Ted Maloney at (920) 388-8863.
I declare under penalty of perjury that the foregoing is true and correct.
Executed on May 3, 2004.
Thomas Coutu Site Vice-President, Kewaunee Nuclear Power Plant Nuclear Management Company, LLC Enclosures (2) cc: Administrator, Region l1l, USNRC Project Manager, Kewaunee Nuclear Power Plant, USNRC Senior Resident Inspector, Kewaunee Nuclear Power Plant, USNRC Electric Division, PSCW
as ENCLOSURE 1 NUCLEAR MANAGEMENT COMPANY, LLC, RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION, KEWAUNEE NUCLEAR POWER PLANT OPERATING LICENSE NO. DPR-43, DOCKET NO. 50-305 REQUEST FOR ADDITIONAL INFORMATION (RAI)
REGARDING PROPOSED AMENDMENT REQUEST TO MODIFY STEAM GENERATOR TUBE INSPECTION FREQUENCY KEWAUNEE NUCLEAR POWER PLANT DOCKET NO. 50-305 A primary-to-secondary leak was observed at a plant which recently replaced its steam generators. In reviewing the eddy current data for the leaking tube (both preservice and in-service inspection data), the licensee noticed an anomalous dent signal. Although the leak was attributed to this dent signal, there was no clear indication of a 100%
through-wall flaw based on the rotating probe data (the leak was attributed to this location based on visual and non-destructive examination data).
Given that your steam generators contain dents/dings, please discuss the potential for a through-wall or near through-wall flaw to exist at these locations (e.g., are there anomalous dent/ding signals). Please discuss your primary-to-secondary leakage history since installation of the steam generators. Please discuss whether the hydrostatic test and/or other pressure tests performed during fabrication would have been able to detect small leaks through the tubes. Please discuss whether any other inspection data could represent through-wall or near through-wall flaws (e.g., do other types of indications exhibit anomalous signals).
Page 1 of 1
ENCLOSURE 2 NUCLEAR MANAGEMENT COMPANY, LLC, RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION, KEWAUNEE NUCLEAR POWER PLANT OPERATING LICENSE NO. DPR-43, DOCKET NO. 50-305
- 1. Given that your steam generators contain dents/dings, please discuss the potential for a through-wall or near through-wall flaw to exist at these locations (e.g., are there anomalous dent/ding signals).
NMC Response to 1:
As discussed in the Enclosure 1 RAI, a primary-to-secondary leak was observed at a plant which recently replaced its steam generators. In reviewing the eddy current data for the leaking tube (both preservice and in-service inspection data), the licensee noticed an anomalous dent signal. Although the leak was attributed to this dent signal, there was no clear indication of a 100% through-wall flaw based on the rotating probe data (the leak was attributed to this location based on visual and non-destructive examination data).
NMC performed a review of the referenced plant bobbin and rotating coil eddy current data for both the pre-service inspection (PSI) and the leakage forced outage. This eddy current data was made available for download and review by the Electric Power Research Institute (EPRI).
The referenced plant bobbin coil data at the leaking tube location shows a typical dent signal with no apparent change between the PSI (Figure 1) and the forced outage (Figure 2). Similarly, the referenced plant Motorized Rotating Pancake Coil (MRPC) data shows little change between the PSI (Figure 3) and the forced outage (Figure 4).
These signals are of the dent and small through wall hole that caused the tube to leak.
The response from this condition resulted in a "non-typical" dent signature in which the lobe opening of the Plus Point (+PtTM) data hooked upward and had a vertical amplitude that is not present in "non-flawed" typical +PtTm dent signals.
Page 1 of 28
The KNPP PSI was performed utilizing eddy current techniques qualified in accordance with Appendix H of the EPRI PWR Steam Generator Examination Guidelines. The reporting criteria for DNG signals during the PSI was Ž2 volts based on the bobbin coil signal. No DNT signals were reported during the PSI as DNT signals are defined as being in-service related (see Table 1). A total of 28 DNG signals were reported during the PSI, ranging in bobbin voltage from 2.02 volts to 5.71 volts. All 28 DNG signals reported during the PSI were tested with MRPC to provide a baseline for future in-service inspections. No degradation, as defined by TS 4.2.b, was reported at any DNG location.
The KNPP ISI was also performed utilizing eddy current techniques qualified in accordance with Appendix H of the EPRI PWR Steam Generator Examination Guidelines. The reporting criteria for both DNG and DNT signals during the ISI was Ž2 volts based on the bobbin coil. MRPC examinations were required to be performed for all DNG and DNT signals Ž5 volts based on the bobbin coil. A total of 30 DNG signals were reported during the ISI, which included the 28-reported during the PSI and 2 newly reported DNG signals. One DNG signal reported during the ISI was tested with MRPC as it exceeded 5 volts. No degradation was reported. Eight DNT signals were reported during the ISI, ranging in voltage from 2.27 volts to 9.69 volts. Five of the eight DNT signals were in excess of 5 volts and were MRPC tested. No degradation, as defined by TS 4.2.b, was reported.
A review of all KNPP dent/ding signals, from both the PSI (2001) and first in-service inspection (151) (2003) as described above, was performed to determine if the signal response from the KNPP dent/ding indications had similar characteristics as the referenced plant data. The DNG and DNT indications revealed a +PtTm response but the signature was a "typical" flat signal that had no significant vertical amplitude.
None of the DNG or DNT indications had a sgnature that mimicked the defective referenced plant tube signal. Sample MRPCR C-scan graphics of the KNPP DNG and DNT signals are attached (Figure 5 through Figure 11) and include the largest voltage bobbin coil signals recorded.
As stated above, none of the KNPP DNG or DNT indications had a signature that mimicked the defective referenced plant tube signal. This, coupled with the satisfactory leakage tests performed during fabrication of the steam generators (see Response to Question 3) and the absence of primary-to-secondary leakage since startup with the replacement steam generators (see Response to Question 4), provides reasonable assurance that a potential through-wall or near through-wall flaw to exist at these locations is extremely low.
In addition to the eddy current data review, a review of the tube packaging process was performed to determine the potential for tube damage caused by the packaging process. The Kewaunee steam generator tubing was fabricated by Valinox Nucleaire in Montbard, France; and was packaged and shipped to Ansaldo Energia in Milan, Italy, for installation. The Kewaunee boxing arrangement utilized foam separators to prevent tube-to-tube contact. The layers of foam were secured in place by plastic pins; as a Page 2 of 28
packaging. The wooden boxes were constructed (prior to loading the tubes) with nails going from the inside of the box to the outside. As a result, there were no sharp ends pointing towards the tubes. Upon completion of packaging, a wooden cover was installed on the box and banded to the box with steel straps. Kewaunee personnel were present during various stages of the packaging process to ensure procedural requirements were being met. Based on the packaging methodology, construction and procedural controls, it can be reasonably concluded that tube damage as a result of tube packaging is extremely low.
- 2. Please discuss your primary-to-secondary leakage history since installation of the steam generators.
NMC Response to 2:
The Kewaunee steam generators were replaced at the end of Cycle 24 during the Fall 2001 refueling outage. Startup from the replacement outage (at Cycle 25) occurred on December 4, 2001. The unit operated until May 5, 2002, where it was shut down for reasons unrelated to SG performance. Upon startup from the forced outage on May 15, 2002, the unit operated until the end of Cycle 25, where it was shut down on April 5, 2003, for refueling. Unit startup for Cycle 26 occurred on May 11, 2003. The unit operated until January 16, 2004, where it was shut down for reasons unrelated to SG performance. Upon startup from the forced outage on February 1, 2004, the unit has been operating until the present time.
Figure 22 depicts the Primary-to-Secondary leakage history since steam generator replacement. There has been no Primary-to-Secondary leakage reported since steam generator replacement.
- 3. Please discuss whether the hydrostatic test and/or other pressure tests performed during fabrication would have been able to detect small leaks through the tubes.
NMC Response to 3:
The following tests were performed during fabrication of the Kewaunee replacement steam generators:
- a. Individual Tube Hydrostatic Test A hydrostatic test was performed on each tube used in the Kewaunee steam generators prior to departure from the Valinox Nucleaire tube mill in Montbard, France. The hydrostatic test was performed after bending and prior to the U-bend dimensional checks. The hydrostatic test was performed in accordance with Valinox procedure No. EP 1347, Hydrostatic Testing. Acceptance criteria for Page 3 of 28
with Valinox procedure No. EP 1347, Hydrostatic Testing. Acceptance criteria for the test was no evidence of leakage. Each tube was subject to an internal pressure of 20.36 MPa to 22.48 MPa (2952 to 3260 psi) for 5 seconds.
Small leaks through the tubes would have been identified either visually or by the inability to maintain hydrostatic test pressure. No leakage was reported from any of the individual hydrostatic tests.
- b. Helium Leak Test Upon completion of the tube-to-tubesheet welds, helium leak testing was performed to confirm the integrity of the welds. For this test, the steam generator secondary side was capped and a vacuum drawn on the secondary side (29 in Hg for 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />). After the vacuum was held, the secondary side was backfilled with a gas mixture (30% helium, 70% nitrogen) until positive pressure (7 in Hg to 20 in Hg) was achieved, and was held for 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />. A calibrated helium sniffer probe was then passed over the tube-to-tubesheet welds to detect the presence of helium. The helium leak testing was performed in accordance with Ansaldo Energia procedure 77501/60, Helium Test. Acceptance criteria for the test was no leaks greater then 3.0 x1 0-7 standard cm 3 /second.
Although this test was performed primarily to demonstrate the integrity of the tube-to-tubesheet welds, it would also aid in identifying any potential through wall leaks in other regions of the steam generator tubing. No evidence of such leaks were reported.
- c. Primary Side Hydrostatic Test A primary side hydrostatic test was performed following fabrication of the steam generators at the Ansaldo manufacturing facility in Milan, Italy. The hydrostatic pressure test was performed in accordance with Ansaldo Energia procedure 77510/60, Hydrostatic Test of Steam Generator Primary Side, and met the requirements of ASME Section III Article NB-6000. To perform the test, the primary side was filled with deionized water and vented. Just prior to hydrostatic test pressurization, an intermediate pressure test was performed at 300+/- 50 psig to test the integrity of the hydrotest system. Hydrostatic test pressure was then increased to 3107 psig to 3262 psig and held for a minimum of 10 minutes. The pressure was then lowered to 2485 psig and all weld joints, connections, gasketed openings and regions of high stress, such as regions around openings and thickness transition sections, were examined for leakage.
Small leaks through the tubes would have been identified by the inability to maintain secondary side hydrostatic test pressure. No leakage was noted during performance of the hydrostatic tests.
Page 4 of 28
Neither the individual tube hydrostatic tests, helium leak tests, nor the primary side hydrostatic tests, identified leakage through the steam generator tubes during the course of fabrication. Small leaks would have been detected during any of these tests. Further assurance that small leaks in the tubing are not present is that no primary-to-secondary leakage has been reported since startup (see Response to Question 2).
- 4. Please discuss whether any other inspection data could represent through-wall or near through-wall flaws (e.g., do other types of indications exhibit anomalous signals).
NMC Response to 4:
All special interest MRPCO +PtTm data was reviewed for the KNPP bobbin coil signals that were recorded during the PSI (2001) and first in-service inspection (ISI) (2003).
The signals of interest-included bulges (BLG), bending machine geometry (BMG), free span differential (FSD), free span indications (FSI), geometry (GEO) and manufacturing burnish marks (MBM) from both inspections. Table 1 provides the definitions for the letter codes identified above.
The FSD, FSI and MBM areas of interest resulted in virtually no response from the
+PtTM Coil.
The BLG, BMG, and GEO indications revealed a +PtTm response but the signature was a "typical" flat signal that had no significant vertical amplitude.
None of the FSD, FSI, MBM, BLG, BMG or GEO indications had a signature that mimicked the defective referenced plant tube signal. Sample MRPC C-scan graphics of the KNPP anomalous signals are attached (Figure 12 through Figure 21) and include the largest voltage bobbin coil signals recorded.
As stated above, none of the KNPP indications had a signature that mimicked the defective referenced plant tube signal. This, coupled with the satisfactory leakage tests performed during fabrication of the steam generators (see Response to Question 3) and the absence of primary-to-secondary leakage since startup with the replacement steam generators (see Response to Question 4), provides reasonable assurance that a potential through-wall or near through-wall flaw to exist at these locations is extremely low.
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Table 1 Nomenclature CODE DEFINITION BLG Bulge Condition where the tubing inside diameter is greater than nominal. This condition shall be recorded with channel P1 at greater than or equal to 2.0 volts.
BMG Bending Machine Geometry A gradual change in the tube diameter and/or wall thickness possibly caused by an interruption or a small disturbance during the bending process DNG Ding Condition where the tubing inside diameter is less than nominal. This condition shall be recorded with channel P1 at greater than or equal to 2.0 volts. This condition to be utilized for manufacturing dings.
DNT Dent Condition where the tubing inside diameter is less than nominal. This condition shall be recorded with channel P1 at greater than or equal to 2.0 volts. This condition to be utilized for in-service dents.
FSD Free Span Differential Free span differential signal that meets the condition of the "Free Span Flow Chart." This signal should have a 200 kHz flaw like response.
FSI Free Span Indication Used by resolution analyst for Free Span Absolute (FSA) and FSD indications that have been looked up in prior examinations and determined that a change (as defined in the Free Span Flow Chart) has occurred.
GEO Geometry Condition where a signal appears to be caused by a geometry change. This code used for tracking purposes.
MBM Manufacturing Burnish Mark Condition where localized tubing imperfections removed in the tubing mill or fabrication shop by buffing are detectable on low frequency absolute due to effects of cold working and localized wall thinning.
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File Layout Help CuI Orderl < re > c*2 Span /2> Null Datak
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Figure 1 Reference Plant 2003 PSI Data R156 L143 Vertical Strap (15.09v) DNT Page 7 of 28
File Layout Help til 1 Coil Orderl < (I> <*2 Span /2>1 Null Data!.
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vpp ll MxR 11 VYrx I GAi l 180 I Figure 3 Reference Plant 2003 PSI Data R156 L143 Vertical Strap (0.96v) SVI Page 9 of 28
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Figure 4 Reference Plant 2004 Forced Outage Data R156 L143 Vertical Strap (1.07v) SVI Page 10 of 28
Figure 5 KNPP 2001 PSI Data S/G A R36 C41 U-Bend (2.15v) DNG Page 11 of 28
I Figure 6 KNPP 2001 PSI Data S/G B R46 C57 Tube Support Plate (2.65v) DNG Page 12 of 28
Figure 7 KNPP 2001 PSI Data S/G B R3 C57 Tube Support Plate (3.11v) DNG Page 13 of 28
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Figure 9 KNPP 2001 PSI Data S/G A R46 C42 Tube Support Plate (5.71v) DNG Page 15 of 28
Figure 10 KNPP 2003 ISI Data S/G A R46 C42 Tube Support Plate (6.04v) DNG Page 16 of 28
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Figure 13 KNPP 2003 ISI Data S/G B R14 C23 Free Span (0.15v) FSI Page 19 of 28
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- -i Figure 17 KNPP 2001 PSI Data S/G B R15 C27 Free Span (7.38v) MBM Page 23 of 28
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Figure 18 KNPP 2001 PSI Data SIG B R14 C78 Tubesheet (193.1v) BLG Page 24 of 28
Figure 19 KNPP 2003 ISI Data S/G B R14 C78 Tubesheet (214.5v) BLG Page 25 of 28
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+ 3,30 i i _ _ _
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20-4 miter:WIIH1AIL SO HIDDEN OFF IWGNIFY rtsXcan=1v1 Air^sXv Tiransu XotL=b' Not=1St i HORZPLOTCROSSH OFF i OFF T I ---
OFF I1 I
< CHAN >
3: 200 G1C1+AX CSCAN 180
<PLOT> PLOT 2.09 CHAN l USER
(+/-1 SELECT SCAN SCAN
(+1-) +1-85%
)SCALE YSCALE 0 =2,0 =2,0 12 SCANS T-OFFSET
- _137J :50 SPAN R-SLEII
-41 ON CIRC CIRC FRON TO b4.Z CIRC AXIAL AXIAL NOMERS FROM TO AXIAL II NOMEAS CIRC AXIAL VON]
ON 07H
+ 3.30 970 0 qA I10 Figure 21 KNPP 2003 ISI Data S/G B R1 C55 U-Bend (0.74v) GEO Page 27 of 28
Kewaunee Air Ejector Leak Rate - Based on Ar-41 0.5 0.45 0.4 -__
0.35 CL0 o, 0.3
, 0.25
, 0.2-0.15 0.1 0.05 0 ___ .z::.ez.~e,.~e. s Oi~~i seo.~
,- \N N N l N1 CM CI) co co CO) C') CO) 'I o o 0 a 0 0 0 0 0 0 0 0 0 0 o 0 0 0 0 0 0 0 0 0 0 0 0 tO Z! (D C\D CXD D (0 CD C O C Ne Ne D D 0 N N 4 C X 0 N N Date Figure 22 KNPP Primary-Secondary Leakage Since Startup From SG Replacement Page 28 of 28