ML050770200

License Amendment Request Proposed Technical Specification Change Regarding Tubesheet Inspection Depth for Steam Generator Tube Inspections

ML050770200
Person / Time
Site:	Waterford
Issue date:	03/15/2005
From:	Venable J Entergy Nuclear South, Entergy Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
WSF1-2005-0009
Download: ML050770200 (16)

Text

U -

'~'En tergy Entergy Nuclear South Entergy Operations. Inc.

17265 River Road Killona, LA 70066 Tel 504 739 6660 Fax 504 739 6678 jvenabl@entergy.com Joseph E. Venable Vice President, Operations Waterford 3 W3Fl-2005-0009 March 15, 2005 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555

REFERENCES:

License Amendment Request Proposed Technical Specification Change Regarding Tubesheet Inspection Depth for Steam Generator Tube Inspections Waterford Steam Electric Station, Unit 3 Docket No. 50-382 License No. NPF-38-260

1. Entergy letter dated October 27, 2004, Response to Generic Letter 2004-01, Requirements for Steam Generator Tube Inspections (W3Fl -2004-0091)

2.

Entergy letter dated November 18, 2003, Combined Category C-3 and 15-Day Special Report SR-03-002-00 on the 12th Refueling Outage Steam Generator Tube Inservice Inspection (W3Fl-2003-0089)

3.

Florida Power & Light letter dated November 8, 2004, Define the Depth of the Required Tube Inspections and Clarify the Plugging Criteria Within the Tubesheet Region of the Original Steam Generators, St.

Lucie, Unit 2

4.

Entergy letter dated July 14, 2004, Supplement to Amendment Request NPF-38-249, Extended Power Uprate (W3F1-2004-0052)

5. Entergy letter dated July 15, 2004, Alternate Source Term (W3FI-2004-0053)

Dear Sir or Madam:

Pursuant to 10 CFR 50.90, Entergy requests to amend Facility Operating License for the Waterford Steam Electric Station, Unit 3. The proposed amendment revises Technical Specification (TS) Section 4.4.4.4 to modify the steam generator tube inspection Acceptance Criteria for the "Plugging or Repair Limit" and the "Tube Inspection," as contained in the Waterford-3 TS Surveillance Requirements 4.4.4.4.a.7 and 4.4.4.4.a.9, respectively. The

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W3F1I-2005-0009 Page 2 of 3 purpose of these changes is to define the depth of the required tube inspections and to clarify the plugging criteria within the tubesheet region.

In letter dated October 27, 2004 (Reference 1) Entergy committed to submit a change in accordance with Generic Letter 2004-01 to add a statement to the Waterford-3 TSs to include a specific limitation for tubesheet depth inspection. This action was proposed in concert with a TS change that is consistent with the EPRI Generic Licensing Change Package (GLCP) as provided by Technical Specification Task Force (TSTF)-449, Revision 2, Steam Generator Tube Integrity. Following discussion with your NRC Staff on February 3, 2005, Entergy will pursue these two changes in separate license amendment requests. Therefore, this submittal only proposes to change the tubesheet inspection depth and clarify the plugging criteria within the tubesheet region in response to Generic Letter (GL) 2004-01.

This license amendment request defines the depth of the required tube inspection and to clarify the plugging criteria within the tubesheet region, as outlined in GL 2004-01. A topical report providing the results of a joint industry program, WCAP-1 6208-P, Revision 0 dated October 2004 entitled NDE Inspection Length for CE Steam Generator Tubesheet Region Explosive Expansions, addresses tube structural and leakage integrity and is used as the technical basis for these changes. WCAP-1 6208-P, as well as the non-Proprietary version, was previously submitted to the NRC by Florida Power & Light for St. Lucie, Unit 2 (Reference 3). Therefore, this report is not being resubmitted to the NRC as part of this Waterford 3 license amendment request. In addition, Westinghouse responses to NRC Requests forAdditional Information were provided in WCAP-16391-P, Responses to NRC Requests for Additional Information on FPL St.

Lucie 2 Submittal of the C* Topical Report, Revision 0 (WCAP-16208) dated January 2005.

The proposed change has been evaluated in accordance with 10 CFR 50.91 (a)(1) using criteria in 10 CFR 50.92(c) and it has been determined that this change involves no significant hazards consideration. The basis for these determinations is included in Attachment 1. This letter contains one new commitment as summarized in Attachment 3.

The proposed amendment is neither exigent nor emergency and as previously discussed in our response to Generic Letter 2004-01, NRC approval of this proposed TS does not need to occur prior to the resumption of power following the upcoming spring 2005 refueling outage SG tube inservice inspection. Entergy requests NRC approval of this change by March 1, 2006. Once approved, the amendment will be implemented within 90 days.

If you have any questions or require additional information, please contact Ron Williams at 504-739-6255.

I declare under penalty of penury that the foregoing is true and correct. Executed on March 15,2005.

Sincerey, JEV/SAB/RLW Attachments:

1. Analysis of Proposed Technical Specification Change

2. Proposed Technical Specification Changes (mark-up)

3. List of Regulatory Commitments

W3F1-2005-0009 Page 3 of 3 cc:

Dr. Bruce S. Mallett U. S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011 NRC Senior Resident Inspector Waterford 3 P.O. Box 822 Killona, LA 70066-0751 U.S. Nuclear Regulatory Commission Attn: Mr. Nageswaran Kalyanam MS O-7D1 Washington, DC 20555-0001 Wise, Carter, Child & Caraway Attn: J. Smith P.O. Box 651 Jackson, MS 39205 Winston & Strawn Attn: N.S. Reynolds 1400 L Street, NW Washington, DC 20005-3502 Louisiana Department of Environmental Quality Office of Environmental Compliance Surveillance Division P. O. Box 4312 Baton Rouge, LA 70821-4312 American Nuclear Insurers Attn: Library Town Center Suite 300S 29th S. Main Street West Hartford, CT 06107-2445

Attachment I W3FI -2005-0009 Analysis of Proposed Technical Specification Change

Attachment I to W3Fl-2005-0009 Page 1 of 7 Analysis of Proposed Technical Specification Change

1.0 DESCRIPTION

A change is proposed to revise the Waterford-3 Technical Specification Section 4.4.4.4 to modify the steam generator tube inspection Acceptance Criteria for the "Plugging or Repair Limit" and the "Tube Inspection," as contained in the Waterford-3 Technical Specification (TS)

Surveillance Requirements (SR) 4.4.4.4.a.7 and 4.4.4.4.a.9, respectively. The purpose of these changes is to define the depth of the required tube inspections and to clarify the plugging criteria within the tubesheet region.

2.0 PROPOSED CHANGE

Entergy proposes a revision to TS 3/4.4.4 for the Waterford 3 Steam Generator SRs.

Specifically, the current steam generator tube inspection Acceptance Criteria for "Plugging or Repair Limit" (SR 4.4.4.4.a.7) and "Tube Inspection" (SR 4.4.4.4.a.9) read as follows:

"Plugging or Repair Limit means the imperfection depth at or beyond which the tube shall be removed from service by plugging or repaired by sleeving because it may become unserviceable prior to the next inspection and is equal to 40% of the nominal tube wall thickness.'

"Tube Inspection means an inspection of the steam generator tube from the point of entry (hot leg side) completely around the U-bend to the top support of the cold leg."

These acceptance criteria will be revised to read as follows:

"Plugging or Repair Limit means the imperfection depth at or beyond which the tube shall be removed from service by plugging or repaired by sleeving because it may become unserviceable prior to the next inspection and is equal to 40% of the nominal tube wall thickness. This Plugging or Repair Limit is not applicable in the portion of the tube that is greater than 10.4 inches below the bottom of the expansion transition or top of the tubesheet, whichever is lower, to the tube end. Degradation detected between 10.4 inches below the bottom of the expansion transition or top of the tubesheet, whichever is lower, and the bottom of the expansion transition or top of the tubesheet, whichever is higher, shall be plugged on detection."

'Tube Inspection means an inspection of the steam generator tube from 10.4 inches below the bottom of the hot leg expansion transition or top of the tubesheet, whichever is lower, completely around the U-bend to the top support of the cold leg."

3.0 BACKGROUND

On August 30, 2004, the NRC issued Generic Letter (GL) 2004-01, Requirements for Steam Generator Tube Inspections. The GL requested Pressurizer Water Reactor licensees to submit information concerning their steam generator tube inspections. The requested information would be utilized by the NRC staff to determine whether licensees are implementing steam generator tube inspections in accordance with applicable requirements to W3Fl-2005-0009 Page 2 of 7 (plant TS in conjunction with 10 CFR Part 50, Appendix B, and the General Design Criteria or the plant specific design basis, as appropriate). Entergy submitted the response to GL 2004-01 for Waterford 3 on October 27, 2004 (Reference 1).

Entergy determined that the Waterford 3 SG tube inspection scope is not consistent with the NRC's position in GL 2004-01 with respect to inspections performed within the tube sheet.

Waterford 3 has utilized the Combustion Engineering owners Group (CEOG) Task 1154 which was developed to evaluate pull-out distance and leakage. Based on this analysis, the inspection scope was limited due to the fact that the tube could not burst and leakage was within safety analysis limits. Additional leakage was accounted for in the safety assessment for portion of the tubesheet (between 8 and 12 inches below the top of the tubesheet) that were inspected using the Bobbin Coil only. The other areas of the SG inspections are consistent with the NRC's position in GL 2004-01. Entergy concluded that there is a potential for degradation to exist below the depth of tube inspections within the tubesheet region to be performed during refueling outage RF13 (spring of 2005). This conclusion is based on recent inspection results from steam generators of similar designs.

The appropriate tube inspection depth is being revised based on a joint industry testing program provided in WCAP-1 6208-P, Revision 0, NDE Inspection Length for CE Steam Generator Tubesheet Region Explosive Expansions, (October 2004) whichdemonstrates that flaws below a defined inspection distance within the tubesheet are not a safety concern.

Westinghouse responses to NRC Requests for Additional Information were provided in WCAP-1 6391-P, Responses to NRC Requests forAdditional Information on FPL St. Lucie 2 Submittal of the C* Topical Report, Revision 0 (WCAP-16208) dated January 2005.

4.0 TECHNICAL ANALYSIS

Waterford 3 has two Combustion Engineering (CE) Model 3410 steam generators. The tubing material in each steam generator is high temperature mill annealed (HTMA) Alloy 600. The tubes are expanded through the full depth of the tube sheet using an explosive process. Tube rows 1 through 18 are U-bends and rows 19 through 147 are square bends.

The resultant interference fit between each of the tubes and tubesheet provides structural integrity to resist tube pull-out, and a leak resistant boundary between the primary and secondary systems. This variation directly affects the tube engagement length and is taken into account when the depth of inspections is established for the tubesheet region. A seal weld joins the tube end to the cladding on the primary face of the tubesheet.

The Waterford 3 Steam Generator Inspection Program requires that a degradation assessment be performed prior to each refueling outage. The purpose of the degradation assessment is to determine the susceptible areas of the tubing to be inspected, and the appropriate techniques for the inspection of each area. Data gathered is utilized as input to the subsequent condition monitoring and operational assessments. The Waterford 3 Steam Generator Inspection Program satisfies Nuclear Energy Institute (NEI) 97-06, Steam Generator Program Guidelines, January 2001.

A detailed description of the Steam Generator tube inservice inspection conducted during the fall 2003 refueling outage was provided in Entergy's letter dated November 18, 2003 (Reference 2). The inspection included bobbin probe examinations of all active tubes, and to W3F1-2005-0009 Page 3 of 7 sample inspections with a rotating Plus Point Probe for low row U-bends. All bobbin indications of potential corrosion degradation were further interrogated using the Plus Point probe. Additionally, all active tube hot legs were inspected with rotating probes from +3 inches to -8 inches, referenced to the secondary faces of the tubesheets to ensure that a minimum tube to tubesheet engagement length was examined. All indications of tube wall degradation, with the exception of wear, were removed from service upon detection. Wear indications were removed from service if they were 40% of the tube wall thickness or greater.

The joint industry test program documented in WCAP-1 6208-P determined the recommended minimum tube engagement length within the tubesheet for inspection (C*) in CE designed steam generators that ensures the structural and accident induced leakage criteria of NEI 97-06 are met. Specifically, the tube to tubesheet joints must resist burst with an internal pressure of 3 times normal operating differential pressure (NODP) or 1.4 times main steam line break (MSLB) differential pressure conditions, and they must maintain primary to secondary accident-induced leakage below 0.5 gallons per minute (gpm) per steam generator (as defined in WCAP-16208-P). As such, this distance is referenced from the bottom of the hot leg expansion transition or top of the tubesheet, whichever is lower.

Tube burst is precluded for a tube with defects in the tubesheet region because of the constraint provided by the tubesheet. Therefore, tube pullout would be a prerequisite for tube burst under the limiting internal pressure conditions of NEI 97-06. WCAP-16208-P evaluated the minimum joint length required to preclude tube pull-out at a load of 3 times NODP, which bounds 1.4 times MSLB differential pressure.

The NEI 97-06 primary to secondary accident-induced leakage criteria of 1.0 gpm per steam generator exceeds the accident analysis leakage limits for most participating utilities, including the Waterford 3 existing limit of 720 gallons per day (gpd) or 0.5 gpm in any one SG per TS 3.4.5.2. To account for this disparity and to allow margin for other possible leak sources, WCAP-16208-P evaluated the minimum joint length required to maintain primary to secondary accident-induced leakage at 0.1 gpm per steam generator, assuming that 100% of the steam generator tubes were leaking below the C* depth.

Entergy previously submitted License Amendment Requests for Extended Power Uprate (Reference 4) and Alternate Source Term (Reference 5). Safety analyses supporting these amendment requests were performed using a lower primary to secondary leakage rate than that assumed in the current licensing basis. Analysis of the events that result in a faulted steam generator (e.g., MSLB) lowered the assumed leakage rate from 720 gpd (0.5 gpm) to 540 gpd (0.375 gpm). While the revised EPU / AST faulted steam generator leakage rate is smaller than that of the current licensing basis, it is still conservative with respect to the 0.1 gpm predicted byWCAP-16208-P, which is the basis of this request. Given the conservative assumption of WCAP-1 6208-P that all steam generator tubes are flawed below the C*

inspection depth, the remaining margin is considered adequate to account for other possible leak sources.

WCAP-16208-P generated empirical pullout load and leakage rate test data for a number of tube to tubesheet joint mock-up samples. The testing determined that the joint length required to satisfy the pull-out criteria was bounded by that required to satisfy the leakage rate criteria.

Analytical methods were utilized to correct the empirical data for tubesheet deflection effects on both the joint strength and leakage resistance. Axial position uncertainties associated with eddy current examinations were also accounted for by adding a correction factor to the data.

to W3Fl-2005-0009 Page 4 of 7 An additional conservatism was introduced by assuming that 100 percent of the steam generator tubes were severed by a 3600 circumferential crack immediately below the C*

inspection length. The final result of WCAP-1 6208-P for Waterford 3 was a C* value of 10.4 inches including non-destructive examination uncertainty.

The current Waterford 3 SG tube inspection methods meet the technical specification requirements in conjunction with 10 CFR Part 50, Appendix B. The rotating Plus Point Probe employed in the tubesheet region is fully capable of detecting axial and circumferential flaws, however there are significant uncertainties associated with flaw sizing. These uncertainties are addressed by the proposed TS changes to the definition of 'Plugging or Repair Limit."

Specifically, all tubes exhibiting degradation within the C* length of the tubesheet region shall be plugged upon detection as is our current practice.

Therefore, the proposed revisions to the steam generator tube inspection Acceptance Criteria for " Plugging or Repair Limit " and "Tube Inspection," as contained in the Waterford 3 SRs 4.4.4.4.a.7 and 4.4.4.4.a.9, respectively, maintain the structural and accident-induced leakage integrity of the steam generator tubes as required by NEI 97-06 and the plant design basis.

Furthermore, the proposed revisions do not involve a significant hazard consideration.

Therefore, this license amendment is acceptable with respect to the operation of Waterford 3.

5.0 REGULATORY ANALYSIS

5.1 Applicable Regulatory Requirements/Criteria The regulatory requirements applicable to SG tube integrity are the following:

5.1.1 10 CFR 50.55a. Codes and Standards - Components which are part of the reactor coolant pressure boundary must meet the requirements for Class 1 components in Section III of the ASME Boiler and Pressure Vessel Code, except as provided in paragraphs (c)(2), (c)(3), and (c)(4) of this section. The proposed change and the Waterford 3 Steam Generator Inspection Program requirements which underlie it are in full compliance with the ASME Code. The proposed technical specifications are effective at ensuring tube integrity and, therefore, compliance with the ASME Code.

5.1.2 10 CFR 50, Appendix A General Design Criteria for Nuclear Power Plants GDC 14 - Reactor Coolant Pressure Boundary. The reactor coolant pressure boundary shall be designed, fabricated, erected, and tested so as to have an extremely low probability of abnormal leakage, of rapidly propagating failure, and of gross rupture. The discussion provided in Section 4.0, Technical Analysis, assures that the proposed change will continue to comply with this regulatory requirement.

GDC 30 - Quality of Reactor Coolant Pressure Boundary. Components which are part of the reactor coolant pressure boundary shall be designed, fabricated, erected, and tested to the highest quality standards practical. Means shall be provided for detecting and, to the extent practical, identifying the location of the source of reactor coolant leakage. There are no changes to the steam generator design that impact this general design criterion. The discussion to W3Fl-2005-0009 Page 5 of 7 provided in Section 4.0 assures that the proposed change will continue to comply with this regulatory requirement.

GDC 32 - Inspection of Reactor Coolant Pressure Boundary. Components which are part of the reactor coolant pressure boundary shall be designed to permit (1) periodic inspection and testing of important areas and features to assess their structural and leaktight integrity, and (2) an appropriate material surveillance program for the reactor pressure vessel. There are no changes to the steam generator design that impact this general design criterion. The discussion provided in Section 4.0 assures that the proposed change will continue to comply with this regulatory requirement.

5.1.3 Waterford 3 Final Safety Analysis Report (FSAR) - The Waterford 3 FSAR was reviewed to determine whether a change in the proposed TS would impact the licensing basis. The following Waterford 3 FSAR sections were noted:

05.4.2.4 Tests and Inspection fSteam Generator Tubesl states:

Baseline and inservice inspection of steam generator tubing will comply with Regulatory Guide 1.83, Rev. 1, July 1975, "Inservice Inspection of Pressurized Water Reactor Steam Generator Tubes".

The Waterford 3 TS, as amended, will continue to meet the intent of Regulatory Guide 1.83.

§1 5.6.3.2 Steam Generator Tube Rupture discusses the Waterford 3 Steam Generator Tube Rupture accident analysis. The proposed change does not impact any of the accident assumptions or analysis results as discussed in the Waterford 3 FSAR. However, the previously submitted AST and EPU changes will affect the accident analysis, but the radiological consequence results will remain within the Regulatory Guide 1.183, Table 6 and 10 CFR 50.67 acceptance criteria.

5.2 No Significant Hazards Consideration A change is proposed to revise the Waterford Steam Electric Station, Unit 3 (Waterford

3) Technical Specifications (TS) Section 4.4.4.4 to modify the steam generator tube inspection Acceptance Criteria for "Plugging or Repair Limit" and "Tube Inspection," as contained in the Waterford 3 TS Surveillance Requirements (SR) 4.4.4.4.a.7 and 4.4.4.4.a.9, respectively. The purpose of these changes is to define the depth of the required tube inspections and to clarify the plugging criteria within the tubesheet region. A joint industry test program is documented in WCAP-16208-P, Revision 0, NDE Inspection Length for CE Steam Generator Tubesheet Region Explosive Expansions, (October 2004). This report defines the non-degraded tube to tubesheet joint length required to preclude tube pullout (C*) and maintain acceptable primary to secondary accident-induced leakage, assuming a 3600 circumferential through wall crack existing immediately below this length, to ensure the structural and accident induced leakage criteria of NEI 97-06 are met. For Waterford 3, C* was determined to be 10.4 inches.

to W3F1 -2005-0009 Page 6 of 7

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

Response: No Conducting the rotating Plus Point probe inspections to a minimum tubesheet length of 10.4 inches maintains the existing design limits and does not increase the probability or consequences of an accident involving tube burst or primary to secondary accident-induced leakage, as previously analyzed in the Waterford 3 Final Safety Analysis Report. Also the NEI 97-06 structural integrity and accident-induced leakage of the steam generator tubes performance criteria will continue to be satisfied.

Tube burst is precluded for a tube with defects within the tubesheet region because of the constraint provided by the tubesheet. As such, tube pullout resulting from the axial forces induced by primary to secondary differential pressures would be a prerequisite for tube burst to occur. Any degradation below C* is shown by empirical test results and analyses to be acceptable, thereby precluding an event with consequences similar to a postulated tube rupture event. WCAP-1 6208-P has shown that tube flaws below the C* length will not result in primary to secondary leakage greater than 0.1 gpm per steam generator. Inspection to the C* length will ensure that the postulated accident induced leakage for events that involve a faulted steam generator (e.g., a main steam line break (MSLB)) will remain within both the current and proposed extended power uprate (EPU) accident analyses of 720 gpd (0.5 gpm) and 540 gpd (0.375 gpm), respectively.

Therefore, the proposed change does not affect the probability or consequences of any Waterford 3 analyzed accidents.

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

Response: No Steam generator tube leakage and structural integrity will be maintained during all plant conditions upon implementation of the proposed inspection scope and plugging or repair limit changes to the Waterford 3 Technical Specifications. These changes do not introduce any new mechanisms that might result in a different kind of accident from those previously evaluated. Even with the limiting circumstances of a complete circumferential separation (3600 through wall crack) of all of the tubes below the C* length, tube pullout is precluded and leakage is predicted to be maintained within both the current and proposed extended power uprate (EPU) accident analyses assumptions.

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

to W3F1 -2005-0009 Page 7 of 7

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

Response: No The proposed inspection and plugging criteria will better assure that steam generator tube performance is maintained within its design basis and within the safety analysis assumptions. Operation with potential tube degradation below the C* inspection length within the tubesheet region of the steam generator tubing meets the intent of the inspection guidance of RG 1.83, Inservice Inspection of Pressurized Water Reactor Steam Generator Tubes, the requirements of General Design Criteria 14, 30 and 32 of 10 CFR 50, and the recommendations of NEI-97-06, Steam Generator Program Guidelines.

The total leakage from an undetected flaw population below the C* inspection length under postulated accident conditions is accounted for to assure that the leakage criterion is met and bounded by both the current and the proposed EPU accident analyses assumptions. Adequate margin remains for other possible steam generator tube leak sources.

The proposed changes also maintain the structural and accident-induced leakage integrity of the steam generator tubes as required by NEI 97-06 and the plant design basis.

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

5.3 Environmental Considerations The proposed amendment does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluent that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.

6.0 PRECEDENCE The proposed changes to the Waterford 3 Technical Specifications are consistent with that submitted by Florida Power & Light in letter dated November 8, 2004, for St. Lucie, Unit 2 (Reference 3). The NRC approved this request on November 18, 2004.

W3FI-2005-0009 Proposed Technical Specification Changes (mark-up) to W3Fl-2005-0009 Page 1 of 2 REACTOR COOLANT SYSTE=

SURVEILLANCE REOUIREMENTS (Continued) 4.4.4.4 acceptance Criteria

a.

As used in this Specification

1.

Tubing or tb means that portion of the tube or sleeve which forms the primary system to secondary system pressure boundary.

2.

Imperfection means an exception to the dimensions, finish or contour of a tube from that required by fabrication drawings or specifications. Eddy-current testing indications below 20% of the nominal tube wall thickness, if detectable, may be considered as imperfections.

3.

Degradation means a service-induced cracking wastage, wear, or general corrosion occurring on either inside or outside of a tube.

4.

Dgaraded Tube means a tube containing imperfections greater l than or equal to 20% of the nominal wall thickness caused by degradation.

5.

% Dearadati means the percentage of the tube wall thickness affected or removed by degradation.

6.

Defect means an imperfection of such severity that it exceeds the plugging or repair limit. A tube containing a defect is defective.

7.

Plsmnina or Renair limit means the imperfection depth at or beyond which the tube shall be removed from service by plugging or repaired by sleeving because It may become unserviceable prior to the next inspection and is equal to 40% of the nominal tube wall thickness.

8.

Unserviceable describes the condition of a tube if It leaks l or contains a defect large enough to affect its structural integrity in the event of an Operating Basis Earthquake, a loss-of-coolant accident. or a steam line or feedwater line break as specified in 4.4.4.3c., above.

Tube InsDection means an inspection of the steam generator tube from the point o n_!tl side)-complctcly

10.

Preservice Inspection means an inspection of the full length of each tube In each steam generator performed by eddy current techniques prior to service to establish a baseline condition of the tubing. This inspection was performed prior to field hydrostatic test and prior to initial POWER OPERATION using the equipment and techniques expected to be used during subsequent inservice inspections.

WATERFORD - UNIT 3 314 4-13 Amendment No. *tT.

to W3Fl-2005-0009 Page 2 of 2 Insert 1 This Plugging or Repair Limit is not applicable in the portion of the tube that is greater than 10.4 inches below the bottom of the expansion transition or top of the tubesheet, whichever is lower, to the tube end. Degradation detected between 10.4 inches below the bottom of the expansion transition or top of the tubesheet, whichever is lower, and the bottom of the expansion transition or top of the tubesheet, whichever is higher, shall be plugged on detection.

Insert 2 10.4 inches below the bottom of the hot leg expansion transition or top of the tubesheet, whicheveris lower, completely around the U-bend to the top support of the cold leg.

To W3FI-2005-0009 List of Regulatory Commitments to W3Fl-2005-0009 Page 1 of 1 List of Regulatory Commitments The following table identifies a revised commitment from Entergy letter dated October 27, 2004, Response to Generic Letter 2004-01, Requirements for Steam Generator Tube Inspections (W3Fl-2004-0091) committed to by Entergy in this document. This license amendment request addresses the specific limitation for tubesheet depth inspection portion of the commitment discussed above. Any other statements in this submittal are provided for information purposes and are not considered to be regulatory commitments.

TYPE (C eck one)

SCHEDULED ONE-CONTINUING COMPLETION COMMITMENT TIME COMPLIANCE DATE (If ACTION Required)

Entergy will submit a technical specification change consistent with the EPRI Generic Licensing Change Package (GLCP) as provided by Technical Specification Task Force (TSTF)-449, Revision 3, Steam Generator Tube Integrity. Entergy will X

By August 1, submit this change as part of the NRC 2005 Consolidated Line Item Improvement Process (CLIIP) or as a Waterford 3 specific amendment request if the CLIIP has not been released by the NRC.