NL-06-008, Proposed Steam Generator Examination Program - 2006 Refueling Outage

Proposed Steam Generator Examination Program - 2006 Refueling Outage

ML060530378
Person / Time
Site:	Indian Point
Issue date:	02/13/2006
From:	Conroy P Entergy Nuclear Indian Point 2
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NL-06-008
Download: ML060530378 (8)

Text

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Indian Point Energy Center 450 Broadway, GSB

-TI P.O. Box 249 i.flnto rJs Buchanan, N.Y. 10511-0249 E- Tel (914) 734-6700 February 13, 2006 Re: Indian Point Unit No. 2 Docket No. 50-247 NL-06-008 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Mail Station O-P1-17 Washington, DC 20555-0001

Subject:

Proposed Steam Generator Examination Program - 2006 Refueling Outage (2R17)

Pursuant to the requirements of Indian Point Unit 2 Technical Specification 5.5.7.f.1, Entergy Nuclear Operations, Inc. (ENO) hereby submits its proposed steam generator examination program (Attachment 1) to be conducted during the 2006 refueling outage (2R17). This examination program was developed in accordance with industry guidelines defined in Nuclear Energy Institute (NEI) 97-06: "Steam Generator Program Guidelines," Rev. 2, and Electric Power Research Institute (EPRI) Report TR-1003138: "PWR Steam Generator Examination Guidelines," Rev. 6.

No new regulatory commitments are being made by ENO in this correspondence.

Should you or your staff have any questions regarding this matter, please contact Mr. Patric W.

Conroy, Licensing Manager at 914-734-6668.

Very truly yours, Patric W. Conroy Licensing Manager Indian Point Energy Center cc: next page 10

NL-06-008 Page 2 of 2

Attachment:

1. Proposed Steam Generator Examination Program 2006 Refueling Outage cc:

Mr. John P. Boska, Senior Project Manager Project Directorate I, Division of Licensing Project Management U.S. Nuclear Regulatory Commission Mr. Samuel J. Collins, Regional Administrator Region I U.S. Nuclear Regulatory Commission Resident Inspector's Office Indian Point Unit 2 U.S. Nuclear Regulatory Commission Mr. Peter R. Smith NYSERPJA Mr. Paul Eddy NYS Department of Public Service

ATTACHMENT 1 TO NL-06-008 Proposed Steam Generator Examination Program 2006 Refueling Outage Entergy Nuclear Operations, Inc.

Indian Point Unit No. 2 Docket No. 50-247

NL-06-008 Attachment 1 Page 1 of 5 Indian Point 2 Proposed Steam Generator Examination Program 2006 Refueling Outage A comprehensive steam generator (SG) examination program has been developed for implementation at Indian Point 2 (IP-2) for the second inservice inspection of the replacement steam generators during the Spring 2006 refueling outage (2R1 7). The examination program and methods comply with the IP-2 Technical Specifications and Entergy procedure EN-DC-317 "Entergy Steam Generator Administrative Procedure."

The steam generator examination program was developed in accordance with industry guidelines defined by the Nuclear Energy Institute (NEI) 97-06: "Steam Generator Program Guidelines," Rev. 2, and Electric Power Research Institute (EPRI) Report TR-1003138: "PWR Steam Generator Examination Guidelines," Rev. 6.

The steam generator examination program incorporates both primary and secondary-side inspections. The scope of the inspections to be performed and the methods employed are detailed in Entergy Engineering Report No. IP-RPT-05-00408: "Steam Generator Pre-Outage Degradation Assessment and Repair Criteria for 2R17, ER-IP2-05-2080 1," Rev. 0 (Reference 1). The degradation assessment defines an integrated plan for the detection, quantification and assessment of degradation of both primary and secondary side steam generator components that could affect structural integrity, pressure boundary leak tightness, and operating reliability.

The primary-side examination plan utilizes eddy current test (ECT) methods to detect and assess potential steam generator tube degradation, and visual inspection to assess the condition of the primary channel head, cladding, and steam generator tube plugs. The secondary-side examination plan utilizses visual inspection to assess steam generator internals, both in bundle and top of tubesheet regions. Visual examination is also utilized to detect loose parts and to assess other secondary-side component conditions that could affect the structural integrity and leak tightness of pressure boundaries.

Elements of the primary and secondary-side inspections described herein address compliance with Technical Specifications, NEI 97-06, and industry guidelines. ENO's compliance with NEI 97-06 is mandated by EN-DC-317 "Entergy Steam Generator Administrative Procedure", which provides for management discretion to define the scope and frequency of certain steam generator examinations that go beyond the requirements of the Technical Specifications. To the extent that the steam generator examination plan for the Spring 2006 exceeds existing Technical Specification requirements, no new licensing commitments are intended or implied in this plan.

Specific details of the 2006 refueling outage steam generator examination program are summarized below.

NL-06-008 Attachment 1 Page 2 of 5 Steam Generator Primary-Side Inspection Primary-side steam generator examinations are summarized in Table 1. Fifty percent (50%/)) of active steam generator tubes will be examined from tube end to tube end utilizing eddy current test (ECT) methods as specified in Table 1. A full length bobbin probe inspection will be performed of the tubes in Rows 3 and higher. In Rows 1 and 2, a bobbin probe inspection will be performed of the hot and cold straight leg sections inclusive of the upper support plate, while U-bends in these two rows will be inspected by rotating Plus Point probe. In addition 20% of hot leg tubes in four steam generators will be inspected at the top of the tubesheet +/'- 3 inches by rotating Plus Point probe.

Potential and actual indications of degradation by the bobbin probe will be further characterized and confirmed by rotating Plus Point probe. The basis used to determine the scope of any selected inspection sample or need to perform an expansion of the inspection scope shall comply with the requirements of the Technical Specification 5.5.7 and the EPRI PWR Steam Generator Examination Guidelines Rev. 6.

Other inspection probes and methods may be used at the discretion of ENO.

Supplementing steam generator tube ECT inspections, visual inspection will be performed of the primary channel heads and tubesheet, including previously plugged tubes (sixteen tubes were plugged in various steam generators during 2R1 5 and two tubes in SG24 were plugged at the factory during manufacturing), in accordance with the requirements of the Westinghouse SG Technical Manual and site procedures.

The ECT methods employed to inspect steam generator tubes meet the requirements of the EPRI PWR Steam Generator Examination Guidelines, Rev. 6, and are qualified in accordance with Appendix H of those guidelines. ECT data analysts will be qualified using a site specific training program in accordance with Appendix G of the same EPRI guideline document. Bobbin probe inspection will be performed of all straight leg tube sections and U-bends in Rows 3 and higher with the maximum diameter probe feasible, which is typically a 720 mil diameter probe.

The results of ECT shall be reviewed, and degraded and defective steam generator tubes shall be identified. The cause of degradation and degradation measurement parameters in degraded steam generator tubes shall be assessed against established structural limits (Reference 2) and Technical Specification criteria, and the result shall be incorporated in the Operational Assessment. If any defective tubes are detected, a bounding selection of defective tubes shall be pressure tested and the results shall be compared against performance criteria for structural integrity and accident leakage and incorporated into the Condition Monitoring Assessment. For tubes with existing degradation, the Operational Assessment shall suitably account for uncertainties in eddy current measurements and continued tube wall degradation between consecutive inspection periods.

NL-06-008 Attachment 1 Page 3 of 5 Degraded tubes, as defined by TS 5.5.7.a.4, shall be considered acceptable for continued service only if the degradation meets the more restrictive of the requirements of TS 5.5.7.e.1 or the required industry standard (NEI 97-06) operational assessment for the next period that conservatively demonstrates continued structural integrity including consideration of ECT error and degradation growth. Tubes that contain degradation that exceeds the more limiting requirement shall be removed from service by plugging. ENO may administratively plug tubes for other reasons. Prior to leaving a degraded tube in service, Entergy will submit to the NRC Ihe bases of such decision including the method of inspection, the plugging criterion used, and a description of the methodology used to develop this criterion.

Any decision to leave degraded tubes in service at Indian Point 2 will be documented in the Condition Monitoring and Operational Assessment (CMOA) Report and justified in accordance with the requirements of the Steam Generator Program Plan, NEI 97-06 and EPR]E Steam Generator Examination Guidelines Rev. 6. The basis to leave degraded tubes in service will duly consider ECT inaccuracy and projected degradation growth rate over the next operating cycle.

Steam Generator Secondary-Side Inspectilon Visual inspection is utilized to assess the presence of loose parts or other steam generator secondary-side component conditions that could affect the structural integrity of the primary boundary and leak tightness.

The secondary-side inspection will incorporate sludge lancing and foreign object search and retrieval (FOSAR). In-bundle inspection will be performed in approximately every fifth column.

A top support plate inspection will be performed on one steam generator. Depending on the results found in the first steam generator the top support plate inspection may be expanded to the other steam generators.

References:

1. Engineering Report IP-RPT-05-00408, "Steam Generator Pre-Outage Degradation Assessment and Repair Criteria for 2R17, ER-IP2-05-20801"

2. Westinghouse Electric Company CN-SGDA-02-128 Rev. 2 "Regulatory Guide 1.121 Analysis for the Indian Point Unit 2 Model 44F Replacement Steam Generators"

NL-06-008 Attachment 1 Page 4 of 5 Table 1: Steam Generator Primary-Side Inspection Plan for 2R17 Inspection Inspection Scope Number of Steam Generators ECT Bobbin Coil 50% of tubes - end to end' Four steam generators ECT Bobbin Coil 50% of Row 1 and Row 2 straight lengths hot and Four steam generators cold legs ECT Rotating Probe (Plus Point) 50% of Row 1 and Row 2 U-bends Four steam generators ECT Rotating Probe (Plus Point) 20% of hot leg tubes at the top of tubesheet +/- 3 Four steam generators inches W of TRnguiD atiuis of degradetion by DUBbblin prbeobe Cetenninea Visual l Channel head, cladding, plugs l Four Steam Generators Notes:

1) Bobbin coil is not qualified for Row 1and Row 2 U-bends.

NL-06-008 Attachment I Page 5 of 5 Table 2: Steam Generator Secondary-Side Inspection Plan for 2R17 Task and Inspection Method Inspection Scope Number of Steam Generators Sludge Lancing Top of tubesheet Four steam generators In-bundle FOSAR - Visual Top of Tubesheet and tube bundle Four steam generators Outer Annulus Visual Region between wrapper and outer shell Four Steam Generators Flow Distribution Baffle Visual Top of plate the full length of tube lane Four Steam Generators Support Plates Visual Top Support Plate One Steam Generator. Depending oni MhuIlt VI first steak- generator, inspection may be expanded to the other steam generators.