W3F1-2009-0020, Response to NRC Request for Additional Information the 2007 and 2008 (Refueling Outage 15) Steam Generator Tube Inspections

Response to NRC Request for Additional Information the 2007 and 2008 (Refueling Outage 15) Steam Generator Tube Inspections

ML091540016
Person / Time
Site:	Waterford
Issue date:	06/01/2009
From:	Murillo R Entergy Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
TAC ME0164, W3F1-2009-0020
Download: ML091540016 (9)

Text

Entergy Operations, Inc.

17265 River Road Killona, LA 70057-3093

@Entergy Tel 504-739-6715 Fax 504-739-6698 rmurill@entergy.com.

Robert J. Murillo Licensing Manager Waterford 3 W3F1-2009-0020 June 1, 2009 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001

SUBJECT:

Response to NRC Request for Additional Information Re: The 2007 and 2008 (Refueling Outage 15) Steam Generator Tube Inspections (TAC No. ME0164)

Waterford Steam Electric Station, Unit 3 Docket No. 50-382 License No. NPF-38

REFERENCES:

1 Entergy letter dated November 25, 2008 "180-Day Steam Generator Tube Inspection Report for the 1 5 th Refueling Outage" (W3F1-2008-0074) 2 NRC letter dated April 17, 2009 "Waterford Steam Electric Station, Unit 3 - Request for Additional Information Re: The 2007 and 2008 (Refueling Outage 15) Steam Generator Tube Inspections (TAC No.

ME0164)" (ILN09-0044)

Dear Sir or Madam:

On April 17, 2009, Entergy received communication (Reference 2) from members of the NRC Staff requesting additional information associated with Entergy's submittal of Waterford 3's "180-Day Steam Generator Tube Inspection Report for the 1 5 th Refueling Outage" (Reference 1).

Attachment 1 contains Entergy's response to the NRC questions. Attachment 2 contains a legible copy of Table E-1.

There are no new commitments contained in this letter.

.40oy

W3F1-2009-0020 Page 2 If you have any questions or require additional information, please contact me at 504-739-6715.

Sincerely, RJM/RJP Attachments:

1. Entergy's response to the NRC questions

2. Legible copy of Table E-1

W3F1-2009-0020 Page 2 cc: Mr. Elmo E. Collins, Jr.

Regional Administrator U. S. Nuclear Regulatory Commission Region IV 612 E. Lamar Blvd., Suite 400 Arlington, TX 76011-4125 NRC Senior Resident Inspector Waterford Steam Electric Station Unit 3 P.O. Box 822 Killona, LA 70066-0751 U. S. Nuclear Regulatory Commission Attn: Mr. N. Kalyanam Mail Stop O-07D1 Washington, DC 20555-0001 Wise, Carter, Child & Caraway ATTN: J. Smith P.O. Box 651 Jackson, MS 39205 Louisiana Department of Environmental Quality Office of Environmental Compliance Surveillance Division P. 0. Box 4312 Baton Rouge, LA 70821-4312 American Nuclear Insurers Attn: Library 95 Glastonbury Blvd.

Suite 300 Glastonbury, CT 06033-4443

Attachment 1 To W3F1 -2009-0020 Response to NRC Request for Additional Information Re: The 2007 and 2008 (Refueling Outage 15)

Steam Generator Tube Inspections

(

to W3F1-2009-0020 Page 1 of 3 Response to Request for Additional Information Question 1:

The information in Table E-1 is not legible; please provide another copy of Table E-1.

Response 1:"

A legible copy of Table E-1 is provided as Attachment 2.

Question 2:

In Table E-1, SG-31 appears to have 8474 tubes inservice prior to RFO15 and 1176 tubes that were previously removed from service. These numbers do not agree with the total number of SG tubes (i.e., 9350 tubes). Please clarify the actual number of tubes in service and removed from service.

Response 2:

A corrected copy of Table E-1 is provided as Attachment 2.

The original submittal includes the correct number of tubes in-service in paragraph 2.0.

Question 3:

In Table F-1, the total number of plugs listed for SG-32 is 1217; however, the numbers associated with the separate outages from the column "SG32 Plugs" sum to 1218, not 1217.

The asterisk associated with the number 460 (for 2006) was not shown in your outage summary report for RFO 14 (fall 2006). Please verify the number of tubes plugged in SG-32.

Also, please discuss the tube that is plugged in just one end (i.e., the tube referenced by the asterisk).

Response 3:

During RF14 tube SG32 R1 C1l15 was selected to be plugged preventatively as part of the response to failed batwings. The tube was plugged on one end only. The inability to plug this tube on one end was entered into the W3 Corrective Action program in Condition Report CR-WF3-2006-04601. Entergy determined that it was acceptable to operate with the tube plugged on one end prior to start-up from RF14.

The number of tubes "in-service" has duplicity because one is treated as "plugged' with respect to plugging limits [reduces RCS flow] and is "open" for tube integrity [RCS pressure boundary].

During RF15 the tube was re-examined and found to be without flaws. The plug was planned to be removed to allow full examination. The plug was not removed due to technical, difficulties. This condition was also entered into the W3 Corrective Action program in

P to W3F1-2009-0020 Page 2 of 3 Condition Report CR-WF3-2008-02203. The open end of the tube was plugged during RF1 5, and the tube was removed from service. The number of tubes plugged in SG32 is 1217.

Question 4:

In Section G of your November 25, 2008, letter, you discuss condition monitoring, but the discussion on structural integrity limits only references the three times the normal operating differential pressure criterion. Please confirm that this criterion is the most limiting of the structural integrity performance criteria. If this is not the most limiting criterion, please discuss whether the tubes satisfied all the structural integrity performance criteria.

Response 4:

Structural Integrity Performance Criteria evaluation concludes 3dP is most limiting.

Question 5:

Please confirm that no crack-like indications were found in the U-bend region of Rows 1 and 2 and that no crack-like indications were found during your dent and ding examinations. If indications were identified, please discuss the nature of the indications and the size of the dent/ding (if applicable) and the basis for not expanding the inspection.

Response 5:

The results of the examination of the Row 1 and 2 tubes identified no U-bend cracks and no dent/ding cracks.

Question 6:

Other than the free span indication in SG 31 in row 109 column 99, please discuss (and identify) whether any other free span indications (other than those near the top of the tubesheet) were detected.

Response 6:

A free span axial Outside Diameter Stress Corrosion Cracking (ODSCC) was also reported on R49 C59 at 04H +14.9" in SG32. Plus Point amplitude was 0.37V; length from profiling was 0.35 inch.

to W3F1-2009-0020 Page 3 of 3 Question 7:

During a conference call in May 2008, preliminary results indicated that one tube had a 42 percent through wall (TW) wear indication. Please identify this tube and confirm it was plugged. Also, please confirm that all other wear indications greater than or equal to 40 percent TW were plugged.

Response 7:

All tubes with greater than or equal to 40 percent TW were plugged. The tube with the 42%

TW is listed.

SG31 had no indications greater to or equal to 40 percent TW.

SG32: R74 C48 at BW5, 42%TW SG32: R1 10 C32 at BW9, 47%TW, both plugged Question 8:

Please discuss whether any crack-like indications were found at or near locations with wear indications (e.g., at the same eggcrate location).

Response 8:

There were no crack wear indications found at the same location.

In SG31, tube R26 C58 at 03H, both axial ODSCC and wear reported at same structure, wear and ODSCC are not coincident (Different bars of eggcrate structure).

Attachment 2 To

) W3F1 -2009-0020 Table E-1 to W3F1-2009-0020 Page 1 of 1 Table E-1 Waterford 3 RFO 15 Repair Summary May 2008 Tube Status SG - 31 SG - 32 Tubes in service prior to RF 8174 8184 Total Number of tubes previously removed from service 1176 1166 Repair Candidates from RFO15:

Hot Leg Top of Tubesheet Axial Indications (Above TTS) '0 0 Hot Leg Top of Tubesheet Circ: Indications (Above TTS) 0 1 Hot Leg Tube Sheet Axial Indications (Within Tubesheet) 23 9 Hot Leg Tube Sheet Circ. Indications (Within Tubesheet) 32 8 Tubesheet with Axial and Circumferential Indications 2 0 Tubesheet and Support Plate with Axial Indications 1 0 Tubesheet Circumferential and Support Plate Axial Indications 0 0 Egg-Crate With Axial Indications 73 15 Batwings With Axial Indication 6 4 Batwings With Axial Indication and Support Plate Axial Indication 0 0 Batwings With Volumetric Indication .0 0 Hot Leg Volumetric Indications 1 0 Cold Leg Volumetric Indications 0 0 Row 1 - Row 2 U-Bend Indications 0 0 Bobbin Percents => 40% 0 2 Customer Decision Preventative (Box In) 0 6 Customer Decision Preventative (Row 1/Row 2) 5 6 Hot Leg Total Tubes Deplugged and Replugged - Post RFO15 0 0 Cold Leg Total Tubes beplugged and Replugged - Post RFO15 3 21 Total Candidate Tubes to be Repaired 146 72 Hot Leg 54" Stabilizers Installed During RFO15* 11 7 Hot Leg 268" Stabilizers Installed During RFO15* 0 4 Hot Leg 384" Stabilizers Installed During RFO15* 0 0 Cold Leg 54" Stabilizers Installed During RFO15* 0 0 Cold Leg 268" Stabilizers Installed During RFO15* 0 5 Cold Leg 384" Stabilizers Installed During RFO15* 0 12 Total Stabilizers Installed - RFO15 11 28 Total Tubes Plugged - Post RFO15 1319 1217 Note: Above Tubesheet is all calls => .01" above.

Note: Within Tubesheet is all calls =<.00".

Note:

• Denotes Includes Deplugged tubes