ML20058L936

Application for Amend to License NPF-38,consisting of TS Change Request NPF-38-146,modifying Spec 3/4.4.4, SGs SRs for SG Tubing.Proprietary Repts CEN-605-P,WCAP-13698 & 51-1223750-00 Encl.Repts Withheld (Ref 10CFR2.790(b)(4))

ML20058L936
Person / Time
Site:	Waterford
Issue date:	12/06/1993
From:	Barkhurst R ENTERGY OPERATIONS, INC.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML19311B243	List: ML20058L936 ML20058L944 ML20058L953
References
W3F1-93-0180, W3F1-93-180, NUDOCS 9312200074
Download: ML20058L936 (10)

Text

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n Entergy Operations,Inc.

K:hona LA 70066-0751 Tel 504 739 6661 Ross P. Barkhurst V*;e Presrw Qvam VatTWhDid 3 W3F1-93-0180 A4.05 PR December 6,1993 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555

Subject:

Waterford 3 SES Docket No. 50-382 License No. NPF-38 Technical Specification Change Request NPF-38-146 Gentlemen:

The attached description and safety analysis support a change to the Waterford 3 Technical Specifications. This amendment request modifies specification 3/4.4.4, " Steam Generators", by revising the surveillance requirements for Waterford 3 steam generator tubing. The proposed amendment would allow the installation of tube sleeves as an alternative to plugging defective SG tubes. The technical specification surveillance requirements are revised to allow steam generator tube repair using Combustion Engineering (CE) Leak Tight Sleeving, Westinghouse Laser Welded Sleeves, or Babcock and Wilcox Nuclear Service (BWNS) Kinetic Sleeve Design.

The details of specific qualification of the individual sleeve types are documented in separate reports and is provided in Attachment 1. These reports contain information which is proprietary to the individual suppliers, for which affidavits are provided. The affidavits set fo.th the basis on which the information may be withheld from public disclosure by the Commission and specifically addresses the considerations listed in paragraph (b)(4) of Section 2.790 of Title 10 of the federal regulations.

Accordingly, it is respectfully requested that Attachment 1 be withheld from public disclosure in accordance with that regulation.

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f Technical Specification Change Request NPF-38-146 W3F1-93-0180 Page 2 December 6,1993 It is important to note that the processes for BWNS Kinetic Sleeve Design and CE Leak Tight Sleeving as described in the attached reports, have been previously submitted and approved for another Entergy Operations, Inc.

facility, Arkansas Nuclear One - Unit 2. The Westinghouse process described in the attached report for Laser Welded Sleeving has been submitted and approved for 3/4" steam generator tubing at Braidwood nuclear facility.

The proposed change has been evaluated in accordance with 10CFR50.91(a)(1) using criteria in 10CFR50.92(c) and it has been determined that this change involves no significant hazards considerations.

We respectfully request a timely review in an effort to achieve maximum efficiency during our upcoming refueling outage (March, 1994), in the event that steam generator sleeving should be desired.

Should you have any questions or comments concerning this request, please contact B.R. Loetzerich at (504) 739-6636.

Very truly yours, Oh Lo R.P. Barkhurst Vi:e President, Operations Waterford 3 RPB/BRL/ssf

Attachment:

Affidavit NPF-38-146 cc: J.L. Milhoan (NRC Region IV), D.L. Wigginton (NRC-NRR),

R.B. McGehee, N.S. Reynolds, NRC Resident Inspectors Office, Administrator Radiation Protection Division (State of Louisiana), American Nuclear Insurers i

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the matter of )

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Entergy Operations, Incorporated ) Docket No. 50-382 Waterford 3 Steam Electric Station )

AFFIDAVIT R.P. Barkhurst, being duly sworn, hereby deposes and says that he is Vice President Operations - Waterford 3 of Entergy Operations, Incorporated; that he is duly authorized to sign and file with the Nuclear Regulatory Commission the attached Technical Specification Change Request NPF-38-146; that he is familiar with the content thereof; and that the matters set forth therein are true and correct to the best of his knowledge, information and belief.

Mkh R.P. Barkhurst Vice President Operations - Waterford 3 STATE OF LOUISIANA )

) ss PARISH OF ST. CHARLES )

Subscribed and sworn to before me, a Notary Public in and for the Parish and State above named this G" day of D Ecc:m a % , 1993.

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- 37 6 12_ . G Notary Public My Commission expires A>'T" " .

DESCRIPTION AND SAFETY ANALYSIS 0F PROPOSED CHANGE NPF-38-146 7

This proposed Technical Specification (TS) change modifies TS-3/4.4.4, " Steam Generators," as follows:

a) Section 4.4.4.4(a), Acceptance Criteria. was revised to add the definition of_ " tubing" or " tube". The definition of " plugging limit" was expanded to include a-reference to-the-repair limit and:

include sleeving as an alternative,to' tube plugging. In addition, the discussion of operability in Section 4.4.4.4(b) was revised to include repaired tubes after sleeving.

1 b) Reporting requirements of Section 4.4.4.5 have been revised to include the reporting of sleeved tubes in addition to the.

reporting of plugged tubes.

c) Table 4.4-2 is revised to reference sleeved-tubes in addition to plugged tubes, described in the steam generator. inspection program.

In addition, the associated Bases Information impacted by-the subject change has been updated as appropriate.

Existina soecification See Attachment A Proposed Specification See Attachment B Description Existing technical specifications require that a steam generator tube which exhibits a through-wall defect be isolated from service by means' of a tube-plug. As steam generator tubes are plugged, the effective heat transfer. area of the steam generator is reduced and the differential _ pressure across the steam generator is increased. This results in reduced coolant flow rate.

The purpose of a sleeve is to repair a defective steam generator tube and maintain the function and integrity of the tube. The sleeving methodology consists of inserting a sleeve into the defective steam generator tube, thereby forming a new pressure boundary in the portion of the tube where the defect exists. The sleeve installation does not significantly affect the heat transfer removal capability of the tube being sleeved, and a number of sleeves can be installed without significantly affecting the primary flow rate.

The proposed change allows for sleeve installation in the Waterford 3 steam generators, according to the qualifications and technologies discussed in three individual supplier reports. Approval of the proposed change in its entirety will allow Waterford 3 to select any one of the three supplier processes in the event that tube sleeve installation is warranted.

Safety Analysis The proposed change described above shall be deemed to involve a significant hazards consideration if there is a positive finding in any of the following areas:

1. Will operation of the facility in accordance with this proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No The proposed change will allow the use of specific steam generator j tubing sleeves to repair Waterford 3 steam generator tubes which exhibit i degradation and can be sleeved (in the tube sheet crevice area and egg crate supports). The technical specification change is proposed to reference the following reports, which qualify the use of steam generator tube sleeves as an alternative to tube plugging, Combustion Engineering Report CEN-605-P, "Waterford 3 Steam Generator Tube Repair Using Leak Tight Sleeves", Revision 00-P, dated December, 1992.

l Westinghouse Report WCAP-13698, " Laser Welded Sleeves For 3/4 Inch Diameter Tube Feedring-Type and Westinghouse Preheater Steam Generators", Revision 1, dated May, 1993.

Babcock & Wilcox Report 51-1223750-00, "BWNS Kinetic Sleeve Design For CE SGs with 0.048" Wall Tubes", Revision 00, dated June 29, 1993.

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1 These reports demonstrate that the repair 'of degraded steam generator  !

tubes using tube sleeves will result in tube bundle integrity consistent ,

with the original design basis. j ;

Sleeve design, materials, and joints were designed to the applicable  !

ASME Boiler and Pressure Vessel Codes. Extensive analyses and testing were performed to demonstrate the adequacy of the tube sleeves. .'The' .;

analyses were performed using design and operating transient parameters  !

which enveloped loads imposed during normal operating, upset and j accident conditions. Mechanical testing was performed to demonstrate leak resistance and joint strength,- including fatigue resistance.

Corrosion testing was also performed' to assess the corrosion resistance i of the sleeve and joint. Based upon the results of the ' analytical and  ;

test programs described in detail in the above mentioned reports, these-tube sleeves meet or exceed all-the established design and operating  ;

criteria.

Utilization of tube sleeves not only. reduces the risk'of primary to  :

. secondary leakage in the steam generator,' but can also provide for more-  ;

margin in the safety analysis. Sleeving a tube results in a_ primary  !

flow reduction which has no significant effect on the steam generator >

performance with respect to' heat transfer or system flow resistance'and i pressure drop. The cumulative impact of multiple sleeved' tubes has been- .

evaluated to ensure the effects remain within~the design bases. The- {

installation of tube sleeves can be accomplished within the tube j plugging analysis.  :

Based on the extensive analysis and test programs performed and the l ability to monitor and remove degraded sleeves from service, this change does not significantly increase the probability or consequences of an ,

accident previously evaluated. j

2. Will operation of the facility in accordance with this proposed change create the possibility of a new or different type of accident from any'  :

accident previously evaluated? I f

Response: No.  !

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A sleeved tube performs the same function ia the same passive manner as the unsleeved tube. Tube ,leeves are designed, qualified, and maintained under the stre',s and pressure limits of ASME Section III and Regulatory Guide 1.121. Eddy current testing is performed following '

installation of each sleeve in order to verify the proper installation of the tube sleeve and to obtain baseline eddy current data. This baseline data is used to monitor any subsequent degradation.

l Therefore, the use of tube sleeves does not create the possibility of a i j new or different kind of accident from any accident previously

evaluated.

3. Will operation of the facility in accordance with this proposed change

involve a significant reduction in a margin of safety?

l Response: No i

Steam generator tube integrity is maintained under the same limits for sleeved tubes as for unsleeved tubes in accordan~ce with ASME Section III and Regulatory Guide 1.1.21. The degradation limit at which a tube is considered inoperable remains unchanged and is detectable for sleeves as well as tubes. The technical specifications continue to require monitoring and restriction of primary to secondary system leakage through the steam generators, such that there remains reasonable assurance that a significant increase in leakage, due to failure of a sleeved (or unsleeved) tube, will be detected. The slight reduction in '

reactor coolant system flow, due to sleeving, is considered to have an insignificant impact on steam generator operation during normal operation and accident conditions and-is clearly bounded by tube )

plugging evaluations. The technical specifications will continue to contain reporting requirements for tubes which have had their -

degradation spanned regardless of whether the tube is plugged or i sleeved.

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

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Safety and Sionificant Hazards Determination

" Based on the above safety analysis, it is concluded that: .(1) the proposed change does not constitute a significant hazards consideration as defined by 10 CFR 50.92; and (2) there is a reasonable assurance that the health and safety of the public will not be endangered by the proposed change; and (3) this action will not result in a condition which significantly alters the l impact of the station on the environment as described in the NRC final

! environmental statement."

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NPF-38-146 l

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