W3F1-2008-0039, Steam Generator Conditions Observed at Waterford 3

Steam Generator Conditions Observed at Waterford 3

ML081440106
Person / Time
Site:	Waterford
Issue date:	05/20/2008
From:	Walsh K Entergy Nuclear South, Entergy Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
W3F1-2008-0039
Download: ML081440106 (74)

Text

Entergy Nuclear South Entergy Operations, Inc.

17265 River Road Killona, LA 70057 Tel 504 739 6660 Fax 504 739 6678 kwalshl @entergy.com Kevin T. Walsh Vice President, Operations Waterford 3 W3F1-2008-0039 May 20, 2008 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555

SUBJECT:

Steam Generator Conditions Observed at Waterford 3 During Refueling Outage 15 Waterford Steam Electric Station, Unit 3 Docket No. 50-382

REFERENCES:

1. Entergy letter dated December 20, 2006, Entergy Actions to Address RF14 Batwing Failures, (W3F1 -2006-0070)

2. Entergy letter dated December 19, 2006, Summary of Cycle 15 OperationalAssessment for Steam GeneratorBatwing Concerns, (W3F1-2006-0072)

Dear Sir or Madam:

This letter communicates the te~chnical evaluations for the inspection, evaluation, and mitigation actions taken during Refueling Outage 15 (RF 15) for Steam Generators 31 and 32. The technical evaluations address: (1) visual characterization of the Steam Generator (SG) batwing related tube wear at tubes immediately adjacent to the stay cavity, a mechanism originally identified at San Onofre Nuclear Generating Station (SONGS) in 1985 and (2) the Waterford 3 (W3) displaced batwing condition initially observed in May 2005 during Refuel Outage 13. This letter also provides the commitments that will continue to be applied for W3 during Operating Cycle 16. These commitments were continued from the commitments of record discussed in Reference 1. This information is provided in three Enclosures; Enclosure 1, which is the SG 31 technical evaluation; Enclosure 2, which is the SG 32 technical evaluation; and Enclosure 3, which is the list of regulatory commitments of record that will continue-to be applied for Operating Cycle 16.

In summary, the augmented SG secondary side inspections have been completed in both SGs for RF15. Acceptance criteria were met, and there were no changes identified to the critical variables or extent of condition used to establish acceptability of the previously approved mitigation actions. The SG conditions observed in RF15 are understood and bounded by the analyzed conditions delineated in Reference 2. The SG tube eddy current data, primary to secondary leak rate trending, and steam generator loose parts monitoring information continue

W3F1-2008-0039 Page 2 of 3 to demonstrate the effectiveness of the mitigation actions taken. External peers and experts reviewed and concurred with the rigor of the evaluations, mitigation actions, and operational monitoring measures. In conclusion, we. have employed conservative and defense in depth approaches we believe will ensure the safe operation of W3.

We will arrange for a meeting with the NRC after RF15 to facilitate further dialogue and discussion on this matter.

The regulatory commitments in this correspondence are specified in the Enclosure 3. Please contact me or Robert Murillo at 504-739-6715 if there are any questions.

Sincerely, KTW/RJM/RLW/ssf

Enclosures:

1. SG 31 Secondary Side Inspection Results Summary and Conclusions Spring 2008 Refuel Outage 15

2. SG 32 Secondary Side Inspection Results Summary and Conclusions Spring 2008 Refuel Outage 15

3. Licensee-Identified Commitments

W3F1-2008-0039 Page 3 of 3 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 Town Center Suite 300S 29th S. Main Street West Hartford, CT 06107-2445

Enclosure 1 W3F1 -2008-0039 SG 31 Secondary Side Inspection Results Summary and Conclusions Spring 2008 Refuel Outage 15

SG31 Secondary Side Inspection Results Summary and Conclusions Spring 2008 Refuel 15 Outage Work..Order 130169.

Prepared by: James W. Hoss Paul M. Melancon Miguel .A.' Barret Paul P.;Ola Bill Heilker (Westinhýouse)

Jeff Hall (Westinghqise)

Don Siska (Westinghouse):.:

Jesse Baron (Westinghouise)

Approved by. Rex G. Putnamn (Electronically Approved in 'P:CRS as CR-WF3-2008-1987 CA 10)

SG31 Secondary Side Inspection Results Summary and Conclusions - Spring 2008 RF15 Outage Executive Summary An inspection of Steam Generator #1 (SG 31) was performed during the Spring 2008 Refuel 15 outage to determine if there were any changes in extent of condition or the critical variables that were the basis for the Refuel-14 and Cycle 15 operational assessment. The visual inspections performed consisted of an upper batwing weld and wrap around bar inspection, diagonal 450 through-tube bundle inspection, a bottom-up inspection of the batwings in the stay cylinder region and a Foreign Object, Search and Retrieval (FOSAR). All inspection results were satisfactory and met the established acceptance criteria. There were no changes to the expected extent of condition or the critical variables that were the basis for the RF14 and Mid-Cycle 15 (PO-07-01) operational assessments. The assessments performed in RF14 and PO-07-01 still remain valid and bounding.

Batwing 85/86 was repaired on the hot leg side during Refuel 15 by adding a weld that had not been installed during original component fabrication. Additionally, tubes along the blowdown lane were plugged to the first tie rod.

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SG31 Secondary Side Inspection Results Summary and Conclusions - Spring 2008 RF15 Outage

\ .

1. Upper Weld and Wrapper Bar Inspection The purpose of this inspection was to look for deformation of the wrap around bar and any obvious damage to the wrap around bar-to-batwing welds. This inspection was also intended to identify any physical changes from the Mid Cycle 15 (PO-07-01) planned outage inspection results (i.e. verify no weld degradation and verify no damage to the wrap around bar). In accordance with Westinghouse letter CWTR3-06-92 dated December 14, 2006, the stay cavity region ranges from column 64 to 111 and the batwing-to-wrapper bar welds of concern are those within this range of SG tube column lines. This inspection included observation of the batwing-to-wrap around bar connections between columns 50 and 120 on the hot and cold legs which conservatively bounds the stay cavity region.

Upon initial entry, into SG31 a visual inspection of the wrap around bar and the accessible wrap around bar-to-batwing welds was made. Instructions for this inspection are provided in Work Order 130169 as Inspection 1. This inspection was conducted by observing the desired areas using a high power spotlight. No damage was noted and the inspection is documented as complete in Work Order 130169.

A more detailed video examination was also performed of the wrap around bar and the stay cavity region batwing supports at the periphery of the hot and cold legs to examine the wrap around bar and confirm the integrity of the welds at the connection point. Instructions for this inspection are provided in Work Order 130169 as Inspection 3. A fiber optic camera wasused for this examination and the results were recorded on digital media. Seventy-one (71) batwing weld locations were inspected on both the hot leg (HL) and cold leg (CL) side. Four additional welds located well outside of the stay cylinder cavity region (tube columns 32 and 139 on both the hot leg and cold leg sides) were also inspected. No damage or degradation was noted and the inspection is documented as complete in Work Order 130169.

The batwing between columns 85 and 86 on the hot leg side was previously observed (in RF14 and PO-07-0 1) to be attached to the wrap around bar by a weld on only one side of the batwing.

During RF15, this connection was enhanced by adding the missing weld per WO 130172 and EC-4681.

Upper weld and wrapper bar inspection results met acceptance criteria and were acceptable.

2. 450 Through Upper Tube Bundle Inspection A diagonal 450 Through Upper Tube Bundle Inspection of the upper stay cavity region of SG31 was performed to assess the physical integrity of the tubes at the batwing to tube interface at the inner most row adjacent to the stay cavity. This inspection was not performed on SG3 1(but was performed on SG32) during the PO-07-01 planned outage. Instructions for this inspection are provided in Work Order 130169 as Inspection 2. Detailed evaluations of the video inspection data were conducted by an engineering team comprised of Entergy and Westinghouse personnel. The results of the evaluations are reported in Section 6 and pictures of indications observed and other points of interest are provided in Attachment I. The following summarizes the results of the 450 inspection.

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SG31 Secondary Side Inspection Results Summary and Conclusions - Spring 2008 RF15 Outage There are 72 wear indications observed during the review of the 450 Through-Tube Bundle Inspection video. The observed wear indications are comprised of 67 as "old wear", 1 as "new wear", and 4 as "second row wear". It is possible that the total wear indications noted include duplicates since it is difficult to track tube bundle locations during video inspection. Therefore this inspection is considered a best effort to inspect the condition of the SG31 upper stay cavity.

Batwing to Tube Interaction The review of the video identified 72 wear indications at the "Batwing to Tube Interface" the majority of which is due to "old wear". Through wall wear was observed.

This wear was predicted in the mid 1980's based on operating experience at the SONGS plant.

The SONGS batwing wear mechanism consisted of upward flow forces in the tube bundle central cavity causing batwing twisting and applying high contact force against the tubes at the periphery and adjacent to the stay cavity. Analysis and testing determined that the wear rate at each successive tube progressing from the stay cavity into the tube bundle would be expected to decrease, that the wear rate would be expected to decrease as more tubes wore, and that the number of tubes affected would be expected to be smaller than the excess heat transfer area built into each steam generator. The analysis determined that 1) tube integrity is maintained, 2) batwing integrity at the weld is maintained, and 3) batwing integrity at the worn section is maintained. Testing performed in the mid 1980's included eddy current testing, ultrasonic testing, radiography, visual inspection, and mock-up testing. Steam Generator performance and plant impacts at steady state and transient conditions were evaluated to establish the potential consequences including LOCA. The wear progression analysis was performed by CE using empirical wear parameters and the validity of the wear progression analysis predictions was verified at St. Lucie 2 by tracking ECT data over approximately 6 consecutive cycles. Plant specific evaluations were prepared, including Waterford 3, and documented by Westinghouse Report CEN-328, Remedy for Steam Generator Tube and Diagonal Strip Wear, dated March 1986 for Palisades (Replacement Generators); Palo Verde Units 1, 2, and 3; St. Lucie Unit 2; SONGS Units 2 and 3; Washington Nuclear Project 3; and Waterford Unit 3. Applicability~was confirmed by LTR -NCE-08-93 "Assessment of CEN-328 for Waterford 3 RF15 Steam generator Batwing-Tube Wear Evaluation.

To evaluate dropped batwing wear a conservative criterion for comparison of the as-found condition of the tube is the criteria for "gross tube damage" provided in Westinghouse Letter LTR-SGDA-07-217. This letter provides criteria for acceptable and unacceptable- tube damage/wear and tube prying action. For tube wear at first row of tubes, immediately adjacent to the stay cavity, a criterion of wear no more than 1/3 of the way through the stabilized tube was acceptable.

Although through wall wear scars were observed none exceeds the 1/3 depth criterion. This criterion is considered the SONGS related "original wear issue". All of the inner most tubes of the stay cavity have been plugged and stabilized. In some cases the through wall wear is such that the stabilizer is visible. In no instances has stabilizer damaged been observed. In four observed instances, wear has been observed on second row of tubes immediately adjacent to the stay cavity.

These tubes were plugged in the mid 1980's but not stabilized. The observed wear is consistent with the predictions of Westinghouse Report CEN-328. These observed tube wear scars met the acceptance criteria defined in Westinghouse Letter LTR-SGDA-07-217. The structural integrity 3

SG31 Secondary Side Inspection Results Summary and Conclusions - Spring 2008 RF15 Outage of the second row wear was evaluated and found acceptable in Westinghouse Letter LTR-SGDA-08-130.

The 450 Through-Tube Bundle Inspection summary and selected still pictures is included as .

Broken Batwings During the 450 Through-Tube Bundle Inspection thecondition of the batwings were also observed.

The points of interest that identify broken batwings at the intersection at the notch at the perforated center support plate are listed in Attachment I as int-01, int-02, int-03, int-04, int-06, int-08, and int-10. The RF15 inspection video shows an estimated 6 to 8 batwings are broken at this location.

During the PO-07-01 bottom-up inspection, 4 batwings were identified as being broken at the notch.

LooseParts Though an estimated 6 to 8 batwings are broken at the center support plate, there are no detached segments.

Intrados Tube Wear No cases of intrados tube wear have been observed in SG 31. This. is reasonable since there are no loose curved batwings.

The 450 Through Upper Tube Bundle Inspection met the acceptance criteria and was acceptable.

3. Batwing Weld Repair In RF 14, it was noted that the batwing between tube columns 85 and 86 on the hot leg side of SG31 was attached to the wrap around bar with a weld on one side. Since this batwing is in the central cavity region and is required to have a double-sided weld, plans were made to perform a weld repair during RF 15. This work was performed as planned and is documented in Work Order 130172. The batwing weld repair was acceptable.

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SG31 Secondary Side Inspection Results Summary and Conclusions - Spring 2008 RF15 Outage SG31 - Weld repair on batwing-to-wrapper bar connection for the batwing between tube columns 85 and 86 on the hot leg side

4. Bottom Up Video Inspection A bottom up video inspection of SG 31 was performed using a camera system installed through the lower hand hole and along the Blowdown Lane to the bottom of the Stay Cavity column. A composite photo was prepared and was compared to the composite photos taken during the PO-07-01. Detailed evaluations of the results were made by the combined Entergy and Westinghouse engineering review team. The results are documented in WO 130169 Task 01, Inspection 4.

Portions of the inner rims of"eggcrate" grids 4 through 7, which encircle the central cavity, could be viewed. No damage was detected at the "eggcrate" grids, nor were any loose batwing segments found.

The lower portions of batwings crossing the central cavity, which are located in the upper stay cavity could be observed and a composite photo was assembled by stitching together frames from the video footage. All batwing segments were identified. It appears that 4 batwings located between tube columns 86 and 90 were found to have broken on the hot leg side of the center notch. However the bottom up inspection is not as precise or revealing as the 45' Through-Tube Bundle Inspection, which showed 6 to 8 batwings broken at the perforated top plate. There were also wear marks found on the underside of the perforated top plate due to the broken batwings rubbing. The batwings themselves were still present but offset from their original position. These batwings did not appear to be broken when inspected during RF 14. The RF 14 and PO-07-01 composite photos (Figures 1 and 2, respectively) are presented for comparison with RF15 composite photo (Figure 3).

The bottom-up video inspection met acceptance criteria and was acceptable.

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SG31 Secondary Side Inspection Results Summary and Conclusions - Spring 2008 RF1 5 Outage

5. Foreign Obiect Search and Retrieval (FOSAR)

A Foreign Object Search and Retrieval inspection was performed following all secondary side work. The FOSAR inspection followed sludge lancing and included all accessible regions of the tube sheet secondary surface including the central cavity, tube lane and annulus regions. One piece of what appears to be weld wire was seen trapped under the blow down pipe. This piece was observed in the same location during RF 13. Many attempts to remove it at that time were unsuccessful because it was lodged under the blowdown pipe. Retrieval during RF 15 was not successful, and the part was evaluated and determined to be acceptable.

6.

Conclusion:

All inspection results were satisfactory and met the established acceptance criteria. No changes in the extent of condition or critical variables that were used as the basis for mitigating actions taken for the RF14 and PO-07-01 operational assessments were found. The assessments performed in RF14 and PO-07-01 remains valid and bounding.

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SG31 Secondary Side Inspection Results Summary and Conclusions - Spring 2008 RF15 Outage Attachment 1 450 Through-Tube Bundle Inspection Summary and Selected Still Pictures Intrados 2nd Row Indication Disc Thru > I/3TD New Stabilizer 2 Sided 2nd Row Comments Old New No Time Wall Wear Visible Wear Wear (See NOTE at end of table) Wear Wear Wear Wear BW spacing appears normal int-01 SG31 0:24:26 HL Zone A except for a couple closer

1. 8 together. Also shown at 0:25:08.

SG31 BW spacing appears normal int-02 #8 0:35:08 HL Zone B except for a couple closer together.

int-03 SG31 0:35:45 HL Zone B Three open center support

1. 8 slots.

SG31 Broken BW ends observed

1. 8 remaining in center slot.

SG31 Broken BW ends observed int-0 #8 0:39:34 HL Zone B remaining in center slot.

Broken BW ends observed at int-06 SG31 0:40:06 HL Zone B top plate remaining in center

1. 8 slot, two adjacent slots empty.

SG31 Shiny spots on top of BW, int-07 #8 1:29:07 HL Zone B material missing from BW, potential active wear.

int-08 SG31

1. 8 1:45:57 HL Zone B Severed spot BWs at center notch

1. 8 support.

SG31 BW diagonal to horizontal int-09 #9 0:17:25 CL Zone A strip, Nickel weld appears thicker than BW sections.

SG31 BWs broken at center notch int-10 #7 1:25:10 CL Zone C between perforated support plate. Also at 1:27:27.

SG31 Through-wall wear with BW in 31-01 #8 0:00:24 HL Zone A Yes No No Yes Unknown Unknown original position, BW wear appears to be active.

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SG31 Secondary Side Inspection Results Summary and Conclusions - Spring 2008 RFI5 Outage Attachment 1 450 Through-Tube Bundle Inspection Summary and Selected Still Pictures Indication Disc Thru New Stabilizer 2 Sided 2nd Row Comments Old New Intrados 2nd Disc Row No Disc Time Leg Entry Pt Wall > I/3TD Wear Visible Wear Wear (See NOTE at end of table) Wear Wear Wear w Wear 31-02 SG31 0:04:42 HL Zone A Yes No No No No No Tube visible with single

1. 8 through-wall wear indication.

Tube visible with single 31-03 SG31 0:04:57 HL Zone A Yes No No No Unknown Unknown through-wall wear indication.

3#8 BW observed in original position.

31-04 SG31 0:05:11 HL Zone A No No No No No Yes Second row tube wear visible

1. 8 with BW in original position.

31-05 SG31 0:05:59 HL Zone A Yes No No No Yes No Tube visible with single

1. 8 through-wall wear indication. 1 SG31 Flat spot noted on tubing 31-06 #8 0:06:49 HL Zone A No No No No No No below BW. 1 SG31 Oxidized wear location 31-07 #8 0:07:05 HL Zone A Yes No No No No No observed near BW to tube 1

1. 6 __interface.

Tube visible with double 31-08 SG31 0:14:20 HL Zone A Yes No No No Yes No sided through-wall wear 1

1. 8 indication. BWs observed in original position.

SG31 Through-wall wear noted on 31-09 #8 0:15:06 HL Zone A Yes No No No No No one side of tube, potentially 1

1. 8_ _ duplicate.

SG31 0Single tube with visible 31-10 #8 0:16:06 HL Zone A Yes No No No Yes No double sided wear 1

1. 8__indications.

SG31 Visible wear indication 31-11 #8 0:16:41 HL Zone A Yes No No No No No aligned with BW in original 1

1. 8__location.

31-12 SG31 0:16:54 HL Zone A No No No No No No Wear indication aligned with 1

1. 8 BW elevation.

SG31 Through-wall wear indication 31-13 #8 0:45:29 HL Zone B Yes No No No No No on tube. 1 SG31 Wear indication aligned with 31-14 #8 0:45:40 HL Zone B No No No No No No BW elevation. 1 8

SG31 Secondary Side Inspection Results Summary and Conclusions - Spring 2008 RF15 Outage Attachment 1 450 Through-Tube Bundle Inspection Summary and Selected Still Pictures Indication Disc Disc Le E Thru New Stabilizer 2 Sided 2nd Row Comments Old New Intrados Row No Leg EntyWear > Visible Wear Wear (See NOTE at end of table) Wear Wear Wear Wer SG31 Single tube with visible 31-15 #8 0:45:50 HL Zone'B Yes Nb No No Yes No double sided through-wall 1 wear indications.

31-16 SG31 0:46:41 HL Zone B Yes No No No No No Wear indication extending 1#8 above BW elevation.

Single tube with two sided 31-17 SG31 0:47:10 HL Zone B Yes No No Yes Yes No through-wall wear indications,

1. 8 stabilizer slightly visible in frame.

Second row tube wear visible 31-18 SG31 0:47:50 HL Zone B Yes No No No No Yes with BW in original position,

1. 8 oxidized wear location. Also seen at 0:48:11.

SG31 Single tube with through-wall 31-19 #8 0:48:03 HL Zone B Yes No No No No No wear indication aligned with 1 BW at original location.

31-20 SG31 0:48:29 HL Zone B No No No No No No Flat wear location aligned

1. 8 with -BW.

SG31 Through-wall wear indication 31-21 #8 0:48:48 HL Zone B Yes No No No No No on adjacent tube, wear 1 location is oxidized.

SG31 1 H Single tube with double sided 31-22 #8 1:02:30 HL Zone C Yes No No No Yes No wear indications. 1 31-23 SG31 1:02:43 HL Zone C Yes No No No No No Through-wall wear indication 1

1. 8 SG31 with rough edges.

Through-wall wear indication 31-23 #8 1:02:43 HL - Zone C Yes No - No No Nos No wtrouighlesdgesotb. 1 31-24 #8 1:03:44 SG31Sigetbwiltwsid HL - Zone C

1. 8on Yes No INo No Yes No Through-wall single sidewear indication of tube.1 31-25 SG#8 1:04:55 HL - Zone C Yes No No No Yes No Single tube with two sided

1. 8 11through-wall wear indications. 1 31-26 SG31 Flat wear location aligned 1

1. 8 1:05:39 HL Zone C No No N No No No with BW.

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SG31 Secondary Side Inspection Results Summary and Conclusions - Spring 2008 RF15 Outage Attachment 1 450 Through-Tube Bundle Inspection Summary and Selected Still Pictures Indication Disc Disc Leg Entry P Thru > 1 .New Stabilizer 2 Sided 2nd Row Comments Old New Intrados Row No Time Wall Wear Visible Wear Wear (See NOTE at end of table) Wear Wear Wear Wear 31-27 SG31 1:06:18 HL Zone C Yes No No No No No Flat wear through-wall 1

1. 8 indications.

31-28 SG31

1. 8 1:06:32 HL Zone C Yes No No No No No Through-wall on single side wear indication of tube. 1 SG31 Active wear near indication, 31-29 #8

1. 8 1:08:48 HL Zone A Yes No No No No No BW BW has has shinyny surface.

surface. 1 31-30 Wear above indication visible just 1 SG31 1:09:43 HL Zone A No No No No No No

1. 8 BW elevations.

SG31 Through-wall wear indication 31-31 #8 1:10:51 HL Zone A Yes No No Yes No No with clearly visible stabilizer. 1 No wear observed on cable.

31-32 SG31 1:14:08 HL Zone A Yes No No No No No Through-wall wear indication 1

1. 8 with oxidized wear location.

31-33 SG31 1:14:38 HL Zone A Yes No No No No No Single sided through-wall 1

1. 8 wear indication.

31-34 SG3

1. 8 1:16:38 HL ZoneA Yes No No No No No Flat wear wear scar indication, most of is not through-wall. 1 31-35 SG31 1:17:34 HL Zone A Yes No No No No No Single through-wall wear scar 1

1. 8 observed on tube.

31-36 SG31 1:22:16 HL Zone B Yes No No No No No Through-wall indication

1. 8 aligned with BW elevation.

5G31 Through-wall tube wear 31-37 3-7 SG31

1. 8 1:24:45 HL Zone B Yes No No No No No indication.

indication.

SG31 1:28:12 HL Zone B Yes No No No No No Single through-wall wear scar 31-38 #8 observed on tube.

SG31 Wear indication at BW 31-39 #8 1:28:41 HL Zone B No No No No No No intersection with tube. 1 SG31 Flat wear indication at BW

1. 8 1:29:32 HL Zone B No No No No No No intersection 1 31-40 #8 intersection.

31-41 SG31 1:30:41 HL Zone B Yes No No No No No Single through-wall wear scar

1. 8 observed on tube.

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SG31 Secondary Side Inspection Results Summary and C6nclusions - Spring 2008 RFI 5 Outage Attachment 1 450 Through-Tube Bundle Inspection Summary and Selected Still Pictures Indication Disc Thru New Stabilizer 2 Sided 2nd Row Comments Old New Intrados 2nd Time Wall Wear Visible Wear Wear (See NOTE at end of table) Wear Wear Wear Row No Wear SG31 Through-wall wear indication 31-42 1:36:38 HL Zone B Yes No No Yes Yes No with oxidized wear location. 1 Stabilizer visible.

SG31 Single through-wall wear scar 31-43 #8 1:38:00 HL Zone B Yes No No No No No observed on tube. Oxidized 1 wear location.

31-44 SG31 1:39:04 HL Zone B Yes No No Yes No No Stabilizer visible through 1

1. 8 wear location.

31-45 SG31

1. 8 1:51:08 HL Zone C Yes No No No Yes No Single tube with through-wall double sided indications. 1 SG31 Single through-wall wear 31-46 #8 1:55:01 HL Zone C Yes No No No No No indication, oxidized wear 1 scar.

SG31 1:55:24 HL Zone C Yes No No No No No Single through-wall wear 31-47 #8 indication.

SG31 Stabilizer visible through 31-48 #8 1:56:37 HL Zone C Yes No No Yes Yes No wear location. Two sided 1 wear location SG31 Second row tube wear 31-49 S9 #9 0:12:12 CL ZoneA Yes No No No No Yes dcaon.

indication. 1 31-50 SG31 0:25:00 CL Zone B Yes No No No Yes No Single tube with double sided 1

1. 9 through-wall wear indications.

SG31 Single tube with double sided 31-51 #9 0:40:30 CL Zone C Yes NO No No Yes No through-wall wear indication 1

1. 9 adjacent to BWs.

31-52 SG31 0:42:33 CL Zone C Yes No No Yes No No Single tube with through-wall

1. 9 indication.

31-53 SG31 0:29:43 CL Zone A Yes No No No Yes No Single tube with 1

. #7 through-wall weardouble sided indications.

SG31

1. 7 7 0:32:55 CL Zone A Yes No No No Yes No Single tube with double sided through-wall wear indications. 1 II

SG31 Secondary Side Inspection Results Summary and Conclusions - Spring 2008 RF15 Outage Attachment 1 450 Through-Tube Bundle Inspection Summary and Selected Still Pictures Indication Disc Thru New Stabilizer 2 Sided 2nd Row Comments Old New Intrados 2nd No Disc Time Leg Entry Pt Wall > I/3TD Wear Visible Wear Wear (See NOTE at end of table) Wear Wear Wear Row Wear SG31 Two tubes visible in frame 31-55 #7 0:35:10 CL Zone A Yes No No No Yes No both with wear indications 1 from BW.

SG31 Two tubes visible in fame 31-56 #7 0:35:46 CL Zone A Yes No No No No No both with wear indications I from BW.

SG31 Flat wear indication aligned 31-57 #7 0:43:13 CL ZoneA No No No No No No with BW. 1 SG31 Two tubes visible with 31-58 #7 0:43:36 CL Zone A Yes No No No No No through wall indication visible. 1 Potential active wear.

Flat wear indication aligned 31-59 SG31 0:45:38 CL Zone A No No No No No Yes with BW, second row wear

1. 7 visible behind. Also visible in 0:45:42.

SG31 Through wall wear indication, 31-60 #7 0:47:10 CL Zone A Yes No No No No No potentially active BW wear.

Lengthy flat BW wear scar, 31-61 SG31 0:48:11 CL Zone B No No Yes No No No appears to be location of a

1. 7 dropped BW. New wear just above new BW location SG31 Single through-wall wear 31-62 #7 0:50:15 CL Zone B Yes No No No Yes No indication, oxidized wear 1 scar.

Single tube with through-wall 31-63 SG31 0:51:47 CL Zone B Yes No No No No No wear indication, adjacent BW 1

1. 7 appears to have dropped from original position.

SG31 Through-wall wear indication 31-64 #7 1:10:25 CL ZoneC Yes No No Yes No No with visible stabilizer cable. 1 SG31 Single tube with double sided 31-65 #7 1:12:05 CL Zone C Yes No No No Yes No through-wall wear indications. 1 SG3 1 Single tube with through-wall 31-66 1:13:46 CL Zone C Yes No No No No No indication aligned with 1 adjacent BW.

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SG31 Secondary Side Inspection Results Summary and Conclusions - Spring 2008 RFI 5 Outage Attachment 1 450 Through-Tube Bundle Inspection Summary and Selected Still Pictures 2nd Leg Entry P Thru > I New Stabilizer 2 Sided 2nd Row Comments Old New Intrados Row Indication Disc Disc Wall Wear Visible Wear Wear (See NOTE at end of table) Wear Wear Wear Wear No Time SG31 Single tube with through-wall 31-67 #7 1:15:40 CL Zone C Yes No No No No No indication. 1 SG31 1:16:44 CL Zone C Yes No No No Yes No Single tube with double 31-68 #7 1 1 Z 1 1 1 1 1 through-wall indication.

Totals 67 1 0 4 Some indications may be duplicates due to inspection video ambiguities NOTE: All indications meet established acceptance criteria 13

SG31 Secondary Side Inspection Results Summary and Conclusions - Spring 2008 RF1 5 Outage Attachment I 450 Through-Tube Bundle Inspection Summary and Selected Still Pictures SG 31 45 deg Inspection Wear Indications 80 70 60 400 E

z 30 20 20 10 0

• Wear Indication Categories

SG31 Secondary Side Inspection Results Summary and Conclusions - Spring 2008 RFI 5 Outage Attachment I 450 Through-Tube Bundle Inspection Summary and Selected Still Pictures inaication No. 61-U1 Active through-wall wear with the batwing shown in original position Indication No. 31-58 Two tubes with through-wall indication visible; potential active wear 15

SG31 Secondary Side Inspection Results Summary and Conclusions - Spring 2008 RFI 5 Outage Attachment I 450 Through-Tube Bundle Inspection Summary and Selected Still Pictures Indication No. 31-10 Two Sided Wear: Single tube with double-sided wear indication Indication No. 31-54 Two Sided Wear: Single tube with two sided through wall wear indication.

16

SG31 Secondary Side Inspection Results Summary and Conclusions - Spring 2008 RFI 5 Outage Attachment I 45' Through-Tube Bundle Inspection Summary and Selected Still Pictures Indication No. 31-18 Second Row Wear: Tube through-wall wear with second row tube wear visible. Batwing is observed in original position.

inaicapon NO. 3i-z Second Row Wear: Single tube with two sided through-wall wear indications.

17

SG31 Secondary Side Inspection Results Summary and Conclusions - Spring 2008 RFI5 Outage Attachment I 450 Through-Tube Bundle Inspection Summary and Selected Still Pictures Indication No. 31-31 Through Wall Wear: Tube through-wall wear with clearly visible stabilizer. The stabilizer cable shows no indication of wear. The worn section does not exceed 1/3 tube diameter.

Exceeding 1/3 tube diameter would require wear of the stabilizer cable. Since the stabilizer cable is not worn then wear does not exceed 1/3 tube diameter.

18

SG31 Secondary Side Inspection Results Summary and Conclusions - Spring 2008 RF15 Outage Attachment I 450 Through-Tube Bundle Inspection Summary and Selected Still Pictures Indication No. 31-55 Two Sided Wear: Two tubes with wear indication from batwing.

Indication No. 31-65 Tube Through-Wall: Single tube with double sided through-wall wear indication 19

SG31 Secondary Side Inspection Results Summary and Conclusions - Spring 2008 RF15 Outage Attachment I 450 Through-Tube Bundle Inspection Summary and Selected Still Pictures Indication No. INT-05 Broken batwing ends observed remaining in center slot of perforated top plate.

20

SG31 Secondary Side Inspection Results Summary and Conclusions

- Spring 2008 RF15 Outage Attachment II Bottom Up Inspection and Summary RFI4 Bottom-uP Composite Photo of SG31 S

21

SG31 Secondary Side Inspection Results Summary and Conclusions - Spring 2008 RFI 5 Outage Attachment 1I Bottom Up Inspection and Summary Mid Cycle 15 Bottom-up Composite Photo of SG31 S

Cold R L eg ..

Four" Broken Batwings Sign of Wear (2 places) T Column Reference 22

SG31 Secondary Side Inspection Results Summary and Conclusions - Spring 2008 RF15 Outage Attachment II Bottom Up Inspection and Summary RF 15 Bottom-up Composite Photo of SG31 S

RF15 - SG31 Bottom-Up Inspection Composite View N

23

SG31 Secondary Side Inspection Results Summary and Conclusions - Spring 2008 RF15 Outage Attachment II Bottom Up Inspection and Summary Summary of Batwing Condition Found in SG 31 Batwing As-Found Identified Identified Detailed Observation during RF15 Location Condition as broken as broken in RF15 during PO- during (tube 1 = intact 07-01 RF15 columns on 2= dangling each side 3 4 == broken bowed (NOTE 1) (NOTE 2) of BW) 5= shifted, 6 = horizontal segment broken off 68 thru 84 1 Batwing intact. No change since RF14 84/85 3 X Broken at notch 85/86 3 X X Broken at notch 86/87 3 X X Broken at notch 87/88 3 X X Broken at notch 88/89 3 X X Broken at notch 89/90 3 X Broken at notch 90/91 3 X Broken at notch 91/92 3 X Broken at notch 92 thru 108 1 Batwing intact. No change since RF14 NOTE 1: No broken batwings were found during the RF14 bottom up inspection.

NOTE 2: The 450 Through-TubeBundle Inspection video clearly shows 6 to 8 batwings broke at the center perforated support plate; however the inspection video does not provide any location information. The bottom-up inspection video and composite drawing lacks the clarity and quality to distinguish which batwings are actually broken. Therefore the above table is a best effort to identify which batwings are broken.

24

Enclosure 2 W3F1-2008-0039 SG 32 Secondary Side Inspection Results Summary and Conclusions Spring 2008 Refuel Outage 15

SG32 Secondary Side Inspection Results Summary and Conclusions Spring 2008 Refuel 15 Outage Work Order 130171 Prepared by: James W. Hoss Paul M. Melancon Miguel A:. Barreto Paul P. Ola Bill Heilker (Westinghouse)

Jeff Hall (Westinghouse)

Don Siska (Westinghouse)

Jesse Baron (Westinghouse)

Approved by: RexG. Putnam" (Electronically Approved in PCRS as CR-WF3-2008-01987 CA 10)

SG32 Secondary Side Inspection Results Summary and Conclusions - Spring 2008 Refuel 15 Outage Executive Summary An inspection of Steam Generator #2 (SG32) was performed during the Spring 2008 Refuel 15 (RF15) outage to determine if there were any changes in extent of condition or the critical variables that were the basis for the mitigating actions taken in Refuel-14 and the Cycle 15 Operational Assessment. The visual inspections performed consisted of an upper batwing weld and wrap around bar inspection, diagonal 450 Through-Tube Bundle Inspection, a Bottom-Up Inspection of the batwings in the central stay cavity region, and a Foreign Object Search and Retrieval (FOSAR). All inspection results met the established acceptance criteria. There were no changes to the extent of condition or the critical variables that were the basis for the mitigating actions taken in Refuel- 14 and the Cycle 15 Operational Assessment. Additionally, the assessments performed in RF14 and the October 2007 Mid-Cycle 15 outage (PO-07-01) remain valid and bounding.

Batwing 84/85 was repaired during Refuel 15 by hydraulically expanding five (5) adjacent tubes.

Expanding the adjacent tubes will apply additional restraining force on the detached batwing which will secure it in its current position. Additionally, the tubes along the blowdown lane were stabilized and plugged to the first tie rod.

2

SG32 Secondary Side Inspection Results Summary and Conclusions - Spring 2008 Refuel 15 Outage

1. Upper Weld and Wrap Around Bar Inspection The purpose of this inspection was to look for deformation of the wrap around bar and any obvious damage to the wrap around bar-to-batwing welds and weld clips installed during Refuel 14 (RF14). This inspection was also intended to identify any physical changes compared to the Mid-Cycle 15 planned outage (PO-07-01) inspection results (i.e. verify weld clips are -intact, verify no weld degradation and~yerify no damage to the wrap around bar). The batwing weld repairs performed during RF 14 are located within the stay cavity region at the wrap around bar. In accordance with Westinghouse letter CWTR3-06-92 dated December 14, 2006, the batwing-to-wrap around bar welds of concern are those within the stay cavity region which includes batwings between tube column numbers 64 and 111. This inspection included observation of the batwing-to-wrap around bar connections between tube column numbers 50 and 120 on the hot and cold leg sides of the steam generator which conservatively bounds the central stay cylinder cavity region.

Upon initial entry into SG32 a visual inspection of the wrap around bar and the accessible wrap around bar-to-batwing welds was conducted. Instructions for this inspection are provided in Work Order 130171 as Inspection 1. Areas to be inspected were observed using a high power light. No damage was noted and the inspection was documented as complete in Work Order 130171.

A more detailed video examination was also performed of the wrap around bar and stay cavity region batwing supports at the periphery of the hot and cold legs to examine the wrap around bar and confirm the integrity of the welds at the connection point. Instructions for this inspection are provided in Work Order 130171 as Inspection 3. A fiber optic camera was used for this examination and the results Were recorded on digital media. Seventy-one (71) batwing weld locations were inspected on the hot leg (HL) side, seventy (70) were inspected on the cold leg (CL) side. The difference in the number of inspected welds (HL vs. CL) is due to batwing 84/85 cold leg having slipped into the tube bundle as observed during RF14. Four additional welds located well outside of the stay cylinder cavity region (tube columns 37 and 144 on both the hot leg and cold leg sides) were also inspected. No damage was noted and the inspection is documented as complete in Work Order 130171.

No significant changes or degradation was observed during the inspections discussed above.

Some single-sided welds were observed outside of the central stay cavity region; however per ER-W3-2006-0362-000, single-sided welds outside of the stay cavity region are acceptable.

All upper weld and wrap around bar inspection results met established acceptance criteria and were acceptable.

2. 45' Through-Tube Bundle Inspection A diagonal 450 Through-Tube Bundle Inspection of the upper stay cavity region of SG32 was performed to assess the physical integrity of the tubes and the batwing-to-tube interface at the inner most row adjacent to the stay cavity. Instructions for this inspection are provided in 3

SG32 Secondary Side Inspection Results Summary and Conclusions - Spring 2008 Refuel 15 Outage Work Order 130171 as Inspection 2. Detailed evaluations of the video inspection data were conducted by an engineering team comprised of Entergy and Westinghouse personnel. In general the results of the PO-07-01 inspection remain valid and the observations are not repeated herein. Fifty-nine (59) total wear indications as shown in Attachment 1 were noted during the performance of the 450 Through-Tube Bundle Inspection of which forty-nine (49) are classified as "old wear", five (5) as "new wear", three (3) as "intrados wear" and two (2) as "second row" wear. It is possible that the total wear indications noted include duplicates since it is difficult to track exact tube bundle locations during video inspection. Therefore, this inspection is considered a best effort to inspect the *condition of the SG32 upper stay cavity.

The following summarizes the results of the 450 inspection.

Batwing to Tube Interaction The detailed review of the inspection videos identified fifty-nine (59) indications of batwing-to-tube interaction, the majority of which is considered to be "old wear". The wear mechanism is the batwing rubbing against the tube surface characterized as the original "batwing issue" from the mid 1980's as described in Combustion Engineering Report CEN-328, "Remedy for Steam Generator Tube and Diagonal Strip Wear." It is considered to be old wear based on the scale and oxide layer being the same on the stabilizer and surrounding tube surfaces and because the batwing has dropped down and is no longer contacting the original wear area. Thus, no additional wear is occurring at the original batwing position. Most of the observed wear is on the inner most tubes of the stay cavity (first row tubes), all of which are plugged and stabilized. In many cases the through-wall wear is such that the stabilizer is visible. In no instances has wear of the stabilizer been observed. Two indications of wear on second row tubes (tubes one row further out into the tube bundle than the inner most tubes in the central.stay cavity) have been observed. These tubes were plugged in the mid 1980's but not stabilized. The observed wear is consistent with the predictions of Combustion Engineering Report CEN-328. These observed tube wear scars met the acceptance criteria as defined in Westinghouse Letter LTR-SGDA-07-217.

The 45' Through-Tube Bundle Inspection summary and selected still pictures are included as Attachment 1.

Loose Part During the 450 Through-Tube Bundle Inspection, a loose batwing section was identified in the upper tube bundle central stay cavity. Based on the inspection video, the loose part is in the vicinity of the tube at Row 35 and Column 95 on the cold leg side. This piece was not observed during inspections conducted in the PO-07-01 outage. During PO-07-01, four (4) loose parts were observed. During RF 15, three of the four loose parts remain at the locations where they were observed in PO-07-01. Based upon batwing inventory and part size it is concluded that the loose part that is lodged between the tubes in the upper stay cavity is one of the four loose parts observed during PO-07-01. Refer to figures 3A, 3B and 3C shown in Attachment 4 for comparison of size and location information.

4

SG32 Secondary Side Inspection Results Summary and Conclusions - Spring 2008 Refuel 15 Outage The following observations and conclusions regarding the loose BW section have been made based on engineering review of the inspection video:

• The loose section has a maximum potential length of six inches and is the nominal two-inch BW width.

• The section is oriented such that the 2" face of the loose BW in the tube gap is parallel with the centerline of the contacting tubes creating a potential for flat wear against the tube.

• The loose section is approximately two to three tube rows deep into the tube bundle and enters the bundle at approximately a 300 angle.

" The section spans and contacts a minimum of three tube columns as it enters the inner rows of the SG central cavity. All of the tubes that the loose section could potentially contact in this region of the tube bundle have been removed from service by being either plugged or plugged and stabilized.

" The loose BW section appears fixed in its current position and not expected to migrate further into the bundle or become dislodged from its current location during operation.

Photographs of the loose BW section in the as-found orientation were captured from the 450 Through-Tube Bundle Inspection video. Annotated versions of these inspection photographs are provided in Figure 1. The loose BW section is also identified as "Int-07" in Attachment 1.

1A lH Figure 1: Loose Batwing Section 5

SG32 Secondary Side Inspection Results Summary and Conclusions - Spring 2008 Refuel 15 Outage Intrados Tube Wear Three intrados wear marks were found during the RF 15 inspection. Photo 2A of Figure 2 was taken from video data obtained during the 2007 PO-07-01 outage. Photo 2B of the figure was obtained during the 2008 RF15 outage. There were no batwings, structural members, or material foreign to the steam generator environment observed at the wear scars and no other discernable indications were seen in the general area of these intrados wear scars. It is believed that the two photos in Figure 2 are the same intrados wear mark based on similarities of the wear and the nearby minor wear marks. Although this appeared to be a potential through-wall indication when observed during the PO-07-01 outage, the video evidence in RF 15 indicates that it is not through-wall.

Figure 3 is a photograph of intrados tube wear found on the hot leg side during the PO-07-01 outage. No wear scars observed during the RF 15 outage appear to match this indication.

Figure 4 and 5 are also photographs of intrados tube wear observed during RF 15. Figure 4 clearly shows a very shiny wear mark on the tube, but does not appear to be through-wall wear. Figure 5 also contains indications of abrasion or rubbing of batwings. However, it does not appear to be through-wall tube wear.

H 1,HLJ1-1 Teardrop-sh&OW- -

wear Minor wear marks

/A - Ivlvu k.ycle I D ýru-u, 7-01) 2B - RF 15 (rotated for clarity)

(pictureCap643) (picture32-40)

Figure2: Intrados Wear Mark 6

SG32 Secondary Side Inspection Results Summary and Conclusions - Spring 2008 Refuel 15 Outage Figure3: Mid-Cycle Wear Mark (pictureCap644)

Figure 4: RF15 Active Wear Mark (Not Through-Wall, picture 32-41) 7

SG32 Secondary Side Inspection Results Summary and Conclusions - Spring 2008 Refuel 15 Outage Nonthrugh waltbewa Figure 5: RF15 Shiny Wear Mark (Not Through-Wall, picture 32-40) 450 Through-Tube Bundle Inspection Acceptability Determination Three wear mechanisms have been identified during the 45' Through-Tube Bundle Inspection, namely, original issue batwing wear, dropped batwing wear and intrados wear. Conservative acceptance criteria have been developed for each.

Through-wall wear at the batwing-to-tube interface, which was predicted in the mid 1980's based on operating experience at the SONGS plant, has been observed in the Waterford 3 steam generators. The SONGS batwing wear mechanism consisted of upward flow forces in the tube bundle central cavity causing batwing twisting and application of high contact force against the tubes at the periphery and adjacent to the stay cavity. Analysis and testing determined that the wear rate at each successive tube progressing from the stay cavity into the tube bundle would be expected to decrease, that the wear rate would be expected to decrease as more tubes wore, and that the number of tubes affected would be expected to be smaller than the excess heat transfer area built into each steam generator. The analysis determined that

1) tube integrity is maintained, 2) batwing integrity at the weld is maintained, and 3) batwing integrity at the worn section is maintained. Testing performed in the mid 1980s included eddy current testing, ultrasonic testing, radiography, visual inspection, and mock-up testing. Steam Generator performance and plant impacts at steady state and transient conditions were evaluated to establish the potential consequences including LOCA. The wear progression analysis was performed by Combustion Engineering (CE) using empirical wear parameters and the validity of the wear progression analysis predictions was verified at St. Lucie 2 by tracking eddy current testing (ECT) data over approximately six (6) consecutive cycles. Plant specific evaluations were prepared, including one for Waterford 3, and documented by CEN-328, "Remedy for Steam Generator Tube and Diagonal Strip Wear," dated March 1986 for Palisades (Replacement Generators); Palo Verde Units 1, 2, and 3; St. Lucie Unit 2; SONGS Units 2 and 3; Washington Nuclear Project 3; and Waterford Unit 3. Applicability was 8

SG32 Secondary Side Inspection Results Summary and Conclusions - Spring 2008 Refuel 15 Outage confirmed by LTR -NCE-08-93 "Assessment of CEN-328 for Waterford 3 RF 15 Steam generator Batwing-tube wear evaluation.

To evaluate dropped batwing wear a conservative criterion for comparison of the as-found condition of the tube is the criteria for "gross tube damage" provided in Westinghouse Letter LTR-SGDA-07-217. This letter provides criteria for acceptable and unacceptable tube damage/wear and tube prying action. For tube wear at the first row of tubes immediately adjacent to the stay cavity, a criterion of wear no more than 1/3 of the way through the stabilized tube was acceptable. Although through-wall wear scars were observed, none exceeds the 1/3 depth criterion. This criteria is considered the SONGS-related "original issue wear".

Three instances of intrados tube wear were observed during the 450 Through-Tube Bundle Inspection. The wear mark found during the PO-07-01 inspection was located and does not show evidence of growth. The other two indications are "shiny" and appear to be new wear however they are not through-wall wear and are on tubes that have been stabilized and plugged. Since the previous observed intrados wear mark has not increased in size and since all observed intrados wear marks are on tubes that have been stabilized and plugged, this condition meets the acceptance criteria provided in Westinghouse letter LTR-SGDA-08-45 "SG 32 Intrados Tube Wear mark Acceptance Criteria and Remediation Recommendations."

During the inspection, visible batwing deformations and tube wear were observed in the upper central cavity region. However, the deformations and tube wear were consistent with expectations and did not exceed acceptance criteria. All evaluations of the acquired video data concluded the as-found condition does not challenge the structural integrity of the stabilized tubes. In conclusion, although there were indications of deformed SG batwings within the stay cavity observed during the RF 15 inspections, all acceptance criteria were met and the observed conditions were determined to be acceptable.

9

SG32 Secondary Side Inspection Results Summary and Conclusions - Spring 2008 Refuel 15 Outage

3. Bottom-Up Video Inspection A bottom up video inspection was performed and a composite photo was created. This was then compared to the composite photo prepared during PO-07-01. General conclusions are

• There has not been significant change to the batwing conditions since PO-07-01.

• There has not been a change in the number of broken batwings since PO-07-01.

• The batwing between tube columns 84 and 85 in the cold leg side has not slipped into the central cavity (tubes around this batwing were hydraulically expanded during RF 15 to lock this batwing in place).

9 No new batwing segments have broken loose since PO-07-01. As shown in Attachment 3, "Summary of SG32 Batwing Condition," segments of the horizontal sections of four (4) batwings are missing. These segments are from Batwing 80/81 Hot Leg, Batwing 80/81 Cold Leg, Batwing 77/78 Cold Leg, and Batwing 79/80 Cold Leg. All four pieces are accounted for as discussed below:

A batwing segment of approximately 7 inches is laying flat on egg crate 4 as shown in Attachment 4 Figure 4 and. can 'not be removed at this time using currently available methods. The analysis documented in LTR-SGDA-07-204 Rev. 1 shows this condition is acceptable.

> A batwing segment of approximately 6 inches long is lodged in the upper tube bundle (see Figure 1 earlier in this report). It is believed that the piece is lodged in the vicinity of Row 35 Column 95 on the cold leg side. This is believed to be the batwing segment that was observed on the top of egg crate 6 during PO-07-01. The analysis documented in LTR-SGDA-08-129 (transmitted by letter CWTR3-08-236) shows that this condition is acceptable.

The As-Found Condition of Waterford-3 SG32 batwings is included as Attachment 2. The Detailed Evaluation of SG32 PO-07-01 outage Bottom-Up Inspection is included as Attachment 3.

In conclusion, there has not been a significant 'change to the batwing conditions since RF 14.

No additional batwings have broken and loose parts have been addressed. The analysis documented in Westinghouse letters LTR-SGDA-07-204 Rev. 1 and LTR-SGDA-08-129 justifies the acceptability of operation in Cycle 16 with these parts remaining in the SG.

10

SG32 Secondary Side Inspection Results Summary and Conclusions - Spring 2008 Refuel 15 Outage

4. Post Tube Expansion Bottom-Up Video Inspection During RF14 it was discovered that the batwing between tube columns 84 and 85 on the cold leg side was disconnected from the wrap around bar and had migrated into the tube bundle.

During RF15 a process of hydraulically expanding five (5) tubes adjacent to the loose batwing was performed in accordance with Westinghouse letter LTR-SGDA-08-36. The original plan called for six (6) tube expansions; however the hydraulic expansion tool was unable to reach the targeted area on one (1) of the planned tubes. The configuration of the successfully expanded five (5) tubes in the tube bundle has been simulated and an acceptability evaluation is documented in Westinghouse letter LTR-SGDA-08-139. The purpose of this tube expansion activity was to provide additional restraining forces to the detached batwing in order to secure the batwing in its current position.

Following the expansion process, a Bottom-Up inspection was performed to observe and document the as-left condition of the SG32 central stay cavity region and to validate that no unexpected changes had occurred following tube expansion. This inspection is identified in Work Order 130171 as Inspection 5: Attachment 5 presents the post expansion view of the central stay cavity region and confirms that the expansion process did not alter the configuration of the batwings from the as-found condition before tube expansion.

5. Foreign Object Search and Retrieval (FOSAR)

A Foreign Object Search and Recovery (FOSAR) inspection of the SG secondary side tube bundle on both the hot and cold leg sides was performed for the presence of loose parts.

Accessible areas of the top of tube sheet, blowdown lane and annulus were visually examined using a fiber optic camera. There were no loose parts or items identified. All'areas appeared clean post sludge lance. The results of this inspection are documented in WO 130171-01 under inspection 6.

6. Conclusions All inspection results were satisfactory and met the established acceptance criteria. There were no changes in the extent of condition or critical variables that were used as the basis for mitigating actions taken for the RF 14 and PO-07-01 (Mid-Cycle 15) operational assessments.

The assessments performed in RF14 and PO-07-01 remain valid and bounding.

11

SG32 Secondary Side Inspection Results Summary and Conclusions - Spring 2008 Refuel 15 Outage Attachment 1 - 450 Through-Tube Bundle Inspection Summary and Selected Still Pictures Indication Disc Disc Leg Entry Thru > New Stabilizer 2 Sided 2nd Row Comments Old New Intrados 2nd Row No Time Pt Wall 1I/3TD Wear Visible Wear Wear (See NOTE at end of table) Wear Wear Wear Wear int-01 SG32 0:22:35 CL Zone N/A N/A N/A Three BWs folded together in

1. 3 C central cavity CL.

int-02 SG32 0:4.6:43 HL Zone Aligned notches and grooves

1. 3 A on BWs.

SG32 104 L Zone int-03 . S3#B 1:08:40 HL Aligned BW notches.

'SG32 Zone int-04 #1

1. 1 1:19:42 CL A A BW to BW interaction.

SG32 Zone Broken BWs collected in int-05 #1 1:35:40 HL AZn single area. Broken BW ends are visible.

SG32 14313 HL Zone BWs overlapping and

1. 1 A wearing on one another.

int-07 SG32 0:15:01 HL Zone End of broken BWs appear to

1. 2 B be sticking into tube bundle.

SG32 Zone BW stuck into bundle with int-08 #2 0:22:12 HL B shiny spots on adjacent I_ tubes.

SG32ZoneLodged piece of broken BW int-09 SG32 0:36:54 HL Zone section in tube bundle.

1. 2 S C Maybe two tube rows deep.

SG32 Zone Slight wear on BW horizontal

1. 1 0:20:50 CL C section at center support plates SG32

1. 1 0:27:20 CL Zone C Marker flag bundle.

through protruding SG32 Zone Broken BW oriented

1. 1 C horizontally on right.

SG32 0:40:49 CL Zone BWs collected together.

1. 1 C SG32 0:41:30 CL zone Pitted BW section close up

1. 1 C , view.

12

SG32 Secondary Side Inspection Results Summary and Conclusions - Spring 2008 Refuel 15 Outage Attachment 1 - 450 Through-Tube Bundle Inspection Summary and Selected Still Pictures Indication Disc Entry Thru > New Stabilizer 2 Sided-, 2nd Row Comments Old New Intrados 2nd Row No Time Leg Pt Wall 1/3TD Wear Visible Wear Wear (See NOTE at end of table) Wear . Wear Wear Wear 3 ZBW broken away from slotted SG32 C Zone . bar. Empty slot supports and

1. 1 0:41:53 CL "C *dropped BWs.

2Zone Through-wall wear indication 32-01 SG32 0:49:27 CL Yes No No Yes Not o Not with visible dropped stabilizer, below BW indication. 1 32-02 SG32 0:50:10 CL Zone Yes No No Not Not Not Through-wall BW wear, flat 1

1. 1 - B observed observed observed wear scar.

SG32 Zone Not Through-wall BW wear, no 32-03 #1 0:50:17 CL B Yes No No Yes Yes observed significantnoted.

stabilizer wear 1 32-04 SG32 0:50:36 CL Zone Unkno Unkno No Not Not Not Tube wear is opposite side of

1. 1 B wn wn observed observed observed 32-03, view is unclear.

Clear view of through wall 32-05 SG32

1. 1 0:50:43 CL Zone B Yes No No Yes Not observed Not observed wear with visible significant wearstabilizer, noted on no 1 cable.

32-06 G32 0 Zone Yes No No Yes Not Not Through-wall BW wear visible stabilizer, with.

oxidized 1

1. 1 0:54:38 . CL B observed observed w wear location.

32-7 :5:2 C G

SG32 ZoneNo Ysoonoees Z Not Not Nt Through-wall BW wear, 32-07 #1 B observed observed potential localized new wear 1 near current BW location.

32-08 SG32 0:57:30 'CL Zone Yes No No Not Yes Not Single tube showing potential

1. 1 B observed. observed 2-sided wear.

32-09 SG32 0:57:45 CL Zone Yes No No Not Yes Not Single tube showing potential

1. 1 B observed observed 2-sided wear.

13

SG32 Secondary Side Inspection Results Summary and Conclusions - Spring 2008 Refuel 15 Outage Attachment 1 - 450 Through-Tube Bundle Inspection Summary andSelected Still Pictures Indication Disc Disc Leg Entry Thru > New Stabilizer 2 Sided 2nd Row Comments Old New Intrados 2nd Row No Time Pt Wall 1I/3TD Wear Visible Wear Wear - (See NOTE at end of table) Wear Wear Wear Wear SG32 Zone Not Not Through-wall BW wear, 32-10 #1 0:59:42 CL B Yes No No Yes observed observed potential 1 current new wear near BW location.

SG32 Zone Not Single tube showing potential 32-11 #1 1:00:31 CL B Yes No No Yes Yes observed 2-sided wear, possible repeat 1 indication.

32-12 SG32 1:00:50 CL Zone Yes No No Not Yes Not Single tube showing 2-sided

1. 1 B observed observed wear indications.

SG32 Zone Not Not Clearly visible is a single tube 32-13 1:08:05 CL Yes No No Yes with 2-sided wear indications 1

1. 1 A observed observed at BW interfaces.

32-14 SG32 1:08:14 CL Zone Unkno No No Not Not Not BW cut into tube wall. 1

1. 1 1 A wn observed observed observed o Not Noted potential BW impact 32-15 1:18:20 CL A1 A Yes No observed No No wear, image is unclear and

1. 1 ed from a distance.

32-16 SG32 1:19:57 CL Zone Yes No No Not Yes Not Single tube with two.sided

1. 1 A observed observed through-wall wear scars.

SG32 Zone Not Not Single tube with two sided 32-17 #1

1. 1 1:20:02 CL ZA Yes No No ot observed Yes ot o bserved through-wall Adjacent wear scars.

to indication 32-16. 1 SG32 Zone Not Not Single tube with two sided 1:20:30 CL Ze Yes No No Nt Yes Nthrough-wallwear 1 Adjacent to indicationscars.

3218 32-18 #1 A observed observed, 32-17.

SG32 Zone NSingle tube with two sided 32-19 #1 1:20:55 CL A Yes No No Not Yes Not through-wall wear scars. 1 Adjacent to indication 32-18.

14

SG32 Secondary Side Inspection Results.Summary and Conclusions - Spring 2008 Refuel 15 Outage Attachment 1 - 450 Through-Tube Bundle Inspection Summary and Selected Still Pictures Indication Disc Disc Lg Entry Th ru > New Stabilizer 2 Sided 2nd Row Comments Old New Intrados 2nd Row No Time Lg Pt Wall II3TD Wear Visible Wear Wear (See NOTE at end of table) Wear Wear Wear Wear Through-wall BW wear with 322 G32 1:01 L Zone Ys N No es Not Not visible stabilizer, oxidized 320 #1 1:01 L A Ys N No es observed observed wear location. Tube next to 1 32-2 1.

Through-wall BW wear with 322 G32 1:20:13 CL Zone Yes, No -No Yes Not Not visible stabilizer, oxidized 3-1 #1 A observed .observed wear location. Tube next to 1 1 32-22.

32-22 SG32 1:23:13 CL Zone Ys N No es Not Not Through-wall wear just above 1 Yes NoNAe observed observed top of BW.

SG32 Zone Not Not Through-wall BW wear in 32-23 #1 1:23:10. CL A Yes No No osre obrvd Yes second row out from the 1

1. 1 A observed observedcenter cavity. ________

Through-wall BW wear in 32-24 SG32 1:23:52 CL Zone Yes No No Not Not Yes second row out from the 1

- #1 A observed observed center cavity. Appears to be 1 old BW wear.

32-25 SG32 1:24:02 CL Zone Yes No No Yes Not Not Through-wall BW wear, no 1

1. 1 A observed observed degradation noted on cable.

Two tubes with through-wall 322 G32 1:52 L Zone Ys N No es Not Not wear indications are visible in 326 #1 1:52 L A Ys N No es observed observed the same video frame. Both 1 tubes have visible stabilizers.

SG32 Zone No Single tube with double sided 32-27 1:26:19 CL Yes No No Yes Yes Nt BW wear. Potential small 1

1. 1 Aobseved amount of new wear.

32-28 S G32 1:26:35 CL Zone Yes No No Not Yes Not Through-wall BW wear on 1

1. 1 A observed observed both sided of tube.

Through-wall BW wear with 32-29 SG32 1:26:43 CL Zone Ys N No es Not Not visible stabilizer. No1 Yes No No Ye observed observed significant wear noted on

_____________ __________________________________________I cable.

15

SG32 Secondary Side Inspection Results Summary and Conclusions - Spring 2008 Refuel 15 Outage Attachment I - 450 Through-Tube Bundle Inspection Summary and Selected Still Pictures Indication Disc Disc Leg Entry Thru > New Stabilizer 2 Sided 2nd Row Comments Old New Intrados 2nd Row No Time Pt Wall 1I/3TD Wear Visible Wear Wear (See NOTE at end of table) Wear Wear Wear Wear SG32 Zone Not Not Single tube with 2-sided BW 32-30 #1 1:28:00 CL A Yes No No observed Yes observed wear. Potential localized new wear.

32-31 SG32 1:28:43 CL Zone Yes No No Not Not Not Through-wall BW wear with

1. 1 A observed observed observed potentially new wear.

Zone Not Not Not Single tube with three SG32 32-32 #1 1:29:00 CL A Yes No No observed observed observed separate through-wall wear indications.

Two through-wall wear SG32 12950 CL Zone Yes No No Yes Yes Not indications visible on 32-33 #1 1A observed separate tubes in same video frame. Both tubes have stabilizers.

G32 1Zone YNot Not First and second row tubes 32-34 #1 A observed observed can be seen with through-wall wear in same video frame.

32-35 SG32 1:45:39 HL Zone Yes No No Not Not Not Through-wall wear scar noted

1. 1 A observed observed observed on one side of tube location.

SG32 Zone Not Not Not Through-wall wear noted with 32-36 #1 14750 HL Yes No No observed observed observed BW in original location.

32-37 SG32 0:06:19 HL Zone Yes No No Yes Not Not Through wall wear noted on

1. 2 A observed observed adjacent tubes.

SG32 Zone Unclear view, shiny spots in 0:12:08 HL distance. Oxidation brushed

1. 2 B off of tubes.

32-38 SG32 0:40:23 HL Zone Yes No No Not Not Not Through-wall wear on one

1. 2 C observed observed observed side of single tube.

32-39 SG32 0:41:30 HL Zone Yes No No . Not Not Not Single tube with through-wall

1. 2 C observed observed observed BW wear on both sides.

32-40 SG32 0:43:43 HL Zone No No Yes No No No Shiny spots, new wear, not

1. 2 C through-wall. Intrados wear?

16

SG32 Secondary Side Inspection Results Summary and Conclusions - Spring 2008 Refuel 15 Outage Attachment I - 450 Through-Tube Bundle Inspection Summary and Selected Still Pictures Indication Disc Entry Thru > New Stabilizer ..2 Sided 2nd Row Comments Old New Intrados 2nd Row No Disc Time Leg Pt Wall 1I/3TD Wear Visible Wear Wear (See NOTE at end of table) Wear Wear Wear Wear 32-41 SG32 0:43:34 HL No No Yes 'No No No Shiny wear scar on tube.

1. 3 Intrados wear?

32-42 SG32 0:47:47 HL Zone No No Yes No No No Shiny spot, corrosion brushed

1. 3 A off tube.

32-43 SG32 Zone Not Potential new wear at

1. 3 A observed dropped BW location.

32-44 SG32 0:48:24 HL Zone Unkno No No Not Not Not BW shaped wear scar 1

1. 3 A wn observed observed observed adjacent to BW section.

32-45 SG32 0:56:50 HL Zone Yes No No Not Yes Not, Single tube with through-wall 1

1. 3 A observed observed BW wear on both sides.

32-46 SG32 0 HL Zone Unkno No No Not No Not Tube wear in distance, view 1 051#3 A wn observed observed is unclear.

Collection of shiny wear SG32 Zone Not Not Not scars, one appears to be 32-47 #3 0:59:47 HL A Yes No Yes observed observed observed through wall. Possible intrados wear identified during mid-cycle inspections.

32-48 SG32 1:41:05 HL Zone Unkno No No Not Not Not . Wear scar visible adjacent to 1

1. 3 A wn observed observed observed BW.

32-49 SG32 1:04:57 HL Zone Yes No No Not Yes Not Single tube with through-wall 1

1. 3 A observed observed BW wear on both sides.

32-50 SG32 1:05:43 HL Zone Yes No No Not No Not Wear scar on tube adjacent

1. 3 A observed observed to BW elevation.

G32 1Zone YNot Not Two tubes visible in video 32-51 #3 1:11:07 HL B Yes No No observed Yes observed frame, both with wear scars 1 adjacent to BW elevations.

32-52 SG32 1:12:25 HL Zone Yes No No Not Yes Not . Single tube with through-wall

1. 3 B observed observed BW wear on both sides.

Two through-wall tube wear 32-53 SG32 0:16:04 HL Zone Yes No No Not Yes Not locations visible in single 1

1. 3 C observed observedframe.

17

SG32 Secondary Side Inspection Results Summary and Conclusions - Spring 2008 Refuel 15 Outage Attachment I - 450 Through-Tube Bundle Inspection Summary and Selected Still Pictures Indication Disc Disc Leg Entry Thru > New Stabilizer 2 Sided 2nd Row Comments Old New Intrados 2nd Row No Time Pt Wall I/3TD Wear Visible Wear Wear (See NOTE at end of table) Wear Wear Wear Wear Through-wall tube wear with 32-54 SG32 0:17:06 HL Zone Yes No No Yes Yes Not visible cable stabilizer, no 1

1. 3 C observed significant wear noted on cable.

SG32 Zone Not Through-wall tube wear on 32-55 #4 0:21:30 HL C Yes No No Yes Yes observed both sides of two adjacent 1 tubes.

TOTALS 49 5 3 2 NOTE: All indications meet established acceptance criteria.

18

SG32 Secondary Side Inspection Results Summary and Conclusions - Spring 2008 Refuel 15 Outage Attachment 1 - 450 Through-Tube Bundle Inspection Summary and Selected Still Pictures Note - The value for 'New Wear' includes 2 indications that are included in the 'Intrados Wear' and 2 indications from the '2nd Row Wear' column.

19

SG32 Secondary Side Inspection Results Summary and Conclusions - Spring 2008 Refuel 15 Outage Attachment I - 450 Through-Tube Bundle Inspection Summary and Selected Still Pictures Indication 31-10 Active Wear: Tube being worn by adjacent batwing. Wear is not through wall.

Indication 32-41 Active Wear: Exterior sludge deposits have been worn away by contact with a broken batwing.

The shiny area is the tube surface. Wear is not through wall 20

SG32 Secondary Side Inspection Results Summary and Conclusions - Spring 2008 Refuel 15 Outage Attachment I - 45' Through-TubeBundle Inspection Summary and Selected Still Pictures Indication 32-43 Active Wear: Exterior Sludge deposits have been worn away by contact with an intact batwing.

The shiny area is the tube surface. Wear is not through wall.

Indication 32-05-2 Slide Down Wear: Through wall tube wear showing the stabilizer cable. Observed wear is at the original batwing to tube interface. The batwing has now dropped and wear is not continuing. The stabilizer cable shows no indication of wear. The worn section is on the order of 4 inches long and does not exceed 1/3 tube diameter. Exceeding 1/3 tube diameter would require wear of the stabilizer cable. Since the stabilizer cable is not worn then wear does not exceed 1/3 tube diameter. Slide Down Wear is wear associated with original batwing wear issues. The batwing has now slid down exposing the wear area.

21

SG32 Secondary Side Inspection Results Summary and Conclusions - Spring 2008 Refuel 15 Outage - 450 Through-Tube Bundle Inspection Summary and Selected Still Pictures Indication 32-17 Slide Down Wear: Two sided tube wear. The stabilizer cable shows no indication of wear.

Indication 32-25 Slide Down Wear: Through wall tube wear showing the stabilizer cable 22

SG32 Secondary Side Inspection Results Summary and Conclusions - Spring 2008 Refuel 15 Outage - 450 Through-Tube Bundle Inspection Summary and Selected Still Pictures Indication 32-26 Slide Down Wear: Through wall tube wear showing the stabilizer cable Indication 32-23-1 Second Row Tube Wear: Example showing both 1"and 2nd row tube wear.

23

SG32 Secondary Side Inspection Results Summary and Conclusions - Spring 2008 Refuel 15 Outage - 45 Through-Tube Bundle Inspection Summary and Selected Still Pictures Indication 32-24 Second Row Tube Wear: Through wall batwing wear in second row out from the center cavity; Appears to be 'old' batwing wear.

24

SG32 Secondary Side Inspection Results Summary and Conclusions - Spring 2008 Refuel 15 Outage Attachment 2 - As-Found Condition of Waterford 3 SG32 Batwings RF14 - SG32 Bottom-Up Inspection View 25

SG32 Secondary Side Inspection Results Summary and Conclusions - Spring 2008 Refuel 15 Outage Attachment 2 - As-Found Condition of Waterford 3 SG32 Batwings PO-07-01 (Mid Cycle 15) - SG32 Bottom-Up Inspection View 26

SG32 Secondary Side Inspection Results Summary and Conclusions - Spring 2008 Refuel 15 Outage Attachment 2 - As-Found Condition of Waterford3 SG32 Batwings RF15 - SG32 Bottom-Up Inspection View 27

SG32 Secondary Side Inspection Results Summary and Conclusions - Spring 2008 Refuel 15 Outage Attachment 3 - Summary of SG32 Batwing Condition Table entries in Bold Italics refer to severed batwing pieces. Figure 1, referred to in the "Detailed Observations During RF15" column, is located after the following tables in this Attachment.

SG32 Hot Leg As-Found Batwing Condition Location RF15 Identified Identified HL 1 = intact Identified 2 = dangling as broken Detailed Observations (tube 33 = broken brokenF1 during,duringduring1 during During RF15 columns on = bowed RF14 PO-07-01 RF15 5 = shifted, each side of 6 = horizontal BW) segment broken off 68/69 1 69/70 1 70/71 1,4 Contact with BW 71/72 71/72 1 72/73 1 73/74 1 74/75 1 75/76 1 76/77 1 77/78 3,5 X X X Broken at notch (Figure 1, Area 4) 78/79 3,5 X X Broken at notch 79/80 3 X X X Broken at notch; Contact

- with BW 80/81 80/81 3,5 X X X Broken at weld with horizontalpiece severed

[LOOSE PART] (See Figure1, Area 7) 81/82 3 X X X Broken at notch (Figure 1, Area 4) 82/83 3 X X X Broken at notch (Figure 1, Area 4) 83/84 3 X X X Appears to be broken.at notch (Figure 1, Area 4) 84/85 3,5 X X X Broken at notch (Figure 1, Area 4) 85/86. 3,5 X X X Broken at notch. Contact with BW 86/87 (Figure 1, Area 4) 28

SG32 Secondary Side Inspection Results Summary and Conclusions - Spring 2008 Refuel 15 Outage Attachment 3 - Summary of SG32 Batwing Condition As-Found Batwing Condition Location RF15 Identified Identified HL 1= intact dagig as broken Identified as broken 2 dangling as broken Detailed Observations during during During RF15 (tube = broken 43 = bowed RF14 during RF15 columns on 5 - shifted, PO-07-01 each side of 6 =horizontal BW) segment broken off 86/87 .3,5 X X X Broken at notch (Figure 1, Area 4) 87/88 3,5 X X X Broken at notch (Figure 1, Area 4) 88/89 3,5 X X X Broken at notch (Figure 1, Area 4) 89/90 3,5 X X X Broken at notch (Figure 1, Area 4) 90/91 3,5 X X X Broken at notch; piece dangling below batwings in same position as mid cycle.

(Figure 1, Area 6) 9 1/92 3,5 X X X Broken at notch; Contact with BW 92/93. (Figure 1, Area 4) 92/93 3,5 X X X Broken at notch; Contact with BW 91/92 and BW 93/94. (Figure 1, Area 4) 93/94 3,5 X X X Broken at notch; Contact with BW 92/93 and BW 94/95. (Figure 1, Area 4) 94/95. 3,5 X X X Broken at notch; Contact with BW 93/94 and BW 95/96. (Figure 1, Area 4) 95/96 3,5 X X X Broken at notch; Contact with BW 94/95 and BW 96/97. (Figure 1, Area 4) 96/97 3 ,5 X X X Broken at notch; Contact with BW 95/96 and BW 97/98 97/98 1 Contact with BW 96/97.

(Figure 1, Area 4) 98/99 1 99/100 1 100/101 1 29

SG32 Secondary Side Inspection Results Summary and Conclusions - Spring 2008 Refuel -15 Outage 9

Attachment 3 - Summary of SG32 Batwing Condition As-Found Batwing Condition Location RF15 Identified Identified HL 21 ==dangling intact as broken Identified Identified as broken as broken Detailed Observations during during (tube 4=

3 = broken bowed RF14 during RF15 During RF15 columns on 5= shifted, PO-07-01 each side of 6 = horizontal BW) segment broken off 101/102 1 102/103 1 103/104 1 104/105 1 105/106 1 106/107 1 107/108 1 1 1 30

SG32 Secondary Side Inspection Results Summary and Conclusions - Spring 2008 Refuel 15 Outage Attachment 3 - Summary of SG32 Batwing Condition SG32 Cold Leg Batwing As-Found Location Condition CL in RF15 Identified Identified S= intactentified 2 = dangling as broken as -broken (tube 3 =broken during as broken Detailed Observations columns on 4- bowed RF14 during RF15 duringbRF15 each side of 5= hifted, PO-07-01 BW) 6 = horizontal segment broken off 68/69 1 69/70 1 70/71 1 71/72 1 72/73 1 73/74 1 74/75 1 Broken at weld. Upper portionfolded over toward 75/76 3 X the south. BWhorizontal segment connected at notch as seen in mid cycle. (Figure 1, Areas 1 and 5)

Broken at weld. Upper portionfolded over toward 76/77 3 X the south. BW horizontal segment connected at notch as seen in mid cycle. (Figure 1, Areas 1 and 5)

Broken at weld. Upper portionfolded over toward 77/78 3,6 x x X the south with horizontal piece severed [LOOSE PART] (Figure 1, Area 1)

Broken at notch; Bent over above other BWs with 78/79 3 X X X horizontal piece still attached (hockey stick). (Figure 1, Areas 2 and 3) 31

SG32 Secondary Side Inspection Results Summary and Conclusions - Spring 2008 Refuel 15 Outage Attachment 3- Summary of SG32 Batwing Condition Batwing As-Found Location Condition CL in RF15 Identified Identified 1 intact as broken Identified Id en (tube 2 = dangling as broken Detailed Observations columns on 3= broken during *. during during RE15 achluid of 4 bowed RF14 PO-07-01 RF15 each side of 5 = shifted, BW) 6 horizontal segment broken off Broken at notch; Bent over 79/80 3,6 x above other BWs with horizontalpiece severed.

(Figure 1, Areas 2 and 3)

Broken at weld, horizontal piece severed [LOOSE 80/81 3,6 X X X PART]. Batwing is bent over and above other batwings.

(Figure 1, Areas 2 and 3) 81/82 3,5 X X XAra4 Broken Area 4) at notch (Figure I, Broken at notch (Figure 1, 82/83 3,5 X X X Area 4) 83/84 '3,5 X x Broken at notch (Figure 1, Area 4) 84/85 3,5 X xBroken at notch (Figure 1, Area 4)

Broken at notch (Figure 1, 85/86 3,5 X X X Area 4) 86/87 3,5 X xBroken at notch (Figure 1, Area 4)

Broken at notch (Figure 1, 87/883,5____ Area 4) 88/89 3,5 X x Broken at notch (Figure 1, Area 4) 89/90 3,5 xBroken at notch (Figure 1, Area 4)

Broken at notch* Contact 90/91 3,5 X X X withBW91/92 Broken at notch; Contact 91/92 3,5 X X X with BW 90/91 (Figure 1, Area 4)

Broken at notch. (Figure 1, 9/93 3,5 X X X4) 32

SG32 Secondary Side Inspection Results Summary and Conclusions - Spring 2008 Refuel 15 Outage Attachment 3 - Summary of SG32 Batwing Condition Batwing As-Found Location Condition CL in RF15 Identified Identified I.= intact 1 as broken Identified as broken (tube 2 = dangling as broken Detailed Observations columns on 34 == broken during during during bowed RF14 P0-07-01 during RF15 each side of 5 = shifted, BW) 6 = horizontal segment broken off Broken at notch; Appears to be broken at weld; Contact with BW 94/95 (Figure 1, Area 4)

Broken at notch; Contact 94/95 3,5 X X X with BW 93/94 (Figure 1, Area 4)

Broken at notch; Contact 95/96 3,5 X X X with BW 96/97 (Figure 1, Area 4)

Broken at notch; Contact 96/97 3 X X X with BW 95/96 (Figure 1, Area 4) 97/98 1 98/99 1 99/100 1 100/101 1 101/102 1 102/103 1.

103/104 1 104/105 1 105/106 1 106/107 1 107/108, 1 Inspection Results Summary Broken Batwings 0 Broken Batwings identified at RF 14 Inspection: 22 0 Broken Batwings identified at PO-07-01 Inspection: 22

• o Broken Batwing locations at PO-07-01 Inspection were verified to be the same as identified at RF 14 Inspection (LTR-CDME-06-195 Rev. 0)

SG32 Secondary Side Inspection Results Summary and Conclusions - Spring 2008 Refuel 15 Outage Attachment 3 - Summary of SG32 Batwing Condition

• Broken Batwings identified at RF 15 Inspection: 22 o Broken Batwing locations at RF 15 Inspection have been verified to be the same as identified at PO-07-01 Inspection (WO- 102365)

Loose Batwing Segments

" Loose batwing segments identified during RF 14 inspection: 2 (LTR-CDME-06-195)

" Loose batwing segments identified during PO-07-01 inspection: 4 (WO -102365) o Change in number of new loose batwing segments from RF14: 2

• Loose batwing segments identified during RF 15 inspection: 4 o Change in number of new loose batwing segments from PO-07-01: 0 o The batwing segment on the top of egg crate 6 observed during the Bottom-up inspection in PO-07-01 is no longer at that location. It is believed that this piece moved to the upper bundle region and is the one observed to be lodged in the upper tube bundle in the vicinity of Row 35 Column 95.

The following are selected pictures from the SG32 Bottom-up and 45-degree inspections that show the batwing damage observed.

Figure 1 RF 15 - Bottom-up View (areas of interest addressed in text are marked) 34

SG32 Secondary Side Inspection Results Summary and Conclusions - Spring 2008 Refuel 15 Outage Attachment 3 - Summary of SG32 Batwing Condition Figure 2 RF 15 - View from above the horizontal batwing sections showing severed batwings Figure 3 RF 15 - Close-up View of severed batwings 35

SG32 Secondary Side Inspection Results Summary and Conclusions - Spring 2008 Refuel 15 Outage Attachment 3 - Summary of SG32 Batwing Condition Fiwure 4 RF 15 - Batwing Between Tube Columns 78 and 79 (This "Hockey Stick" is the end of the broken batwing that is curled up above the horizontal parts of the other batwings at the connection bar in the central cavity region) 36

SG32 Secondary. Side Inspection Results Summary and Conclusions - Spring 2008 Refuel 15 Outage Attachment 4 - Batwing Inventory Evaluation The following discussion and pictures provides an evaluation of the Waterford 3 RF 15 steam generator outage results from secondary side visual inspections performed on SG32. The evaluation primarily focuses on the composite photograph generated from the "bottom-up" inspection and utilizes the video of that examination as well as the 450 Inspection of the upper stay cavity region in the area between the batwings and the tubing U-bends at the top of the SG32 tube bundle.

The results indicate there has been very little change in the batwings since the PO-07-01 outage. For comparison, the PO-07-01 composite photograph is included. The hot leg side is essentially identical to that found during PO-07-01. The cold leg side is also essentially the same with the exception that the loose part on egg crate #6 has moved. It is believed that this part has entered the tube bundle and is lodged in place.

Following the composite photos, figures are provided, as available, to show the progression and status of loose batwing parts and their. estimated locations over time (RF14, PO-07-01 and RF15).

37

SG32 Secondary Side Inspection Results Summary and Conclusions - Spring 2008 Refuel 15 Outage Attachment 4 - Batwing Inventory Evaluation RF15 - SG32 Bottom-Up Inspection Composite Photo 38

SG32 Secondary Side Inspection Results Summary and Conclusions - Spring 2008 Refuel 15 Outage Attachment 4 - Batwing Inventory Evaluation

--- T 1U-U07-01 iI- .) LU,111 I %J1 VII I %3 Lý V 1%,V"J 1A: The piece above did not appear to be part 1B: Picture above still shows what was of the egg crate during PO-07-01 and was assumed to be a loose part in figure 1A on the assumed to be a loose part. left. The location is the same.

Figure 1 - Cold Leg Side lU-U/-U I KI-1 (Item 2 on uomposite View) 2A: A shadow at the same location (above egg 2B: Improved composite quality during RF15 crate on south side of hot leg) of a loose batwing confirms that the shadow shown in 2A to the left piece identified during RF 14 was observed is a loose batwing piece that remains in same during PO-07-01. I location Figure 2 - Hot Leg Side 39

SG32 Secondary Side Inspection Results Summary and Conclusions - Spring 2008 Refuel 15 Outage Attachment 4 - Batwing Inventory Evaluation I

RF14 PO-07-01 RF15 (No longer at location depicted by Item 3 on Composite View) 3A: Batwing part on cold leg 3B: At PO-07-01 the loose 3C: Batwing loose part side estimated to be 5-6 inches batwing part from figure 3A shown to the left in 3B has long identified during RF 14. moved to location shown above moved. It appears based on egg crate #6. Identification is upon size and batwing made by size and batwing inventory that the part inventory, shown in figure 3B is the same as the lodged piece of broken batwing in the tube bundle on the south side of the hot leg shown above.

Figure 3 - Cold Leg Side PO-07-01 RF 15 (Item 4 on Composite View) 4A: Loose part on hot leg side estimated to be 5- 4B: Same loose part observed in 4B to the 6 inches long on egg crate #4 which was left is observed again in same location (egg assumed to be a severed piece from batwing crate #4).

80/81 during PO-07-01.

Figure 4 - Hot Leg Side 40

SG32 Secondary Side Inspection Results Summary and Conclusions - Spring 2008 Refuel 15 Outage Attachment 5 - Post Tube Expansion Bottom-Up Inspection The photo below was obtained from video data taken after the tube expansions were performed in SG32 to secure the detached batwing between tube columns 84 and 85 on the cold leg side.

Comparison of this picture with the RF 15 Bottom-Up view shown in Attachment 2 confirms that the expansion process did not alter the batwing configuration.

RF15 - SG32 Post Expansion Bottom-Up Inspection View Detail 1 41

Enclosure 3 W3F1-2008-0039 Licensee-Identified Commitments

• Table 1 Licensee-Identified Commitments From Refuel 15 / Operating Cycle 16 This enclosure contains those actions committed to by Entergy in this document. Any other statements in this submittal are provided for information purposes and are not considered to be regulatory commitments.

TYPE (Check one)

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

Waterford 3 will monitor trends in primary to X Maintained in secondary leakage rate in the steam generators. existing ODMI This monitoring will aid in understanding the or plant probable cause(s) of the increase in leakage and procedures assure early detection of an adverse trend prior to challenging one of the administrative limits below. A typical value of this operational leakage rate has been about 0.25 gpd.

Any change in the indicated primary to secondary X Maintained in leakage of greater than or equal to 2 gpd will result in existing ODMI or increased monitoring to identify the leaking SG and plant procedures to evaluate and stabilize the condition. The condition will also be evaluated by the Steam Generator Integrity Committee.

Should leakage of between 5 gpd and 15 gpd be X Maintained in detected, Waterford 3 will increase monitoring of existing ODMI or the N-16 and Condenser Air Evacuation Radiation plant procedures Monitors and evaluate data from the loose parts monitor to determine if loose parts exist in the stay cavity area of the steam generators. Waterford 3 procedure UNT-005-032 includes actions to address the loss of one of the radiation monitors, including analyzing the leak rate using grab samples from the main condenser evacuation system or the SG blowdown system. This condition will also be evaluated by the Steam Generator Integrity Committee.

The Waterford 3 Technical Specification 3.4.5.2 X Maintained in limit for steam generator primary to secondary existing ODMI or leakage is 75 gallons per day (gpd). Waterford 3 plant procedures will administratively invoke a limit of 15 gpd and require the plant be placed in Cold Shutdown within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> if this limit is exceeded.

Table 1 Licensee-Identified Commitments From Refuel 15 / Operating Cycle 16 IfWaterford 3 is placed in Cold Shutdown due to X Maintained in violating either of these administrative limits, the existing ODMI or steam generators will be inspected, the findings plant procedures and steam generator condition will be analyzed and evaluated, and appropriate repairs will be made.

The installed accelerometers.on the SG shell to X Maintained in aid in detecting possible batwing failures or loose existing ODMI or parts in the batwing region of the SG will continue plant procedures to be monitored thru the Loose Parts Monitoring systemn. The alarm response procedure actions include steps to increase monitoring of SG leakage for a valid loose parts alarm in the steam generator.

Waterford 3 will continue to perform augmented X RF16 inspections of the secondary side of the steam generators in each subsequent refueling outage (next outage) until the current steam generators are replaced.

The augmented inspections will include the upper batwing to wrapper bar welds, inspection of the stay cavity region, and foreign object search and retrieval (FOSAR) of the secondary side.

Waterford 3 operator training will be updated to X 60 days after address the details of the condition of the steam startup generator.

Steam generator leakage transient simulator X Maintained in scenarios will be used in the operator training in existing training alternating cycles, procedure NTP-101