ML13051A199

Enclosure 6, LTR-SGDA-12-36, Rev. 3, Flow-Induced Vibration and Tube Wear Analysis of the San Onofre Nuclear Generating Station Unit 2 Replacement Steam Generators Supporting Restart. Page 228 of 415 Through End

ML13051A199
Person / Time
Site:	San Onofre
Issue date:	02/15/2013
From:	Bell B A, Cullen W K, Hall J M, Langford P J, Norman T L, Pournaras T J, Prabhu P J, Thakkar J G Westinghouse
To:	Office of Nuclear Reactor Regulation
References
TAC ME9727 1814-AA086-M0238, Rev 0, LTR-SGDA-12-36, Rev 3
Download: ML13051A199 (204)

Text

{{#Wiki_filter:Page 227 of 414 LTR-SGDA-12-36, Rev. 3 NP-Attachment February 15, 2013 6.0 Critical Tubes 6.1 Method A review of the available eddy current data was performed for SG 2E088 and SG 2E089 looking at tube wear indications primarily in the U-bend region of the SG. The review determined that almost 600 tubes had indications of tube wear in SG 2E088, and approximately 800 tubes were found with SG tube wear in the U-bend region of SG 2E089. The range of wear that was reported varied from approximately 4% through-wall (TW) to over 30%TW. Clearly all tubes with wear in Unit 2 do not need to be evaluated individually, since the type of wear was, in general, very similar. Since the wear was determined to be similar, the tubes were placed in three groups of tubes having similar wear depths. For the purposes of this analysis, it was determined that reasonable groupings of tubes would include tubes with indications of wear in the U-bend as indicated below: Group 1 -Tubes with >20%TW tube wear Group 2 -Tubes with 10% to 19%TW tube wear Group 3 -Tubes with 0% to 9%TW tube wear Figures 6-1 and 6-2 contain plots of the SG cross section in the general region of interest with each of the above general regions identified. It should be noted that there are some 'outliers' corresponding to the three groups defined above that are not included in the associated region.It was not possible to include every tube with a given wear depth in a relatively small region without also including additional tubes that have significantly reduced or no indicated level of wear. This could result in plugging additional unaffected tubes should a plugging recommendation become necessary. As a result, it was determined that the analysis would focus on limiting tubes having the largest amounts of tube wear on an individual basis.Since tubes currently having significant wear would be expected to continue to have the largest amounts of additional wear in future operation, these tubes were selected for further analysis.The selection process included a review and sort of tubes looking at maximum eddy current indicated wear depth. The tubes were grouped into the three categories of tube wear as described above. The majority of the emphasis was placed on looking at tubes with >20% wear since it is expected that these tubes will continue to have the largest amounts of wear in future operation. The acceptance criteria for plugged tubes and active tubes are different since a plugged tube can withstand significantly more wear before exceeding criteria. As a result, when looking at plugged tubes, only tubes with wear >20% were considered since these tubes would be expected to have the largest amounts of future tube wear in the plugged tube population. Tubes that have a large amount of wear will continue to be the basis for the limiting tubes based on the assumption that the wear at the AVB support location will be small at reduced power levels. If the wear is small, the support conditions between the AVB and the tube are not expected to change so the tubes with small amounts of wear will continue to have small amounts of wear. The wear analysis presented in Section 7 shows that the wear at reduced power levels is less than what would be expected at 100% power. Therefore, it can be concluded that the tubes with large amounts of wear after operation at 100% power will continue to have the limiting AVB support conditions at reduced power operation. The tube eddy current data were also reviewed to determine the appropriate anti-vibration bar (AVB) support case for use in the FIV analysis. The potential cases are described in Table 4-1.The eddy current test (ECT) data were used to determine the tube support condition likely to be 1814-AA086-M0238, REV. 0 Page 228 of 415 Page 228 of 414 LTR-SGDA-12-36, Rev. 3 NP-Attachment February 15, 2013 present during the prior cycle of operation. In general, the primary FIV analysis case of interest was defined by determining the largest number of consecutive AVB locations that showed indications of tube wear. Ineffective AVB support locations were defined as locations where AVB wear was reported. If there were more than one group of consecutive AVB wear locations on a single tube, the location with the highest wear values was chosen to be representative of the primary FIV tube support condition. These kinds of tubes, i.e., with more than one group of sequential AVB wear locations, were also selectively considered for further analysis. This was performed by considering an additional analysis case where the wear groupings on both sides of an 'effective AVB' were assumed to be indicative of ineffective AVBs, including the AVB site that was apparently effective. This resulted in some analysis cases with many missing AVB supports.6.2 Tube Groups The eddy current data and the AVB support case determination for SG 2E088 are shown in the following tables: Table 6-1 Tubes with >20% wear -Active Tubes Table 6-2 Tubes with 10% to 19% wear -Active Tubes Table 6-3 Tubes with >20% wear -Plugged Tubes The eddy current data and the AVB support case determination for SG 2E089 are shown in the following tables: Table 6-4 Tubes with >20% wear -Active Tubes Table 6-5 Tubes with 10% to 19% wear -Active Tubes Table 6-6 Tubes with >20% wear -Plugged Tubes These tables were then used to select tubes for further analysis using the wear model. This is discussed in Section 6.3.1814-AA086-M0238, REV. 0 Page 229 of 415 Page 229 of 414 LTR-SGDA-12-36, Rev. 3 NP-Attachment February 15, 2013 Table 6-1 AVB Case Determination for Active Tubes with >20% Wear at Power Level Steam Generator 2E088 AVB SG 2E088 Active Tubes with > 20% Wear AVBs Row Col B01 B02 803 B04 B05 B06 B07 B08 B09 B10 B11 B12 Missing Case 88 96 17 21 2 19 133 87 9 19 20 13 6 2 18 112 96 17 20 13 17 2 17 132 96 18 23 11 3 29 120 90 23 16 7 3 28 117 83 14 17 10 24 7 3 31 118 86 23 12 13 14 6 3 31 116 96 23 18 15 7 3 31 105 81 22 12 8 3 28 125 91 9 22 10 3 28 134 84 10 11 21 15 8 3 28 118 82 8 21 10 3 29 98 90 8 8 11 20 7 3 27 97 87 11 25 23 16 4 38 97 91 14 12 22 19 4 38 108 94 22 15 10 13 4 38 131 91 8 22 17 8 4 38 108 88 12 9 22 12 4 38 125 95 9 10 18 22 10 4 37 113 95 10 14 12 9 21 4 39 127 93 6 6 23 10 8 5 48 128 92 8 22 20 11 12 14 5 45 97 93 10 11 23 19 11 5 47 124 96 13 22 14 14 9 5 47 96 92 14 21 16 18 9 5 47 101 95 21 11 11 10 12 5 47 116 82 14 8 17 20 14 5 47 93 89 14 12 11 20 11 5 47 1814-AA086-M0238, REV. 0 Page 230 of 415 Page 230 of 414 LTR-SGDA-12-36, Rev. 3 NP-Attachment February 15, 2013 Table 6-2 AVB Case Determination for Active Tubes with 10% -19% Wear at Power Level Steam Generator 2E088 AVB SG 2E088 Active Tubes with 10>19%% Wear Row Col B01 B02 B03 B04 B05 B06 B07 B08 B09 810 B11 812 Miss Case I I Missing 133 136 129 126 127 123 113 109 110 138 137 124 102 100 133 130 117 114 118 117 113 112 103 97 128 118 129 114 129 126 114 104 95 93 98 87 90 97 91 93 87 98 88 95 94 82 94 89 92 95 94 94 87 97 100 81 95 90 90 89 84 91 98 82 94 95 9 12 11 7 8 8 10 6 13 6 12 7 11 13 6 7 7 11 6 13 6 5 16 8 8 6 13 8 7 12 8 9 13 14 12 7 13 12 9 8 16 6 13 9 9 13 19 7 19 11 18 8 13 6 8 14 10 19 12 7 8 9 7 11 12 9 10 12 13 6 15 13 12 12 9 11 7 13 9 7 14 15 11 12 11 6 8 15 13 9 12 6 9 10 2 2 2 2 2 2 2 2 2 3 3 3 3 3 3 3 3 3 3 3 3 3 3 3 3 3 4 4 4 4 4 4 4 6 9 6 15 5 13 14 10 10 7 11 14 8 6 10 6 8 9 9 10 11 7 15 5 19 10 10 10 7 5 8 1814-AA086-M0238, REV. 0 Page 231 of 415 Page 231 of 414 LTR-SGDA-12-36, Rev. 3 NP-Attachment February 15, 2013 Table 6-2 (Continued) AVB Case Determination for Active Tubes with 10% -19% Wear at Power Level Steam Generator 2E088 122 96 5 11 15 6 4 38 112 82 9 6 9 12 4 38 109 97 6 9 5 12 4 38 105 99 15 17 9 17 4 38 103 97 6 10 5 7 4 38 101 85 12 7 12 14 4 38 95 85 9 14 13 19 4 38 98 88 11 10 7 7 4 38 94 88 12 7 7 7 4 38 89 87 10 14 10 8 74 38 124 84 8 11 8 6 10 4 39 123 99 6 7 12 5 4 39 135 93 5 8 10 5 6 4 40 99 89 7 10 12 5 4 40 93 97 9 17 10 9 4 40 103 95 7 8 11 6 6 5 45 130 86 6 15 7 7 13 5 46 118 84 9 16 15 9 9 5 46 112 94 6 16 19 11 14 5 46 94 86 7 14 6 8 8 5 46 96 88 9 14 17 18 15 11 5 46 120 96 10 12 15 13 12 5 47 99 95 10 5 8 5 5 5 47 96 86 8 9 11 15 13 5 47 96 84 11 13 11 11 6 5 47 89 93 12 9 8 11 10 5 47 128 84 7 6 10 4 5 5 48 1814-AA086-M0238, REV. 0 Page 232 of 415 Page 232 of 414 LTR-SGDA-12-36, Rev. 3 NP-Attachment February 15, 2013 Table 6-3 AVB Case Determination for Plugged Tubes with >20% Wear at Power Level Steam Generator 2E088 AVB SG 2E088 Plugged Tubes with > 20% Wear AVBs Row Col B01 B02 803 B04 B05 B06 B07 B08 B09 B10 Bll B12 Missing Case 108 92 23 17 17 2 17 133 91 8 12 35 29 2 18 124 88 10 20 5 2 18 109 91 23 7 13 9 3 28 107 91 22 9 8 7 3 28 101 91 16 8 21 3 28 104 88 10 20 17 17 16 3 28 114 90 7 8 15 13 22 8 3 30 103 91 7 25 11 9 10 4 37 111 91 26 20 17 23 4 38 110 90 12 17 25 5 4 38 110 88 5 9 20 15 4 38 116 86 11 6 29 28 13 12 5 46 112 86 19 13 24 20 13 14 5 46 105 87 9 11 20 12 11 5 46 117 93 14 27 12 12 9 5 47 117 91 17 16 21 12 7 5 47 115 85 6 19 27 13 7 11 5 48 113 87 22 22 14 18 11 S 48 119 89 16 21 5 13 11 5 5 48 123 89 14 13 15 20 7 5 48 114 86 13 8 11 21 17 8 15 6 53 101 87 11 15 20 7 21 24 6 54 97 89 7 18 11 14 23 16 6 54 129 93 8 13 15 11 21 9 6 54 111 87 5 5 6 10 21 9 6 54 105 89 6 10 10 15 20 20 6 54 112 88 15 16 23 17 35 10 6 55 124 92 19 25 7 9 14 9 6 55 112 92 18 24 11 18 10 9 6 55 108 90 21 12 7 11 18 13 6 55 104 92 7 18 19 12 20 12 6 55 1814-AA086-M0238, REV. 0 Page 233 of 415 Page 233 of 414 LTR-SGDA-12-36, Rev. 3 NP-Attachment February 15, 2013 Table 6-3 (Continued) AVB Case Determination for Plugged Tubes with >20% Wear at Power Level Steam Generator 2E088 128 94 6 10 7 13 10 32 25 7 60 116 92 9 11 24 18 18 16 16 7 60 102 92 7 12 24 15 7 18 8 7 60 113 91 8 13 26 16 13 9 11 7 61 118 92 8 20 13 8 14 11 8 7 61 105 85 9 20 13 8 13 8 6 7 61 103 89 8 20 12 15 6 18 13 8 7 62 120 92 7 11 14 11 32 25 11 10 8 66 97 85 7 11 21 14 9 21 25 7 8 66 99 93 7 9 5 7 5 14 21 12 8 67 1814-AA086-M0238, REV. 0 Page 234 of 415 Page 234 of 414 LTR-SGDA-12-36, Rev. 3 NP-Attachment February 15, 2013 Table 6-4 AVB Case Determination for Active Tubes with >20% Wear at Power Level Steam Generator 2E089 AVB SG 2E089 Active Tubes with > 20% Wear AVBs Row Col B1 B2 B3 B4 B5 B6 87 B8 B9 B10 B11 B12 Missing Case 131 91 8 21 6 2 17 113 71 14 21 2 18 121 95 20 14 5 2 18 119 95 7 20 12 3 28 129 93 is 22 6 3 28 91 73 10 8 22 3 29 105 77 7 21 15 3 29 106 78 6 26 23 13 3 29 119 77 6 14 21 3 29 126 90 5 7 12 21 14 4 36 121 91 12 15 28 23 4 37 124 86 5 9 21 12 4 37 123 83 13 12 23 12 10 4 38 124 88 10 23 14 6 4 38 125 89 8 22 18 6 4 38 119 89 5 6 17 28 5 5 46 88 78 9 9 7 22 10 5 47 93 77 5 7 16 20 22 5 47 100 76 13 21 11 14 12 5 47 109 75 6 7 8 21 13 5 47 112 96 21 9 5 14 17 5 47 1814-AA086-M0238, REV. 0 Page 235 of 415 Page 235 of 414 LTR-SGDA-12-36, Rev. 3 NP-Attachment February 15, 2013 Table 6-5 AVB Case Determination for Active Tubes with 10% -19% Wear at Power Level Steam Generator 2E089 AVB SG 2E089 Active Tubes with 10% -19% Wear Row Column B1 B2 B3 B4 B5 86 B7 B8 B9 B1O Bil B12 Miss Case R C m Missing 99 122 58 69 8o 98 111 114 114 120 66 81 83 84 85 86 87 88 88 88 89 89 90 90 90 90 91 91 92 92 93 95 96 101 95 90 162 163 76 94 95 78 98 94 162 77 77 74 71 72 83 74 84 88 71 87 78 84 88 90 75 87 78 88 71 71 92 95 13 14 13 11 10 11 11 16 12 14 14 11 11 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1814-AA086-M0238, REV. 0 Page 236 of 415 Page 236 of 414 LTR-SGDA-12-36, Rev. 3 NP-Attachment February 15, 2013 Table 6-5 (Continued) AVB Case Determination for Active Tubes with 10% -19% Wear at Power Level Steam Generator 2E089 103 79 12 1 6 111 101 13 1 6 113 71 14 1 6 113 95 11 14 1 6 114 70 11 1 6 115 101 11 1 6 116 96 14 12 1 6 116 102 10 1 6 117 71 10 1 6 117 99 13 1 6 119 89 17 1 6 120 80 10 1 6 120 86 15 11 1 6 122 80 11 1 6 122 128 10 1 6 124 80 12 1 6 125 91 10 1 6 127 81 10 1 6 129 93 15 1 6 130 88 11 1 6 77 71 10 1 7 86 86 10 1 7 88 82 13 11 1 7 89 75 11 1 7 92 76 10 1 7 93 77 16 1 7 95 79 11 1 7 98 70 15 1 7 100 70 12 1 7 102 74 11 1 7 103 71 11 1 7 104 74 10 1 7 104 98 11 1 7 106 74 10 1 7 106 92 10 1 7 106 96 16 1 7 1814-AA086-M0238, REV. 0 Page 237 of 415 Page 237 of 414 LTR-SGDA-12-36, Rev. 3 NP-Attachment February 15, 2013 Table 6-5 (Continued) AVB Case Determination for Active Tubes with 10% -19% Wear at Power Level Steam Generator 2E089 107 71 13 1 7 108 74 10 1 7 108 94 11 1 7 108 96 10 1 7 110 94 14 1 7 111 71 17 1 7 113 79 10 1 7 115 79 15 1 7 119 77 14 1 7 120 102 11 1 7 121 79 11 1 7 121 95 14 1 7 122 98 13 1 7 123 89 19 1 7 123 93 13 1 7 125 87 16 1 7 125 89 18 1 7 126 82 14 1 7 126 94 10 1 7 127 89 13 1 7 128 92 11 1 7 130 82 17 1 7 133 87 14 11 1 7 28 4 7 11 1 8 45 7 11 1 8 63 163 11 1 8 74 70 10 1 8 82 80 10 1 8 83 71 10 1 8 85 77 11 12 1 8 85 83 15 1 8 86 76 10 1 8 86 78 10 1 8 87 71 11 1 8 88 70 10 1 8 89 73 12 1 8 89 81 15 1 8 1814-AA086-M0238, REV. 0 Page 238 of 415 Page 238 of 414 LTR-SGDA-12-36, Rev. 3 NP-Attachment February 15, 2013 Table 6-5 (Continued) AVB Case Determination for Active Tubes with 10% -19% Wear at Power Level Steam Generator 2E089 90 91 91 92 93 93 93 95 96 97 97 97 98 99 99 100 102 102 104 104 105 109 109 110 110 111 111 111 112 112 113 117 117 118 119 119 120 70 71 89 94 73 75 79 91 78 71 73 91 72 69 75 74 96 118 76 96 77 69 93 70 96 73 93 99 68 96 93 93 101 78 69 99 74 1 8 1 8 1 8 1 8 1 8 1 8 1 8 1 8 1 8 1 8 1 8 1 8 1 8 1 8 1 8 1 8 1 8 1 8 1 8 1 8 1 8 1 8 1 8 1 8 1 8 1 8 1 8 1 8 1 8 1 8 1 8 1 8 1 8 1 8 1 8 1 8 1 8 10 1814-AA086-M0238, REV. 0 Page 239 of 415 Page 239 of 414 LTR-SGDA-12-36, Rev. 3 NP-Attachment February 15, 2013 Table 6-5 (Continued) AVB Case Determination for Active Tubes with 10% -19% Wear at Power Level Steam Generator 2E089 120 121 122 123 131 132 135 88 89 96 96 103 103 109 117 120 121 125 126 127 131 98 121 123 124 86 90 91 110 111 113 121 123 125 127 84 92 92 101 100 75 79 94 75 78 79 74 90 73 75 75 73 96 75 81 90 95 89 76 93 85 90 84 80 91 92 91 97 91 83 95 91 88 70 12 14 17 10 11 12 10 10 13 10 11 10 14 14 10 13 10 13 12 13 10 15 14 12 16 12 1 8 1 8 1 8 1 8 1 8 1 8 1 8 1 9 1 9 1 9 1 9 1 9 1 9 1 9 1 9 1 9 1 9 1 9 1 9 1 9 1 9 1 10 2 16 2 16 2 16 2 17 2 17 2 17 2 17 2 17 2 17 2 17 2 17 2 17 2 17 2 18 2 18 10 11 11 10 15 13 15 11 14 13 11 10 15 14 11 10 10 13 11 11 10 11 15 12 10 12 15 13 12 12 10 10 10 17 12 16 13 11 10 10 1814-AA086-M0238, REV. 0 Page 240 of 415 Page 240 of 414 LTR-SGDA-12-36, Rev. 3 NP-Attachment February 15, 2013 Table 6-5 (Continued) AVB Case Determination for Active Tubes with 10% -19% Wear at Power Level Steam Generator 2E089 95 75 10 10 2 18 96 76 11 11 2 18 99 73 15 11 2 18 101 71 18 12 2 18 103 91 15 18 2 18 106 70 12 12 2 18 107 97 12 14 2 18 108 72 11 12 2 18 108 80 10 14 2 18 112 72 11 11 2 18 112 92 10 12 2 18 113 77 17 14 2 18 115 71 16 18 2 18 117 95 10 18 2 18 118 80 12 13 2 18 119 79 13 11 2 18 119 91 17 15 2 18 122 88 15 10 2 18 124 82 12 14 2 18 126 80 12 13 2 18 126 92 16 19 2 18 130 94 13 13 2 18 87 77 10 16 2 19 88 76 11 14 2 19 89 77 12 14 2 19 90 76 13 16 2 19 94 76 12 11 2 19 96 72 10 11 2 19 97 77 16 12 2 19 98 90 10 15 14 2 19 99 77 17 12 2 19 101 77 14 13 10 2 19 102 70 19 10 2 19 103 77 13 16 2 19 107 75 10 12 2 19 107 77 19 17 2 19 107 79 18 19 12 2 19 1814-AA086-M0238, REV. 0 Page 241 of 415 Page 241 of 414 LTR-SGDA-12-36, Rev. 3 NP-Attachment February 15, 2013 Table 6-5 (Continued) AVB Case Determination for Active Tubes with 10% -19% Wear at Power Level Steam Generator 2E089 109 112 122 129 133 133 134 87 94 95 102 103 103 105 126 129 135 138 125 99 110 118 130 88 91 98 106 123 124 129 95 104 123 108 118 77 76 92 95 89 95 86 75 78 73 76 81 97 79 78 83 93 90 83 71 100 94 84 80 77 78 80 79 84 91 77 8o 87 76 92 15 12 10 10 15 11 15 13 14 10 13 15 15 13 11 10 10 19 18 11 15 12 15 13 11 13 14 12 13 11 11 12 13 10 14 14 12 12 14 16 12 11 11 19 19 19 19 19 19 19 20 20 20 20 20 20 20 20 20 20 20 21 28 28 28 28 29 29 29 29 29 29 29 30 30 38 39 39 16 11 19 17 19 10 10 10 11 11 16 18 11 11 18 13 11 12 11 10 14 11 12 17 12 15 13 12 13 14 14 14 11 11 16 10 13 17 13 10 18 10 11 10 14 12 10 14 19 11 14 16 17 11 13 1814-AA086-M0238, REV. 0 Page 242 of 415 Page 242 of 414 LTR-SGDA-12-36, Rev. 3 NP-Attachment February 15, 2013 Table 6-6 AVB Case Determination for Plugged Tubes with >20% Wear at Power Level Steam Generator 2E089 AVB SG 2E089 Plugged Tubes with > 20% Wear Row Col B01 B02 B03 B04 B05 B06 B07 B08 B09 BlO Bl1 812 AVBs Missing Case 121 83 6 24 9 8 2 16 115 91 19 22 22 3 28 97 79 5 7 12 22 4 38 118 88 10 14 21 16 7 4 38 110 80 11 23 12 8 11 5 39 117 89 9 13 17 26 9 5 46 114 92 6 11 13 24 18 5 46 131 89 6 23 11 7 16 5 47 112 90 9 21 16 11 5 7 5 46 109 87 6 8 14 15 22 7 5 47 108 90 8 6 12 27 21 6 6 53 120 82 5 14 16 16 16 22 6 53 118 82 6 8 17 20 10 19 6 53 106 82 8 6 13 18 20 11 6 53 103 83 6 15 20 24 20 12 6 54 120 84 7 12 12 16 23 9 6 54 115 87 7 22 14 15 6 9 6 54 110 88 8 8 14 16 22 8 6 54 121 89 8 15 22 10 13 13 6 54 104 84 5 14 19 21 12 9 6 54 103 87 5 14 14 21 9 96 54 117 81 6 16 12 19 29 10 6 55 122 84 5 21 6 16 13 8 6 55 106 88 8 18 21 9 8 11 6 55 100 82 20 9 10 18 7 8 6 55 100 88 5 14 10 15 22 9 7 6 55 115 83 5 8 6 9 5 21 6 6 55 134 90 S 11 9 13 6 18 26 10 6 56 114 88 7 23 19 24 21 17 8 6 56 115 85 9 8 9 15 22 16 5 7 59 102 82 6 6 19 15 17 21 10 7 60 1814-AA086-M0238, REV. 0 Page 243 of 415 Page 243 of 414 LTR-SGDA-12-36, Rev. 3 NP-Attachment February 15, 2013 Table 6-6 (Continued) AVB Case Determination for Plugged Tubes with >20% Wear at Power Level Steam Generator 2E089 99 85 102 88 117 85 122 82 106 84 105 83 104 86 98 86 123 91 98 88 112 84 100 84 9 7 6 8 7 6 S 6 8 5 5 11 14 9 20 13 12 18 11 20 12 25 10 10 18 23 11 13 8 15 9 10 5 9 14 15 20 15 15 17 15 20 18 15 27 6 16 12 11 17 14 22 23 15 18 5 6 15 9 16 6 15 20 19 11 16 27 17 20 19 12 7 24 9 5 8 11 27 15 10 8 17 11 11 14 22 18 14 7 13 12 11 14 12 5 7 7 7 8 8 8 8 8 8 8 8 8 60 60 62 66 66 66 66 66 66 66 67 67 1814-AA086-M0238, REV. 0 Page 244 of 415 Page 244 of 414 LTR-SGDA-12-36, Rev. 3 NP-Attachment February 15, 2013 6.3 Enveloping Tubes The figures for the bounding box used to select critical tubes are shown in Figures 6-1 and 6-2 for the 2E088 and 2E089 steam generators, respectively. Originally this method was going to be used to identify the initial groupings of tubes. However, after some initial work, this method was determined to include too many tubes that are not showing indications of tube wear and would result in excessive tube plugging if this criterion was used to select the tube groups.Using the eddy current data and the missing AVB cases determined in Section 6.2, an alternate selection of limiting tubes was used. The limiting tubes were chosen based on the number of missing AVB supports, the location of those AVB supports, and the severity of tube wear at the AVB locations. The tubes determined to be the most limiting are listed in Table 6-7. These tubes include the base case determined in Section 6.2 as well as extra alternate cases to consider based on gaps in sequential AVB tube wear.In general the tubes were selected to find: 1) Limiting active tube in SG 2E088 2) Limiting active tube in SG 2E089 3) Limiting plugged tube in SG 2E088 4) Limiting plugged tube in SG 2E089 In addition, the following was also performed:

1) Confirm limiting tubes were indeed limiting based on tube excitation ratios and wear criteria, 2) Address tubes with tube-to-tube wear, 3) Consider effects of additional missing AVBs beyond what is indicated by ECT.Results of the evaluation of these tubes can be found in subsequent sections of this report. It should be noted that the expected trends, meaning tubes with higher tube excitation ratios have higher wear, were generally confirmed in these analyses.

This confirms the enveloping tubes have been addressed. 1814-AA086-M0238, REV. 0 Page 245 of 415 Page 245 of 414 LTR-SGDA-12-36, Rev. 3 NP-Attachment February 15, 2013 Table 6-7 Limiting Tubes Determined for AVB Wear Considerations Number Number Tube SG Tube Tube ECT ECT FASTVIB ] FASTVIB IMissing Missing R/C No Status Description Value w/Uncertainty Case Case.[jAVB AVB R97C87 88 Active Limiting Active Tube in SG 88 25 27.4 38 4 46 5 R119C89 89 Active Limiting Active Tube in SG 89 (1/2) 28 30.5 46 5 54 6 28 30.4 37 4 45 5 R121C91 89 Active Limiting Active Tube in SG 89 (2/2) x 30.4 x x 46 5 x 30.4 x x 53 6 R131C91 89 Active Less limiting active tube 21 23.6 17 2 38 4 R129C93 89 Active Less limiting active tube 22 24.6 28 3 46 5 R126C90 89 Active Less limiting active tube 21 23.6 45 5 60 7 R112C88 88 Stab Limiting Plugged Tube in SG 88 35 37.2 47 5 55 6 R133C91 88 Stab Limiting Plugged Tube in SG 88 35 37.2 38 2 45 5 R114C90 88 Stab Limiting Plugged Tube in SG 88 22 24.5 48 3 60 7 R111C91 88 Stab Limiting Plugged Tube in SG 88 26 28.4 38 4 x x R116C86 88 Stab Limiting Plugged Tube in SG 88 29 31.3 46 5 61 7 R117C93 88 Stab Limiting Plugged Tube in SG 88 27 29.4 47 5 x x R115C85 88 Stab Limiting Plugged Tube in SG 88 27 29.4 48 5 61 5 R114C86 88 Stab Limiting Plugged Tube in SG 88 21 23.5 53 6 66 8 R128C94 88 Stab Limiting Plugged Tube in SG 88 32 34.3 60 7 x x R120C92 88 Stab Limiting Plugged Tube in SG 88 32 34.3 66 8 x x R121C83 89 Stab Limiting Plugged Tube in SG 89 24 26.4 16 2 46 4 R117C89 89 Stab Limiting Plugged Tube in SG 89 26 28.4 46 5 x x R108C90 89 Stab Limiting Plugged Tube in SG 89 27 29.4 53 6 x x R117C81 89 Stab Limiting Plugged Tube in SG 89 29 31.3 55 6 x x R134C90 89 Stab Limiting Plugged Tube in SG 89 26 28.4 56 6 67 8 R114C88 89 Stab Limiting Plugged Tube in SG 89 24 26.4 56 6 67 8 R117C85 89 Stab Limiting Plugged Tube in SG 89 24 26.4 62 7 74 10 R122C82 89 Stab Limiting Plugged Tube in SG 89 27 29.4 66 8 x x R112C84 89 Stab Limiting Plugged Tube in SG 89 27 29.4 67 8 x x R113C81 89 Stab Tube with Tube-to-Tube Wear (1/2) 16 18.6 28 3 18 20.5 38 4 55 6 R11lC81 89 Stab Tube with Tube-to-Tube Wear (2/2)x 20.5 x x 67 8 Additional Check Cases 21 23.5 18 2 28 3 R113C71 89 Active Low SR & High Wear -Check Cases x x x 29 3 x x x 38 4 R121C95 89 Active Low SR & High Wear -Check Cases 20 22.5 45 5 39 4 1814-AA086-M0238, REV. 0 Page 246 of 415 Page 246 of 414 LTR-SGDA-12-36, Rev. 3 NP-Attachment February 15, 2013 to CU C?4 cm, 0 N 0 o 0 0 SMON Figure 6-1 Bounding Box for SG 2E088 1814-AA086-M0238, REV. 0 Page 247 of 415 Page 247 of 414 LTR-SGDA-12-36, Rev. 3 NP-Attachment February 15, 2013 I............ .... ......... ......................................C13 0)i V I V gl 0....................... .... ....................I ..: : :..................... ......... .. .................. .............. .......... .....................x ol E 4 0 0 00--S.w = w I I TI Ii I..........,..0 ..'..00 .,,°*° ..0...00o. 00.. ., *0.,.....................,.... ..... .......*..............., ., ............ i i I.--------------- .... .......i at K............ 0 Ln+--------------------------------------- .... .... .......LA 0 CA-4 0 N-4 0-4-4 M08 Figure 6-2 Bounding Box for SG 2E089 1814-AA086-M0238, REV. 0 Page 248 of 415 Page 248 of 414 LTR-SGDA-12-36, Rev. 3 NP-Attachment February 15, 2013 7.0 Wear Analysis 7.1 General Methodology Tube and support interaction leading to rapid wear in the U-bend region is a complex, highly nonlinear process involving impact dynamics, friction, boundary conditions and forcing functions that change with time during the process. Rather than attempt to calculate and benchmark the nonlinear calculations, Westinghouse performed baseline tests that incorporated the nonlinear interaction for a range of tube and AVB support conditions and measured enveloping workrates that could be scaled to other conditions using forcing functions that are obtained from results of linear vibration analyses. Tube wear is then calculated as a function of time following Archard wear theory using the equation V = K(WR)(t)where V is the calculated wear volume, K is the appropriate tube wear coefficient, WR is the workrate, and t is time. The same equation is used to determine the corresponding AVB wear volume using an appropriate wear coefficient for the AVB as relative tube and AVB wear volumes are apportioned for conformal interaction. These calculations require three inputs: 1. Specific wear coefficients for the tube and AVB, 2. The normal force/sliding motion workrate, and 3. The depth-volume relationship at the interface. Each is discussed in the context of testing, design bases, and application to SONGS operating experience in the following section.7.2 Wear Considerations -Fluidelastic Tube Excitation versus Turbulence The methodology that is applied in this evaluation treats the mechanism that was found to be the cause of moderate wear in the U-bend region of conventional Westinghouse Model 51 and Model F steam generators before the development of advanced tube/AVB support configurations in the mid 1980s as described in Reference 7-1. This mechanism has been variously referred to as "fluidelastic vibration in the support inactive mode," "double-span behavior," "fluidelastic rattling within loose supports," and "amplitude limited fluidelastic vibration." Its characteristics are fundamentally different in many respects from those of random flow turbulence that is always present in steam generators. Given the evolving state of knowledge and analytical capabilities at the time as typified by References 7-2 through 7-5, Westinghouse developed a semi-empirical methodology to use as a design tool in treating the fundamental characteristics observed in testing.A brief overview of the mechanism is provided in order to facilitate understanding the supporting Westinghouse tests described in Section 7.2.1, details of semi-empirical workrate formulation described in Section 7.2.2, Westinghouse experience with its application in Section 7.2.3, and how it is applied to the SONGS evaluation in Section 7.2.4. When Westinghouse experienced moderate tube wear in the U-bend region of conventional steam generators as described in Reference 7-1, the understanding of the gap-limited fluidelastic vibration mechanism was in its infancy. S. S. Chen et al (References 7-2 and 7-3) provided some of the first descriptions, noting among other things that: 1. "To facilitate manufacture and to allow for thermal expansion of the tubes, small clearances are used between tubes and tube supports. When the clearance is relatively 1814-AA086-M0238, REV. 0 Page 249 of 415 Page 249 of 414 LTR-SGDA-12-36, Rev. 3 NP-Attachment February 15, 2013 large, the tube may rattle inside some of the support clearances with small-amplitude oscillations. This type of mode, in which some supports do not provide effective support, is called tube-support-plate (TSP)-inactive mode." 2. "...the natural frequencies of the TSP-inactive modes are lower than those of the 'TSP-active modes,' in which the support plates provide 'knife-edge' type support." 3. "Tube displacements associated with the instability of a TSP-inactive mode are small;however, impacts of the tube against TSPs may result in significnt damage in a relatively short time." 4. "In addition, tube response is intrinsically nonlinear, with the dominance of the TSP-inactive or TSP-active modes depending on the magnitudes of different system parameters. In general, such a system is difficult to model; only a full-scale test can provide all the necessary characteristics." 5. "In the region in which the TSP-inactive mode is unstable, tube displacement close to the baffle plate varies very little with the flow velocity." 6. "When the tube is offset to one side, the tube does not impact with the other transducer. However, there are double impacts against one of the transducers during each cycle of vibration." 7. "For a given flow velocity, the tube displacement and impact force depend on diametral 3 gap. For larger gaps, tube motion is more steady and the impact force is larger." 8. "Fluidelastic instability associated with a TSP-inactive mode for loosely held tubes has been demonstrated in laboratory tests and observed in a few heat exchangers. It is suspected to be one of the main causes of tube failures in some operating steam generators and heat exchangers." There are many other papers dealing with this mechanism that were published during the time when Westinghouse was resolving the moderate AVB wear in conventional steam generators and developing advanced designs as summarized in Reference 7-1. Bouecke (Reference 7-4)concluded that fluidelastic rattling within a relatively loose tube/support strip was the mechanism that led to wear in an operating steam generator. Fricker (Reference 7-5) noted that nonlinear analysis which deals with impacting and sliding was one approach to evaluating consequences of this mechanism, and further, that numerical results indicated a linear relationship between clearance and impact force for a given level of negative damping. However, he also noted that the approach was rather cumbersome requiring small time steps to obtain the required accuracy and numerical stability, while long time histories are required. Perhaps more importantly for Westinghouse development of a practical design tool, he noted that the cumbersome "analysis has to be repeated for each change in the boundary conditions, (e.g. clearances)." Given this environment and the need for a practical design tool that could be used to optimize advanced AVB support systems for the U-bend region, Westinghouse developed a semi-empirical methodology that incorporated the complex, nonlinear characteristics of gap-limited fluidelastic tube excitation from full-size baseline tests that could be scaled to other loading conditions using results of linear analyses. All the characteristics described in the extracted summary descriptions from others were confirmed in Westinghouse testing. Sections 7.2.1 3 This is the spelling in the published paper.1814-AA086-M0238, REV. 0 Page 250 of 415 Page 250 of 414 LTR-SGDA-12-36, Rev. 3 NP-Attachment February 15, 2013 through 7.2.4 describe that development in more detail and how it is applied for the current evaluation of SONGS operating experience. 7.2.1 Westinghouse Test Programs Extensive flow-induced vibration testing and evaluation to support steam generator design were performed using a broad array of consistent methods for much of four decades at the Westinghouse Research Laboratories (now Science and Technology Center). References 7-6 through 7-8 illustrate the kinds of idealized tests used in characterizing mechanisms of interest and development of analytical models to evaluate them in more complex steam generator configurations. Subsequently, a variety of tests on segmented portions of full-size steam generators, scale-model tests in air and prototypic steam environments, and instrumentation programs for initial operation of newer models of steam generators served to confirm and refine analytical models. Early testing supported SG design with tubes arranged in square array patterns, but new tests were conducted for triangular arrays with the same pitch-to-diameter ratio in the 1980s in the same test rigs to develop consistent models for evaluation of both configurations. Only those tests pertinent to the methodology applied in evaluation of SONGS flow-induced vibration and wear potential are described in this report.Figure 7-1 shows the idealized triangular arrangements that were tested first in the same water tunnel that had been used two decades earlier for square pitch configurations. Figure 7-2 provides a context and reference for discussion of tube vibration response characteristics and flow-induced vibration (FIV) mechanisms using sample results that were obtained from one of those tests. The tube response data on Figure 7-2 includes vortex shedding contributions in the idealized water test that may exist around the periphery of the steam generator inlet regions, but they are not a concern in the two-phase, highly turbulent flow in the U-bend region of interest to this evaluation. The narrow band tube response to random flow turbulence typically varies as velocity raised to about the second power 4 and is illustrated by the red line on Figure 7-2.However, there is a critical velocity above which fluidelastic tube excitation initiates and tube response is so extreme that it must be avoided altogether in design (see Section 7.2.2 for more discussion of Westinghouse design bases). For illustration purposes, the black line on Figure 7-2 varies with velocity to the tenth power, and it envelopes the tube response in the sample shown.The FIV mechanisms of interest to U-bend tube response are fluidelastic excitation and flow turbulence with the same characteristic trends as shown in Figure 7-3. However, the parameters that determine initiation and response must be obtained from more representative tests because tube stiffnesses are different for out-of-plane (OP) and in-plane (IP) directions in the U-bend region. They also vary to a lesser extent with tube radius, so the U-bend region is much less homogeneous than the straight leg region in terms of tube stiffness and frequency response characteristics. Figure 7-4 is a schematic of the quarter-scale U-bend model with a parallel triangular array pattern that was tested in the same wind tunnel as earlier quarter-scale models for square-pitch configurations to obtain parameters for evaluating U-bend tubes. Tests were performed first with no AVBs present and then for six other configurations representing different numbers of AVB supports with increasing frequency response. Test results included the following relative to initiation of fluidelastic tube excitation with no AVBs in the model: 4 The specific exponent applicable to FIV analyses in Section 4.0 and to the trend line on this plot using the same correlation is [ ]a,c,e.1814-AA086-M0238, REV. 0 Page 251 of 415 Page 251 of 414 LTR-SGDA-12-36, Rev. 3 NP-Attachment February 15, 2013 1. Vibration amplitudes were small until a critical velocity was exceeded. Amplitudes increased rapidly with increasing flow after that.2. Large amplitudes were caused by fluidelastic vibration and they were in the OP direction only.3. The triangular-pitch arrangement was [ ]be as the square-pitch arrangement with the same pitch/diameter ratio 5 when tested without AVBs.4. Not all the tubes responded equally to the fluidelastic excitation. This was also true for the earlier square array tests, but [ ]b,e in the triangular array tests.Additional tests were performed with all but one of the tubes having six included the following: AVBs pinned. Results 1. [2.3.]Pe be]b.e 4.]b,e A piezoelectric force gauge and a non-contacting fiber-optic vibration displacement transducer were installed to measure tube response characteristics of the same tube for two different AVB support configurations. During these tests, front and back locations of AVB surfaces were controlled by micrometer extensions to determine 6 the effects of gap magnitude and symmetry on both impact forces and displacements. Results included the following: 1.2.[[be 3.4.b,e be 5 6 I be I b,e 1814-AA086-M0238, REV. 0 Page 252 of 415 Page 252 of 414 LTR-SGDA-12-36, Rev. 3 NP-Attachment February 15, 2013 5.]b,e 6.]b,e Figure 7-5 illustrates the basic characteristics of results from these quarter-scale tests that include both turbulence and fluidelastic excitation mechanisms when U-bend tubing interacts with AVBs across large gaps. Portions of data plots recorded to the same scales for flows up to about twice the tube excitation threshold during the U-bend tests have been copied and pasted above the schematic illustration of the two mechanisms originally shown on Figures 7-2 and 7-3.As flow velocity increases up to the point of fluidelastic instability, the displacements from turbulence are small and insufficient to interact with the AVB even sporadically. For narrow band random turbulence response, the peak amplitudes follow []ac.e. For the illustrated conditions there will be either zero or negligible turbulence interaction with the AVB across the clearance up[]b,e The observed almost instantaneous change from a benign to a significant tube/AVB interaction long before random flow turbulence causes any interaction by itself, as illustrated on Figure 7-5 using actual U-bend flow response characteristics, is the reason why FEI and not turbulence is considered the mechanism to be avoided or controlled. Not all tubes will respond this way from fluidelastic excitation, but it is possible anywhere that AVB gaps are large enough to create a tube span that is long enough to become unstable if the AVB did not exist. What to call the mechanism can be debated, but the dominant tube vibration results from energy extracted from fluidelastic excitation and not random flow pressure fluctuations. This data is sufficient to explain why FEI causes tube wear, but not to explain how because the consequential workrates are needed for wear calculations using the Archard type equation described in Section 7.1.Following tests on both the square-pitch and triangular-pitch small-scale U-bend configurations, two series of wind tunnel experiments were conducted on cantilever tubes designed to simulate the response of curved U-bend tubes as described generally in Reference 7-1. A 7-row by 5-column array of full-size tubes mounted in such a way that orthogonal stiffnesses differed to match U-bend response as shown on Figure 7-6 provided two kinds of information. Basic fit-up effects on tube response to both fluidelastic and turbulent excitation were determined first. []b.e Both the threshold tube excitation constant and turbulent tube response correlations were consistent with those derived from the scale-model U-bend tests. Then the test rig was modified to refine basic fluidelastic driving force correlations for use in properly controlling mechanical shaker tests of full-size steam generator U-bends.1814-AA086-M0238, REV. 0 Page 253 of 415 Page 253 of 414 LTR-SGDA-12-36, Rev. 3 NP-Attachment February 15, 2013 Mechanical excitation tests followed on full-size 0.688 inch OD x 0.040 inch average wall thickness U-bends configured as shown on Figure 7-7 to characterize the wear producing forces and motions at the tube/AVB intersections. These tests are also described generally in Reference 7-1 and in depth in Reference 7-8. Two different size tubes with up to either 4 or 6 AVB intersections were evaluated. Each had a full-length straight leg span supported at a top plate with simulated broached flat contact lands. All tests were performed with tubes filled with water and pressurized to 1200 psi. Parametric tests covered a range of fit-up conditions subject to simulated out-of-plane fluidelastic excitation, in-plane turbulence, and out-of-plane turbulence. Initial tests with four AVB intersections (simulating two sets of AVB's) first confirmed the fundamental conclusion that out-of-plane fluidelastic vibration within tube/AVB gaps was the likely explanation for wear which had been observed in some operating steam generators. Subsequent tests with six AVB intersections simulated the excitation forces and fit-up conditions characteristic of advanced design configurations. Wear producing forces and motions were determined and recorded in the form of workrates that could be used for wear calculations. These workrates were verified by independent testing on the same full-size tube using a simulated negative damping feedback loop as explained in Reference 7-9 in addition to the original effective sinusoidal force simulation described in Reference 7-8.Several overall conclusions from the test programs are important to subsequent discussion:

1. The tests described in this section for triangular array configurations are most applicable to the evaluation of the SONGS steam generators.

However, the methodology and design bases were originally developed for square pitch configurations based on earlier tests. The limiting amplitude limited fluidelastic vibration mechanism leading to tube/AVB wear that is illustrated by large displacements and impact forces before significant turbulence interaction on Figure 7-5 affects a larger percentage of tubes in square pitch configurations.

2. Displacements, impact forces, and workrates derived for wear calculations from these laboratory tests are more modulated in steam generators with complex geometry and variations in two-phase flow. This implies they are conservative for the range of tested configurations for the design purposes for which they were intended, but in that sense may overpredict wear in steam generators.

3. On the other hand, the range of tested tube/AVB support conditions tested for design purposes does not cover the apparent range of support conditions implied from the ECT wear indications described in Section 5.1. In this sense, the test and design bases may underpredict the extreme wear in the SONGS steam generators.

These factors are addressed more fully in Section 7.2.4.7.2.2 Westinghouse Design Basis 7.2.2.1 Wear Coefficients Determination of appropriate wear coefficients is based on both extensive testing within Westinghouse and correlation of results from licensees and external sources. Specific wear coefficients for the Alloy 690 tubes (Kt) and 405 Stainless Steel (SS) TSP/AVBs (Ka) were derived from all available impact/sliding wear test data. The median value of the wear coefficient for tubing when interacting with 405 SS from the raw test data was [ ]b.e. However, three additional factors are considered in establishing a calculation reference: 1814-AA086-M0238, REV. 0 Page 254 of 415 Page 254 of 414 LTR-SGDA-12-36, Rev. 3 NP-Attachment February 15, 2013 1. Raw data is typically based on extrapolating wear rates linearly from time zero through conditions defined at the end of a wear test. This is typically conservative by factors of from 2 to 4 depending on the material couple, test specimen surface conditions, environment, and test duration. In addition to an inherent minimum run-in effect, Figure 7-8 shows how initial surface roughness can significantly increase the wear coefficient during initial operation prior to achieving conformal wear between the tube and AVB such that the coefficient is determined solely by the internal structure of the two materials. Correlation of the data from an early EPRI program (Reference 7-12) intended to characterize steady state effects in prototypic SG environments with Alloy 600 tubing and 405 SS supports yielded a median value of 69 (1012 in 2/lb). More recent tests (Reference 7-12) with Alloy 690 tubing and 405 SS supports indicate an obtained value only two percent different for average wear coefficients for Alloy 690 than for Alloy 600 tubing. The significant wear observed in the SONGS steam generators may not allow any normal surface films and oxides to develop such that higher coefficients would apply. Early tests sponsored by Westinghouse in which all surface oxides were removed during testing produced tube wear coefficients that were [ ]b,e higher than the EPRI value intended for long-term low level wear in prototypic environments.

2. Following theory described by Rabinowicz (References 7-13 and 7-14), relative hardness of the tube and AVB (from chemistry and structure:

not cold work) is an important factor in determining relative wear effects. The harder of two materials generally wears less and has a lower wear coefficient: a factor of three difference is common. This effect is part of the typical variability in wear coefficients of 16 (+/- 4 times). Apparent differences between some groups of data are consistent with relative AVB/tube hardness trends. []b e This indicates that actual tubing wear coefficients for similar AVBs could be expected to be higher than nominal. The processing history and materials properties associated with the SONGS tubes and AVBs is not known.3. Wear tests are necessarily more severe than service conditions in order to obtain results in reasonable test durations. Wear coefficients typically vary little with load over a broad range of loading. However, classical wear theory indicates there is a load below which burnishing or polishing will occur, but wear particles will not form. Loads measured during shaker tests intended to conservatively simulate nominal operating conditions in advanced design configurations are about the same as this threshold. Thus, it is likely that the wear tests with loads more than two orders of magnitude higher may be very conservative relative to expected service conditions for advanced configurations with tight tube/AVB fit-up. On the other hand, for the specific SONGS evaluation with short-term wear, this factor is moot.Based on these considerations, a design value of]b,e 1814-AA086-M0238, REV. 0 Page 255 of 415 Page 255 of 414 LTR-SGDA-12-36, Rev. 3 NP-Attachment February 15, 2013 On the other hand, nothing other than nominal drawing specifications is known about the actual structure of the materials, the initial surface conditions, or the effect of severe wear interfering with development of prototypic surface oxides and films. Therefore, it is considered possible that a number up to three or four times higher could be possible for the wear observed during the first operating cycle of the SONGS steam generators. The average ratio of AVB material wear coefficient to tubing wear coefficient in the original impact/sliding test data was 2.1. However, this data included much softer AVBs. Relatively harder AVBs that wear slower in the early stages are especially limiting if the AVB is not perfectly aligned with the tube. Therefore, the AVB specific wear coefficient is typically considered to be the same as the tubing for reference calculations, but is varied from 0.01 times (negligible AVB wear) up to two times (more AVB wear than tube wear) in normal design calculations. Section 7.2.4 explains the approach taken for this evaluation. 7.2.2.2 Workrates Workrates are scaled from baseline mechanical shaker test trends using inputs from qualified thermal-hydraulic and FIV analyses such as ATHOS/VGUB and FASTVIB as described in Sections 3.1 and 4.2 for the SONGS RSGs. As noted in Section 7.2.1, vibration tests were originally conducted to simulate tube/AVB interaction that occurred in earlier model steam generators that experienced moderate tube/AVB wear in less than seven years as described in Reference 7-8. Wear producing forces and motions from these tests were assimilated in terms of workrate for use in calculating tube wear depth (Reference 7-10). The product of the normal force and sliding motion during contact was numerically summed as a time integral to approximate the workrate parameter used to quantify test results.Two mechanical shakers were used to excite the tube. Instrumentation used to measure forces and displacements at the tube/AVB intersections included conventional force and displacement gauges in addition to light sensors that measured the small in-plane relative displacements during impact. Out-of-plane sinusoidal drive force simulated fluidelastic excitation, and random forces in both out-of-plane and in-plane directions simulated turbulence. Various combinations of tube/AVB clearances, force levels, tube/AVB contact impedance, and tube/AVB interface friction were tested.Initial tests simulated conditions representative of previous steam generator models to see if workrates consistent with field experience would result for expected operating conditions. Workrate trends and characteristics that were originally obtained using equivalent sinusoidal excitation were also confirmed by additional simulated negative damping tests using the same test rig (Reference 7-9). After confirming the resulting workrates, which could explain the observed wear progression trends for conventional designs, additional tests were performed as a benchmark for advanced designs with shorter spans, better controlled tube/AVB interfaces, triangular pitch configurations, and AVBs with lower tubing wear coefficients. Shaker tests for the triangular configuration were done using a negative damping simulation since the reference design at that time had staggered AVBs that intersected the tube at different locations on each side of the tube.Evaluating any other geometry, including tube row and AVB location, and any other flow field, requires adjustment of experimentally determined workrates using parameters appropriate to the configuration of interest. In this case, workrates for the SONGS steam generators were determined using scaling factors derived from analyses in Sections 3.3 and 4.3. This is done using an equation that is a function of tube frequency, secondary fluid density, effective velocity of the 1814-AA086-M0238, REV. 0 Page 256 of 415 Page 256 of 414 LTR-SGDA-12-36, Rev. 3 NP-Attachment February 15, 2013 fluid for the limiting vibration mode, fluidelastic tube excitation ratio, effective tube span length, and tube/AVB clearance as described in Reference 7-8. The form of this semi-empirical equation for predicting workrates uses an analytical expression of the fluidelastic excitation force, F, = CfPoDU,2 { )- UC L.en that is consistent with measured wind tunnel test results, taken together with experimental trends determined in the baseline U-bend shaker tests. Overall results of the test program were provided in the form of workrate coefficients, Wr, for use in an equation of the form WR = WJf DF.where F, is the appropriate fluidelastic force calculated from the previous equation that is a function of cross flow excitation. Values for the parameters are obtained from linear vibration analyses using FASTVIB and the extracted ATHOS properties that have been interpolated using VGUB for the tube as explained in Sections 3.1 and 4.2.Figure 7-9 shows schematically how workrates that are proportional to the fluidelastic excitation force expression would convert increasing fluidelastic excitation into workrates that can be used in Archard's equation to calculate tube and AVB wear volume. Figure 7-9 is simply a normalized representation that uses the parameters obtained from ATHOS and FASTVIB to scale the consequences of increasing the amplitude limited fluidelastic tube excitation ratio on the workrate after impacting begins up to the point where turbulence effects could modulate the tube/AVB interaction forces and displacements. Note that the sharply increasing trend with increasing flow would start at a higher or lower value depending upon the available clearance. This semi-empirical formulation was developed to envelope workrates using interactions characterizing the tube/AVB interactions at up to three ineffective supports. Figure 7-10 illustrates the typical logic diagram followed during design analyses. Figure 7-11 shows the basic characteristics of the measured workrate trends from U-bend shaker tests as described more fully in Reference 7-10. The methodology uses the workrate trend ACDE on Figure 7-11 as the dominant characteristic of the limiting wear from amplitude limited fluidelastic excitation. It therefore captures the effects of increasing flow rates and increasing gaps due to wear on the excitation and impact forces, but it does not explicitly calculate what is happening at the effective intersections on each end of a long span that would be unstable if the supports with large gaps were actually not present. For nominal tube/AVB gaps, the adjacent effective intersections may indeed have higher initial workrates that could lead to gaps and longer spans as shown on the left side of Figure 7-11. Thus, when performing normal design calculations, a range of potential support conditions must be evaluated separately. However, as wear progresses for any given support configuration, the workrate at the large gap becomes limiting after some point illustrated by D on Figure 7-11. This methodology therefore does not explicitly calculate details of modal interactions and detailed physics of the process for the entire tube, but it does follow the dominant trend for the mechanism that can lead to rapid wear in tubes with ineffective supports from large gaps that allow amplitude limited fluidelastic rattling within the clearances. The semi-empirical methodology takes workrates that include all nonlinear interactions present in the shaker tests, scales them to levels appropriate to the design being evaluated using results of thermal-hydraulic 1814-AA086-M0238, REV. 0 Page 257 of 415 Page 257 of 414 LTR-SGDA-12-36, Rev. 3 NP-Attachment February 15, 2013 and linear FIV analyses, and preserves the mode shape for the unstable frequency as wear progresses. For fundamental modes resulting from multiple consecutive gaps, wear progresses at the first support with tube/AVB interaction, depending upon the mode shape and the existing gaps, to interaction with successive supports as the tube amplitudes fill the gap as it grows from wear at both the tube and the support. If more ineffective locations with gaps are involved in a configuration being evaluated, the first three to interact depending upon the gaps and relative mode shapes can be evaluated. The total workrate that is available to wear the interacting sites (WR) is determined by scaling the characteristic workrate trend from shaker tests (Wr) using the excitation force (F,) apportioned to the various intersections to preserve the fundamental mode shape. Sharing among the different intersections depends upon whether one, two, or three intersections are wearing at the same time as illustrated on the right side of Figure 7-11. This process is sensitive to the mode shape and the gaps at the three intersections such that wear begins, pauses, or stops at any given location to preserve the dominant mode shape.One additional factor has a significant effect on the depth of wear at an intersection. If the tube is off-centered more than []b.e and relative workrates were confirmed during the shaker tests to be about twice as high for single-sided interaction on one side of a tube as for splitting the available energy to wear both sides of the tube at the same intersection. Current coding allows either choice for all sites, but all intersections in the configuration being evaluated must be either single- or double-sided. 7.2.2.3 Depth- Volume Relationship Depth-volume relationships are calculated based on tube and matching support geometric relationships (Reference 7-15). Figure 7-12 illustrates those applicable to 0.750-inch diameter tubing (Reference 7-16B through 7-16D) and 0.59-inch wide AVBs (Reference 7-16H) for various degrees of twist. Note that there is almost an order of magnitude difference in the depth of the combined tube and AVB wear that results from the volume removed from wear required to reach the dashed line that represents 40% through-wall (TW) for the 0 to 4 degree range illustrated on Figure 7-12. The factor is even higher for smaller wear depths, e.g., about 25 at 10%TW. The relative factor for the tube alone depends upon the size of the corner radius and the relative tube and AVB wear coefficients in addition to the unknown degree of actual twist.7.2.3 Operational History of "Plant B" Figure 7-13 shows the general arrangement of the tube bundle support structure, and Table 7-1 provides a summary comparison of design features for the Westinghouse steam generators that are most comparable to the SONGS steam generators evaluated in this document. The SONGS tube bundles have a maximum radius that is about 3 percent larger with a smaller pitch/diameter ratio, but Plant B has about 9 percent more, with smaller and more flexible tubes. The straight leg tube support structures are similar with broached trifoil 405 SS support plates having flat tube contact lands and similar clearances to constrain tube motion. The SONGS plates are thicker, but the range of contacting support land lengths can actually be smaller for the thicker plates due to the tolerances on shaping the holes. Both designs have a first span above the tubesheet that 1814-AA086-M0238, REV. 0 Page 258 of 415 Page 258 of 414 LTR-SGDA-12-36, Rev. 3 NP-Attachment February 15, 2013 is close to the nominal span length for the rest of the straight leg. This is not common for Westinghouse designs, but it tends to make the comparison more consistent. The U-bend tube support structures are similar in many respects, but markedly different in one that has several ramifications. Both have V-shaped AVBs made of 405 SS with similar tight tube-to-AVB clearances if welded at the nominal TSP pitch spacing. However, the SONGS bundles have a different AVB configuration that has two sets of AVBs on each side of the centerline and two sets centered in the middle (the conventional way). This design necessitates an extra orthogonal bridge structure to keep the off-centered sets in place. This extra weight and attachment to the longer AVBs at a 15-column spacing introduces new reactions during rotations that are necessary during fabrication as well as added weight on the bundle in the installed RSGs. The Plant B configuration has five sets of AVBs with the bends all centered in the bundle, but alternate columns have staggered insertion depths to reduce the pressure drop for flow through the U-bend. The U-bend region of the Plant B steam generators extends beyond the top TSP about six inches more than the SONGS RSGs in spite of the larger maximum radius of the SONGS tubing. This is a consequence of the smaller indexing between tubes in the same column for SONGS with comparable values for the same radial zones included in Table 7-1.This spacing and the tubesheet drilling tolerances at the bottom of the table are discussed further in Section 8.2.1.At the time of the last operating cycle that included an ISI inspection of the tubing, Plant B had operated for 6 cycles accumulating 8.1 effective full power years (EFPY). Figure 7-14 shows a comparison of the average number of tube/AVB wear indications for the two Plant B steam generators compared to the averages for SONGS Units 2 and 3 using data taken from Reference 7-17. Plant B is the only domestic steam generator with advanced U-bend support systems that were developed in the 1980s that has significant U-bend wear. However, it is small when compared with the SONGS experience, and Plant B is currently operating for multiple fuel cycles between inspections. a,e 7.2.4 Application to SONGS Steam Generators The semi-empirical wear calculation methodology developed for design as described in Section 7.2.2 and based on testing described in Section 7.2.1, was adapted for characterizing the SONGS tube wear experience. It includes projecting expectations for future operation at different power levels. The only change to the structure of the coding was to allow continued 1814-AA086-M0238, REV. 0 Page 259 of 415 Page 259 of 414 LTR-SGDA-12-36, Rev. 3 NP-Attachment February 15, 2013 operation from an existing conformal tube/AVB wear geometry developed during an earlier time period with a different excitation level for the new time period. Without this change, the highly nonlinear effects of beginning with a fresh tube and AVB depth-volume relationship as shown on Figure 7-12 would have prevented meaningful extrapolation of continued operation of the existing steam generators. The other significant change was in the approach to accomplish a different objective; i.e., continued operation versus evaluation of a new design.Normal design practice involves definition of ranges of potential parameter variables and tube/AVB geometry configurations and then demonstrating that the maximum tube wear consequences are less than a design margin. For the SONGS application, the resulting wear distribution after a cycle of operation is known, or can be inferred from existing ECT data, but for any given tube, there are many parameters that resulted in the wear distribution that are unknown. For example, neither the tube nor the AVB wear coefficient is known except over a range of possibilities for the two materials (Alloy 690 TT tubing and 405 SS AVBs). Whether the inferred tube wear distribution has less wear on the AVB, equal wear on the AVB, or more wear on the AVB markedly affects the combination of other parameters that would produce the same tube wear depth distribution. It can be assumed that the tube and AVB surfaces will not have significant run-in effects (see Figure 7-8) for the first cycle of operation, but even this assumption involves a potential error of several hundred percent. Most importantly, the tube/AVB geometry is expected to be different than the original design intent, but all that can be inferred with the available information is the minimum length of the dominant tube vibration span. In the largest sense, the answer (wear distribution) is known, but the inputs are unknown.Based on the testing and design basis methodology described in Sections 7.2.1 and 7.2.2, the dominant flow-induced vibration mechanism leading to the observed tube/AVB wear in the SONGS steam generators is considered to be amplitude limited fluidelastic vibration with characteristics as shown on Figures 7-5 and 7-9. Based on the findings of the SCE root cause evaluation (Reference 7-18), the possibility of in-plane (IP) fluidelastic instability leading to tube-to-tube wear must also be precluded in this overall evaluation. Even though Westinghouse tests have never produced an IP instability for any U-bend configuration, initial calculations in Reference 7-19 and in Section 4.3.2 used a very conservative threshold IP instability constant, I ]b.e, equal to the lower bound OP constant, [ ]b.e, to address that objective. In order to address concerns about IP instability potential that are not based on such a conservative assumption, recent tests by Pettigrew et al (Reference 7-20) were reviewed, and the test results shown in Figure 7-5 were extended and modified as shown on Figure 7-15.Previously, displacements and impact forces were shown on Figure 7-5 only out to about twice the OP tube excitation threshold. Figure 7-15 includes the same data that was recorded for the full range of tests out to more than four times the beginning of OP tube excitation. Significant modulation of both displacements and stresses occurs after []b,e In tests with all U-bend tubes loosely held during testing, Pettigrew et al (Reference 7-20) obtained IP instability at about twice the OP tube excitation threshold with [ ]b,e.Westinghouse tests on triangular pitch U-bends had been tested for flow rates only up to about 1.7 times the threshold that first caused tube excitation in the out-of-plane direction.when all tubes were non-supported or loosely constrained as in the cited Pettigrew (Reference 7-20)tests. This is illustrated schematically on Figure 7-15 in the upper left corner. Therefore, it is 1814-AA086-M0238, REV. 0 Page 260 of 415 Page 260 of 414 LTR-SGDA-12-36, Rev. 3 NP-Attachment February 15, 2013 theoretically possible that a bundle with many tubes subject to many loose support conditions in many adjacent tubes could develop IP instability for flow excitation that exceeds twice the OP threshold (consistent with the Pettigrew citation and not disproved by the Westinghouse tests with all tubes loosely constrained). For the Westinghouse tests with all tubes loose, the actual threshold was]b,e. If twice the minimum P 3 op obtained from Westinghouse tests were to be used for Pip (as in the Reference 7-20 Pettigrew citation), then the implied in-plane instability constant, P 3 ip, would be]b.e, a number much larger than the Reference 7-20 value. Since this would likely invite questions about using a best-estimate Westinghouse value compared to the reported Pettigrew value of 7.1, a more conservative value of [ ]be is used in subsequent evaluation of IP instability for this evaluation as explained in Section 8.1. This value is []b,e still considered a very conservative basis relative to Westinghouse data.Calculation of tube/AVB wear for SONGS Unit 2, before occurrence of any IP instability as precluded by explanations in Sections 7.3 and 8.1, follows the semi-empirical methodology adapted as described earlier in this section to continue from the end of Cycle 16 interface conditions. The process can be illustrated by an example tube for which ECT indicates wear at intersections with AVB4 and AVB5. The first step is to adjust the raw ECT indication to cover the range of bobbin coil uncertainty using the equation from Reference 7-21 Wi = 0.98ECTi + 2.89 where WV is the wear for eddy current indication ECT, at the tube intersection with AVB i. Then FASTVIB solutions for various cases of postulated missing AVBs as described in Section 4.2 are reviewed to obtain the case with the lowest number of missing AVBs that is unstable in the OP direction. Values for the reference density, po, modal effective velocity, Uen, tube excitation ratio, ER=UJIUcn, and modal effective length, Len, are then extracted for use in the fluidelastic force scaling equation defined in Section 7.2.2.2. These values, along with the corresponding modal frequency for the unstable mode, fn, are then used in the equation to scale the U-bend shaker test reference workrate, Wr, to obtain the workrate, WR, applicable to the SONGS flow excitation and support configuration being evaluated. The semi-empirical wear calculation procedure apportions the overall workrate available for the limiting vibration amplitude determined by Ce among the interacting AVBs depending upon the relative clearances at each intersection. Figure 7-16 illustrates this example with a postulated set of initial clearances that could have produced approximately equal wear at AVBs 4 and 5.Following the observed trends for displacements to fill the available clearance as shown on Figure 7-5, amplitude limited vibration occurs with the overall workrate applied at the first intersection to interact with the dominant unstable mode. Wear progresses at that AVB until the clearance becomes big enough from combined wear at the tube and the AVB to allow the dominant mode to begin impacting at the second AVB. As shown on Figure 7-16 the workrates and wear volumes at AVBs 4 and 5 will be about equal to half the total amount that is possible for the configuration being evaluated. If the observed ECT wear indications are not equal, the postulated initial gaps can be changed to make the site with the highest wear closer than the other and wear longer than the second site with all the energy on the first until impacting at the second begins. Wear volumes at each site 1814-AA086-M0238, REV. 0 Page 261 of 415 Page 261 of 414 LTR-SGDA-12-36, Rev. 3 NP-Attachment February 15, 2013 are converted into depths (for both tubes and AVBs) following the selected correlation for different degrees of twist from Figure 7-12. A manual, iterative "tuning" process then apportions the available energy to produce the relative wear depths observed from ECT. These depths, which have been tuned to match the observations, could have been obtained with many different combinations of wear coefficients, amounts of AVB cross-sectional twist, workrate trends (nominal or maximum to cover individual tests), single-or double-sided interaction choices, and various factors of uncertainty on FIV parameters. After achieving wear at both sites consistent with ECT after Cycle 16, the combination that produced the result can be held constant while evaluating various excitation levels for subsequent operation using FIV scaling parameters from FASTVIB calculations based on appropriate part load ATHOS analyses. This is the approach that has been used to obtain results described in the following Section 7.3.When choosing a set of initial conditions for observed wear at AVBs 4 and 5, it is also possible that a different FASTVIB case corresponding to a different span length with more than two AVBs having ineffective supports. Figure 7-17 shows one such possibility with similar clearances that could have existed at AVBs 3, 4, 5, and 6, but the wear during the first cycle did not progress deep enough to lead to interaction at AVBs 3 and 6. An entirely different set of geometric and material parameters could be used with this case to tune the computed wear at AVBs 4 and 5 to match the observed wear. Then, this new combination could also be used to project expectations for future operation at different levels of excitation. There is no appropriate way to know what the correct combination of geometric and material properties is for various tubes in the SONGS steam generators. Minor differences in the projections for wear in Cycle 2 have been obtained when making limited comparisons of different combinations, but in all cases the differences would not impact a decision about the appropriate choice of future operating levels as indicated by results in Section 7.3. There is insufficient data available to make statistical arguments about precision. However, this methodology follows dominant trends of the mechanism considered to be the source of the observed tube/AVB wear in the SONGS Unit 2 steam generators. It takes the available energy arising from constrained amplitude fluidelastic excitation for any support configuration, matches the starting levels of wear for subsequent operation, and allows rapid evaluation of the relative effects of many variables. As concluded in an earlier evaluation for three specific tasks (Reference 7-19), the geometric tube/AVB interaction conditions must be outside the range of expectations during the design phase, but all tubes above about Row 100 could have significant wear for multiple ineffective AVB intersections. The greatest uncertainty in these calculations is considered to be the appropriate geometric parameters to apply. No attempt has been made to guess the applicability of any of the variables to unknown conditions inside the SONGS steam generators in the following evaluation. Any range of selected variables to be imposed could be evaluated, but such an effort would have a different objective and would be beyond the scope of assessing consequences of operating at different power levels in the near-term future.7.3 Tube Wear Projection Results Data files for SONGS Unit 2 steam generators SG 2E088 and SG 2E089 that were available at the beginning of this study (those used for Reference 7-17) were reviewed and sorted to obtain groups of tubes having maximum wear in three different categories based on bobbin coil ECT results from the ISI inspection following the first cycle of operation. The three categories were: 1814-AA086-M0238, REV. 0 Page 262 of 415 Page 262 of 414 LTR-SGDA-12-36, Rev. 3 NP-Attachment February 15, 2013 1. Tubes with 0-9 percent wear, 2. Tubes with 10-19 percent wear, and 3. Tubes with wear equal to or greater than 20 percent.This ranking was performed for both Unit 2 steam generators separately for both active and plugged tubes. Then each category within each group was further subdivided by matching the number of consecutive AVB intersections having wear to the appropriate FASTVIB case 7 taken from Section 4.3.1 out-of-plane tube excitation ratio results. These subdivisions were then sorted to allow selection of the limiting case with maximum wear for each support condition. Wear calculations were performed for limiting tubes as described in Section 7.3.1 for remaining active tubes and in Section 7.3.2 for tubes which have already been plugged, but are still in the steam generators. 7.3.1 Active Tubes Table 7-2 shows the tubes with indicated wear greater than or equal to 20%TW and ECT bobbin coil data that was used to define limiting tubes. Maximum wear values for each tube are shown in bold font. Tubes that were selected as being limiting have row and column numbers shown in bold font. SG 2E089 was evaluated first. Only one additional tube from the SG 2E088 list had not already been enveloped in this preliminary evaluation. The referenced FASTVIB analysis case is listed in the next to last column with additional cases covering postulated cases to address consequences of continuing wear leading to longer effectively unsupported spans shown in the last column. Yellow shaded locations were used to define the postulated additional cases before starting analyses. Amber shading shows cases added during evaluation. Results of additional ECT evaluations done with RPC and +Pt coils that are described in Section 5.1 were not available in time to affect choices for limiting cases documented in this preliminary evaluation. Locations with low level wear based on these additional ECT evaluations as shown on Table 5-2 have been added to Table 7-2 to indicate which have already been covered and how best to update preliminary analyses for the final report. In most cases, consideration of the additional shallow wear scars simply moved the configuration to another location in the table that has already been enveloped. Active tube analyses documented in this preliminary report were done based on the assumption that Cycle 16 operation for 22 calendar months was at full power conditions covered by the ATHOS analyses in Section 3.2. ECT wear indications were then adjusted to cover uncertainty in the bobbin coil data, and wear calculation parameters were adjusted to match the target distribution as described in Section 7.2.4. Then calculations were made for subsequent operation at different power levels for an additional 18 months. Results of these extended calculations were also extracted after 6 months into the new cycle for use in assessing wear potential at an interim ISI inspection currently planned to occur within that time. After completion of these analyses, the duration of Cycle 16 was determined to be 627 effective full power days (EFPD) which corresponds to 20.6 effective full power months (EFPM), so these preliminary results were re-evaluated for the final report. The effect of this difference was shown to be small as indicated by final results added to the plots referenced in the following discussion. 7 Table 4-1 provides a detailed description of the 79 cases including definition of which AVBs are inactivated for the FASTVIB analysis of each case.1814-AA086-M0238, REV. 0 Page 263 of 415 Page 263 of 414 LTR-SGDA-12-36, Rev. 3 NP-Attachment February 15, 2013 Figure 7-18 shows the results of wear calculations for the first limiting SG 2E089 tube on Table 7-2 in a format that is repeated for several others. The first 22 months on the abscissa are for Cycle 16 operation. Both the raw ECT values and the higher target values intended to cover the bobbin coil uncertainty are shown on the plot above the 22 month time. The degree to which the wear calculations match the observed wear distribution can be judged from the plot(s).Times after 22 months are for continued operation at various power levels with results tabulated for both the planned interim ISI after 6 months and at the end of an additional 18 months operation. Only two AVBs were considered ineffective when defining the reference FASTVIB Case 17 and the tube excitation ratio was close to, but not above, 1.0. The semi-empirical methodology treating amplitude limited fluidelastic vibration excitation only applies for configurations with tube excitation, so a 1.3 factor was applied to include the potential range of uncertainty normally considered possible from mass density distribution approximations or damping uncertainty. This made the Cycle 16 loading produce tube excitation, but all other part load conditions did not. The same R131C91 tube was then evaluated for Case 38 which assumed that there could have been a gap at AVB7 also such that there were actually 4 ineffective AVBs with large gaps with results shown on Figure 7-19. These assumptions change details of wear calculations, but do not appreciably change projections beyond the target values because all the input parameters for both cases have been tuned to produce the same overall energy or workrate applied over 22 months to reach the same target before extending to further operating times at other load levels.Figure 7-20 shows similar preliminary calculations for a reference Case 28 applied to the R129C93 tube with alternative calculations for Case 46 shown on Figure 7-21. These results actually targeted the same wear distribution on Table 7-2, but the target was shifted as if the wear had occurred at AVBs 5 to 7 rather than 6 to 8, so a new reference Case 29 with an alternative Case 47 were evaluated for this final report at the same time that the adjustment for 20.6 months rather than 22 months in Cycle 16 is made.Figures 7-22 and 7-23 show reference and alternative calculations for R126C90. Figure 7-24 shows reference calculations for R121C91, one of the two tubes with 28%TW maximum ECT values among the remaining active tubes. Three different alternative Cases 45, 46, and 53 were evaluated for this tube with a comparison of results for all four cases for the 80% part load level of excitation shown on Figure 7-25. The maximum projected additional wall loss after 6 months of operation at a part load level of 80% does not exceed [ ]a.c.e and varies only from [ ]a,c,e. Operation at lower part load levels results in even less potential. Figure 7-26 shows the reference calculations for R1 19C89, the other tube with 28%TW maximum ECT indicated wear. Calculations for the alternative Case 54 are not plotted, but projections of potential additional wear are very similar to the reference when projected. Table 7-3 provides summary results for these active tubes and the limiting tube for SG 2E088 along with results of plugged tube calculations that are discussed in the next two Sections 7.3.2 and 7.3.3.7.3.2 Plugged Tubes Wear calculations for further operation of plugged tubes were done after learning that Cycle 16 covered 20.6 rather than 22 EFPM, so these analyses used an availability factor built into the coding to obtain a better match for the starting conditions for Cycle 2 operation (factor of 20.6/22 = 0.936). This procedure imposes the same factor on subsequent operation such that the maximum length of Cycle 2 that is already covered by preliminary calculations is 0.936 x 18 =1814-AA086-M0238, REV. 0 Page 264 of 415 Page 264 of 414 LTR-SGDA-12-36, Rev. 3 NP-Attachment February 15, 2013 16.8 EFPM. For this report, only calculations at 0.936 x 6 = 5.6 EFPM are consistently documented for all cases, but all intermediate calculations at half-month intervals can be extracted from the output. Limiting results were added to each of the tables on the plots for the location with highest wear. These analyses were also performed using active tube mass density distributions since the FASTVIB analyses described in Section 4.3.3 demonstrated this approach is conservative relative to plugged tubes with stabilizers considering the mass of the stabilizers with no additional damping contributions. Table 7-3 includes results for both plugged and active tubes. Projections for additional wear potential are similar except that a few of the plugged tubes could have slightly higher wear potential as might be expected for those that were preventatively plugged after the first cycle of operation. The highest projection of additional wall loss is still not more than 0.0012 inches (1.2 mils).7.3.3 Rl11-113/C81 Tube/AVB Wear Results Two of the preventively plugged tubes had free span indications that were considered to potentially represent the presence of conditions that lead to more severe tube-to-tube wear in Unit 3 steam generators. They have therefore been much more extensively evaluated in many respects such as in Sections 5.1, 5.2, 8.1, and 8.2 for this evaluation. Indeed, these two tubes are the only potential connection of Unit 2 experience with all the in-plane instability concerns arising from extensive tube-to-tube wear observed in Unit 3. Both Tubes Ri11C81 and Ri 13C81 were preventively plugged because of this concern even though the tube/AVB wear was not above 20%TW for either tube.Table 7-3 has four sets of calculations for the Ri11C81 tube that envelopes the adjacent R1 13C81 tube with regard to tube/AVB wear. The maximum raw ECT value was 18%TW with a targeted wear depth of 20.5%TW to cover the bobbin coil uncertainty. Continued operation at the same Cycle 16 loading would produce an increase only to [ ]a'c'eTW for the reference FASTVIB Case 38 and only to [ ]a'c'eTW using the first mode of alternative Case 67. The configuration evaluated for the reference case has 6 ineffective AVBs and the alternative has 8 ineffective AVBs. For tubes with 4 or more ineffective AVBs, more than one OP mode is unstable at the same time. The reference shaker tests that defined the baseline workrate trends for scaling using FIV calculated parameters did not include such severe loading: no multiple modes, and no background simulated turbulence that would be consistent with such high loading. There was no incentive to develop such bases for design, so how to combine multiple modal effects in wear calculations is not clear. If each mode is treated separately, the first mode is limiting. If both modes are evaluated as for the first and second modes in Case 67 for this tube, two sets of comparable numbers are obtained as shown, but the second mode produces more wear at AVBS 5, 6, and 7, while the first was at AVBs 6, 7, and 8. Two of the locations therefore have significant contributions from each mode. Although not shown in the table, if they are summed and then scaled to match the observed ECT and wear targets, the projected growth is less than shown for either case separately. However, if the effects are summed as would seem reasonable, the underlying parameters required to produce the observed wear would be smaller, i.e., much smaller gaps would produce the combined wear. This observation is not germane to projections, but could be important if using the methodology for other objectives. For purposes of this evaluation, the two tubes in SG 2E089 with free span indications have much less tube/AVB wear potential during subsequent operation than the limiting plugged tubes discussed in Section 7.3.2.1814-AA086-M0238, REV. 0 Page 265 of 415 Page 265 of 414 LTR-SGDA-12-36, Rev. 3 NP-Attachment February 15, 2013 7.3.4 Potential for Increased Probability of IP Modes after Wear It has been determined that all active tubes would be expected to be stable in the in-plane direction during the next cycle of operation. The analysis considers the current AVB support configuration and various potential future power levels of operation. It must be noted that even at operation at the 100% power level used in Cycle 16, the remaining active tubes are stable in the in-plane direction. In order for an in-plane mode to develop during the next cycle of operation it would be necessary for at least one of several changes to take place versus the conditions that existed during the first cycle of operation. These changes include: 1. SG operating conditions that would increase the likelihood of IP stability.

2. Changes in tube support condition due to tube wear.With respect to the effects of changes in operating condition, it has been shown in Section 4.0 that decreasing the power level has a large effect on decreasing both the out-of-plane and the in-plane stability ratio. Power reduction from 100% to 70% power effectively reduces the potential for in-plane instability by about half. Since power levels of this magnitude are being considered for the next cycle, the potential for a reduction in IP stability ratio is a more likely outcome. It should be repeated that the eddy current analysis of tube wear in Unit 2 has not found any indications of wear that would indicate in-plane instability is occurring in these SGs. Therefore, reducing the power level would further reduce the potential for an event that has not yet been observed in prior operation.

With respect to tube support conditions, the effects of additional wear on the tubes that could occur during the next cycle were also considered. It should be noted that any additional wear at existing wear sites would not affect the boundary conditions for that tube since the AVB at that particular location would already be ineffective. Increased gaps at these locations would increase the rate of wear, but the tube was already unstable in the out-of-plane direction; therefore. that would not change the boundary conditions of that tube. As indicated in the prior sections, any tube wear that has been projected to occur over the next cycle of operation has been calculated to be very small. Calculations indicate that the amount of tube wear that could occur would range from [ ]a,c,e for the most limiting tubes at the most limiting location. The most limiting location on any give tube is the location with the largest wear depth at the end of the last cycle of operation. Should wear begin to occur at a new location along the tube, then a change in the tube boundary condition could potentially occur with that tube. However, the rate of wear at that new location (with no current wear) would be much less than what has been calculated at the limiting location. This is a result of how the tubes wear while unstable in that the available energy tends to focus at the location with the largest tube gap. Should any wear develop at that new location, the amount of wear would be much less than the maximum amount of wear calculated for the next cycle of operation with expected levels of wear [ ]a,c,e. Gap changes of this magnitude are considered to be so small as to be negligible as it relates to support of the tube.In conclusion, the potential for in-plane stability to develop over the next cycle of operation is not considered credible for several reasons. First, the power level reduction (to 70%) power effectively reduces the IP stability ratio by about half and that reduces the potential for any IP instability to develop versus the response during the prior cycle of operation. Also, it has been noted that the potential for any wear to begin to develop at currently effective AVBs is considered 1814-AA086-M0238, REV. 0 Page 266 of 415 Page 266 of 414 LTR-SGDA-12-36, Rev. 3 NP-Attachment February 15, 2013 to be negligible and will not affect the boundary conditions at those sites. Therefore additional, modes will not become active and result in in-plane instability. 7.4 Potential for Wear on AVB Surfaces 7.4.1 Tube FIV Induced Wear The methodology used to evaluate maximum tube/AVB wear potential simultaneously calculates the conformal wear in both the tube and AVB. Results that have been discussed to this point have used input wear coefficients that maximize tube wear and minimize AVB wear. The reverse could be done, or any other combination of relative wear could be prescribed. In typical design calculations based on experience with Westinghouse AVB material and processing history, equal tube and AVB wear coefficients are typically used with a check for variability effects in either direction (up to AVBs having twice the tube wear coefficient). It is not likely that the AVBs would wear significantly more than the tubing, and they are significantly thicker than the tubing wall thickness, so this is not a major concern for near-term operation. 7.4.2 AVB FIV Induced Wear Potential On the other hand, there is a potential that AVBs can vibrate and cause tube wear if long, unsupported spans are created inside the bundle. The SCE root cause evaluation (Reference 7-18) concluded there was no indication of AVBs vibrating and causing tube wear.However, there are several instances of AVBs having 15 or more consecutive tubes in a column with wear indications. As a result, an additional evaluation including review of all available ECT data including any RPC evidence was performed. Table 7-4 provides a summary of the results from that additional review for Column 81 in SG 2E089. There are 20 consecutive tubes in this same column having wear scars along AVB 7. AVBs 5, 6, 8, and 9 have similar sequences of multiple scars on every tube in this column. Reference 7-23 describes two types of galloping instability that are possible in bluff structures that are exposed to cross-flow excitation that is mostly parallel to the width of the cross section (such as these AVBs with long spans). The width/thickness aspect ratio of the SONGS AVBs are shown to be inherently stable against the plunge type of galloping instability using quasi-steady evaluation of how the lift and drag forces vary with the angle of attack of the flow. Evaluation of potential torsional instability using the same theory is more complex, but review of ECT results in Table 7-4 demonstrates that opposite edges of the AVBs are not impacting the tubes because the consecutive wear scars are predominantly flat. Torsional instability would produce multiple hourglass wear scar profiles.Therefore, it is concluded that the AVBs are not likely responding in any kind of aerodynamically unstable mode, but they are likely vibrating as a response to flow turbulence and reactions to impacts from other tubes in the same column due to gap-limited fluidelastic vibration in the regions having many consecutive intersections with significant tube wear. AVB displacements due to longer spans in turbulent flow, combined with reactions from simultaneous impacting from up to 19 other tubes provides additional relative tube/AVB sliding motions during impacting due to gap-limited fluidelastic excitation that exceeds levels that were included in the baseline shaker tests. However, the process of matching the observed wear as a starting point for projections would account for this potential by choosing a set of parameters that produced the workrates necessary to produce the observed wear.1814-AA086-M0238, REV. 0 Page 267 of 415 Page 267 of 414 LTR-SGDA-12-36, Rev. 3 NP-Attachment February 15, 2013 7.5 Potential for Additional Tube-to-Tube Wear at Rl11/113C81 Eddy current tests indicate that 14% through-wall tube wear has been found 8 on both R111C81 and R113C81 in SG 2E089 with the wear located between AVB9 and AVB10. Subsequent UT measurements indicate that the tube wear was closer to 7% through-wall. Although there is no evidence of in-plane displacements (e.g., no tube wear at an AVB was identified that extends outside of the AVB width), a concern has been expressed that this tube wear could have been caused by tube-to-tube contact from in-plane displacements associated with active in-plane fluidelastic instability. Further, there is a concern that additional wear at this location could result in significant degradation of the tubes during future operation. The following wear indications were reported based on the bobbin data. It should be noted that shallow AVB wear indications were also reported at B08, B09 and B10 on R113C81 and at B09 on Rl11C81 based on a detailed review by Westinghouse of the +Pt data. However, the evaluations described herein are based on the bobbin data.Reported Wear Indications Based on Bobbin Data SG Row Col B12 811 BIO FSc B09 B08 807 806 805 804 B03 B02 B01 89 113 81 14 5 5 16 89 111 81 7 14 18 13 8 14 The tube most likely to become excited by the secondary side flow would be RI 11C81 since this is the tube with the most sequential ineffective AVB supports. Wear calls have been reported at AVB 5 through 8, which could imply up to four sequential ineffective AVBs. The FASTVIB computer code was used to evaluate this case (Case 38) where four AVBs are sequentially missing starting at AVB5. An additional case has also been considered to address the possibility that significant wear is not occurring at AVB9, but that the AVB is still an ineffective support.Should this be the case, which is consistent with the RPC data, it would be possible that up to six sequential AVBs would be ineffective for this tube. This would include AVB5 through AVB10.This case (Case 55) was also considered in the FASTVIB analysis. Calculations for a third and fourth case, which considered seven and eight sequential AVBs ineffective (Case 62, 61 and 67)were also performed. The following is a summary of the in-plane excitation ratios calculated for these cases: 8 See Section 5.2 regarding the eddy current resolution of these indications. 1814-AA086-M0238, REV. 0 Page 268 of 415 Page 268 of 414 LTR-SGDA-12-36, Rev. 3 NP-Attachment February 15, 2013 Summary of In-Plane Excitation Ratios 100% Power 80% Power 70% Power Case Number of Stability Ratio Stability Ratio Stability Ratio (With Stabilizer) (With Stabilizer) a,c,e Case 38 4 1-- -Case 55 6 Case 62 7 Case 61 7 Case 67 8 As can be observed, these tubes are stable in-plane for the 100% power case until it is assumed that seven AVBs are missing. All cases are stable at reduced power levels. The cases for 70%and 80% power were calculated assuming a cable stabilizer was installed in the tubes.Calculations performed for in-plane instability used Beta values that are consistent with the out-of-plane direction and are considered to be conservative values for use when looking at the in-plane direction. However, if best estimate Betas would be used, the calculated stability ratio would be less than 1.0 even for the case of 7 or 8 missing AVBs. If a Beta of []a.c:e is used, the largest IP stability ratios for 8 missing AVBs would be approximately ]a,c,e. Therefore, missing 2 additional AVBs beyond the 6 indicated by bobbin/RPC would indicate the tube with the tube-to-tube wear was stable in-plane during the last cycle. In addition, any motion that would result in wear at the tube-to-tube contact site would also likely be evident on at least the two nearest AVBs (AVB9 and AVB10). No indications of wear were found outside the location immediately below these AVBs (or other AVBs on these tubes), which indicates that motion in the in-plane direction at the tube-to-tube wear site also would not be occurring. All the other characteristics of indications for these two tubes are more consistent with proximity issues than with IP motion issues.Note that the additional mass of the stabilizer was conservatively included in the calculation, but any additional damping was not included in the calculation based on the damping test results from MHI (Reference 7-22).The analytical calculation indicating stability in the in-plane direction is supported by eddy current data at the AVB/tube contact locations. Since any in-plane motion would also produce wear extending outside the AVB and no such indications were found, it strongly suggests that vibration of the tube in the in-plane direction is not occurring for this tube. It should be noted that wear is occurring in the tubes directly under the AVB location, which is not unexpected for the AVB support configurations considered possible from the ECT results. Wear outside of AVBs was not characterized in the results files for Unit 2. A comparison of the RPC and bobbin wear reports for Unit 3 indicates there are many non-reported bobbin indications at AVBs within tube-to-tube wear regions. The tube-to-tube wear (TTW) likely is overpowering the bobbin signal. A comparison of the Unit 2 and Unit 3 combined bobbin/RPC results suggests there is a detection capability difference between the two units, most likely from the TTW overpowering bobbin AVB wear signals. Since there is not significant TTW in Unit 2, the bobbin detection is not affected.1814-AA086-M0238, REV. 0 Page 269 of 415 Page 269 of 414 LTR-SGDA-12-36, Rev. 3 NP-Attachment February 15, 2013 In conclusion, the Westinghouse review of the Unit 2 wear signals confirmed that no wear extends from the AVBs.The following is a summary of the out-of-plane tube excitation ratios for the cases of interest: Summary of Out-of-Plane Tube Excitation Ratios 100% Power 80% Power 70% Power Case Number of Tube Excitation Tube Excitation Tube Excitation Missing AVBs Ratio Ratio Ratio (With Stabilizer) (With Stabilizer) Case 38 4 Case 55 6 Case 67 8 From the above, it can be concluded that the tube was most likely excited in the out-of-plane direction and that out-of-plane tube excitation produced tube wear at the indicated AVBs. Should the actual support condition at Ri 13C81 include six or more ineffective AVBs, then it is very likely that additional wear at the indicated AVB locations will occur even at reduced power levels as a result of out-of-plane tube excitation. There is no analytical or eddy current evidence to suggest that in-plane instability or displacements are occurring at these tubes. The two tubes with TTW in Unit 2 are located in the same region as the large number of tubes with TTW in Unit 3. This is the only commonality with the Unit 3 TTW findings that is currently known. Westinghouse is not aware of any assessment that concludes the Unit 2 TTW is a result of in-plane instability. However, if another assessment can be provided that shows IP instability for the Unit 2 TTW, then Westinghouse could review and comment once the data is provided. However, the question remains regarding the possibility of future wear between these tubes. The following provides a basis to conclude that significant TTW wear will not occur at this location during the next operating cycle.Eddy current results described in Section 5.2 indicate that tubes R111/C81 and R113/C81 are closer than what is specified in Design Drawing L5-04FU053. When this occurs, it is generally termed a proximity condition. The nominal gap between the Row 111 and Row 113 tubes in Column 81 increases from 0.25 inches in the straight leg to 0.344 inches at the apex of the U-bend. However, the Pre-service Inspection (PSI) eddy current results show a "proximity" call between these tubes, and are discussed in more detail in Section 5.2. Based on the eddy current results from the PSI, the proximity call indicates the outer diameters (OD) of the two tubes are very close to each other.Figure 7-27 contains a view of how tubes R1 110C81 and Ri 13C81 could have developed a close proximity condition between AVB 9 and 10. U-bend tubes are thought of as components that are essentially perfect half circles with straight legs attached. However, in practice there is always a degree of flexibility and non-uniformity, especially in tubes with large radius U-bends. Tube R111C81 has a bend radius of 60.77 inches, producing a tube bend diameter that is over 10 feet. Tubes of this size are very flexible and it is possible that Tubes Ri 110C81 and Ri 13C81 could have contacted as shown in Figure 7-27. As can be observed in the figure, the length of contact between the tubes would be expected to be fairly limited. This small proximity length and 1814-AA086-M0238, REV. 0 Page 270 of 415 Page 270 of 414 LTR-SGDA-12-36, Rev. 3 NP-Attachment February 15, 2013 also the recorded wear length are supported by ECT data and are consistent with how the tubes are configured in Figure 7-27. Small deviations in the assembly of the SG could further exacerbate this condition. Upper bundle tube proximity potential is discussed in more detail in Section 8.2.As indicated above, calculations show that tubes with out-of-plane tube excitation have little to no in-plane motion during operation. Calculations also show that the tubes are not moving in-plane as a result of in-plane instability. In addition, PSI ECT data indicates the tubes were very close to each other and as a result were likely either in contact during startup of the plant, close enough to come into contact when pressurized and heated, or came into contact through in-plane turbulence. Wear could have occurred between the tubes during operation as a result of the out-of-plane motion associated with out-of-plane tube excitation. Once Ri11/C81 and R113/C81 wear to the point where there is an in-plane gap between them, tube wear would cease. This phenomenon is called 'wear arrest', since the wear stops occurring once the initial interference is worn away. Additional work regarding how the tube wear could have developed is contained in Appendix B of this report. This additional work describes a scenario where the tubes were initially very close to each other and then 'skipped' to a new location where tube-to-tube contact is no longer possible.Also, based on the wear calculations in Section 7.4, the wear at the various AVB locations will not progress through the tube wall. Therefore, Westinghouse concludes that there will not be significant additional tube-to-tube wear on R111/C81 and R113/C81 during operation of SONGS Unit 2.7.6 Summary Westinghouse testing and consistent design methodology supports the conclusion that tube/AVB wear that could approach plugging margins within one operational cycle is caused by amplitude limited fluidelastic tube excitation within larger than expected clearances. Potential manufacturing issues that could lead to such unexpected tube/AVB fit-up are discussed in Section 8.2. The amplitude limited fluidelastic mechanism has been demonstrated to exist and produce workrates that are many times greater than those from flow turbulence in single-phase air tests, and these characteristics have been used for over two decades to produce bounding wear potential in the design phase. The only domestic steam generators with any tube/AVB wear since adopting this approach is the Plant B experience that was described in Section 7.2.3, and those results were largely attributed to unexpected large scale interactions within the tube bundle associated with fabrication methods and the relatively large amount of stagger in the outermost AVBs for that design.Pettigrew et al (Reference 7-20) also reported the presence of the amplitude limited fluidelastic mechanism for two-phase air-water tests for low void fractions before turbulence effects are large enough to disrupt the consistency of the fluidelastic excitation. Air-water tests are somewhat different than a steam environment, and considering the extremely high void fractions present in the region of most severe wear in the SONGS steam generators (see Figures 7-16 and 7-17 for example), it is considered to be the most likely explanation for tube/AVB wear in the SONGS steam generators as explained and supported by calculations in this section. Application of the semi-empirical methodology to obtain observed wear patterns in the SONGS Unit 2 steam generators demonstrates that subsequent operation at any part load levels not exceeding 80 percent will not lead to unacceptable tube wear during the next operating cycle before a planned interim ISI.1814-AA086-M0238, REV. 0 Page 271 of 415 Page 271 of 414 LTR-SGDA-12-36, Rev. 3 NP-Attachment February 15, 2013 7.7 References 7-1. P. J. Langford, "Design, Assembly, and Inspection of Advanced U-Bend/Anti-Vibration Bar Configurations for PWR Steam Generators," Transactions of the ASME Journal of Pressure Vessel Technology, Vol. 111, Nov. 1989, pp. 371-377.7-2. S. S. Chen, J. A. Jendrzejczyk, and M. W. Wambsganns, "Dynamics of Tubes in Fluid With Tube-Baffle Interaction," Symposium on Flow-Induced Vibrations, Vol. 2, presented at the ASME WAM, Dec. 1984, pp. 285-304.7-3. Y. Cai, S. S. Chen, and S. Chandra, "A Theory for Fluidelastic Instability of Tube-Support-Plate-Inactive Modes," Transactions of the ASME Journal of Pressure Vessel Technology, Vol. 114, May 1992, pp. 139-148.7-4. R. Bouecke, Kraftwerk Union A. G., "Experience with KWU Steam Generators KWU Steam Generator U-Bend Support Concept," in "Part C Additional Information," Topical Report on Replacement Steam Generators, KWU-UPC-8601-A, transmitted to K. Wichman of USNRC March 23,1988, pp. 70-83.7-5. A.J. Fricker, "Numerical Analysis of the Fluidelastic Vibration of a Steam Generator Tube With Loose Supports," 1988 International Symposium on Flow-Induced Vibration and Noise, Vol. 5 Flow-Induced Vibration in Heat-Transfer Equipment, Nov. 27 -Dec. 2, 1988, pp. 105-120.7-6. H. J. Connors, "Fluidelastic Vibration of Heat Exchanger Tube Arrays," ASME Transactions Journal of Mechanical Design, Vol. 100, The American Society of Mechanical Engineers, New York, New York, April 1978, pp. 347-353.7-7. H. J. Connors, "Flow-Induced Vibration and Wear of Steam Generator Tubes," Nuclear Technology Vol. 55, Nov. 1981, pp. 311-331.7-8. H. J. Connors and F. A. Kramer, "U-bend Shaker Test Investigation of Tube/AVB Wear Potential," Fifth International Conference on Flow-Induced Vibrations, Paper C416/014, IMechE, Brighton, U. K., May, 1991, pp. 57-67.7-9. E. R. France and H. J. Connors, "Simulation of Flow Induced Vibration Characteristics of a Steam Generator U-tube," Fifth International Conference on Flow-Induced Vibrations, Paper C416/020, IMechE, Brighton, U. K., May, 1991, pp. 33-43.7-10. P. J. Langford and H. J. Connors, "Calculation of Tube/AVB Wear from U-Bend Shaker Test Data," Fifth International Conference on Flow-Induced Vibrations, Paper C416/040, IMechE, Brighton, U. K., May, 1991, pp. 45-55.7-11. P. J. Hofmann and T. Schettler, "PWR Steam Generator Tube Fretting and Fatigue Wear," EPRI Report NP 6341 prepared by Siemens Kraftwerk Union AG, April, 1989.7-12. Steam Generator Management Program: PWR Steam Generator Tube Wear -Alloy 690/Supports, EPRI, Palo Alto, CA: 2008. 1014991.7-13. E. Rabinowicz, "Wear Coefficients -Metals," Wear Control Handbook, Ed. M. B. Peterson and W. 0. Winer, The American Society of Mechanical Engineers, New York, 1980, pp. 475-506.1814-AA086-M0238, REV. 0 Page 272 of 415 Page 272 of 414 LTR-SGDA-12-36, Rev. 3 NP-Attachment February 15, 2013 7-14. E. Rabinowicz, "Adhesive Wear," Friction and Wear of Materials, Wiley, New York, 1965, pp. 125-166.7-15. "Geometry and Mensuration, Ungula of Right Circular Cylinder," Standard Handbook for Mechanical Engineers, McGraw-Hill, New York, 6th Ed., p. 2-19.7-16. San Onofre Nuclear Generating Station Units 2 and 3 Replacement Steam Generators MHI Design Drawings: A. L5-04FU001, Rev. 6, "Component and Outline Drawing 1/3".B. L5-04FU051, Rev. 1, "Tube Bundle 1/3".C. L5-04FU052, Rev. 1, "Tube Bundle 2/3".D. L5-04FU053, Rev. 3, "Tube Bundle 3/3".E. L5-04FU107, Rev. 3, "Tube Support Plate Assembly 2/3".F. L5-04FU108, Rev. 3, "Tube Support Plate Assembly 3/3".G. L5-04FU 112, Rev. 1, "Anti-Vibration Bar Assembly 2/9".H. L5-04FU118, Rev. 3, "Anti-Vibration Bar Assembly 8/9".7-17. Westinghouse Report No. SG-SGMP-12-6, "San Onofre SG Tube Wear Degradation Comparison," May 2012.7-18. "Root Cause Evaluation: Unit 3 Steam Generator Tube Leak and Tube-to-Tube Wear Condition Report: 201836127," Revision 0, May 7, 2012, San Onofre Nuclear Generating Station (SONGS).7-19. Westinghouse Letter LTR-SGDA-12-24, "San Onofre Units 2 and 3 MHI RSG Flow-Induced Vibration Evaluation Customer Correspondence," May 21, 2012.7-20. V.P. Janzen, E.G. Hagberg, M.J. Pettigrew, and C.E. Taylor, "Fluidelastic Instability and Work-Rate Measurements of Steam-Generator U-Tubes in Air-Water Cross-Flow," Transactions of the ASME Journal of Pressure Vessel Technology, Vol. 127, February 2005, pp. 84-91.7-21. "Examination Technique Specification Sheet 96004.1," Revision 13, EPRI, April 2010.7-22. "San Onofre Nuclear Generating Station, Units 2 & 3 Replacement Steam Generators Damping Test Results for Stabilizer," Mitsubishi Heavy Industries, L4-04GA581, Revision 1, June 4, 2012.7-23. R. D. Blevins, "Chapter 4 Galloping and Flutter," "Flow-Induced Vibration," Krieger Publishing Company, Malabar, FL, 2 nd Ed., p. 104-113.1814-AA086-M0238, REV. 0 Page 273 of 415 Page 273 of 414 LTR-SGDA-12-36, Rev. 3 NP-Attachment February 15, 2013 Table 7-1 Feature Comparison of SONGS and Plant B Steam Generators Feature SONGS Plant B Number of Tubes 9727 10637 Tube Material Alloy 690 TT Alloy 690 TT Tube Dimensions (in) 0.750 OD x 0.043 t 0.688 OD x 0.040 t Triangular Pitch (in) 1.00 0.95 Pitch/Diameter 1.33 1.38 Largest Radius, Rmrax (in) 76.27 74.025 Number of TSPs 7 8 TSP Material 405 SS 405 SS Trifoil Broach Radius (in) 0.381-0.384 0.349-0.353 Radial Tube Clearance (in) 0.006-0.009 0.005-0.009 TSP Thickness (in) 1.38 (0.2-1.07 land height) 1.125 (0.94-1.08 land height)TSP CL Spacing (in) 42.82 first, 43.66 typical 34.67 first, 35.23 typical Number of AVB Sets 6 (2 Each Side, 2 Centered) 5 Centered + Staggered AVB Material 405 SS 405 SS AVB Dimensions (in) 0.590 W x 0.114 t 0.480 W x 0.133 t Nominal* Diametrical Gaps 0.0020 0.0017 (in)Average U-bend Span @ Rmax 13 @ -19.4 in 11 @ -23.9 in U-bend Overhang (in) 83 89 IP Tube Spacing** at Apex (in) 0.298, 0.344, 0.400 0.442, 0.502, 0.562 Alloy 690 Retainer Bars (in) 24 Round (12 ea @ 0.19, 0.41) 20 @ 0.63 W x 0.125 t Alloy 690 Retaining Rings (in) 0.38 Round 0.38 Square Alloy 690 End Caps (in) 0.38 t x 1.00 W x 1.97 L 0.451 t x 0.860 W x 2.00 L End Cap to Ring Welds (in) 0.12 leg 0.19 leg x 0.38-0.63 long Orthogonal Structure 13 Segmented Bridges None SG Power Level (MWt) 1729 1522 Maximum Steam Quality 0.89 0.75 Maximum Void Fraction 0.9955 0.9851 Operating Time @ Last ISI Cycle 16 (1.7 EFPY) Cycle 6 (8.1 EFPY)Tubesheet Thickness (in) 27.95 31.56 Hole Tolerances (in) 0.756-0.762 (0.769 for 1%) 0.696-0.701 Diametrical Expansion (in) 0.006-0.012 (0.019 for 1%) 0.008-0.013

• Assuming AVBs are welding at the nominal TSP hole pitch spacing.**For larger tubes in radial zones 55, 56-67, and 68-maximum.

1814-AA086-M0238, REV. 0 Page 274 of 415 Page 274 of 414 LTR-SGDA-12-36, Rev. 3 NP-Attachment February 15, 2013 Table 7-2 Limiting Active Tubes for Wear Greater Than 20% Through-wall SG 2-88 Active Tubes with > 20% Wear Row Col 7H BI B2 B3 B4 B5 B6 B7 B8 B9 B10 311 B12 7C #AVBs Case Comment 112 96 17 20 13 17 2 17 118 86 23 12 13 14 6 2 17 133 87 9 19 20 13 6 2 18 88 96 17 21 2 19 116 96 23 18 15 7 2 20 117 83 14 17 10 24 7 2 20 98 90 8 8 11 20 7 3 27 105 81 22 12 8 3 28 120 90 23 16 7 3 28 125 91 9 22 10 3 28 125 95 9 10 18 22 10 3 28 134 84 10 11 21 15 8 3 28 118 82 8 21 10 3 29 132 96 18 23 11 3 29 97 87 11 2S 23 16 4 38 Case46 97 91 14 12 22 19 4 38 108 88 12 9 22 12 4 38 108 94 22 15 10 13 4 38 131 91 8 22 17 8 4 38 113 95 10 14 12 9 21 4 39 93 89 14 12 11 20 11 5 38 96 92 14 21 16 18 9 5 38 97 93 10 11 23 19 11 5 38 101 95 21 11 11 10 12 5 38 116 82 14 8 17 20 14 5 38 124 96 13 22 14 14 9 5 38 128 92 8 22 20 11 12 14 5 45 127 93 6 6 23 10 8 5 48 1 1 SG 2-89 Active Tubes with > 20% Wear Row Col 7H B1 B2 B3 84 B5 B6 B7 B8 B9 B10 B11 B12 7C #AVBs Case Comment 131 91 8 21 6 x 2 17 Case 38 113 71 14 21 2 18 Cases 28,29, 38,46 121 95 20 14 5 2 18 Case 39,47 119 95 7 20 12 3 28 129 93 x x 15 22 6 3 29 Case47 91 73 10 8 22 3 29 105 77 7 21 15 3 29 106 78 6 26 23 13 3 29 119 77 6 14 21 3 29 121 91 x x 12 15 28 23 4 37 Cases45,46,53 124 86 5 9 21 12 4 37 123 83 13 12 23 12 10 4 38 124 88 10 23 14 6 4 38 125 89 8 22 18 6 4 38 126 90 5 7 12 21 21 x 14 x 5 45 Case 60 119 89 x x 5 6 17 28 5 x 5 46 Case54 88 78 9 9 7 22 10 5 47 93 77 5 7 16 20 22 5 47 100 76 13 21 11 14 12 5 47 109 75 6 7 8 21 13 5 47 112 96 21 9 5 14 17 5 47 1 x Low level wearfound in +Pt data from WEC review 1814-AA086-M0238, REV. 0 Page 275 of 415 00 0 co (0 CD r%)-4 0)0 C-f Page 275 of 414 LTR-SGDA-12-36, Rev. 3 NP-Attachment February 15, 2013 Table 7-3 Summary of Limiting TubelAVB Wear Calculations with Additional Wall Loss Projections at 80% Part Load Max Tube/AVB Wear Baseline Calculations @ +6 Months Additional Missing AVB Check -Calculations @ + 6 Months Tube SG Tube ECl ICTUncert FAS'.flB NoSeq MaxWearDepth@PowerLevel MitsWal FAS'IIB NoSeq WearDepth PowerLevel Milswal R/C No Status Value Value Case AV~s Cyce I W1% 70% 160% 10. @ 80% Case AV~ls Cvde 1 M0% 70% 160% loss @t Sol.................... ...... ... ........... ................ 1 ............... ............................... a ac R97C07 88 Active 25 27.4 38 4 46 5 11..19289 -. 9. ...A tv.. ...... .28 3..... 0... -10 3 ... 46...... ....... 5 5....... .6............. ..R121C91 89 Active 28 30.3 37 4 45 5 x 30.3 x X 46 5 x 30.3 x x 53 6 R131C91 89 Active 21 23.5 17 2 38 4 R129C93 89 Active 22 24.5 29 3 47 5 R126C90 89 Active 21 23.5 45 5 60 7 R112CBS 88 Stab 35 37.2 47 5 x Kt R13C W 88 tab 35 37.2 38 43C; 45 5............ ..... L. " .. ......... .3........ .... .7.... ........... .3..8............ ..... ....... 4. .. ......... ........... R114C90 88 Stab 22 24.5 48 5 6..R111C91 88 Stab 26 28.4 38 4 x X R116C86 88 Stab 29 31.3 46 5 61 7 R117C93 88 Stab 27 29.4 47 5 -X t R115C85 88 Stab 27 29.4 49 5 61 5 R:IIA4 B6 .... .-Stab ..... ....21 _235 ....... .... .53 .6 _ _6. .. 8 R112CB8 88 Stab 35 37.2 55 6 X X R128C94 88 Stab 32 34.3 60 7 t x R120C92 88 Stab 32 34.3 66 8 x x R121IC3 89 Stab 24 26.4 16 2 46 4 R 117C89 89 Stab 26 28.4 46 5 X .X R108C90 89 Stab 27 29.4 53 6 X S R117C81 89 Stab 29 31.3 55 6 x.R .. 89 Sa.b 26 2&4 56 6 67 8I 8 5 S a .... I6 ; ....... , ..... .. .. .. ......... ...... .4 ............ .. ......o R114W88-89 ..Stab 24 26.4. 56_ 6 67 8.... ......... .... ............ R1172C85 89 Stab 24 26.4 62 7 74 10 R122C821 89 1Sta b 27 29.4 66 8 X St R112C84 89 Stab 27 29.4 67 8 1 x R113C81 89 Stab 16 18.6 28 3 S S R111C81 89 Sta b 18 2015 38 4 55 6 X 16,6 x X 8 Notes: No Seq AVBs -number of sequential AV assumed ineffective due to wear scars for base me plus additional check cases.Multiple cases were considered that are not shown. Many have multiple unstable modes, but only one is shown for Ri 11C81. -0 0-A)o0 m 0 Page 276 of 414 LTR-SGDA-12-36, Rev. 3 NP-Attachment February 15, 2013 Table 7-4 Summary Results from Detailed Review of ECT Files for the Region Having Multiple Consecutive Wear Scars on AVBs B5, B6, B7, B8, and B9 on Column 81 for SG 2 E89 SG2-89 B1 B2 63 B4 B5 B6 B7 88 B9 B1O Bll B12 C R 81 129 81 127 81 125 81 123 81 121 81 119 81 117 81 115 81 113 81 111 81 109 81 107 81 105 81 103 81 101 81 99 81 97 81 95 81 93 81 91 81 89 81 87 81 85 81 83 81 81 7 8 1 10 1 Xs XS X X Ix x xS xS I 7S 5S.xS xS 14 8 11 5 25 5 ,,x1 __ xl_ I EiII 14 10 X X 17D us xs 82 I 298SO _16~~I 12 19 29 10 8S los 9S 7S I xS I I 4 4 SD 55 xS xS xS I I I I 8S 13S 18s xS 7S Twist i I112S 13S 11D 8D 7S I ___ 44I I I 7S SD 14D 15D 6S 6 6s~sr t 9 14 12 8 _ 7 _ 9 _ 1 1 6 8 6 11 7 6 6 12 12 10 8 11 17 I 1x [ 1 5 1 12 1 x S 6 1 15 6 6 5 5 8 6 9 Notes: 1) x = Location of low level wear from +Pt data, 2) s = Single-sided tube wear, 3) D = Double-sided tube wear,4) Yellow Highlight = One of several consecutive wear scar locations, 5) Twist = Tapered wear scar, 6) Vertical Hash = Location with discrete shift in wear scar location, 7) Double-lined Boxes = Locations with tube-to-tube proximity during PSI, 8) Rose Highlight = Region of maximum AVB symmetry variance. Page 277 of 414 LTR-SGDA-12-36, Rev. 3 NP-Attachment February 15, 2013 000000O*eeooooo S00000060 0000000 T000e0st Test 1 o 00o 0 0 ©Test 3 00000 00000 00000 00000 Test 2 p 00 0 Test 4*S Rigid Tube 0 Flexible Tube Flexible Instrumented Tube Figure 7-1 Schematic Illustrations of Triangular Pitch Tube Array Patterns Tested in the STC Water Tunnel with Pitch/Diameter Equal to 1.42 1814-AA086-M0238, REV. 0 Page 278 of 415 O0 0 m 0 o-Page 278 of 414 LTR-SGDA-12-36, Rev. 3 NP-Attachment February 15, 2013 Figure 7-2 Comparison of Analytical Models of FIV Mechanisms with RMS Tube Displacements for Sample Vibration Test Data a,b 0, 1%.L O, m-A OD PD X M Page 279 of 414 LTR-SGDA-12-36, Rev. 3 NP-Attachment February 15, 2013 6 E 0 (U a...0 (0 Velocity, U Figure 7-3 FIV Mechanisms of Interest to U-bend Tube Wear Potential Page 280 of 414 LTR-SGDA-12-36, Rev. 3 NP-Attachment February 15, 2013 b,e Figure 7-4 Schematic Illustration of Quarter Scale U-bend Air Flow Test Used to Obtain Instability Constants for Parallel Triangular Array Configuration -0 0 CA)m 00 C)o Page 281 of 414 LTR-SGDA-12-36, Rev. 3 NP-Attachment February 15, 2013 b,e Figure 7-5 Comparison of Observed Vibration Amplitudes and Impact Forces in Scaled U-bend Air-Flow Tests During Single-sided Interaction with an AVB Page 282 of 414 LTR-SGDA-12-36, Rev. 3 NP-Attachment February 15, 2013__3 m 0+ ~+-1-.-4-. 4+ 4- +4+.+44+~+ 4--I SIMULATED OUT-OF-PLANE DIRECTION TUBE EXTENSION MAKES INSTALLATION OF SIMULATED AVB'S, IMPACT FORCE GAUGES, POSITION DETECTORS, AND PRELOAD DEVICES SIMPLE TO ACCOIPLISH L FLAT STRIP PROVIDES OUT-OF-PLANE MOTION Figure 7-6 Conceptual Arrangement of Full-Size Cantilever Tube Test Used to Simulate U-bend Response and Characterize Fluidelastic Driving Forces Page 283 of 414 LTR-SGDA-12-36, Rev. 3 NP-Attachment February 15, 2013 b,e Figure 7-7 Conceptual Sketch of Full-Size U-bend Shaker Test Used to Characterize Workrates for Both Turbulence and Amplitude-Limited Fluidelastic Vibration (Full Size Westinghouse Model F or Delta 75 Design with inch Radius) Page 284 of 414 LTR-SGDA-12-36, Rev. 3 NP-Attachment February 15, 2013 Running-in period K->1 K 5 8 Figure 7-8 Potential for Increased Wear Coefficient During Initial Operation (Reference 7-11) Page 285 of 414 LTR-SGDA-12-36, Rev. 3 NP-Attachment February 15, 2013 a,c,e Figure 7-9 Schematic Illustration of Initiation of Amplitude Limited Fluidelastic Excitation on Workrate Trend for Tube-to-AVB Interaction across a Gap if SR > 1 without the AVB 030 00 0)00 03 0 Page 286 of 414 LTR-SGDA-12-36, Rev. 3 NP-Attachment February 15, 2013 a,c,e Figure 7-10 Typical Application of Semi-Empirical Wear Calculation Methodology for Amplitude Limited Fluidelastic Excitation in Steam Generator Design 0o 0 0)90 X3Page 287 of 414 LTR-SGDA-12-36, Rev. 3 NP-Attachment February 15, 2013 Drive Force, FOS Fluidelastic Excitation Force, F, Figure 7-11 Fundamental Characteristic Trends Treated in Semi-Empirical Methodology C).0;U.m 0ýPage 288 of 414 LTR-SGDA-12-36, Rev. 3 NP-Attachment February 15, 2013 C C-4)25 20 15 10 5 0 0 2 4 6 8 10 12 14 16 18 Wear Volume, V (0.0001 in 3)20 Figure 7-12 Wear Depth vs. Wear Volume (0.750 inch OD Tube 0.59 inch AVB Width) CD C:)0 0 US~Page 289 of 414 LTR-SGDA-12-36, Rev. 3 NP-Attachment February 15, 2013*~ ~.FEEDWATER NOZZLE AND ELEVATED FEEDWATER RING WRAPPER CONE iANTI-VIBRATION BARS HANDHOLE<(ROTATED INTO VIEW)TOP TUBE SUPPORT PLATE INSPECTION PORTS It VESSEL SHELL I-- STAYRODS TUBE BUNDLE HAN DHOLE% -BLOWDOWN NOZZLE TUBE PLATE CHANNEL HEAD PARTITION PLATE INLET/OUTLET NOZZLES AND PRIMARY MANWAYS SUPPORT PEDESTAL Figure 7-13 Illustration of Tube Bundle Support Structure in Plant B Steam Generators 00.0,;0 O Co, 0, m Page 290 of 414 LTR-SGDA-12-36, Rev. 3 NP-Attachment February 15, 2013 600* *** SONGS SG 2 (1 Cycle).C 0.Uo 0~0)500-- SONGS SG 3 (< 1 Cycle)-- Plant B (6 Cycles)400 F 300 F 200 0 0 00 100.0-______t__C___t____ 0 0 30 60 90 Angle Around U-bend 120 150 180 Figure 7-14 Comparison of Number of AVB Wear Indications for Plant B versus SONGS RSGs -A 00 C>00 0, Po m 0 C)Page 291 of 414 LTR-SGDA-12-36, Rev. 3 NP-Attachment February 15, 2013 b,e Figure 7-15 Comparison of Observed Vibration Amplitudes and Impact Forces in Scaled U-bend Air-Flow Tests During Single-Sided Interaction with an AVB Page 292 of 414 LTR-SGDA-12-36, Rev. 3 NP-Attachment February 15, 2013 a,c,e Figure 7-16 OP U-bend Mode in Sample Evaluation Showing First Unstable FASTVIB Case and Postulated Initial Positions of AVBs 4 and 5 Relative to Mode Shape 0)0 m 0 N)Page 293 of 414 LTR-SGDA-12-36, Rev. 3 NP-Attachment February 15, 2013 a.ce Figure 7-17 Significant OP U-bend Modes in Sample Evaluation Showing 2 FASTVIB Cases and Postulated Initial Positions of AVBs 3, 4, 5, and 6 Relative to Mode Shape Page 294 of 414 LTR-SGDA-12-36, Rev. 3 NP-Attachment February 15, 2013 a,c,e Figure 7-18 R131C91 Case 17 Tube Wear Calculations Cycle IR for 22 Months Followed by Various Load Levels for Cycle 2 03L 00 C)!OD (30 m C0 Page 295 of 414 LTR-SGDA-12-36, Rev. 3 NP-Attachment February 15, 2013 a,ce Figure 7-19 R131C91 Case 38 Tube Wear Calculations (Case 17 with Gap)Cycle IR for 22 Months Followed by Various Load Levels for Cycle 2 Page 296 of 414 LTR-SGDA-12-36, Rev. 3 NP-Attachment February 15, 2013 a,c,e Figure 7-20 R129C93 Case 28 Tube Wear Calculations Cycle 1 R for 22 Months Followed by Various Load Levels for Cycle 2[Final esults for Case 29 Not Plotted] -.L 00 C)OD CO m D Page 297 of 414 LTR-SGDA-12-36, Rev. 3 NP-Attachment February 15, 2013 ace Figure 7-21 R129C93 Case 46 Tube Wear Calculations (Ref. Case 28 + Gaps Each End)Cycle 1R for 22 Months Followed by Various Load Levels for Cycle 2 Page 298 of 414 LTR-SGDA-12-36, Rev. 3 NP-Attachment February 15, 2013 a,c,e Figure 7-22 R126C90 Case 45 Tube Wear Calculations Cycle IR for 22 Months Followed by Various Load Levels for Cycle 2 00 02 Cy)k m 0 Page 299 of 414 LTR-SGDA-12-36, Rev. 3 NP-Attachment February 15, 2013 a,c,e Figure 7-23 R126C90 Case 60 Tube Wear Calculations Cycle IR for 22 Months Followed by Various Load Levels for Cycle 2 Page 300 of 414 LTR-SGDA-12-36, Rev. 3 NP-Attachment February 15, 2013 a,c,e Figure 7-24 R1 21 C91 Case 37 Tube Wear Calculations Cycle 1 R for 22 Months Followed by Various Load Levels for Cycle 2 Page 301 of 414 LTR-SGDA-12-36, Rev. 3 NP-Attachment February 15, 2013 a,c,e Figure 7-25 R121C91 Tube Wear Calculations (Cases 37, 45, 46, 53)Cycle 1R for 22 Months Followed by 80% PL for Cycle 2 0)0 (C)0, m C0 Page 302 of 414 LTR-SGDA-12-36, Rev. 3 NP-Attachment February 15, 2013 Figure 7-26 R11 9C89 Case 46 Tube Wear Calculations Cycle 1R for 22 Months Followed by Various Load Levels for Cycle 2 Page 303 of 414 LTR-SGDA-12-36, Rev. 3 NP-Attachment February 15, 2013 Tubes may only be close at this location Top Cnter~Tube to Tube Wear Here -RII11C81 and R113C81 I I Ho egSide Row 1 Row 15 Row 27 Row 1421 Row 48 Figure 7-27 Postulated Geometry for Tubes R111/C81 and R1131C81 1814-AA086-M0238, REV. 0 Page 304 of 415 Page 304 of 414 LTR-SGDA-12-36, Rev. 3 NP-Attachment February 15, 2013 8.0 Additional Considerations 8.1 Evidence for Lack of In-Plane Instability in Unit 2 8.1.1 FIV Results The flow-induced vibration analysis has considered many postulated boundary conditions regarding how AVBs can support the SG tubes in SONGS Unit 2. The potential for in-plane instability being the primary reason for wear in Unit 2 has been explored by considering certain selected tubes having high degrees of wear. The analysis focused on certain tubes that are plugged since these tubes have the largest amount of wear. The analysis will consider tubes that: 1. Have the largest amount of wear at a given AVB location 2. Have the largest number of ineffective AVBs as evidenced by the number of eddy current reported wear sites Using the above criteria, the following tubes will be addressed: SG 2E088: Tubes with largest amount of wear (35%TW) -R1 33C91, R1 12C88 Tubes with largest number of ineffective AVBs (8) -R1 20C92, R97C85, R99C93 SG 2E089: Tube with largest amount of wear (29%TW) R1 17C81 Tubes with largest number of ineffective AVBs (8) R122C82, R106C84, R105C83, R104C86, R98C86, R123C91, R98C88, Rl12C84, R100C84 Table 8-1 contains a summary of the in-plane stability ratios calculated for these tubes. Of the approximately 1400 tubes found with indications of tube wear in the U-bend, only 3 of these tubes have an in-plane stability ratio greater than 1.0 when calculated using an updated Beta of I Ia,c,e. The limiting tube (R123C91) would require a Beta of approximately [ ]ac~e in order to have a calculated in-plane stability ratio less than 1.0.The analysis indicates that for a very small population of tubes (3), the calculated instability ratio marginally exceeds 1. However, as determined in the eddy current results review, the number of tubes with wear is on the order of 1400. Since all the tube wear found to date is very similar, it can be concluded that the mechanism for this wear would also be similar. Since only 3 tubes have calculated stability ratios greater than 1.0, and the wear on these tubes is similar to wear found on other tubes with calculated stability ratios less than 1.0, it would be reasonable to expect that the 3 tubes respond in a manner similar to the -1400 tubes with wear. This evidence suggests that the actual Beta's (and potentially other related factors) associated with in-plane motion are such that the tubes remain stable in the in-plane direction. It should also be noted that after review of the Unit 3 eddy current data, discussed in Section 9.0, it was determined that the two tubes with tube-to-tube wear in Unit 2 did not have the major characteristic associated with Unit 3 tubes exhibiting in-plane motion and tube-to-tube wear. All of the Unit 3 tubes in the sample population had indications of wear at the top TSP. An explanation of why that is relevant for in-plane motion can also be found in Section 9.0. The observation that the two Unit 2 tubes with tube-to-tube wear did not exhibit the major characteristic of tube-to-tube wear found in the Unit 3 sample is an important finding that further indicates that in-plane motion was not occurring in R1 11/113C81. As a result of the above, it can be concluded that the tube wear found in Unit 2 1814-AA086-M0238, REV. 0 Page 305 of 415 Page 305 of 414 LTR-SGDA-12-36, Rev. 3 NP-Attachment February 15, 2013 is not related to in-plane instability and therefore is not a credible mechanism from an analytical point of view.Note that all of the tubes listed in Table 8-1 have been removed from service. In addition, any currently active tubes or plugged tubes would have calculated in-plane stability ratios less than 1.0 for power levels of 70%.8.1.2 ECT Results A supplemental review of selected eddy current data was performed as part of the support effort for the FIV analysis. This review included an investigation of the AVB and AVB wear data using the available +Pt data for all SG 2E089 tubes with bobbin coil indicated depths of 20% through-wall or greater; all other tubes in Columns 81 and 82 between Rows 120 and 110; and the identified limiting tubes for the FIV analysis. The SG 2E088 review included the identified limiting tubes for the FIV analysis, which includes both tubes with 35%TW indication depths. Both the hot and cold leg +Pt RPC data for these tubes were reviewed (if available). A total of 70 tubes in SG 2E089 encompassing 394 bobbin reported indications and 5 tubes in SG 2E088 encompassing 37 bobbin reported indications were reviewed.This review concluded that: 1. All wear at the AVBs was found to be contained within the width of the AVBs.2. For tubes with both single- and double-sided AVB wear, the majority of single-sided AVB wear was found on one side of the tube.3. For tubes with the single-sided wear not on the same side, the side orientation of the indications was grouped. That is, wear could be observed at AVB2 on one side, with wear at AVB3, AVB4, AVB5, and AVB6 on the opposite side.4. AVB axial symmetry variance at AVB6, AVB1, and AVB7 had the largest amount of variance as indicated by the 95th percentile value (0.32, 0.25, and 0.23 inch, respectively); the variance at all other AVBs are approximately equal.5. The most extreme AVB symmetry variance of 0.50 inch was not associated with wear at that AVB.When the bobbin coil inspection results are combined with a review of the +Pt data for the tubes identified on Table 8-1, it is observed that the number of bobbin reported indications is equal to the number of +Pt indications for all but SG 2E088, R113 C91 (7 consecutive wear sites), SG 2E089, R123 C91 (9 consecutive wear sites), and SG 2E089, R100 C84 (9 consecutive wear sites).In conclusion, there is no indication from the eddy current data that suggests in-plane instability has occurred in the Unit 2 steam generators during the prior cycle of operation. 8.2 Upper Bundle Tube Proximity 8.2.1 Potential Manufacturing Issues There are several potential manufacturing issues associated with review of the design drawings based on Westinghouse experience. The first two are related to increased proximity potential that is likely associated with the ECT evidence for proximity that is described in Section 8.2.2.Two others are associated with the AVB configuration and the additional orthogonal support 1814-AA086-M0238, REV. 0 Page 306 of 415 Page 306 of 414 LTR-SGDA-12-36, Rev. 3 NP-Attachment February 15, 2013 structure that can interact with the first two during manufacturing. Another relates to AVB fabrication tolerances. These potential issues include: 1. The smaller nominal in-plane spacing between large radius U-bend tubes than comparable Westinghouse experience. Differences in axial shrinkage of tube legs can change the shape of the U-bends and reduce in-plane clearances between tubes from what was installed prior to hydryaulic expansion.

2. The much larger relative shrinkage of different sides of each tube that can occur within the tubesheet drilling tolerances.

3. The potential for the ends of the lateral sets of AVBs (designated as side narrow and side wide on the Design Drawing Anti-Vibration Bar Assembly Drawing LU-04FU116, Rev. 2)that are attached to the AVB support structure on the sides of the tube bundle to become displaced from their intended positions during lower shell assembly rotation.4. The potential for the orthogonal bridge structure segments that are welded to the ends of end cap extensions on 13 AVBs to produce reactions inside the bundle due to weld shrinkage and added weight during bundle rotation.5. Control of AVB fabrication tolerances sufficient to avoid undesirable interactions within the bundle. If AVBs are not flat with no twist in the unrestrained state they can tend to spread tube columns and introduce unexpected gaps greater than nominal inside the bundle away from the fixed weld spacing.The weight of the additional support structure after installation could accentuate any of the above potential issues. There is insufficient evidence to conclude that any of the listed potential issues are directly responsible for the unexpected tube wear, but these issues could all lead to unexpected tube/AVB fit-up conditions that would support the amplitude limited fluidelastic vibration mechanism described in Section 7.1. None were extensively treated in the SCE root cause evaluation.

8.2.1.1 Nominal In-Plane Tube Spacing Table 7-1 shows that the nominal tube spacing between the apex of successive tubes in the same column is 0.400 inch for the largest radius tubes and only 0.344 inch for the tubes in Rows 101 through 124 that have much of the observed tube wear. This nominal at the apex is misleading in the sense that it is the maximum clearance if all tube fabrication tolerances are precisely maintained including the length of the straight legs which positions the U-bend relative to the primary face of the tubesheet. The distance between tubes on the sides at the intersection with the top TSP is 0.250 inch plus or minus the small broached hole tolerances. The actual shape of the U-bend has a profile tolerance that is not provided in the referenced drawings, but Westinghouse experience is that it may be between [ ]a,c,e for similar size tubing. The only check during tube bundle assembly is the ability to pass a 0.12 to 0.14 inch pin gauge between successive tubes 1.Any tube that lies within the adjacent tubes with any tolerances will satisfy this check. However, any variations in leg length or form tolerances will lead to tubes that are much closer than the nominal spacing, and most deviations will lead to tubes being closer on one side, for example near AVB3 and AVB4 and farther from AVB9 and AVB1 0, or vice versa.ac,e Westinghouse does not have access to the assembly procedures. The 0.12 to 0.14 dimensions are anecdotal without verification. 1814-AA086-M0238, REV. 0 Page 307 of 415 Page 307 of 414 LTR-SGDA-12-36, Rev. 3 NP-Attachment February 15, 2013[]a,c,e Therefore, it is expected that it would have been difficult to maintain uniform spacing in the U-bend given the smaller incremental spacing on the SONGS manufacturing drawings. The SCE root cause evaluation notes that between 132 and 390 tubes required adjustment of tube bending radius for each of the steam generators. This process is inherently difficult to control in a manufacturing environment. 8.2.1.2 Tube Leg Shrinkage During Hydraulic Expansion (HX)The entire tube bundle is assembled before hydraulic expansion is performed with no ability to see the consequences of variations in leg shrinkage inside the bundle. Expansion is a process that involves plastic deformation of the portion of tubing that is inside the tubesheet, and plastic deformation is a constant volume process that necessitates shortening the length of the straight portions of tubing to account for the increase in diameter because wall thinning is small for the pressures involved. Figure 8-1 shows expectations for the range of relative shrinkage for Plant B and for the SONGS steam generators using drawing tolerances shown on Table 7-1. For most of the holes, both applications would have a maximum variation of about [ ]a,c,e inch between different sides of the same tube. However, the SONGS drawing allows up to one percent of the holes to be so large that a difference twice that large is possible for about 100 tubes in each RSG. When combined with the small clearances that are possible after installation, the superimposed HX shrinkage could lead to the level of proximity indications observed as discussed in Section 8.2.2. When installed and then heated and pressurized, it is possible that tube-to-tube contact would be possible, and in the extreme, there could be interference leading to tubes pushing against each other and then against adjacent AVBs tending to increase the column spacing. Any such tendencies would tend to make the next two issues more problematic during fabrication. 8.2.1.3 Lateral A VB Nose Movement During Shop Rotation The side-wide and side-narrow AVBs that are cantilevered from the sides of the bundle must be held in place by attachments to the retaining bars, and these bars must in turn be held in position by the orthogonal support bridge structure. For this design, gravity and friction tend to interact with the cantilevered AVBs whenever the horizontal SG is rotated during fabrication in an asymmetric way that could potentially move the noses of the AVBs and deform the straight portions leading to bending or twisting that could expand the column spacing in some regions and leave some regions of tubing with larger than nominal clearances. During shop rotation the overhanging portion of the tube bundle (about 83 inches or almost 7 feet for SONGS) bends downward several inches when the tube U-bends are horizontal, less when they become vertical, and then several inches in the opposite direction at 180 degrees from the starting position. This rotation occurs several hundred times during welding operations for not only the channel head but also the closing weld after AVB assembly. The ends of each leg of each AVB are deflected the same amount for AVBs that have their bends along the bundle centerline, but each rotation of the cantilevered AVBs deflects the leg that is nearest the center more than the one that is nearest the TSP. If the noses do not return to the original position they had when installed during the tube column and AVB layering process, the tube column spacing could be adversely impacted from consequential bending or twisting of the AVB legs. If there were any extreme proximity conditions from a combination of the first two potential issues that tended to push one tube locally against its neighbor, there could be a tendency to push the AVB legs apart locally and make it more difficult for all AVBs to maintain their original positions after rotation.1814-AA086-M0238, REV. 0 Page 308 of 415 Page 308 of 414 LTR-SGDA-12-36, Rev. 3 NP-Attachment February 15, 2013 8.2.1.4 Orthogonal Bridge Structure Impact on Bundle During Fabrication The segments of the orthogonal bridge are welded to the ends of longer than normal AVB end caps at 13 columns spaced evenly around each retaining ring. Weld shrinkage at these attachments could possibly impose forces on the ends of those AVBs that must be reacted inside the bundle. The added weight of the structure would also tend to amplify gravitational effects during shop rotations. 8.2.1.5 Control of A VB Fabrication Tolerances Large radius U-bend tubing has very little flexural rigidity out-of-plane of the tube even when pressurized during SG operation. The tops of the straight leg portions are held in place by the TSP broached hole spacing, and the AVB end cap-to-retaining bar welds maintain spacing around the periphery, more at the bundle center, but less so around the bundle because the bars are also flexible. However, there is no structural component to keep the interior of the bundle at the intended nominal spacing in the region of most wear in the SONGS steam generators, especially along a line between the bottoms of the locations where the weight of the structure is reacted by retainer bars that can tend to push the columns apart near the Row 111 tube radius.Therefore, it is even more critical for the SONGS steam generators to maintain flatness and twist tolerances on AVBs so they will not have any tendency to separate the tube columns anywhere between the end caps and the bends deep inside the bundle. If acceptance criteria for AVB tolerances did not include inspections for flatness and twist in the unrestrained condition 2 , the AVBs could contribute to the apparent off-nominal spacing in the SONGS steam generators. 8.2.2 Summary Eddy Current Data -PSI / ISI Section 5.2 describes the numerous proximity findings in the Unit 2 steam generators during both PSI and ISI. There are no specific indications associated with the observed tube wear pattern, but there is much eddy current evidence of tubing much closer than nominal while not operating in both the horizontal (PSI) and vertical (ISI) orientations. For example, a detailed study of Rows 80 and higher for Columns 50 through 110 found 334 indications of proximity less than 0.125 inch during PSI and 363 in the same range during ISI for SG 2E089. The locations of the proximity indications shifted slightly between nearby tubes in the same column based on orientation, and they also sometimes shifted from one side of the bend region to the other. This is the kind of proximity response in unpressurized tubing that is a consequence of the first two potential manufacturing issues noted above (small nominal spacing, added impact of hydraulic expansion shrinkage). Pressurization would tend to move the proximity locations in a similar fashion, and when pressurized the tubing is much stiffer in the plane of the U-bend.ECT findings discussed in Section 5.1.4 also indicate that denting is associated with the bend region of many of the smallest angle AVBs on the sides of the bundle (AVB2/AVB3 and AVB10/AVB11) at Rows 30 through 33. They are also noted to be on the outboard edge of each AVB indicating not only a larger than expected spacing, but also a local twist. This kind of twist could be from as-fabricated AVBs, or it could result from installing the AVBs deeper than intended and bending the legs to match the retaining ring profile. In either case, there is ECT 2 Westinghouse does not have access to final manufacturing or inspection details, but anecdotal input indicates that six-pound weights were allowed and used during AVB inspection for consistency with AVB drawing tolerances. 1814-AA086-M0238, REV. 0 Page 309 of 415 Page 309 of 414 LTR-SGDA-12-36, Rev. 3 NP-Attachment February 15, 2013 evidence that the AVB tolerances and dimensions were not as expected in the Unit 2 steam generators. 8.2.3 Additional Considerations from Unit 3 Extensive review of ECT data available for the Unit 3 RSGs was conducted as described in Section 9.0 to develop conservative criteria for identifying tubes that could be susceptible to tube-to-tube wear. Figures 8-2 through 8-6 identify various findings of tube proximity, AVB symmetry variance on opposite sides of the same intersection, and tapered wear scars associated with twisted AVB legs that are inconsistent with assuming tube/AVB interactions based on Gaussian distributions about nominal design conditions. Figure 8-2 is an overview of all the noted variables. There is a line of proximity indications in Rows 121 and 122 that is not random, but there is insufficient information to know if it is associated with the weight of the AVB structure imparted here through the retainer bar supports or if it could be that the next incremental tube index does not occur until Row 124. The distribution of significant symmetry variances and tapered wear scar locations also does not appear random. The boundary between tubes with mostly double-sided wear scars inside the SVI region (the region on the tube with the single volumetric indication) and single-sided wear scars above and below is not shown here, but the boundary is consistent and markedly not random.Figure 8-3 shows both the spatial and quantitative distribution of AVB symmetry variance in this region. The maximum symmetry variance of 0.78 inches occurs at AVB 6 on Row 87 in Column 85, and it decreases both going outward at larger radii going towards the tube/AVB weld and inward going towards the bend region. It is not likely that the middle of an AVB can be displaced this much in-plane without introducing significant bending and twist beyond design expectations. The ECT review noted that more tubes in Unit 2 had symmetry variances than in Unit 3, but they were more scattered with a smaller maximum (about 0.5 inch). Figure 8-4 shows that locations with twist are present in the vicinity with the largest taper distribution from about 5 to 35%TW shown on Figure 8-5.8.2.4 Conclusions The mechanism considered most likely to be able to cause the wear observed in the SONGS steam generators during the first cycle of operation is considered to be amplitude limited fluidelastic excitation resulting from out-of-plane tube vibration within larger than expected clearances in the U-bend tubing support structure. All of the potential issues described above could lead to such conditions in various combinations, but none were extensively considered in the SCE root cause evaluation. 8.3 Low Stability Ratio Tubes with Higher Wear Several active tubes with significant wear had only a few ECT indications from the original bobbin coil evaluation. If only the AVBs with wear were used to define FASTVIB cases, then calculated excitation ratios would not be greater than one, apparently inconsistent with using the semi-empirical wear calculation methodology described in Section 7.2 to explain the observed wear. Two limiting tubes in Table 7-2 for SG2E89 are examples that were evaluated assuming that one or two additional adjacent AVBs were also ineffective as a consequence of the mode shape assumed for the reference case relative to the existing gaps as shown on Figure 7-17.Considering the slightly longer spans to define the characteristic FASTVIB case then allows matching the actual wear after the initial operating period and projecting the result as was done 1814-AA086-M0238, REV. 0 Page 310 of 415 Page 310 of 414 LTR-SGDA-12-36, Rev. 3 NP-Attachment February 15, 2013 for all the other tubes shown on Figure 7-3. The R1 13C71 and R121C95 tubes had a reference FASTVIB case 18 based on bobbin ECT indications at AVBs B6 and B7. Cases 38 and 46 both produce the observed wear at Ri 13C71 and project to 23.5 and 23.9 %TW after 6 months of operation at 80 percent part load. Cases 39 and 47 both produce the observed wear at R121C95 and project to 22.5 and 23.6 %TW respectively for the same 80 %PL operating conditions. Thus, the apparent inconsistency of large wear and few bobbin indications is explained by evaluating other likely cases, in effect moving the tubes to other locations in the table.8.4 Wear Projection Uncertainty As described in the prior subsections, the wear projection methodology applied here is based on selecting the input variables related to materials and geometry of the tube-AVB intersections to match the wear depth reported in the U2C17 inspection. The methodology then uses the same values of the input variables for projection of the wear depth in Cycle 17. Since values of several input variables are unknown, this approach involves selecting input values within an expected range based on test results, published data and experience and using these values to obtain a match for the U2C17 inspection results by trial and error. There will a number of possible"solutions" (combinations of different values of the given input variables) that satisfy the criteria.The wear projection process applied here is very time consuming due to the trial and error involved in obtaining a match for the inspection results, often for three different AVB wear indications in a given tube. Therefore the uncertainty evaluation is based on the following analysis applied to one tube. In this evaluation, the method uncertainty (standard deviation of growth) is determined as a fraction of the mean estimated growth of an AVB wear indication. This allows estimation of the growth uncertainty from the estimated growth by applying this ratio.Tube R121C91 in SG 2E089, which has four AVB indications reported in the U2C17 inspection, was selected since this is one of the tubes that will be returned to service with the deepest wear scar.a,c,e 1814-AA086-M0238, REV. 0 Page 311 of 415 Page 311 of 414 LTR-SGDA-12-36, Rev. 3 NP-Attachment February 15, 2013 a,c,e Hence the standard deviation of growth will be calculated as [ ]a,c,e times the estimated growth for an indication. Using this standard deviation, the growth at 95% probability and 50%confidence can be estimated using the normal distribution (z = 1.645).The growth uncertainty will be applied as follows:* [ ]a,c,e* [ ]a,c,e* [ ]ace* [ ]ace A common sense test of the derived normalized standard deviation was applied as follows.Using the first of the eleven solutions, the growth at 95% probability and 50% confidence was calculated and added to the reported wear depth at U2C1 7. This was done for each of the three AVB indications at each of the three loads and two durations of Cycle 17. The number of times the estimated Cycle 17 wear depth in the eleven solutions exceeded the 95% probability 50%confidence values by more than 0.5%3 was counted. It was found that, of the 198 projected depths in the eleven solutions, only 4 exceeded the 95 percentile values. Hence, the uncertainty evaluation was validated. A question may be raised regarding the uncertainties in the supporting evaluations such as thermal-hydraulic evaluation and flow-induced vibration evaluations that formed the inputs to the wear projection. Results of those evaluations were applied consistently for both the Cycle 16 assessments that benchmarked the solutions with the U2C17 inspection results and to the Cycle 17 assessments resulting in the wear projection. Hence, the uncertainties in those results are present in both cases, balance out each other, and are considered irrelevant. Similarly, the calculation of the excitation ratios (and stability ratios) is based on the thermal-hydraulic and vibration evaluation results and the support conditions. The support conditions of a tube are the same during the first cycle of operation and the next operating cycle. Hence the change in excitation ratios from the last cycle to the next cycle occurs only due to the change in operating 3 For four of the 22 cases, the calculated growth was 0. Hence the estimated uncertainty (standard deviation) was also 0, although the true uncertainty is not. Thus the small 0.5% grace value was used to account for such cases. It is possible to apply a small (0.5% or 1%) grace value as the minimum uncertainty allowance (1.645 times the standard deviation) for growth to overcome this drawback. However, it is judged to be so small and, hence, inconsequential. Thus, the simple approach without any adjustment in the uncertainty value to overcome the calculated growth value of 0 was applied in this evaluation. 1814-AA086-M0238, REV. 0 Page 312 of 415 Page 312 of 414 LTR-SGDA-12-36, Rev. 3 NP-Attachment February 15, 2013 conditions (power reduction). Hence the conclusion related to the uncertainties balancing out due their presence in both cycles is also applicable to the excitation ratios and stability ratios.1814-AA086-M0238, REV. 0 Page 313 of 415 Page 313 of 414 LTR-SGDA-12-36, Rev. 3 NP-Attachment February 15, 2013 Table 8-1 Enveloping Cycle I Tubes No Missing IPSR100% IPSR70%Tube SG Case AVBs power power R!33C91 2e88 45 5 Nc:e!Ri12Css 2e88 55 6 R120C92 2eSS 66 8 R97C85 2e88 66 8 R99C93 2e88 67 8 R117C81, 2e89 55 6 R122C82 2e89 66 8 R!.06CS4, 2e89 66 8 R205C83 2e89 66 8 R0ICC86 2e89 66 8 R98C86 2eS9 66 8%123C91 2e89 66 8 R98C88 2e89 66 8 RlI2CS4 2e89 67 8 R100C84 2eS9 67 8 1) AVB5 assumed to be ineffective even though no wear was reported.1814-AA086-M0238, REV. 0 Page 314 of 415 Page 314 of 414 LTR-SGDA-12-36, Rev. 3 NP-Attachment February 15, 2013 ace Figure 8-1 Potential Range of Axial Shrinkage for Plant B and SONGS Steam Generators Using Drawing Tolerances for TS Drilled Hole Diameter 1814-AA086-M0238, REV. 0 Page 315 of 415 00 0 0 Page 315 of 414 LTR-SGDA-12-36, Rev. 3 NP-Attachment February 15, 2013 a,c,e Figure 8-2 Overview of ECT Results from SG 3E088 Using ISI Proximity Results Map with AVB Support Structure (Boxes with numbers are locations of AVB symmetry variance; smaller rectangles are locations with twist) O0 00 (30 C)9Do m 0 X Page 316 of 414 LTR-SGDA-12-36, Rev. 3 NP-Attachment February 15, 2013 a,c,e Figure 8-3 Locations and Magnitudes of AVB Symmetry Variances Near SVI Region of SG 3E088 -k 00 CO 70 Page 317 of 414 LTR-SGDA-12-36, Rev. 3 NP-Attachment February 15, 2013 a,c,e Figure 8-4 Distribution of AVB Locations with Tapered Wear Scars Indicating AVB Twist 0, 0 r,.3.Co m 00 C)M Page 318 of 414 LTR-SGDA-12-36, Rev. 3 NP-Attachment February 15, 2013 a,c,e Figure 8-5 Largest Implied Twist from Preliminary Tapered Wear Scar Review Near SVI Region of SG 3E088 -0 0,-0 0 co)m 0 PO (0 CD 0 Page 319 of 414 LTR-SGDA-12-36, Rev. 3 NP-Attachment February 15, 2013 Figure 8-6 Elevation View of Locations of AVB Misalignment and Tapered Wear Scars Obtained During ECT Review of the SG 3E088 SVI Region a,c,e Page 320 of 414 LTR-SGDA-12-36, Rev. 3 NP-Attachment February 15, 2013 9.0 Consideration of Unit 3 Tube Wear on Wear Model Applied in Unit 2 9.1 Unit 3 Critical Tube Selection for Model Validation More severe tube/AVB wear occurred in Unit 3 than in Unit 2. Unit 3 also experienced significant tube-to-tube wear and more extensive tube/TSP wear than in Unit 2. Therefore, the Unit 3 tube wear experience was reviewed to develop refined criteria that correlate the Unit 3 results in order to apply the same criteria to preclude similar tube-to-tube wear in Unit 2. Section 5.4 describes the extensive ECT evaluation that was performed on a large (86) sample of tubes from SG 3E088 that had experienced tube-to-tube wear to establish a consistent basis for this evaluation. There was a focus on 16 tubes that had tube-to-tube wear with only a few bobbin called indications of tube/AVB wear because these tubes would be the most difficult to explain using other criteria. It is not likely just a coincidence that these tubes happened to be around the boundary of the region with the most severe tube-to-tube wear as shown on Figure 9_112. These"boundary tubes" reflect the transition from severe free span wear experienced by the "interior tubes" on Figure 9-1. While developing criteria to correlate these two extremes of tube-to-tube wear experience, 15 additional "adjacent tubes" were added to the evaluation. 9.2 Unit 3 Analysis The 86 tubes from SG 3E088, comprising 55 interior tubes, 16 boundary tubes, and 15 adjacent tubes, were subjected to an in-depth, independent evaluation of RPC results contained in the digital ECT files provided by SCE as described in Section 5.4. Both the original reported wear indications from bobbin data and the new RPC results were used to define a range of potential ineffective AVB locations. This range of potential support conditions was evaluated using various FASTVIB cases using methods described in Section 4.2. Then, all calculations and ECT observations were reviewed to establish the most likely physical explanation for the tube-to-tube wear that occurred in the Unit 3 RSGs. Tables 9-1 and 9-2 provide a summary of the pertinent results. Note that all tables and figures discussed in Sections 9.2 through 9.5 were produced using FASTVIB analyses that restricted degrees of freedom for modes in the plane of the U-bend for the straight-leg portions of the tubes. This approach reflected the need to reduce the volume of data being processed to concentrate on U-bend response. All analyses have been repeated without this restriction with no impact on conclusions discussed in this section Table 9-1 addresses the more difficult to explain boundary tubes along with the adjacent tubes that are required to explain the occurrence of free span (FS) tube-to-tube wear in some instances. Notes explaining legends used in the evaluation follow at the bottom of the second page. The first tube in the table, R114C74, is a boundary tube that has an indicated FS wear depth of 26 %TW on the hot leg side between AVBs B3 and B4, but the only indications of tube/AVB wear are at AVBs B3 and B4 from the bobbin data plus an indication of very small wear (too small for the bobbin detection threshold) at B2 from the RPC evaluation. The support conditions evaluated for the implied support configuration Cases 15 and 25, that simulated ineffective supports at the AVBs with wear, show that OP gap-limited fluidelastic excitation could produce wear at those AVBs, but there was no indication of closer proximity to adjacent tubes in either the PSI or the ISI inspections to explain how that could have caused the FS wear between 12 Note that the tubes later called "boundary tubes" due to their location on the map were originally selected by sorting ECT data results and choosing ones that appeared not to have many consecutive tube wear indications at the AVBs. The adjacent tubes were added later. The original terminology was retained for the evaluation and the map labels.1814-AA086-M0238, REV. 0 Page 321 of 415 Page 321 of 414 LTR-SGDA-12-36, Rev. 3 NP-Attachment February 15, 2013 those AVBs. The same support configuration Cases 15 and 25 are also clearly insufficient to have the possibility of IP fluidelastic instability as the explanation for the FS wear because the calculated stability ratio is only about half the required threshold even using what is considered a conservative Pip [ a,c,e Furthermore, the wear scars that were present showed no extensions outside the AVB intersections, so there had been no apparent significant in-plane motion of this tube.The next tube in the Column R112C74 (nearest inside neighbor in the same column) was already in the list as a boundary tube because it had only one wear call at B5, so it was also reviewed to determine if it could be the source of the FS wear that had been found on R1 14C74.Table 9-1 shows how this is considered to be a possible explanation since it showed indications of in-plane motion outside the AVB at B8, and the IP stability ratio would have exceeded the threshold if AVBs B2, B6, and B7 had been ineffective in providing support in-plane in addition to the 7 other locations with small wear observed only with detailed RPC inspection. The wear depths on these two boundary tubes were similar (26%TW and 25%TW) to support this conclusion. However, the requirement to find 7 small wear scars and assume three others is a stretch when defining criteria based on analyses alone, so adjacent Tube R110C74 was evaluated to determine if it could have provided some of the interaction as well.The inside neighbor adjacent Tube R1 10C74 had 4 bobbin indications and 4 more low level RPC indications, and it also required 3 additional AVBs to be ineffective at preventing in-plane motion in order to have potential IP instability. It also had reasonably similar FS wear between B3 and B4 (19%TW), so it could have provided some of the energy leading to FS wear for all three tubes. However, it also would be difficult to identify from a purely analytical perspective. These three tubes illustrate tubes that are difficult to identify by any means other than observation of FS wear on the tube or an adjacent neighbor that interacts with it.The next two tubes are similar in that one (R101C75) has FS wear on the cold leg between AVBs B9 and B10, but there is no analytical basis to explain it. However, the adjacent tube R103C75 is potentially unstable in the IP direction using support conditions evident from both bobbin and RPC test results. The FS wear scars also match at 19% and 18%TW, and there is clear evidence of in-plane motion demonstrated by wear scar extensions. The remaining tubes in Table 9-1 with FS wear that were selected as being the most difficult to explain all have adjacent neighbors that appear to be the sources of IP motions that cause wear at the interface of both tubes. Some are obvious after reviewing the additional RPC indications while others require reasonable, but not obvious, assumptions that are consistent with physical observations and analytical predictions of potential for IP instability. However, the main conclusion of the evaluation is that tubes with FS wear can all be explained as either having that potential, or by interacting with neighbors that have the potential to be unstable in-plane.A second major conclusion relates to the observed levels of TSP wear that characterize the results shown for most of the interior tubes in Table 9-2 and for several of the adjacent tubes in Table 9-1. Tubes with significant TSP wear correspond to the calculated OP gap-limited tube excitation ratios from about 7 to 9 and IP stability ratios greater than about 1.5. As such, they correspond to tubes having very long unsupported spans with obvious potential for IP instability based on the FASTVIB cases considered most representative of the available observations. This observation allowed the addition of another conservative criterion to identify tubes with potential for FS tube-to-tube wear as explained in the following section under 9.3.4 Criterion 4 -Wear at Top TSP Sites.1814-AAO86-M0238, REV. 0 Page 322 of 415 Page 322 of 414 LTR-SGDA-12-36, Rev. 3 NP-Attachment February 15, 2013 9.3 Plugging Criteria Development As a result of the extensive review of the Unit 3 eddy current data, additional revisions to the plugging criteria were developed to address tubes not currently plugged. Revisions to the plugging criteria were necessary as the level of degradation experienced in Unit 3 was more severe than that observed in Unit 2. Information obtained from the Unit 3 eddy current data has provided additional insights as to what should be considered to develop a more robust plugging recommendation or plugging criteria. Additional indications of wear were observed not only at AVB locations at Unit 3, but also at TSP locations that should also be considered in the development of the plugging recommendations. Note that each criterion has been developed to address the various boundary conditions that are necessary for the tubes to experience wear. There is discussion provided for each criterion to help explain why it is important, and how the observed conditions coupled with analysis models explain why a tube should be removed from service if one or more of the indicated eddy current indications are found on a tube.The following is a summary of each criterion that should be considered to determine if any additional plugging is required beyond the tubes that are currently plugged. These criteria are applicable for tubes in both the Unit 2 and Unit 3 steam generators. 9.3.1 Criterion I -Free Span Contact Any tube with free span tube-to-tube wear will be plugged along with all immediately adjacent tubes. Review of the sample of 86 Unit 3 tubes has found that all 86 of these tubes have indications of free span wear.9.3.2 Criterion 2 -Wear Outside A VB sites Any tube with known wear outside the AVBs would be treated as potentially unstable and removed from service. For suspected in-plane instability locations, a review of the surrounding tubes should be performed as well as the tubes surrounding those tubes with the largest number of bobbin reported AVB indications. This indicates that in-plane motion could potentially be occurring, and as a result, the tube could then contact a neighboring tube and therefore should be removed from service.9.3.3 Criterion 3 -Ineffective A VB Sites and In-Plane Motion Any tube with a sufficient number of ineffective AVBs (as determined via wear at AVB sites) and is unstable in-plane would be removed from service. The in-plane instability potential would be determined based upon the power level and operating conditions associated with the next cycle of operation. Any tube with in-plane stability ratios greater than 1.0 would indicate that in-plane motion could potentially develop. As a result of the large stability ratios, the tube could then contact a neighboring tube and therefore should be removed from service.1814-AA086-M0238, REV. 0 Page 323 of 415 Page 323 of 414 LTR-SGDA-12-36, Rev. 3 NP-Attachment February 15, 2013 9.3.4 Criterion 4 -Wear at Top TSP Sites There are some instances where review of the AVB eddy current data for Unit 3 does not clearly indicate that the tube has a sufficient number of ineffective AVBs to produce in-plane motion, but there is evidence of tube-to-tube wear. This is possible since an ineffective AVB support can be a result of either a gap condition, where the tube contacts and then wears against an AVB as a consequence of impacting due to out-of-plane gap-limited FEI, or the case where the gaps are larger than modal displacements such that the tube would not contact an AVB. In the second case, where the tube does not contact an AVB, there might not be any tube wear at that location and as a result would not be detectable by eddy current examination. However, in these cases there may be evidence of wear at the top TSP. This TSP wear would be an indicator of out-of-plane tube excitation that would be a result of additional ineffective AVBs that are not detected by eddy current, and the support conditions that allow this TSP wear are consistent with conditions where in-plane instability leading to tube-to-tube contact may be possible.Tube support conditions in the U-bend region usually have many ineffective AVBs such that multiple out-of-plane modes are present when in-plane instability is possible. For example, Figure 9-2 shows [a,c. The average wear for seven of the tubes in the most severe region of SG 3E088 is shown on the same plot as mode shapes from the FASTVIB analyses of a tube in the same vicinity. Wear depths depend upon the tube/AVB gaps relative to the unstable out-of-plane mode nearest each AVB, and may not be above the detection threshold for locations away from the maximum modal displacement. The plotted average wear depths actually have contributions from additional out-of-plane modes and increased work rates due to in-plane modes that are described next, but gap-limited out-of-plane fluidelastic tube excitation alone can cause most of the observed wear in the U-bend region.Figure 9-3 shows how additional gap-limited FEI modes in the U-bend can add to wear at the AVBs, but more significantly, they can lead to highly loaded spans at the top of both the hot and cold legs consistent with the observed wear distribution for these severely worn tubes. Some tubes in this highly loaded region that have large gaps at all AVBs have only the additional third mode, while others have yet another fourth unstable out-of-plane mode. These appear to be consistent with some tubes having wear at the top two TSPs and others having wear in decreasing amounts all the way down to the second TSP. No specific wear calculations have been made for the TSP wear, but the observed distributions match both the severity of the modal displacements and the nature of the rocking/whirling 1 3 vibration that would be expected at the TSPs due to the mode shapes associated with the given support condition. Note this support condition could also result in in-plane instability. Figure 9-4 shows two in-plane mode shapes that can become unstable at about the same excitation levels and support conditions that lead to the third and fourth out-of-plane modes 13 Fluidelastic instability in the U-bend region is predominantly characterized by out-of-plane displacements usually considered to be the result of the significant differences in stiffnesses there. However, tubes with instability in the straight leg region where stiffnesses are the same in all directions typically exhibit orbital motions. In this situation where energy derives from gap-limited excitation in the U-bend, tube motions in the straight leg may be limited by modal characteristics determined by the gaps in the U-bend, but the orbital displacements could be several times larger than they otherwise would have been due to flows in the straight leg alone.1814-AA086-M0238, REV. 0 Page 324 of 415 Page 324 of 414 LTR-SGDA-12-36, Rev. 3 NP-Attachment February 15, 2013 shown on Figure 9-3. The in-plane modes may have a significant contribution to observed tube-to-tube free span wear, but they do not contribute significantly to straight leg vibration based on these simple linear analyses. However, they occur at about the same excitation levels and support conditions as the out-of-plane modes that lead to wear at the top two TSPs. This is the reason that wear at the top TSPs can be used to identify tubes with ineffective support conditions that could be indirect indicators of conditions leading to unacceptable free span wear even though one or two AVB locations may not be worn enough after Cycle 1 to clearly identify that potential directly. Updated analyses with no restraints on the degrees of freedom in the straight leg have small responses between the top TSPs, but they do not extend down to the lower TSPs as is the case for the out-of-plane modes with highest excitation ratios as shown on Figure 9-3.Figure 9-5 is included to confirm that inspections of tube wear scar extensions in SG 3E088 are consistent with in-plane frame Mode 1. Dotted lines are theoretical first in-plane mode shapes from FASTVIB. This is the frame mode that is swaying from side to side at [ ]a. The tangential part of that mode is the red dotted line and it would extend wear scars at B6 and B7, the most and least for AVBs closest to the TSP. The radial part of the frame mode is the light blue dotted line with maximum impact on scar extension at B3-B4 and B9-B10 and no impact on scar extension at B6 and B7 (radial tube motion at B6 and B7 would increase wear depth, but not extension). The resultant of those two components is the double-humped darker black dotted line, and this is the one that would be closest to expectations of fitting scar extensions from ECT measurements. This is indeed the case for many tubes as illustrated by the one tube with a red line connecting its data points. There are at least three times this many tubes that could be added to the plot, but they would not change the conclusion. The overall average of the data points is the very dark thick line. It has a single peak, but is obviously spread out more than the tangential mode alone as a consequence of the radial mode effects away from the center line.Based upon the above, Criterion 4 has been developed to remove from service any tube that has wear at the top TSP and has any wear at 2 or more consecutive AVB locations for power levels between 80% and 100%. For power levels 70% or below, the tube would have wear at the top TSP and also have wear at 3 or more consecutive AVB locations. Analysis has determined that it requires a minimum of 2 consecutive ineffective AVB locations at 80-100% power, and a minimum of 3 consecutive ineffective AVB locations at 70% power, before the tube becomes unstable in the out-of-plane direction at the limiting location in the SG tube bundle. This is considered to be a conservative criterion since the Unit 3 experience indicates that many more missing supports are required before in-plane instability actually occurs. This criterion effectively envelopes all possible fluidelastic wear mechanisms, considering both the in-plane and out-of-plane directions. 9.3.5 Criterion 5- A VB Sites and Wear Potential due to Out-of-Plane Motion There is a potential that additional tube wear would develop at the AVB locations that could result in leakage. This criterion has been developed to address the potential that out-of-plane motion could produce unacceptable amounts of tube wear during a given operating cycle. As a result, any tube with a sufficient number of ineffective AVBs (via wear at AVB site) and has indications of out-of-plane gap-limited fluidelastic tube excitation that results in additional tube wear greater than the plugging limit, will be removed from service.1814-AA086-M0238, REV. 0 Page 325 of 415 Page 325 of 414 LTR-SGDA-12-36, Rev. 3 NP-Attachment February 15, 2013 9.4 Application of the Criteria to the Unit 3 Tube Sample The criteria defined in the previous sections have been applied to the group of 87 Unit 3 tubes selected for validation of the plugging criteria. Table 9-3 contains a summary of the applications of the criteria. It is noted that in general all of the tubes considered in this sample have been identified for plugging by two or more of the criteria. The only exception where only one criterion was found to be applicable is for tubes that are being contacted by tubes that are experiencing in-plane displacements. These tubes are experiencing wear as a result of an adjacent tube that is experiencing in-plane motion. The following is a summary of how the samples of tubes meet each of the criteria: Criterion 1: Review of the sample of 86 Unit 3 tubes has found that all 86 of these tubes have indications of free span wear.Criterion 2: Review of the sample of 86 Unit 3 tubes has found that 17 of these tubes have indications of wear outside the AVBs.Criterion 3: Review of the sample of 86 Unit 3 tubes has found that 56 of these tubes have a sufficient number of ineffective AVBs (defined by wear noted at the AVB site) such that in-plane instability could potentially develop.Criterion 4: Review of the sample of 86 Unit 3 tubes has found that 79 of these tubes have both sequential AVB wear and wear at the top TSP. In addition, all of the remaining 7 tubes (including R118C80 and R114C82, which are not explicitly called out in Table 9-3) are experiencing wear as a result of tubes that do not meet Criterion

4. So in essence, it could be stated that the entire population of tubes that have experienced tube-to-tube wear have either been a tube that has not met this criterion, or is in contact with a tube that has not met this criterion.

Criterion 5: Wear calculations typically require significant amounts of time to complete;therefore, these calculations were not performed for the 86 Unit 3 tubes since these tubes had already been plugged.9.5 Application to Unit 2 The five rules, or plugging criteria, developed to explain the tubes in Unit 3 that were developed to explain the limiting tubes are applied to the eddy current data for the Unit 2 steam generators. Only the eddy current bobbin data was used in the Unit 2 data since the five criteria were sufficient to bound the bobbin only data for Unit 3. The results found for the five criteria are explained in the following paragraphs. The first criterion states that any tube with free span tube-to-tube wear or contact should be plugged as well as the surrounding tubes. There were only two tubes in Unit 2 which had free span wear. These tubes are Row 111 Column 81 and Row 113 Column 81. These tubes have already been plugged and in addition, all of the tubes surrounding these tubes have been plugged. Therefore, it can be concluded that no additional tubes need to be plugged due to this criterion. The second criterion states that any tubes that show AVB wear indications outside of the AVB support location should be plugged. The criterion is designed to pick up any tubes with an indication of in-plane stability. There are no tubes in Unit 2 that show any indication of wear 1814-AA086-M0238, REV. 0 Page 326 of 415 Page 326 of 414 LTR-SGDA-12-36, Rev. 3 NP-Attachment February 15, 2013 outside of the AVB locations and therefore this criterion does not identify any additional tubes to be plugged.The third criterion states that any tubes that have a number of sequential AVB wear indications in the eddy current data and that are predicted to be unstable for the next cycle's power level should be plugged. A review of the FASTVIB results at different power levels shows that a minimum of 5 sequential AVBs needs to be ineffective to have in-plane instability, 8 sequential missing AVBs at 80% power, and 9 sequential missing AVBs at 70%power. A review of the eddy current data shows that there are no tubes that have 8 or more sequentially missing AVB supports. Therefore, it can be concluded that this criterion does not select any additional tubes to be plugged.The fourth criterion states that any tubes having wear at the top tube support plate and AVB wear at two consecutive locations of the tube should be plugged. This criterion is based on the premise that it takes a minimum of two sequential AVB supports at 100% power for the worst tube to have an out-of-plane tube excitation ratio over one. It also takes a minimum of two sequentially missing AVBs out-of-plane to obtain a tube excitation ratio above one at 80%power. It takes a minimum of three sequentially missing AVBs out-of-plane to obtain a tube excitation ratio above one at 70% power. In Table 9-4 for Steam Generator 2E088 and Table 9-5 for Steam Generator 2E089, the tubes that need to be plugged due to these criteria at 70% power are shown in green. The tubes in these tables shown in yellow should be plugged for power levels of 80% and 100%. At 100 to 80% power, Steam Generator 2E088 has 10 additional tubes that require plugging and Steam Generator 2E089 has 10 additional tubes that require plugging. At 70% power, Steam Generator 2E088 has 2 additional tubes that require plugging and Steam Generator 2E089 has 3 additional tubes that require plugging.The fifth criterion states that any tube that has gap-limited FEI out-of-plane and has wear projections exceeding the plugging limit should be plugged. The wear evaluation shows that the limiting tubes have small amounts of projected wear at both 80% and 70% power and that no additional tubes will require plugging during the next cycle.In summary, it was found that by applying the five criteria that were developed based on the Unit 3 eddy current data to the Unit 2 eddy current data, 5 additional tubes (beyond those currently plugged) would need to be plugged at 70% power and 15 additional tubes (beyond those currently plugged) would be required to be plugged for operation at 100% to 80%power. A list of the additional tubes to be plugged at the 70% and 80% power levels is shown in Table 9-6.1814-AA086-M0238, REV. 0 Page 327 of 415 00 m C0 Page 327 of 414 LTR-SGDA-12-36, Rev. 3 NP-Attachment February 15, 2013 Table 9-1 Results of Eddy Current Review and Flow-Induced Vibration Analyses for Boundary and Adjacent Tubes in Columns 74-85 (Page 1 of 2)Selected Tubes wi TubelD SG Row Col 114074 SGM 114 74 112074 5GM 112 74 110074 5GM 110 74 103075 SG88 103 75 101075 5088 101 75 115075 SG88 115 75 U3075 5G88 113 75 111075 ,568 111 75 1000176 SG88 1(30 76 98076 5688 98 76 121077 SG88 121 77 119077 5G88 119 77 98078 SG88 98 78 96078 SG88 96 78 122078 SG88 122 78 120078 5G88 10 73 113083 5G88 113 83 111083 SG88 111 83 92184 ,GM 92 84 9M4 SGM 90 8W 93085 SG88 93 85 91085 SG88 91 85 SONGS-3 SG8S his < 8 AVU Indlcation (Bobbin] Wth Adjacent Nelhbobr 301 B02 3 M3 IF% 60 M M 6 M 1ON -I B10 B11 8I1 IC 13812 2MOMN Xxs-. It XC 7X X 191 1 U , x x 1 I 6d.-19I74-X X , X 6d- 121 X 10 7 IC S a Sj x 119 x. x 2xl 1 9 x x x 12 5l 7-X I 7 1221d-- 7s- X-. 6sX 23- .8- X 6 X x 6 32 S X X 6s- XI 5 1151 6 9 I 6M 6 x 6 9 S 1151 ,, x 12 4 24 20 8 xd I 1(7)0 14 11 55,Its 19d

• 14i , Hll 12 10 8 5 1 16 10 16 xI 1U as-. 1- 7 3W IS 16 28 37 37 17 XC 11 19 20 IS15 MMN 2611812 17 IC 1x 6 7 16 18 17 21 .-6d 9 146- 44 14 6 x x 14 1411 17 M I X 9 12 6 xý4 is1401 30 --Ud Sd &M 11d 11 7[X13 17 19 X X 123L1 Cases 1 15 26 27 77 36 64 52 78 78 47 2 27 3 4 5 43 76 67 71 76 6D 69 76 78% 6a U8 3652 77 78 is Out of Plane In Plane Ali Wear SR for 0- 5D SRfor p7.8 Contained OP0 OP2 0P3 0P4 0PS IP2 IP3 IP4 1, within AM?Yes No Yes No Yes Yes Yes No No Yes No No No Yes Yes No Yes No Yes Yes No Yes No No No 63 77 78 36 66 To 74 26 73 78 45 78 61 73 78 27 45 61 66 70 73 29 55 16 78 39 47 65 70 111085 SG88 109085 S588 107085 SG88 111 109 107 as 85 85 66 46 70 77 0,-.31 00 0 0, m 0 Page 328 of 414 LTR-SGDA-12-36, Rev. 3 NP-Attachment February 15, 2013 Table 9-1 (Continued)

Results of Eddy Current Review and Flow-Induced Vibration Analyses for Boundary and Adjacent Tubes in Columns 88-90 (Page 2 of 2)a.Ce I *5 -It-96M~ S688 94088 SG88 10O89~ SG88 103089 SG88 30M SG88 104090 S688 96 94 105 105 106 1U4 88 88 6 X 1211 6 L!gj A 23 Xa-. 7 11 89 x a9 X 133 _ 12 X_1311 -10, X a 78 28 37 45 76 78 47 61 66 55 66 7s 55 70 54 61 74 4=No Yes No No Yes No 90 90 S 7 X IMMM M241 XI IX X X X X 6"- X 1MIS Notev/Lgend: RN x R C ID SG Row Numbers In black font under AVS locations Indicate bobbin %rW from original data ie Numbers In red font under AVS locations Indicate RPC%TW from original data file Indicates low level wear from WEC evaluation of RPCECT file Black box shows extent of consecutive AVis In the OP mode that best fits the data and analyses Dark red box shows extent of consecutive AVMs In IP mode that best fits the data and analyses Arrows show direction of wear scar extent outside AVI, s or d for single- or double-dded wear on tub*ULght red shading Indicates AVB anomaly such as observable taper/twist In wear scar LIght green shading Indicates oneaof a number of consecutive AVIBs with wear Yellow shading Indicates a potential Ineffective site when defining cases to evaluate Orange shading corresponds to tubes with 4 or more TSP wear calls on both sides AVB misalignment or off-nominal Interaction (other than twist)Col Tubes Identified by blue font Indicate tubes that could have TtT wear due to IF lnstabilt (either alone or due to adjacent tube In same column) Page 329 of 414 LTR-SGDA-12-36, Rev. 3 NP-Attachment February 15, 2013 Table 9-2 Results of Eddy Current Review and Flow-Induced Vibration Analyses for Interior Tubes in Columns 76-80 (Page I of 2)m 0 C<Selected Tubes wlki 7AVy3lndlcatons lftbbin) Cases T_ SRfor f.-5.0 SR f.oF 7.8 TuMlD SG Row C0l 881 O02 SM JFS4l *06 WS BOO B07 BW 80 FStl 510 511 BL2 1 2 3 4 OP1 0P2 0P3 0P4 0P51 IPt 1P2 INIM IP4 L 11M076 S.(21 106 76 103077 SGB8 103 77 107077 SG88 107 7 109077 5388 109 77 113077 SG8H 113 77 118977 S(M 115 77 117077 SG88 117 77 107078 52m 107 78 104078 5,G8 104 78 MOMB S(M8 lUb 18 108078 SG88 108 78 11D078 5;83 118 78 103079 SG88 103 79 105079 5(88 105 79 107079 UM 107 79 109079 5(188 109 79 1U./9 S(, l, /9 117079 SG88 117 79 121079 S088 121 79 96080 5G88 95 80 9800 SG88 98 80 100080 SG88 100 80 102080 SG88 102 80 10408) 5G88 104 80 106080 SGBB 106 80 109M80 SG88 103 80 112080 5G88 112 80 114080 S(88 114 80 116080 SG88 116 80 118000 SG88 118 80 13 13 15 21 14 18 21 19 11 40 21 23 37 14 28 80 20 25 39 14 S 6 x x 15 9 8 6 13 8 9 7-9 14 11 21 6 9 6 23 77 9 0 11 14 1' 17 7 53 12 8 22 27 I i0 71 2S 13 22 14 S 24 13 '9 11 11 10 18 1U 18 17 11 1j 9 13 24 S9 23 lb 99 X 17 65 10 17 18 12 18 39 20 15 5D 20 1. .57 14 18 39 16 lb 24 1U 18 81 10 15 14 6 6 11 11 10 7 17 8 16i 16 17 20 14 17 9 10 10 9 6 9 13.13 8 10 12 9 11 8 11 11 16 12 7 14 16 11 13 5.5 17 12 7 14 13 23 16 lb 11 13 is 12 13 23 11 17 13 70 16 10 I 14 11 10 46 19 48 48 31 70 46 49 22 45 3B 43 41 3b 38 17 10 15 8 7 22 16 13 17 11 8 17 15 12 16 11 12 13 24 14 14 1i 25 20 18 15 27 25 5 6 X 14 i1 23 13 23 26 17 19 24 13 13 25 21 14 18 13 10 20 78 76 74 78 78 18 90 10 1 21 22 17 27 13 13 13 13 12 7 1 13 311 17 19 20 13 31 17 10 6 22 7 16 16 22 16 22 24 22 18 15 24 10 15 18 72 18 81 14 57 17 59 11 11 18 22 20 33 17 35 12 31 15 31 26 16 11 18 19 7'23 7 12 7 22 13 21 9 22 5 17 7 9 x 7 x 12 5 14 x 13 9 9 8 10 6 5 8 6 x 8 10 7 12 9 9 9 9 a 8 7 7 13 32 8 31 9 19 10 14 14 30 19 57 16 51 9 33 8 47 12 13 12 15 11 17 15 17 9 6 6 13 17 15 16 18 23 14 12 9 7 8 10 19 17 26 26 26 16 19 77 78 25 23 19 is 18 20 10 13 10 10 11 76 78 I I 4., _L 00 OD CO N, m 0;U Page 330 of 414 LTR-SGDA-12-36, Rev. 3 NP-Attachment February 15, 2013 Table 9-2 (Continued) Results of Eddy Current Review and Flow-Induced Vibration Analyses for Interior Tubes in Columns 81-86 (Page 2 of 2)S* ctd Tlswith > 7AV Indkctlm IBon 1801% Cases SR to- 5.0 SR tot f 7.8 TUab.1 50 Row Ca Sol O 0 IF5 wo. OW Mo n7 606 am IFScl BIG 811 812 1 2 3 4"0 1)(D 0--h C,'95061 5688 95 81 97OR1 WM 97 81 99"61 M 99 81 101081 S88 101 81 103091 SG88 103 81 107081 5388 107 81 11mil SGM 111 A1 113081 588 113 81 113261 SG88 115 81 96082 SG88 06 82 2UJ8IU 14, IM 82 104082 5M88 104 82 206082 SG88 106 82 108082 5G88 108 82 114062 SG88 114 82 103063 5688 101 93 103083 SG8 103 83 100284 SG88 100 84 102084 SG88 102 94 104084 5488 104 84 10(04 SGS8 108 84 112084 SGR3 112 84 99083 5(38 99 85 104086 5(38 104 86 22 9 18 16 it 12 20 15 13 13 7- 19 10 19 7 1?9 10 18 68 16 12 8 11 18 67 16 16 7 17 15 z 18 78 25 15 7 6 20 SO 16 6 12 6 23 W 13 X 9 I 22 59 15 6 8 3 17 % 14 5 r 18is S 3 10 9 11 9 S 7 11 8 8 9 I 10 41 12 5 45 6 44 12 8 27 6 11 41 9 10 38 X 9 35 11 6 13 10 9 9 8 6 25 8 30 9 10 39 21 13 48 1I 8 51 9 14 22 16 6 9 9 54 9 X 46 8 5 R 10 10 13 9 10 11 10 11 11 2D 17 21 19 71 18 18 17 if 14 23 5 18 21 20 19 19 X 23 25 X 26 9 8 14 I 15 10 20 8 13 12 12 9 8 21 13 14 11 is 13 12 15 14 43 22 42 14 59 18 52 13 46 12 18 15 31 is 15 22 22 7 10 6 15 6 17 1 7 7 19 13 10 9 I1 X_oP1 oP2 OP3 oP4 oP51 iP1 IP2 IP3 gP4 IP5a ce-I 18 6 1U 12 16 8 27 6 x x 9 8 8 10 15 8 10l 78 78 43 78 78/8 78.57 43 78 78 78 79 63 77 78 78 72 51 78 78 70 78 51 W3 /8 43 57 78 7A 78 12 12 16 42 16 78 78 78 50.. .. .g .. .. ..17 17 3 7 25 X 8 11 8 7 5. 13 1i 23 11 1411 X 11 21 37 1321 17 20 2D 22 37 I 11 8 14 6 13 21 12 37 14 14 20 9 50 6 18 12 t 10 11 11 5 11 X 16 13 7 5 6 9 6 8 6 9 12 9 12 11 11 12 9 23 10 9 36 12 66 19 10 11 14 10 44 11 44 8 10 B 7 17 18 17 78 6 15 9 15 73 76 50 73 00 (3o ,)ro3 m<Co Page 331 of 414 LTR-SGDA-12-36, Rev. 3 NP-Attachment February 15, 2013 Table 9-3 Application of Criteria to Unit 3 Tube Sample (Page 1 of 2)31 1 be So Row Co 0 Gm 214 N.568 112 M4 0 5SM 110 74 M SGSI 103 7S a* SCGI 115 75 55 SGSI 113 so SG3S 111 7S U5 S88 10.0 76 U59G83 93 76 6* SCSI 1U 77* SC88 119 77 0 SGSS 95 78" 5SS3 96 73 0 $GOS 122 73* 5GMI 12'0 78 I MSCI 111 83 to~ OWI 07 S 13 19 15 14 10 9 14 in 14 11 31W 19 23 19 23 27 6 24 32 2 1) 32 801 M M iW M ON W9 i'll s18 all 521 7 OX 12 11 13 is 22 S a S xi119 Y,~ x A 6I 10 9, Xý .x 12- 5-5~i~~ 7 1201 A x~ fit x 1231 x A 0 A 5 ;: 7122 I II -C x AdJ-. XI- 5,W 1231 XS-.I AV Weir¥e5 oPI IPI SM1 vwthoýAVKI Yes No Yes No 12 Yes Yes 11 Yes No 13 No YeN No 13 No 2) No Yes Yet yet 30 No s x 0 ?x II a I l 3 4) x *i x x#A 23 43 x x x 9 N 20 43 II-I;=I26 1181 17 9 'x X 6.11-"'Tube V-41)Yet Yes yesrl) Yes(I Yes Yes Ye',(l)yes~i yes Yes Yes No Ye, Ye.4.)Yes yes Yes Yes No yes-I 7 SGBS s 5GM8 N# SG8M M S38I a* SCSI GISSCSGSS 65SGSB 92 wo 93 91 W19 107%94 106 103 106 104 AM f8e BS 56 IS as 7-q 35 2S Ix 13 17 29 .X 1231 1 1 S A: 405 9 as-. 20 x 9 x 1211 5 10 x 17 23 13 9 ,13 R14 14 0 7 1 855 53 89 SO 90'43 A Yes Yet No Yes No No No No Yes No No Me No K x It"I:1: X M 9 K(x 9 A tl4'a s4',ý At- 6 7 (W

• A 1 2! 3 XI; 7 I.is 23 15 16 15 19 22 js -t5iLE z s x.. ........ .. ?,? .. ..14k 1311 Ill 12 13 19 12 11:1:: a 7 7 x x X x Ok-I A 16 15,...Yet 0, Oo 00 o0 m 0 Page 332 of 414 LTR-SGDA-12-36, Rev. 3 NP-Attachment February 15, 2013 Table 9-3 (Continued)

Application of Criteria to Unit 3 Tube Sample (Page 2 of 2)S2M455418 ,4 Raw Cul o AM* 0344 Ml1 gal IF, we4 WS4 A44 go1 M6 M J~ ;-U oil g12 Sets310676t:39 SO 1.3 14 1114021 6 is 13 it 16 46 17 1o 1s tSs0313 r, 35 46 13 i 2 37 14 6 9 a 13 7 19 9 7 71" Sets37 r 3 44 1s 31 1n so 0 x I 9 14 16 a 16 12 17 aSet 1097 41 t 21 19 i19 14 x 6 7 11 13 4 11 a 17 0 Sets1Ili77 327 9 14 11.33 4 9 S 31 IS U 5son13t 1 .9 as 22 9 10 U 14 S 12 20 ,1 13 son117 77 17 30 117 7 s,10 a 32 lIV 1 12 13 55 232 1I10 41 1 21 12 " 12 1i 16 17 7 14 34 14 14*S2 IN1 47 s54 35 13 24 97 3 14 10 14 13 23 is is 20 noS38 10 t1 44 SO 92 14 17 fib to & 17 1 11 13 49 5 so3ses1 is n 173 9 W4 17 is 13 11 10 10 16 12 22 S & 9" so M103 Is 041, on Sis470 123930 11 9 11 13461 4 1.1 33 , W 53114IS654 " 13 9 14 So 20 tO 9 .11 17 25213 23 2 M *6 M 107 79 0 44 it It i1 Is "7 14 7 13 a1 1 22 0 4317 V 1I 24 49I13979 402010 19 1o i 14 13 10 t 2 16 10 413 13 3 a'a2SetsS671 333 13 0 Is 1is 6 10 4 9 11 1 14 3 21 14 to SSets177n5 39 6 17 1 1 0 10 15 13 11 103 13 10 55Sts13:21 76 23 33 E1 3 1 E is is 113 1 12 71 55 e96 3 10 3 7 11 ,101 16 31 9 9 1t 13 32 12 13 I a 52138 " a, 11 16 1w 73 5 15 n I 7 w 31 12 17 10 5523129247463 19 33 1:1111 it 7t 11 11 9 19116 14 is a Se3s 201 Ws 16 14 V7 19 ? x 6 9 10 14 31 1i 1I 552Se31M, 9204 01441M 13 la 17 443 21 1 62 9 14 30 17 is It 0 3SG 1 0 37 SS 21 24 11 U 17 7 6. 9 4 1967 16 33 ,6 5590312w91542 17 32 17 n 13 14 6 9 1 1 17 14 5 13113 JS 54 10 Is 20 13 31 2 3 9 2 9 $2 9 U 34 55 31 0 40 4 76 173621 6 t3 11 7 i7 6 9 19 552G 316 17 22 21 24 12 311 17 7 1 a 7 13 6 7 a0S31t 36 3t1 19 1 9 30 10 13 10 13 11.2 .1.47 5 194411 It 6 11 11 10 41 12 6 19 554G1 3971 903 1 14 1947 14 16 17 1 V S 46 4 a 7t1 5Sets "9W. 43 a 17 1 IS 172 U 1321 6 5 441% 10 i2" Sea3101 M 044 672 1t 152s 3s 7 Is is 9 It 7 6 10 is 603 113 it 37 B 13 is 20 SO 1 6 10 7 1141 9 10 17 55 213 13 r, 44 19 is 7 11 10 A 9x 13 17 551109 27201 19 3341 31 W 6o 9, 9 9i 3S2 9l 14 5 5t 111'1 44S 7 it 17 44 I& s 4 2 s 130 10 3 , W3 113 M 37 40 0 10 1i M1 as 106 9 0 9 9 11 6 a 5 S 9 112 I t s 35 21 14 16 It 4 It I 6 is 10 N 55t 91962 V is 13103 43 72 7 9 $ 30 .1 U 13 59 S,03 09 44 67 13 7 14 41 14 10 6 0 8 10 Ut It 7 21 55G 3104 W 1 44 63 1S 10 11 49 is 16

• 13
• 13 43 16 11 20 No9Ses M W 43 S4 N a 1 166 13 37 14 96 "0 1 S1 I is 19"12 103 & AD 13 13 13 46 13 7 a is 14 11 W 19 550 31143 1N 13 1 1i i 7 1t 7 a .x 9" Scat 101 in # SS a 1 631 6s 13 10 6 9 $ M 17 23 66 Sets 103 Io S 44 61l 11 %a 16 a s 9 i x _ 0 x 46 Is a set l1v 84 43 11 17 A aSX 8 Ita 7 6 2 55903 ~ A 1221764 so Se IO S 23 1 41 1 1! 11 1 1 36 12 10 31 5 511314 M 244 0 Is 21 17 93 17 11 1 11 6 31 14 66 19 a 19 5so s3as i 746 10 20 It 37 9 1 x 1s 1. 7 9 to 11 7 17 1Ox 10 l 14 10 on Seat " M, 33 5 13 21 Il 3"7 14 a 9 12 1041 11 6 st 1" 141 S 42 58 1 14 21 9 s0 6 9 1 11 9 44 a 2 16 36 1211 17' w4-1 N I 1 233467 I YrdýIV VI.Ye.V_Y_5 Ve_Yet YV'S VI'V.', Y15 YV,s VI'01-, VI'I VI'.ON', VI'K VI', VI', VI',VI', VI'.ON'S 00 0, m 0 Page 333 of 414 LTR-SGDA-12-36, Rev. 3 NP-Attachment February 15, 2013 Table 9-4 Steam Generator 2E088 Application of Criterion 4 Row Col 07C B12 B11 B10 B09 B08 B07 B06 B05 B04 B03 B02 B01 07H 123 133 6 76 120 6 142 86 7 140 82 8 93 113 8 3 115 10 138 108 12 6 132 120 12 134 116 13 138 96 7 109 79 6 8 137 65 8 135 91 6 8 10 7 5 9 135 63 9 138 68 10 136 72 10 134 88 8 7 19 11 139 73 12 113 81 6 9 8 6 9 13 134 62 13 133 65 14 136 64 16 0.0 C,)m 0 Page 334 of 414 LTR-SGDA-12-36, Rev. 3 NP-Attachment February 15, 2013 Table 9-5 Steam Generator 2E089 Application of Criterion 4 I Row I Col 107C I B12 B11 B10 B09 B08 B07 B06 B05 B04 B03 B02 B01 107H I-u (A 0 139 109 9 103 97 16 1 31 116 96 6 12 14 7 8 126 78 10 13 7 8 134 88 8 6 8 6 6 8 120 96 r9 13 7 6 5 9 141 89 9 132 102 9 138 90 16 14 9 I11 6 10 134 92 8 9 5 7 10 118 98 10 132 104 10 95 91 11 6 14 137 111 14 Page 335 of 414 LTR-SGDA-12-36, Rev. 3 NP-Attachment February 15, 2013 Table 9-6 Tube Plugging Recommendation Steam Generator 2E088 Steam Generator 2E089 80% Power 70% Power 80% Power 70% Power Row Column Row Column Row Column Row Column 113 81 135 93 80 68 80 68 134 88 137 89 103 97 104 72 135 91 104 72 132 94 135 93 116 96 137 89 120 96 126 78 132 94 134 88 134 92 138 90 1814-AA086-M0238, REV. 0 Page 336 of 415 0)00 IA*.0.Page 336 of 414 LTR-SGDA-12-36, Rev. 3 NP-Attachment February 15, 2013 16 Boundary Tubes-Have FS wear but only a few bobbin ECT indications at AVBs 15 Adjacent Tubes-Investigated as potential sources of TtT interaction 55 Interior Tubes-All have clear evidence of multiple ineffective AVB supports based on bobbin ECT indications

-) <-) U (j)S0 0b%0 eo 0 oo 0 J3 8)Condition Reoort: 201836127 Rev. 0 4/30112 D. 60 Figure 9-1 Location of SG 3E088 Tubes Evaluated to Develop Criteria for Tube-to-Tube Wear Page 337 of 414 LTR-SGDA-12-36, Rev. 3 NP-Attachment February 15, 2013 a,c,e Figure 9-2 RowlOOCBO Case 78 OP Modes I and 2-UBend Tube/AVB Wear* is Consistent with Gap-Limited FEI-(*Average for Seven Tubes in R102-R106 SG 3-88) 0, 0 m 0 Page 338 of 414 LTR-SGDA-12-36, Rev. 3 NP-Attachment February 15, 2013 a,,c,e Figure 9-3 RowlOOC8O Case 78 OP Modes 1 through 4-Both Straight Leg and UBend Tube/AVB Wear* are Consistent with Out-of-Plane FEI-(*Average for Seven Tubes in R102-R106 SG 3-88) 00 00 0)0 CD 0O 0 CA"13 Page 339 of 414 LTR-SGDA-12-36, Rev. 3 NP-Attachment February 15, 2013 a,c,e Figure 9-4 R100C.O IP Modes 1 and 2 Become Possible at Similar Excitation Levelsto OP Modes 3 and 4 (00Page 340 of 414 LTR-SGDA-12-36, Rev. 3 NP-Attachment February 15, 2013 a,c,e 0 00 Co 0 Figure 9-5 Tube Wear Scar Extension in SG 3E088 are Consistent with IP Frame Mode 1 Page 341 of 414 LTR-SGDA-12-36, Rev. 3 NP-Attachment February 15, 2013 10.0 Recommendations Regarding Operation at Reduced Power Levels The prior section developed a set of plugging criteria considering both the Unit 2 experience and the Unit 3 experience. Five general criteria were developed and focused on tubes not currently plugged. The first two criteria (Criterion 1 and Criterion

2) are not related to power level; however the remaining three are related to power level. Criterion 3 considered the effects of ineffective AVBs and the potential for in-plane motion. It was determined that no currently unplugged Unit 2 tubes were affected by this criterion, therefore this criterion would not affect the selection of an acceptable future power level, as all tubes passed this criterion even at 100% power. This criterion indicates that operation at a reduced power level will not adversely affect the remaining unplugged tubes in Unit 2. However, both Criterion 4 and Criterion 5 are affected by the power level. These two criteria are discussed in the following sections.Recommendations regarding operation of the SONGS Unit 2 steam generators during the next operating period are then summarized in the last section and are based upon application of all applicable criteria.10.1 Additional Unit 2 Tube Plugging Due to Criterion 4 As discussed in Section 9, there are 5 additional tubes in SG 2E088, and 10 additional tubes in SG 2E089 that do not meet this criterion for power levels at 80% or larger. For operation at 70%power, 2 additional tubes in SG 2E088 and 3 additional tubes in SG 2E089 fail to meet this criterion.

All other active tubes in Unit 2 do not show the ECT characteristics associated with tube-to-tube contact observed in Unit 3. These ECT characteristics were developed after review of the Unit 3 data. Consideration should be given to plug these tubes for operation at the indicated power level.10.2 Tube Wear Criterion 5 It is known that wear at the U-bends is typically a result of limited displacement fluidelastic tube excitation and extensive testing has been performed (Reference 10-1, 10-2, 10-3) to develop methods to predict wear associated with this mechanism. As long as the gaps are reasonably small and the other wear parameters, such as [ ]a,c,e etc., can be quantified, then it is possible to effectively manage the amount of wear that could occur while the tube is vibrating within a limited gap. The amount of tube wear that is acceptable depends upon design allowances incorporated into the tube relative to the SONGS technical specification limits, and what is considered acceptable based upon operational or commercial considerations. With respect to the SONGS technical specification limits, as long as the wear is less than 35%through-wall, then the tube is considered to be acceptable and will not require plugging should wear progress to this depth. With respect to SONGS Unit 2, the primary concern is to maintain an acceptable amount of tube wall thickness (SONGS technical specification limit) after the next period of operation such that appropriate SG performance criteria would be met. In addition, it is desirable not to have a large amount of additional tube wall degradation such that many more tubes would then be required to be removed from service during some future outage after 1814-AA086-M0238, REV. 0 Page 342 of 415 Page 342 of 414 LTR-SGDA-12-36, Rev. 3 NP-Attachment February 15, 2013 additional cycles of operation. Since there are plans to implement a longer term fix, higher wear rates are considered to be acceptable for a short period of time. Once the longer term fix is implemented, there would be a reduction in the rate of wear that would occur over subsequent periods of operation. Calculations performed in Section 7.0 indicate that for the power levels considered, the amount of wear that could occur on the limiting tubes over the next period of operation, 6 months, would be small (less than [ ]a,c,e). Additional analysis was performed in Reference 10-4 to consider the effect of wear after 18 months of operation. This analysis indicates that additional wear would occur, but this level of wear was also relatively low. This was found to be the case for both the limiting active tubes, and the limiting plugged tubes 1 4.Tube wear rates of these amounts would not impact the pressure boundary and also would not be expected to significantly increase tube plugging levels before implementation of the longer term fix. Operation for longer periods of time could potentially result in additional tubes requiring plugging, however since SCE is planning on a longer term fix, this is currently judged to be acceptable. 10.3 Recommendations The wear analysis indicates that SCE can operate the SONGS Unit 2 steam generators without significant additional tube wear at power levels of at least 80% at the current plugging level. The analysis has determined that some tubes would vibrate between AVBs in the out-of-plane direction but the amplitude would be limited. Therefore the tubes would not be unstable in the classical sense, as large motions are prevented by the tube impacting on the AVBs. In addition, no active tubes were found to be unstable in the in-plane direction for operation at 100% power.Displacements between AVBs will cause some tubes to experience additional wear over the next period of operation. However, the amount of wear associated with that mechanism would be manageable over that period of time with maximum additional wear on both active and plugged tubes to be less than [ ]a,c,e mils. Note that operation of Westinghouse steam generators with marginally unstable tubes in the constrained amplitude sense is not uncommon since the amount of wear that occurs during operation is small and within design wear allowances. The consequences of this type of motion are modulated, or reduced by random flow turbulence for the condition where there are effective supports with small clearances. The amount of wear that has been experienced at the SONGS Unit 2 SGs during the prior operating cycle is larger than what would normally be considered acceptable. As a result, certain actions have been taken by SCE to reduce the likelihood of a tube leakage event. This includes plugging and stabilizing certain tubes with large wear scars along with tubes with little or no wear in affected regions of the SG. In addition to these actions, Westinghouse recommends that SCE operate the SONGS Unit 2 SGs at a 70% power level for the operational period after plugging the additional tubes as indicated in Section 9.14 Some tubes with very low level wear may have more absolute wear depth increase when sharing of tube/AVB interaction involves locations that are on the beginning of the depth-volume curve (see Figure 7-12), but the total %TW depth for such cases will be much less than for the limiting tube locations with fully developed wear characteristics. 1814-AA086-M0238, REV. 0 Page 343 of 415 Page 343 of 414 LTR-SGDA-12-36, Rev. 3 NP-Attachment February 15, 2013 10.4 References 10-1 P. J. Langford, "Design, Assembly, and Inspection of Advanced U-Bend/Anti-Vibration Bar Configurations for PWR Steam Generators," Transactions of the ASME Journal of Pressure Vessel Technology, Vol. 111, Nov. 1989, pp. 371-377.10-2 H. J. Connors and F. A. Kramer, "U-bend Shaker Test Investigation of Tube/AVB Wear Potential," Fifth International Conference on Flow-lnduced Vibrations, Paper C416/014, IMechE, Brighton, U. K., May, 1991, pp. 57-67..10-3 P. J. Langford and H. J. Connors, "Calculation of Tube/AVB Wear from U-Bend Shaker Test Data," Fifth International Conference on Flow-Induced Vibrations, Paper C416/040, IMechE, Brighton, U. K., May, 1991, pp. 45-55.10.4 LTR-SGMP-12-73, "San Onofre Nuclear Generating Station (SONGS) Unit 2 -Projected Tube Wear Values for 18 Month Refuel Cycle at 70% Power Level", J. X. Jenko.1814-AA086-M0238, REV. 0 Page 344 of 415 Page 344 of 414 LTR-SGDA-12-36, Rev. 3 NP-Attachment February 15, 2013 Appendix A: Nomenclature A Ai A, A,B,C ASME ATHOS ATHOGPP ATHOSGPP AVB Cl CL Cm CR CCQR CE CFD CL CLCOLD CLEGGC CLHOT CLSEP d, D De Ditube E ECT EFPM EPRI ER fn F FASTVIB FLOVIB FIV FSR FW HL HTRESF ID IP area tube inside area stabilizer area empirical constants in damping correlations American Society of Mechanical Engineers Analysis of the Thermal-Hydraulics of Steam Generators Westinghouse's version of the pre-processor program to ATHOS EPRI's version of the pre-processor program to ATHOS anti-vibration bar empirical turbulence constant (magnitude) lift coefficient added mass coefficient random excitation coefficient pressure loss factors for AVBs in the U-bend region Combustion Engineering computational fluid dynamics cold leg pressure loss factors for the downcomer on cold leg pressure loss factors for the tube support plates pressure loss factors for the downcomer on hot leg pressure loss factors for the primary separators tube diameter equivalent hydraulic diameter tube inner diameter modulus of elasticity eddy current test effective full power months Electric Power Research Institute Excitation Ratio vibration frequency in nth mode (Hz)force computer code for FIV analysis computer code for FIV analysis flow-induced vibration fluidelastic instability ratio = Ue/Uc feedwater hot leg fouling factor value input to ATHOS inside diameter in-plane 1814-AA086-M0238, REV. 0 Page 345 of 415 Page 345 of 414 LTR-SGDA-12-36, Rev. 3 NP-Attachment February 15, 2013 ISI IX, IY, IZ K L m MHI Ms, ms N NDD NSSS OD OP p PDRUM Peff Air PeffWater PLATES Ps,ps Pw, Pw R RMS RPC RSG RxCy S SCE SG SONGS SR SS SVI t TAPE7, TAPE20 Tod Tw TEMA TH TSP TTW U Uc, Ucn Ue, Uen in-service inspection index directions, x, y, and z in ATHOS model appropriate tube wear coefficient length mass per unit length Mitsubishi Heavy Industries stabilizer weight per length number no detectable degradation nuclear steam supply system outer diameter out-of-plane tube pitch pressure in the steam dome stabilizer effective density with air surrounding stabilizer effective density with water surrounding pre-processor program to ATHOS stainless steel density water density radius, radial direction root mean square rotating pancake coil replacement steam generator row x column y tube location empirical turbulence constant (slope)Southern California Edison steam generator San Onofre Nuclear Generating Station stability ratio or instability ratio (same as FSR)stainless steel single volumetric indication time binary files to the PLATES program tube outer diameter tube wall thickness Tubular Exchanger Manufacturers Association thermal-hydraulic tube support plate tube-to-tube wear velocity critical velocity effective velocity 1814-AA086-M0238, REV. 0 Page 346 of 415 Page 346 of 414 LTR-SGDA-12-36, Rev. 3 NP-Attachment February 15, 2013 V calculated wear volume VGUB post-processor program from ATHOS Wr workrate coefficient WR workrate ZW axial locations in ATHOS model 1814-AA086-M0238, REV. 0 Page 347 of 415 Page 347 of 414 LTR-SGDA-12-36, Rev. 3 NP-Attachment February 15, 2013 Greek oa modal effective slip void fraction j3 threshold fluidelastic instability constant 6 damping log decrement, 5=2nr 8(x) displacement at position x in ASME terminology critical damping ratio (%)Tcircumference/diameter of circle, 3.141...p density normalized mode shape factor 0 circumferential direction Subscripts upstream a TSP/AVBs e equivalent Eff effective f liquid phase g vapor phase G geometry inside, index for summation or integration index for summation or integration m mass max maximum n mode number o outside, reference condition t tube Superscripts empirical exponent in damping correlation 1814-AA086-M0238, REV. 0 Page 348 of 415 Page 348 of 414 LTR-SGDA-12-36, Rev. 3 NP-Attachment February 15, 2013 Abbreviations for Units in Measurement Systems Hz kg, Ibm Ib, lbf t m, mm, ft, in hr, sec or s bar, Pa, psia, ksi W, Btu OK, °C, OF Hertz (cycles/s) kilograms, pounds mass pounds force 1000 kg or metric ton meters, millimeters, feet, inches hours, seconds 105 Pascals, Pascals, pounds per square inch absolute, 1000 psi Watts, British thermal units degrees Kelvin, Celsius, Fahrenheit 1814-AA086-M0238, REV. 0 Page 349 of 415 Page 349 of 414 LTR-SGDA-12-36, Rev. 3 NP-Attachment February 15, 2013 Appendix B Additional Proximity Analysis for R111/1113C81 This appendix contains additional discussion and analysis results not contained in Revision 0 of this report. This discussion provides a reasonable explanation of how the two SG 2E089 tubes were in contact and produced the free span wear found on R11IC81 and R113C81. It is recognized that there may be other explanations regarding how this wear was produced, however, the following provides a basis for the observations found during both the PSI and the recent ISI inspections. B-1 Introduction Section 7.5 addresses the two tubes found with tube-to-tube wear in Unit 2. After completion of the original report, additional eddy current and computer analysis of the conditions associated with SG 2E089 was performed. The following contains results of this analysis. One key aspect of the analysis is the condition of the SG tube bundle prior to start up. During the pre-service inspection, it was determined that a proximity condition existed for these two tubes (R111/113C81). These indications are likely to be associated with conditions that developed during SG manufacture. Section 8.2.1 discusses issues that can occur during assembly of the SG tube bundle that could affect how proximity conditions could develop.B-2 Eddy Current Review The FIV analysis performed by Westinghouse concludes that tube locations Ri 11 C81 and R113 C81 in SG 2E089 remain stable in the in-plane direction at both 100% and 70% power levels. The review of AVB wear scar characteristics indicates that there was no extension of the wear scars beyond the width of the AVBs, thus supporting the analysis results that these tubes, as well as all other tubes in SGs 2E088 and 2E089 that had a review of their ECT data performed, remained stable in the in-plane direction. Westinghouse was requested to provide an explanation as to how freespan wear could be observed on R1ll C81 and R113 C81 without extension of the wear scars beyond the AVBs.The following discussion presents an explanation of how this could occur.B-2.1 Industry Freespan Wear Experience Without In-Plane Instability In recirculating style SGs, there have been numerous examples of tube-to-tube wear without in-plane instability; these examples are exclusive to the original Combustion-Engineering (C-E) SG plants, in the upper bundle square bend region. The tube OD and triangular pitch array in the original C-E style is identical to the SONGS RSGs. In the original C-E SG design, variances in the tube horizontal run dimension, square bend control, and eggcrate tube support positioning can create a reduced tube-to-tube gap condition. Tube wear patterns at the vertical strap assembly often showed tapered wear scars on both of the vertical strips, and sometimes at both edges of the vertical strips. This would indicate that the tube was experiencing out-of-plane displacement, with an oscillatory pattern. It is then entirely plausible that tube-to-tube wear could be experienced at reduced tube-to-tube gap conditions just below the square bend region.1814-AA086-M0238, REV. 0 Page 350 of 415 Page 350 of 414 LTR-SGDA-12-36, Rev. 3 NP-Attachment February 15, 2013 At one plant, tube-to-tube wear was experienced in the horizontal run region, just outside of the square bend. In this instance, variance in the tube vertical straight leg dimension created a reduced tube-to-tube gap dimension at this location.At another plant in 2004, tube-to-tube wear was reported on a tube in the vertical straight leg region, just below the square bend. The elevation of the indication was actually within the bounds of the diagonal bar, but clearly rotated 90 degrees from the diagonal bar on the +Pt terrain plot.One of the adjacent tubes in the same column was degradation free; the other tube was plugged several outages prior and no RPC data was available for this tube at the time of plugging. It should be noted that this indication would have remained in service if the RPC testing had not been performed. This SG has mill annealed tubing and one of the special interest RPC programs implemented was a sampling of historical bobbin signals at tube support structures to confirm the degradation morphology. Due to the tubing material, axial ODSCC was a potential degradation mechanism thus the RPC sampling program intended to confirm the morphology of the historic bobbin signals.Scrutiny of the bobbin data could not identify presence of tube-to-tube proximity below the indication. In the square bend region, it was judged that the inherent interference associated with the square bend geometry, limited proximity detection using the bobbin coil. RPC data is available for both 3-coil and single coil +Pt probes. The 3-coil probe includes a +Pt coil, a 0.115 inch pancake coil, and a 0.080 inch high frequency pancake coil. The single coil +Pt and the +Pt coil of the 3-coil probe did not detect proximity above or below the indication. The elevation of the indication was such that a substantial length of tube above the indication could be acquired with the 3-coil probe, thus adequate pancake coil data is available to formulate proximity judgments. The 0.115 inch pancake coil does not show proximity below the indication, but proximity is observable immediately above the indication, in the square bend, and in-line with the wear indication. A short portion of the wear length and proximity length overlap, but wear is not reported over the entire length of proximity. The 0.115 inch pancake coil signal amplitude suggests a proximal gap of approximately [ ]a,b,c inch. Figure B-1 presents the 0.115 pancake coil terrain plot showing the proximity signal and the tube-to-tube wear signal. The cursor (small white arrow) is located at the upper edge of the wear signal.B-2.2 Causative Mechanism for Explanation of the Presence of Freespan Wear Without Wear Extension from A VBs A review of the PSI bobbin data for SG 2E089 indicates that numerous proximity reports were observed on the Row 95 to 123 tubes in Column 81. Based on the bobbin coil proximity amplitude on Rlll C81, the estimated gap with R113 is [ ]a,b,c inch. The signal amplitude on R113 C81 could estimate the gap at [ ]a,bc inch, however, a proximity signal with Rl15 C81 is also present. Since RPC data was not collected at the PSI, the true contribution to the signal observed on RI13 C81 cannot be determined. Therefore, the gap condition has to apply the most conservative value of 0.11 to 0.12 inch.The proximity review described in Section 5 shows that between the PSI and ISI inspections, proximity signals can remain unaffected, could no longer be observable, could be created, or 1814-AA086-M0238, REV. 0 Page 351 of 415 Page 351 of 414 LTR-SGDA-12-36, Rev. 3 NP-Attachment February 15, 2013 could shift from one leg to the other on the same tube. With that said, the proximal condition at any point in time during the first operating cycle could be indeterminate. The PSI proximity condition suggests that the U-bend shape could be non-uniform. This non-uniform condition will create residual stresses within the U-bend. Contact forces between tubes and AVBs could be such that tubes could be held in position for some operating period until such time that these forces are reduced or relaxed, thereby allowing the tube to return to its equilibrium condition. An evaluation of tube motions due to thermal, pressure, and turbulence effects indicate that relative displacements of these tubes to each other can close a proximal gap of 0.03 inch but is not quite sufficient to close a gap of 0.11 to 0.12 inch.The ISI bobbin data could not identify a proximity condition on these (RI1l/R113 C81) tubes.Similarly, a proximity condition was not observed on R115 C81 in the ISI data. UT examination performed by AREVA suggests a tube-to-tube proximity condition between Ri 11 C81 and R113 C81 of approximately 0.19 inch in the area of the tube-to-tube wear, while at the same elevation, the tube-to-tube gap between R113 C81 and Rl15 C81 was approximately 0.31 inch, or near the design nominal condition. Thus, the UT data suggests that the proximity condition between R111, R113, and R115 could imply that if these tubes returned to an equilibrium condition during the first operating cycle, the gap between RI13 and Ri15 is near nominal, whereas the gap between R1 11 and R1 13 could suggest that the R1 11 U-bend length is longer than design nominal. Alternatively, this condition could be attributed to a longer than design vertical straight leg dimension for RI 11, which would only increase the potential for tube-to-tube wear due to out-of-plane vibration. The UT data for Ri I1 C81 also indicates that the dimensions to R112 C80 and R112 C82 are much smaller than nominal, while the dimensions to R110 C80 and R1 10 C82 are larger than nominal. These observations also support the judgment that either the R1 11 U-bend is not near normal, or the vertical straight leg length of R1 11 C81 is longer than nominal.Still the question which must be answered is how the current gaps could be justified. An extensive review of the wear scars on the Column 81 tubes was performed. A pattern quickly emerged, which was that oddly shaped wear scars were observed at AVB 5. The profile of these wear scars has a differing depth profile that is not uniformly deep (flat wear) and not a single tapered indication. Instead, these wear scars exhibited a "saw-tooth" profile, clearly formed by two distinct wear scars. This pattern can be explained by a sudden shift in the tube position relative to the AVB, in other words, the tube "skipped" relative to the AVB. The proximity review concludes that changing proximity condition is common within these SGs. To rule out displacement of the AVB, the bobbin data of the PSI and ISI examinations was reviewed. Since no RPC data is available for the PSI, bobbin data must be used. The bobbin low frequency differential channel was used to establish that the overall length of the bobbin signal response (from a null-to-null condition) was essentially identical between the PSI and ISI exams, thus it can be concluded that the AVBs did not change position.These characteristic wear scars were observed on R113 C81, R115 C81, R117 C81, R119 C81, R121 C81 and R123 C81, all at the AVB 5 location. An example of such wear scars is shown on 1814-AA086-M0238, REV. 0 Page 352 of 415 Page 352 of 414 LTR-SGDA-12-36, Rev. 3 NP-Attachment February 15, 2013 Figure B-2, Figure B-3, and Figure B-4. Figure B-3 presents the +Pt terrain plot of R113 C81 at the AVB 5 location. Each figure includes the +Pt 300/100 mix channel (for flaw detection) and the 35 kHz channel response, for identification of the edges of the AVBs. If the wear bounded by the AVB edges represents the most recent wear (prior to shutdown), and the wear is tapered, the distance from the edge of the original wear to the edge of the AVB can be used to estimate the amount of tube displacement. This dimension has been estimated to range from 0.12 to 0.40 inches, for those tubes which show this characteristic. Note also that this same characteristic was observed on R1 29 C91, at AVB 5. This tube was reported with a proximity call on the cold leg in the PSI data but in the ISI data, a proximity call was reported on the hot leg.Another characteristic of the wear at AVB 5 on these tubes was that shallow depth, short length wear scars were sometimes observed on the opposite AVB. These wear scars were clearly of much shallower depth than the wear scars which exhibited the odd shape. The only way that a wear scar could be observed in the middle of the AVB (not extending to any AVB edge) is if the tube shifted relative to the AVB at some point in time during operation. These atypical indications are associated with significant observations of AVB symmetry variance. In SG 2E089, the largest AVB symmetry variance is observed at AVB 6, and for Column 81, AVB 7 also has significant AVB symmetry variance. If the AVB symmetry variance is associated with AVB twist, and the amount of twist is correlated with symmetry variance, then the largest contact forces would be observed for AVB 6 and AVB 7. As the larger contact forces would reduce the potential for wear, once sufficient wear has occurred at other AVBs to reduce the overall contact force thus permitting the tube to return to its equilibrium condition, the tube can then skip to its current condition. For AVBs 5, 6, 7, and 8, the 95th percentile AVB wear depths are essentially equal, but the AVB 5 depths are deeper for Column 81. For Ri 13 C81, the deepest AVB wear depth is observed at AVB 5 (based on +Pt results).The deepest AVB wear depth reported from +Pt analysis in SG 2E089 was reported on R121 C83 at AVB 5. The indication appears to be uniformly deep and does not show signs of tube displacement relative to the AVB. The wear is single sided; the opposite AVB has not caused degradation of the tube. The +Pt 35 kHz residual data suggest no AVB twist on either bar, however the residual responses for the AVB without wear are modestly less than the AVB with wear. The deepest indication in SG 2E089 reported by bobbin coil analysis was reported on Ri 17 C81 at AVB 9; this indication also appears to have a uniformly deep profile. The deepest wear depth reported from bobbin coil analysis in SG 2E088 was reported on R1 33 C91 at AVB 6.The +Pt terrain plot indicated the indication is stepped. The opposite AVB does not contain wear.The +Pt 35 kHz residual voltages are essentially equal for this AVB, indicating no twist. The 35 kHz +Pt residual voltages on the AVB with wear show a large variance, suggesting significant AVB twist (about 2 degrees).B-2.3 Detection Condition Associated with Wear Extension from AVBs The detection condition associated with wear extension from AVBs was investigated. To perform this assessment, the +Pt 300/100 mix channel noise was compared for the middle of the AVB region and the freespan region just outside of the AVB. The vertical maximum noise condition outside of the AVB was exceptionally small; on the order of 0.02 to 0.04 volt. The noise condition 1814-AA086-M0238, REV. 0 Page 353 of 415 Page 353 of 414 LTR-SGDA-12-36, Rev. 3 NP-Attachment February 15, 2013 within the AVB was typically 50% larger than just outside of the AVB. Therefore, if tapered wear is experienced, and the shallower edge of the wear has a distinct character (i.e., the tapered wear extends for the full length of the AVB width) and no wear is observed outside of the AVB, it can be concluded that no wear is present outside of the AVB as the length along the tube axis from the edge of the wear to just outside of the AVB is short, and not of sufficient length to allow the wear to runout to the tube OD. Since the noise condition within the AVB is greater than just outside of the AVB, the detection of wear within the AVB would then imply a detectable condition and the wear extension would be detected.B-3 Temperature Pressure and FIV Effects A tube-to-tube gap of approximately 0.19 inch near the tube-to-tube wear region was measured after the first cycle of operation between the Rl11C81 and RI13C81 tubes. The gaps between AVBs 3 and 4 were also measured for these tubes. The gap between R1 11C81 and R113C81 was not measurable but a gap of 0.18 inch was measured between R109C81 and R111C81. The gaps between AVBs 3 and 4 and AVBs 9 and 10 between R113C81 and R115C81 were measured around 0.30 to 0.31 inch which is close to the nominal gap of 0.31 inch for this location in the U-bend. The maximum design spacing is 0.344 inch at the top of the U-bend for these tubes. The design spacing of the tubes is shown in Figure B-5. In the UT data there is no reference point to determine if any of the tubes are in the design shape so an assumption needs to be made for the geometry of these tubes. It appears that the RI111C81 tube is deformed relative to the other tubes so it will be assumed that the Ri 13C81 tube is nominal in shape and the R1l1C81 tube is deformed in a way that follows the gap measurements. A sketch of this geometry is shown in Figure B-6.B-3.1 Tube Thermal Expansion One way to postulate a closure in the tube spacing is to assume that the two tubes with tube-to-tube wear are allowed to move within the tube support plate holes as they expand due to normal operating temperature and pressure.Using the tube support plate drawing, Reference B.1, for the broached hole pattern, the maximum geometrical tolerances for the tube support plate holes were considered. Using the maximum tube support plate dimensions and the minimum tube size, it was determined that the tube can move [ ]a,c,e inch within the tube support plate before it comes to rest on the opposite side of the tube. The maximum dimensions of the tube support plate broaching are shown in Figure B-7.The maximum tube movement within the tube hole is also shown in Figure B-7. The scenario that would cause the maximum movement between the tube support plate is the scenario when R1 11C81 is resting on the left side of the broaching at the hot leg and cold leg side. When the tube is brought up to the normal operating temperature and pressure, the tube will expand outward which will cause the tube to move to the outside positions in the tube support plate holes.The RI 13C81 tube is assumed to be in the exact opposite configuration where the tube is pushed to the right side of the tube support plate holes. A schematic of this effect is shown in Figure B-8.This tube model was simulated using the ANSYS finite element program using Solid186 three-dimensional structural solid elements and Solid90 thermal elements. These elements are a 20 1814-AA086-M0238, REV. 0 Page 354 of 415 Page 354 of 414 LTR-SGDA-12-36, Rev. 3 NP-Attachment February 15, 2013 node brick element. A plot of the meshed model in the U-bend region is shown in Figure B-9.The temperature solution was obtained from the FASTVIB output for the 100% power case for the Ri11C81 tube. The temperature profile for the Ri13C81 tube was almost identical to the Ri11C81 tube so the same temperature profile was applied to both tubes. The temperature distribution was applied to the tube by fixing the temperature at the tube support plate locations and then solving for the steady state temperature solution. The temperature change around the tube is fairly gradual such that the steady state solution from ANSYS matches the ATHOS data fairly closely.The tubes were fixed at the tubesheet end of the model and nodes were pinned in the X and Z directions at the tube support plate locations. The AVB supports were neglected in the model.The AVB supports are assumed to be sufficiently loose such that they do not provide support in the in-plane direction. The results show that the R111C81 displaces 1.181 inches and R113 displaces 1.159 inches which gives a relative displacement of negative 0.022 inches.B-3.2 Tube Movement at A VB 5 It has been found that at AVB 5 for Tube R1 13C81 that there appears to be a jump in the position of the wear scar found in the eddy current data. There are two sawtooth marks on the one side of the tube which indicates that the AVB is twisted and wore a mark that moved slightly then began to wear in a different spot. In the opposite side of the tube, the AVB also appears to be twisted but the wear scar is near the center of the AVB position at the cold leg. This is an indication that the tube has shifted in position relative to AVB 5. The postulation that R 110C81 and Ri 13C81 were initially much closer than the current measurement states that they moved farther apart when this shift in tube position occurred. The finite element model works backwards from this scenario by assuming the inspection geometry of the tubes and then applying a displacement to determine how close the tube was prior to the displacement. The eddy current wear scars indicate the tube moved approximately 0.12 inch to 0.18 inch.The deformed shape model from Section B-3.1 was used and the tube was displaced towards the cold leg side in the X direction 0.12 inch then 0.18 inch. The displacement was applied to the model at the centerline where AVB 5 would cross Tube R1 13C81. A local coordinate system was then used to determine the amount of displacement of Tube Ri 110C81 relative to Tube R1 13C81.The results of the displacement models are shown in Figure B-10 and Figure B-11 for the 0.12 inch and 0.18 inch displacement, respectively. It is shown that for a displacement of 0.12 inch or 0.18 inch, the close up in the gap is approximately one for one. The difference in displacement versus gap closure is only 1 mil different. B-3.3 In-Plane Turbulent Displacement In addition to the finite element models used to show that the tube gap closes, there can also be in-plane motion due to flow turbulence. This in-plane turbulence motion is displacement limited and should not be considered a similar effect as in-plane stability. The purpose of this section is to evaluate the magnitude of turbulent displacement to be used to support the explanation that 1814-AA086-M0238, REV. 0 Page 355 of 415 Page 355 of 414 LTR-SGDA-12-36, Rev. 3 NP-Attachment February 15, 2013 the tubes with tube-to-tube contact are not unstable in-plane. It is known that these tubes have closer than nominal proximity at the cold condition so the tube-to-tube contact is being explained as extreme tube-to-tube proximity with a combination of in-plane turbulent motion and out-of-plane fluidelastic motion.A FASTVIB evaluation was performed for the tubes that had tube-to-tube contact in Steam Generator 2E089. These tubes are R111C81 and R113C81. The turbulent constants C1 and S applicable to the SONGS steam generators are shown in Table B-i. There are two sets of constants based on the flow characteristics around the tube. Two FASTVIB runs for each case are run based on each set of constants. The FASTVIB evaluation was condensed to only include the tubes in Row 111 and Row 113. T he two tubes, R11IC81 and R113C81, have a defined missing AVB Case 61.The results of the FASTVIB runs show that the root mean square (RMS) turbulent displacement is approximately [ Ia,c,e inch for each tube using either set of turbulence constants. Using Reference B.2, the RMS turbulent displacement can be converted to a peak displacement by a factor of 3.5. Assuming both tubes are vibrating, the maximum distance the tubes can be apart and touch due to turbulent displacement is [ ]a,c,e B-4 Summary From the review of the eddy current data and the analysis of the tubes response due to pressure temperature and FIV effects, it appears that the two tubes were very close or were in contact at the start of operation following replacement. The tubes would not have necessarily been in contact before operation, but could have contacted due to peak displacements as a result of in-plane turbulence. Note that displacements associated with the fluidelastic mechanism are not similar to turbulence induced displacements, as the turbulence mechanism is self limiting.UT measurements performed during the recent outage indicates that the tubes could be as close as 0.19 inch. As with all measurements of this type, there are measurement uncertainties that are present in the signals. The uncertainty associated with the UT measurements could range from an estimated low of 4 mils to approximately 20 mils. This means that the actual low end of the gap could range from 170 mils to 186 mils. This is the range of gap sizes that could have developed after the tubes have shifted to the current location. Figure B-12 describes how the tubes could have initially worn due to proximity, and then moved or shifted during operation coupled with temperature and pressure effects to result in the currently observed condition. In summary, it appears as if the tubes were initially very close, or actually contacting prior to operation, where FIV induced turbulence vibration could have produced the observed wear.Then after operation for a period of time, the tubes moved, or skipped to a new location, similar to the skip found in other tubes in the region (up to 0.4 inches). Figures B-13 and B-14 provide a visual indication of how these tubes could have moved. Additional movement of the tubes is possible due to pressure and temperature effects that would then result in the currently observed condition. 1814-AA086-M0238, REV. 0 Page 356 of 415 Page 356 of 414 LTR-SGDA-12-36, Rev. 3 NP-Attachment February 15, 2013 B-5 References B-I. San MHI A.B.C.D.E.F.G.H.I.J.K.Onofre Nuclear Generating Station Units 2 and 3 Replacement Steam Design Drawings: L5-04FU001, Rev. 6, "Component and Outline Drawing 1/3".L5-04FU051, Rev. 1, "Tube Bundle 1/3".L5-04FU052, Rev. 1, "Tube Bundle 2/3".L5-04FU053, Rev. 3, "Tube Bundle 3/3".L5-04FU 101, Rev. 5, "Wrapper Assembly 1/5".L5-04FU 107, Rev. 3, "Tube Support Plate Assembly 2/3".L5-04FU108, Rev. 3, "Tube Support Plate Assembly 3/3".L5-04FU112, Rev. 1, "Anti-Vibration Bar Assembly 2/9".L5-04FU1 18, Rev. 3, "Anti-Vibration Bar Assembly 8/9".L5-04FU 134, Rev. 6, "Moisture Separator Assembly 4/6".L5-04FU135, Rev. 5, "Moisture Separator Assembly 5/6".Generators B-2. B. Brenneman and J. Q. Talley, "RMS Fatigue Curves for Random Vibrations," Transactions of the ASME,Vol. 108, Nov. 1986.1814-AA086-M0238, REV. 0 Page 357 of 415 Page 357 of 414 LTR-SGDA-12-36, Rev. 3 NP-Attachment February 15, 2013 Table B-1 Turbulence Constants aiqht LeQ ReQion I U-bend Reqion , Parameter I Str 4 ---I -Turbulence (fD/U > 0.13)C, S Turbulence (fD/U < 0.13)C, S 1814-AA086-M0238, REV. 0 Page 358 of 415 Page 358 of 414 LTR-SGDA-12-36, Rev. 3 NP-Attachment February 15, 2013 Figure B-1 Other Plant Experience Showing Relation of Tube-to-Tube Wear and Proximity at Shutdown Condition 1814-AA086-M0238, REV. 0 Page 359 of 415 Page 359 of 414 LTR-SGDA-12-36, Rev. 3 NP-Attachment February 15, 2013 Figure B-2 SONGS SG 2E089 Stepped Indication at AVB 5 on RIl 15 C81 1814-AA086-M0238, REV. 0 Page 360 of 415 Page 360 of 414 LTR-SGDA-12-36, Rev. 3 NP-Attachment February 15, 2013 Figure B-3 SONG SG 2E088 Stepped Indication at AVB 6 on R133 C91 1814-AA086-M0238, REV. 0 Page 361 of 415 Page 361 of 414 LTR-SGDA-12-36, Rev. 3 NP-Attachment February 15, 2013 Figure B-4 SONGS SG 2E089 Stepped Indication at AVB 5 on R113 C81 1814-AA086-M0238, REV. 0 Page 362 of 415 Page 362 of 414 LTR-SGDA-12-36, Rev. 3 NP-Attachment February 15, 2013-.34 113-I01 _ .34 DETAIL A 113 I'll I1 DETAIL B Figure B-5 Shape of R1IIC81 and R113C81 Tubes Based on Nominal Dimensions 1814-AA086-M0238, REV. 0 Page 363 of 415 Page 363 of 414 LTR-SGDA-12-36, Rev. 3 NP-Attachment February 15, 2013 113 DETAI I1 DETAIL B "-Io-9" .18 DETAIL A AVB 3-4 AVB 9-10 1 13 -I'll -.109.Figure B-6 Shape of R111C81 and R113C81 Tubes Based on Measured Gaps 1814-AA086-M0238, REV. 0 Page 364 of 415 Page 364 of 414 LTR-SGDA-12-36, Rev. 3 NP-Attachment February 15, 2013 *b Figure B-7 Tube Support Plate Maximum Dimensions 1814-AA086-M0238, REV. 0 Page 365 of 415 Page 365 of 414 LTR-SGDA-12-36, Rev. 3 NP-Attachment February 15, 2013 COLD HOTNQT TO SCALE TO S£OW EXA=,ET-AT EhO Figure B-8 Tube Support Plate Hole -Tube Movement 1814-AA086-M0238, REV. 0 Page 366 of 415 Page 366 of 414 LTR-SGDA-12-36, Rev. 3 NP-Attachment February 15, 2013 Figure B-9 Meshed Tube Model 1814-AA086-M0238, REV. 0 Page 367 of 415 Page 367 of 414 LTR-SGDA-12-36, Rev. 3 NP-Attachment February 15, 2013 0.000 1.000 (in)0.500 Figure B-10 0.12 Inch Displacement at AVB 5 Results (inches)1814-AA086-M0238, REV. 0 Page 368 of 415 Page 368 of 414 LTR-SGDA-12-36, Rev. 3 NP-Attachment February 15, 2013 0.000 10.000 (in)5.000 inI Figure B-11 0.18 Inch Displacement at AVB 5 Results (inches)1814-AA086-M0238, REV. 0 Page 369 of 415 Page 369 of 414 LTR-SGDA-12-36, Rev. 3 NP-Attachment February 15, 2013 Gap -> 0 Mils 1 I R11IC81 and R113C81 Tube in Contact During Operation (Including Turbulent Displacement) IGap ->[21 M,1. ]a c,e I Tube Gap without Peak Turbulent Displacement] [ T b G (2 1 M l ) ] , , IGap ->141 to -201 ]rc'e Mils Tube Gap Including Tube Shift in Eddy Current 3 Wear Data (120 to ~180 mils)Mils 1 Tube Gap Including Pressure and Thermal 4H Effects on One Tube (11 mils)170 -186 mil minimum measure gap with these*7 ranges 5 ap-4 °3to 3 1 5 Kl Tube Gap Including Pressure and Thermal Effects on 2nd Tube (11 mils)Figure B-12 Tube Gap Development 1814-AA086-M0238, REV. 0 Page 370 of 415 Page 370 of 414 LTR-SGDA-12-36, Rev. 3 NP-Attachment February 15, 2013 AVB 5--CURRENT POSITION R1 13C81 , AVB 5 INITIAL POSITION\\INITIAL WEAR SCAR I Figure B-13 R113C81 AVB "A" Eddy Current Wear Profile 1814-AA086-M0238, REV. 0 Page 371 of 415 Page 371 of 414 LTR-SGDA-12-36, Rev. 3 NP-Attachment February 15, 2013 CURRENT POSITION POSITION R 1 13C 81-jiD CURRENT WEAR SCAR Figure B-14 R113C81 AVB "B" Eddy Current Wear Profile 1814-AA086-M0238, REV. 0 Page 372 of 415 Page 372 of 414 LTR-SGDA-12-36, Rev. 3 NP-Attachment February 15, 2013 Appendix C Effect of Installation of Split Cable Stabilizers in the Tube FIV Response C-1 Introduction The main body of this report documents the acceptability of operation of the SONGS Unit 2 steam generators after finding significant tube wear during the recent eddy current inspection. The analysis determined that future operation at 70% power would result in all active tubes satisfying the applicable SG tubing performance criteria. During the course of the outage a significant number of tubes were removed from service, and many of these tubes will be stabilized using AREVA split stabilizers. The post-inspection tube FIV analysis addressed future operation at a reduced power level of 70%, but it did not address changes in FIV response with the addition of the AREVA split stabilizers. The purpose of this appendix is to determine how the tube FIV response changes once the stabilizers are installed while the SGs are operated at 70%power. This information was originally transmitted in Reference C-2 and has been included as a supplementary appendix to this report.The effects of the addition of stabilizers in the tubes will be determined as indicated below: 1) Generate stability ratio maps for all tubes for the more limiting support condition cases (higher number of missing AVBs) for the conditions both with and without stabilizers for operation at 70% power.2) Prepare a more detailed analysis of the limiting tubes as identified in Table 8-1. This will look at specific tubes with the specific support condition at 70% power. Stability ratios will be presented for the cases both with and without stabilizers for operation at 70% power.The following is a summary of the methods and results associated with this analysis. Note that the analysis focused on the fluidelastic stability ratios calculated for the in-plane direction. Out-of-plane excitation ratios were also included for the limiting plugged tubes.C-2 Method C-2.1 FASTVIB The analysis makes use of the FASTVIB computer code used in the original analysis and discussed in the main body of the report. The inputs and boundary conditions used in the current analysis are the same as those used in the original analysis for the base case (70% power, no stabilizers). The prior analysis contains all the relevant background information associated with the FIV analysis. For the cases where a stabilizer is to be installed, the properties associated with the stabilizer are those defined in Section C-2.2.1814-AA086-M0238, REV. 0 Page 373 of 415 Page 373 of 414 LTR-SGDA-12-36, Rev. 3 NP-Attachment February 15, 2013 C-2.2 Stabilizer Properties The stabilizer is a 1/2 inch diameter wire rope manufactured from 304 or 316 stainless steel. The weight and damping properties for the stabilizers have been defined in Reference C-1 and are repeated below: I I]a,b,c,e -Minimum additional damping 0.46 lbs/ft -Weight The length of the stabilizer varies depending upon which row the cable is to be installed. Table C-1 contains a summary of lengths associated with each of the rows. Each tube will have two cables installed, one in the hot leg and one in the cold leg. Note that the design objective is to have the cable installed from the tubesheet and extend into the U-bend to a point 60 degrees from the top of the straight leg (not the top tube support plate (TSP)). This places the ends of the stabilizers 30 degrees from the top of the U-bend on both of the of the tube legs.1814-AA086-M0238, REV. 0 Page 374 of 415 Page 374 of 414 LTR-SGDA-12-36, Rev. 3 NP-Attachment February 15, 2013 Table C-1 Cable Stabilizer Lengths per Row b 1814-AA086-M0238, REV. 0 Page 375 of 415 Page 375 of 414 LTR-SGDA-12-36, Rev. 3 NP-Attachment February 15, 2013 C-3 Results The out-of-plane and in-plane results for both active tubes and stabilized tubes were tabulated for the limiting tubes in Table C-2. These results were compared at 70% power where an active tube is the result for unplugged tube and the stabilized result is for a plugged tube containing a stabilizer. The stabilized tube is also assumed to be filled with water. It was shown in Section 4.4.2 that the difference between the excitation/stability ratios is small whether the tube is surrounded by air or is surrounded by water. In all cases, the stability ratio decreased as a result of the introduction of the stabilizer in the tube.Stability ratio plots are also provided for a set of representative cases for the in-plane direction. Figure C-1 through Figure C-13 show the active tube stability ratio maps calculated at 70% power. Figure C-14 through Figure C-26 show the stability ratio plots for the cases where the split cable stabilizer is considered with operation at 70% power. A summary table of all of the included stability ratio maps is included in Table C-3. Note that these figures have been generated assuming that all of the tubes in the maps have been stabilized with the split stabilizer. Tables C-4 and C-5 contain the actual tube plugging/stabilization lists for SONGS Unit 2.Figures C-27 and C-28 provide the same information in a tubesheet map form.1814-AA086-M0238, REV. 0 Page 376 of 415 Page 376 of 414 LTR-SGDA-12-36, Rev. 3 NP-Attachment February 15, 2013 Table C-2 Limiting Plugged Tube Stabilizer Excitation/Stability Ratio Comparison Number No Stabilizer No Stabilizer with o Stabilizer with Water Stabilizer Water SG Case of 70% Power 70% Power 70% Power 70% Power Missing Out-of-Plane Out-of- In-Plane In-Plae AVBs PlaneIn-Plane I __ Limiting Plugged and Stabilized Tubes R133C91 2E088 45 5 RI12C88 2E088 55 6 R120C92 2E088 66 8 R97C85 2E088 66 8 R99C93 2E088 67 8 R117C81 2E089 55 6 R122C82 2E089 66 8 R106C84 2E089 66 8 R105C83 2E089 66 8 R104C86 2E089 66 8 R98C86 2E089 66 8 R123C91 2E089 66 8 R98C88 2E089 66 8 R112C84 2E089 67 8 R100C84 2E089 67 8 F _ _Tubes with Tube-to-Tube Wear R111C81 2E089 61 7 [R113C81 2E089 61 7 E a,c,e 1814-AA086-M0238, REV. 0 Page 377 of 415 Page 377 of 414 LTR-SGDA-12-36, Rev. 3 NP-Attachment February 15, 2013 Table C-3 FASTVIB IN-Plane Stability Ratio Plots Number of Figure Number for Case Missing Power Plugged and No. AVB Level Active Tube Stabilized Tube 17 2 70% C-1 C-14 28 3 70% C-2 C-1 5 37 4 70% C-3 C-16 38 4 70% C-4 C-17 45 5 70% C-5 C-18 46 5 70% C-6 C-19 53 6 70% C-7 C-20 54 6 70% C-8 C-21 60 7 70% C-9 C-22 66 8 70% C-10 C-23 71 9 70% C-11 C-24 75 10 70% C-12 C-25 78 12 70% C-13 C-26 1814-AA086-M0238, REV. 0 Page 378 of 415 Page 378 of 414 LTR-SGDA-12-36, Rev. 3 NP-Attachment February 15, 2013 Table C-4 SG 2E088 Tube Plugging/Stabilization List (Page 1 of 3)RSG 2E088 Tube Plugging/Stabilizing Listd Row J Col Plug I Stab Type" 121 1 81-1 Yes Split Stab Length (in)Reason~-1 -. -Noteb Preventative -FSW 120 82 Yes Split Note b Preventative FSW 105 Z3 "fes Split Note b Prevenlative -FSW 107 83 Yes Split Note b Prepvntativa -FSW 104 84 Yes Split Note b Preventative -FSW 106 84 Yes Split Note b Preventative -FSW 108 84 Yes Split Note b Preventative .FSW 122 84 Yes Split Note b Preventative -FSW 97 85 Yes Split Note b Preventative -FSW 99 85 Yes Split Note b Preventative -FSW 103 85 Yes Split Note b Preventative SW 1D 25 Yes Split Note b Preventative -FSW 107 85 Yes Split Note b Preventative -FSW 115 85 Yes Split Note b Preventative -FSW 121 85 Yes Split Note b Preventative-FSW 123 85 Yes Split Note b Preventative -FSW 133 85 Yes Split Note b Preventative -FSW 98 86 Yes Split Note b Preventative -rsw 100 86 Yes Split Note b Preventative -FSW 102 86 Yes Split Note b Preventative FSW 104 86 Yes Split Note b Preventative.- FSW 106 86 Yes Split Note b Preventative -FSW 108 86 Yes Split Note b Preventative FSW 112 86 Yes Split Note b Preventative -FSW 114 86 Yes Split Note b Preventative -FSW 116 86 Yes Split Note b Pteventative -FSW 122 86 Yes Split Note b Preventative -FSW 124 86 Yes Split Note b Preventative -FSW' 26 86 Yes Split Nnte h Preventative -FSW 101 87 Yes Split Note b Preventative -FSW lM 87 Yes Split Note b Preventative -FSW 105 87 Yes Split Note b Preventative -FSW 111 87 Yes Split Note b Preventative -FSW 113 87 Yes Split Note b Preventative -PSW 115 87 Yes Split Note b Preventative -FSW 121 Yes Split Note b Preventative -FSW 123 87 Yes Split Note b Preventative -FSW 125 87 Yes Split Note b Preventative -FSW 100 88 Yes Split Note b Preventative -rSW 102 88 Yes Split NOte b Preventative -FSW 104 88 Yes Split Note b Preventative -FSW 106 88 Yes Split Note b Preventative -FSW 110 88 Yes Split Note b Preventative -FSW 114 88 Yes Split Note b Preventative -FSW a) Split stabilizers are installed on the hot and cold side of the tube b) See AREVA ProduLt Information Sheet for Stabilizer U-Bend (Ref. 7) for split stabilizer lengtth c) Conservatively plugged as a defense in depth action per WEC recommendation (Ref 9)d) See Table 1 in "8. Functional Objective of the Change" section for tubes that will maintain single stabilizer 1814-AA086-M0238, REV. 0 Page 379 of 415 Page 379 of 414 LTR-SGDA-12-36, Rev. 3 NP-Attachment February 15, 2013 Table C-4 (Continued) SG 2E088 Tube Plugging/Stabilization List (Page 2 of 3)RSG 2E088 Tube Plugging/Stabilizing Listd Row Col Plug Stab Type* Stab Length (in) Reason 116 88 Yes Split Note b Preventative -FSW 118 88 Yes Split Note b Preventative -FSW 120 88 Yes Split Note b Preventative -FSW 122 88 Yes Split Note b Preventative -FSW 124 88 Yes Split Note b Preventative -FSW 95 89 Yes Split Note b Preventative -FSW 101 89 Yes Split Note b Preventative -FSW 103 89 Yes Split Note b Preventative -FSW 105 89 Yes Split Note b Preventative -FSW 107 89 Yes Split Note b Preventative -FSW 111 89 Yes Split Note b Preventative -FSW 113 89 Yes Split Note b Preventative -FSW 115 89 Yes Split Note b Preventative -FSW 117 89 Yes Split Note b Preventative -FSW 119 89 Yes Split Note b Preventative -FSW 121 89 Yes Split Note b Preventative -FSW 123 89 Yes Split Note b Preventative -FSW 127 89 Yes Split Note b Preventative -FSW 94 90 Yes Split Note b Preventative -FSW 100 90 Yes Split Note b Preventative -FSW 102 90 Yes Split Note b Preventative -FSW 104 90 Yes Split Note b Preventative -FSW 106 90 Yes Split Note b Preventative -FSW 110 90 Yes Split Note b Preventative -FSW 112 90 Yes Split Note b Preventative -FSW 114 90 Yes Split Note b Preventative -FSW 116 90 Yes Split Note b Preventative -FSW 95 91 Yes Split Note b Preventative -FSW 101 91 Yes Split Note b Preventative -FSW 103 91 Yes Split Note b Preventative -FSW 105 91 Yes Split Note b Preventative -FSW 107 91 Yes Split Note b Preventative -FSW 109 91 Yes Split Note b Preventative -FSW 111 91 Yes Split Note b Preventative -FSW 113 91 Yes Split Note b Preventative FSW 115 91 Yes Split Note b Preventative -FSW 117 91 Yes Split Note b Preventative -FSW 98 92 Yes Split Note b Preventative -FSW 100 92 Yes Split Note b Preventative -FSW 102 92 Yes Split Note b Preventative -FSW 104 92 Yes Split Note b Preventative -FSW 106 92 Yes Split Note b Preventative -FSW 108 92 Yes Split Note b Preventative -FSW 110 92 Yes Split Note b Preventative -FSW a) Split stabilizers are installed on the hot and cold side of the tube b) See AREVA Product Information Sheet for Stabilizer U-Bend (Ref. 7) for split stabilizer lengths c) Conservatively plugged as a defense in depth action per WEC recommendation (Ref 9)d) See Table 1 in "B. Functional Objective of the Change" section for tubes that will maintain single stabilizer 1814-AA086-M0238, REV. 0 Page 380 of 415 Page 380 of 414 LTR-SGDA-12-36, Rev. 3 NP-Attachment February 15, 2013 Table C-4 (Continued) SG 2E088 Tube PlugginglStabilization List (Page 3 of 3)RSG 2E088 Tube Plugging/Stabilizing Listd Stab Type' I Stab Length(in) Row 112 Col Plug Reason.ventative -FSW 92 Yes Split Note b Pre 114 92 Yes Split Note b Preventative -FSW 116 92 Yes Split Note b Preventative -FSW 118 92 Yes Split Note b Preventative -FSW 136 92 Yes Split Note b Preventative -FSW 99 93 Yes Split Note b Preventative -FSW 101 93 Yes Split Note b Preventative -FSW 103 93 Yes Split Note b Preventative -FSW 107 93 Yes Split Note b Preventative -FSW 111 93 Yes Split Note b Preventative -FSW 117 93 Yes Split Note b Preventative -FSW 129 93 Yes Split Note b Preventative -FSW 94 94 Yes Split Note b Preventative -FSW 137 89 Yes Split Note b Preventative -FSW'135 93 Yes Split Note b Preventative -FSWf 98 84 Yes Split Note b Wear at 6 Continuous AVBs 88 88 Yes Split Note b Wear at 6 Continuous AVBs 97 89 Yes Split Note b Wear at 6 Continuous AVBs 108 90 Yes Split Note b Wear at 6 Continuous AVBs 124 92 Yes Split Note b Wear at 6 Continuous AVBs 134 94 Yes Split Note b Wear at 6 Continuous AVBs a) Split stabilizers are installed on the hot and cold side of the tube b) See AREVA Product Information Sheet for Stabilizer U-Bend (Ref. 7) for split stabilizer lengths c) Conservatively plugged as a defense in depth action per WEC recommendation (Ref 9)d) See Table I in "8. Functional Objective of the Change" section for tubes that will maintain single stabilizer 1814-AA086-M0238, REV. 0 Page 381 of 415 Page 381 of 414 LTR-SGDA-12-36, Rev. 3 NP-Attachment February 15, 2013 Table C-5 SG 2E089 Tube Plugging/Stabilization List (Page 1 of 5)RSG 2E089 Tube Plugging/Stabilizing List Row Col Plug StabTypet Stab Length (in) Reason 111 81 Yes Split Note b 14% TWD -FSW (Preventative) 113 81 Yes Split Note b 14% TWDD- FSW(Preventative) 103 77 Yes Split Note b Preventative -FSW 109 77 Yes Split Note b Preventative -FSW 111 77 Yes Split Note b Preventative -FSW 100 78 Yes Split Note b Preventative -FSW 102 78 Yes Split Note b Preventative -FSW 104 78 Yes Split Note b Preventative -FSW 108 78 Yes Split Note b Preventative -FSW 110 78 Yes Split Note b Preventative -FSW 112 78 Yes Split Note b Preventative -FSW 97 79 Yes Split Note b Preventative -FSW 99 79 Yes Split Note b Preventative -FSW 101 79 Yes Split Note b Preventative -FSW 111 79 Yes Split Note b Preventative -FSW 92 80 Yes Split Note b Preventative -FSW 94 80 Yes Split Note b Preventative -FSW 96 80 Yes Split Note b Preventative -FSW 98 80 Yes Split Note b Preventative -FSW 100 80 Yes Split Note b Preventative -FSW 102 80 Yes Split Note b Preventative -FSW 110 80 Yes Split Note b Preventative -FSW 112 80 Yes Split Nute b Preventdtive -FSW 114 80 Yes Split Note b Preventative -FSW 91 81 Yes Split Note b Preventative -FSW 93 81 Yes Split Note b Preventative -FSW 95 81 Yes Split Note b Preventative -FSW 97 81 Yes Split Note b Preventative -FSW 99 81 Yes Split Note b Preventative -FSW 101 81 Yes Split Note b Preventative -FSW 103 81 Yes Split Note b Preventative -FSW 105 81 Yes Split Note b Preventative -FSW 107 81 Yes Split Note b Preventative -FSW 109 81 Yes Split Note b Preventative -FSW 115 81 Yes Split Note b Preventative -FSW 117 81 Yes Split Note b Preventative -FSW 119 81 Yes Split Note b Preventative -FSW 121 81 Yes Split Note b Preventative -FSW 90 82 Yes Split Note b Preventative -FSW 92 82 Yes Split Note b Preventative -FSW 94 82 Yes Split Note b Preventative -FSW 96 82 Yes Split Note b Preventative -FSW 98 82 Yes Split Note b Preventative -FSW 100 82 Yes Split Note b Preventative -FSW 102 82 Yes Split Note b Preventative -FSW a) Split stabilizers are installed on the hot and cold side of the tube b) See AREVA Product Information Sheet for Stabilizer U-Bend (Ref, 7) for split stabilizer lengths c) Conservatively plugged as a defense in depth action per WEC recommendation (Ref 9)1814-AA086-M0238, REV. 0 Page 382 of 415 Page 382 of 414 LTR-SGDA-12-36, Rev. 3 NP-Attachment February 15, 2013 Table C-5 (Continued) SG 2E089 Tube Plugging/Stabilization List (Page 2 of 5)r104 RSG ZE089 Tube Plugging/Stabilizing List C!O~l 82 Plug Yes Stab Type' Stab Length (in)Split T Note b Reason Preventative FSW 106 82 Yes Split Note b Preventative FSW 108 82 Yes Split Note b Preventative -FSW 110 82 Yes Split Note b Preventative -FSW 112 82 Yes Split Note b Preventative -FSW 114 82 Yes Split Note b Preventative -FSW 116 82 Yes Split Note b Preventative -FSW 118 82 Yes Split Note b Preventative -FSW 120 82 Yes Split Note b Preventative -FSW 122 82 Yes Split Note b Preventative -FSW 91 83 Yes Split Note b Preventative -FSW 93 83 Yes Split Note b Preventative -FSW 95 83 Yes Split Note b Preventative -FSW 97 83 Yes Split Note b Preventative -F$W 99 83 Yes Split Note b Preventative -FSW 101 83 Yes Split Note b Preventative -FSW 103 83 Yes Split Note b Preventative -FSW 10S 83 Yes Split Note b Preventative -FSW 107 83 Yes Split Note b Preventative -FSW 109 83 Yes Split Note b Preventative FSW 111 83 Yes Split Note b Preventative -FSW 113 83 Yes Split Note b Preventative -FSW 115 83 Yes Split Note b Preventative FSW 117 83 Yes Split Note b Preventative -FSW 119 83 Yes Split Note b Preventative -FSW 121 83 Yes Split Note b Preventative -FSW 90 84 Yes Split Note b Preventative -FSW 92 84 Yes Split Note b Preventative -FSW 94 84 Yes Split Note b Preventative -FSW 96 84 Yes Split Note b Preventative -FSW 98 84 Yes Split Note b Preventative -FSW 100 84 Yes Split Note b Preventative -FSW 102 84 Yes Split Note b Preventative -FSW 104 84 Yes Split Note b Preventative -FSW 1OG 84 Yes Split Note b Preventative -FSW 108 84 Yes Split Note b Preventative -FSW 110 84 Yes Split Note b Preventative -FSW 112 84 Yes Split Note b Preventative -FSW 114 84 Yes Split Note b Preventative-FSW 116 84 Yes Split Note b Preventative -FSW 118 84 Yes Split Note b Preventative -FSW 120 84 Yes Split Note b Preventative FSW 126 84 Yes Split Note b Preventative -FSW 128 84 Yes Split Note b Preventative -FSW 132 84 Yes Split Note b Preventative -FSW a) Split stabilizers are installed on the hot and cold side of the tube b) See AREVA Product Information Sheet for Stabilizer U-Bend (Ref. 7) for split stabilizer lengths c) Conservatively plugged as a defense in depth action per WEC recommendation tRef 9)1814-AA086-M0238, REV. 0 Page 383 of 415 Page 383 of 414 LTR-SGDA-12-36, Rev. 3 NP-Attachment February 15, 2013 Table C-5 (Continued) SG 2E089 Tube Plugging/Stabilization List (Page 3 of 5)R~C 2~flR~ Tube PlneelnelStnbllltlne List Row Col Plug Stab Typeb Stab Length (in) Reason 91 85 Yes Split Note b Preventative -FSW 93 85 Yes Split Note b Preventative -FSW 95 85 Yes Split Note b Preventative -FSW 97 85 Yes Split Note b Preventative -FSW 99 85 Yes Split Note b Preventative -FSW 101 85 Yes Split Note b Preventative -FSW 103 85 Yes Split Note b Preventative -FSW 105 85 Yes Split Note b Preventative -FSW 107 85 Yes Split Note b Preventative -FSW 109 85 Yes Split Note b Preventative -FSW 111 85 Yes Split Note b Preventative -FSW 113 85 Yes Split Note b Preventative -FSW 115 85 Yes Split Note b Preventative -FSW 117 85 Yes Split Note b Preventative -FSW 119 85 Yes Split Note b Preventative -FSW 121 85 Yes Split Note b Preventative -FSW 127 85 Yes Split Note b Preventative -FSW 88 86 Yes Split Note b Preventative -FSW 92 86 Yes Split Note b Preventative -FSW 94 86 Yes Split Note b Preventative -FSW 96 86 Yes Split Note b Preventative-FSW 98 86 Yes Split Note b Preventative -FSW 100 86 Yes Split Nute U Preventative -FSW 102 86 Yes Split Note b Preventative -FSW 104 86 Yes Split Note b Preventative -FSW 106 86 Yes Split Note b Preventative -FSW 108 86 Yes Split Note b Preventative -FSW 110 86 Yes Split Note b Preventative -FSW 112 86 Yes Split Note b Preventative -FSW 114 86 Yes Split Note b Preventative -FSW 116 86 Yes Split Note b Preventative -FSW 118 86 Yes Split Note b Preventative -FSW 122 86 Yes Split Note b Preventative -FSW 130 86 Yes Split Note b Preventative -FSW 93 87 Yes Split Note b Preventative -FSW 95 87 Yes Split Note b Preventative-FSW 97 87 Yes Split Note b Preventative -FSW 99 87 Yes Split Note b Preventative -FSW 101 87 Yes Split Note b Preventative -FSW 103 87 Yes Split Note b Preventative -FSW 105 87 Yes Split Note b Preventative -FSW 107 87 Yes Split Note b Preventative -FSW 109 87 Yes Split Note b Preventative -FSW 111 87 Yes Split Note b Preventative -FSW 113 87 Yes Split Note b Preventative -FSW a) Split stabilizers are installed on the hot and cold side of the tube b) See AREVA Product Information Sheet for Stabilizer U-Bend (Ref. 7) for split stabilizer lengths c) Conservatively plugged as a defense in depth action per WEC recommendation (Ref 9)1814-AA086-M0238, REV. 0 Page 384 of 415 Page 384 of 414 LTR-SGDA-12-36, Rev. 3 NP-Attachment February 15, 2013 Table C-5 (Continued) SG 2E089 Tube Plugging/Stabilization List (Page 4 of 5)7 Row1 Col PIu~RSG 2E089 Tube Plugging/Stabilizing List Stab Type[ Stab Length (in) Reason Plug 115 87 Yes Split Note b Preventative -FSW 117 87 Yes Split Note b Preventative -FSW 119 87 Yes Split Note b Preventative -FSW 129 87 Yes Split Note b Preventative -FSW 94 88 Yes Split Note b Preventative -FSW 96 88 Yes Split Note b Preventative -FSW 98 88 Yes Split Note b Preventative -FSW 100 88 Yes Split Note b Preventative -FSW 102 88 Yes Split Note b Preventative -FSW 104 88 Yes Split Note b Preventative -FSW 106 88 Yes Split Note b Preventative -FSW 108 88 Yes Split Note b Preventative -FSW 110 88 Yes Split Note b Preventative -FSW 112 88 Yes Split Note b Preventative -FSW 114 88 Yes Split Note b Preventative -FSW 116 88 Yes Split Note b Preventative -FSW 118 88 Yes Split Note b Preventative -FSW 138 88 Yes Split Note b Preventative -FSW 95 89 Yes Split Note b Preventative -FSW 97 89 Yes Split Note b Preventative -FSW 99 89 Yes Split Note b Preventative -FSW 101 89 Yes Split Note b Preventative -FSW 103 89 Yes Split Note b Preventative -FSW 105 89 Yes Split Note b Preventative -FSW 107 89 Yes Split Note b Preventative -FSW 109 89 Yes Split Note b Preventative -FSW 111 89 Yes Split Note b Preventative -FSW 113 89 Yes Split Note b Preventative -FSW 115 89 Yes Split Note b Preventative -FSW 117 89 Yes Split Note b Preventative -FSW 131 89 Yes Split Note b Preventative -FSW 100 90 Yes Split Note b Preventative -FSW 102 90 Yes Split Note b Preventative -FSW 104 90 Yes Split Note b Preventative -FSW 106 90 Yes Split Note b Preventative -FSW 108 90 Yes Split Note b Preventative -FSW 110 90 Yes Split Note b Preventative -FSW 112 90 Yes Split Note b Preventative -FSW 114 90 Yes Split Note b Preventative -FSW 116 90 Yes Split Note b Preventative -FSW 118 90 Yes Split Note b Preventative -FSW 130 90 Yes Split Note b Preventative -FSW 132 90 Yes Split Note b Preventative -FSW 134 90 Yes Split Note b Preventative -FSW 99 91 Yes Split Note b Preventative -FSW a) Split stabilizers are installed on the hot and cold side of the tube b) See AREVA Product Information Sheet for Stabilizer U-Bend (Ref. 7) for split stabiliier lengths c) Conservatively plugged as a defense in depth action per WEC recommendation (Ref 9)1814-AA086-M0238, REV. 0 Page 385 of 415 Page 385 of 414 LTR-SGDA-12-36, Rev. 3 NP-Attachment February 15, 2013 Table C-5 (Continued) SG 2EO89Tube Plugging/Stabilization List (Page 5 of 5)RSG 2E089 Tube Plugging/Stabilizing List Stab Type" I Stab Length (in)Row I Col Plug, Reason eventative -FSW 105 91 Yes Solit Note b Prc 107 91 Yes Split Note b______ Preventative -FSW 109 91 Yes Split Note b Preventative -FSW 113 91 Yes Split Note b Preventative -FSW 115 91 Yes Split Note b Preventative -FSW 117 91 Yes Split Note b Preventative -FSW 123 91 Yes Split Note b Preventative -FSW 98 92 Yes Split Note b Preventative -FSW 104 92 Yes Split Note b Preventative -FSW 108 92 Yes Split Note b Preventative -FSW 114 92 Yes Split Note b Preventative -FSW 116 92 Yes Split Note b Preventative -FSW 103 93 Yes Split Note b Preventative -FSW 115 93 Yes Split Note b Preventative -FSW 102 94 Yes Split Note b Preventative -FSW 114 94 Yes Split Note b Preventative -FSW 116 94 Yes Split Note b Preventative -FSW 103 95 Yes Split Note h Preventative -FSW 105 95 Yes Split Note b Preventative -FSW 107 95 Yes Split Note b Preventative -FSW 109 95 Yes Split Note b Preventative -FSW 115 95 Yes Split Note b Preventative -FSW 109 97 Yes Split Note b Preventative -FSW 110 98 Yes Split Note b Preventative -FSW 112 98 Yes Split Note b Preventative -FSW 80 68 Yes Split Note b Preventative -104 72 Yes Split Note b Preventative -FSW'132 94 Yes Split Note b Preventative -FSW'98 76 Yes Split Note b Wear at 6 Continuous AVBs 87 79 Yes Split Note b Wear at 6 Continuous AVBs 89 83 Yes Split Note b Wear at 6 Continuous AVBs 128 84 Yes Split Note b Wear at 6 Continuous AVBs 121 89 Yes Split Note b Wear at 6 Continuous AVBs 120 90 Yes Split Note b Wear at 6 Continuous AVBs a) Split stabilizers are installed on the hot and cold side of the tube b) See AREVA Product Information Sheet for Stabilizer U-Send (Ref. 7) for split stabilizer lengths c) Conservatively plugged as a defense in depth action per WEC recommendation (Ref 9)1814-AA086-M0238, REV. 0 Page 386 of 415 Page 386 of 414 LTR-SGDA-12-36, Rev. 3 NP-Attachment February 15, 2013 a,c,e Figure C-1 In-Plane Stability Ratio Map -Active Tube -70% Power -2 AVBs Missing (Case 17)1814-AA086-M0238, REV. 0 Page 387 of 415 Page 387 of 414 LTR-SGDA-12-36, Rev. 3 NP-Attachment February 15, 2013 a,c,e Figure C-2 In-Plane Stability Ratio Map -Active Tube -70% Power -3 AVBs Missing (Case 28)1814-AA086-M0238, REV. 0 Page 388 of 415 Page 388 of 414 LTR-SGDA-12-36, Rev. 3 NP-Attachment February 15, 2013 a,c,e Figure C-3 In-Plane Stability Ratio Map -Active Tube -70% Power -4 AVBs Missing (Case 37)1814-AA086-M0238, REV. 0 Page 389 of 415 Page 389 of 414 LTR-SGDA-12-36, Rev. 3 NP-Attachment February 15, 2013 a,c,e Figure C-4 In-Plane Stability Ratio Map -Active Tube -70% Power -4 AVBs Missing (Case 38)1814-AA086-M0238, REV. 0 Page 390 of 415 Page 390 of 414 LTR-SGDA-12-36, Rev. 3 NP-Attachment February 15, 2013 a,c,e Figure C-5 In-Plane Stability Ratio Map -Active Tube -70% Power -5 AVBs Missing (Case 45)1814-AA086-M0238, REV. 0 Page 391 of 415 Page 391 of 414 LTR-SGDA-12-36, Rev. 3 NP-Attachment February 15, 2013 a,c,e Figure C-6 In-Plane Stability Ratio Map -Active Tube -70% Power -5 AVBs Missing (Case 46)1814-AA086-M0238, REV. 0 Page 392 of 415 Page 392 of 414 LTR-SGDA-12-36, Rev. 3 NP-Attachment February 15, 2013 a,c,e Figure C-7 In-Plane Stability Ratio Map -Active Tube -70% Power -6 AVBs Missing (Case 53)1814-AA086-M0238, REV. 0 Page 393 of 415 Page 393 of 414 LTR-SGDA-12-36, Rev. 3 NP-Attachment February 15, 2013 a,c,e Figure C-8 In-Plane Stability Ratio Map -Active Tube -70% Power -6 AVBs Missing (Case 54)1814-AA086-M0238, REV. 0 Page 394 of 415 Page 394 of 414 LTR-SGDA-12-36, Rev. 3 NP-Attachment February 15, 2013 a,c,e Figure C-9 In-Plane Stability Ratio Map -Active Tube -70% Power -7 AVBs Missing (Case 60)1814-AA086-M0238, REV. 0 Page 395 of 415 Page 395 of 414 LTR-SGDA-12-36, Rev. 3 NP-Attachment February 15, 2013 a,c,e Figure C-10 In-Plane Stability Ratio Map -Active Tube -70% Power -8 AVBs Missing (Case 66)1814-AA086-M0238, REV. 0 Page 396 of 415 Page 396 of 414 LTR-SGDA-12-36, Rev. 3 NP-Attachment February 15, 2013 a,c,e Figure C-ll In-Plane Stability Ratio Map -Active Tube -70% Power -9 AVBs Missing (Case 71)1814-AA086-M0238, REV. 0 Page 397 of 415 Page 397 of 414 LTR-SGDA-12-36, Rev. 3 NP-Attachment February 15, 2013 a,c,e Figure C-12 In-Plane Stability Ratio Map -Active Tube -70% Power- 10 AVBs Missing (Case 75)1814-AA086-M0238, REV. 0 Page 398 of 415 Page 398 of 414 LTR-SGDA-12-36, Rev. 3 NP-Attachment February 15, 2013 a,c,e Figure C-13 In-Plane Stability Ratio Map -Active Tube -70% Power -12 AVBs Missing (Case 78)1814-AA086-M0238, REV. 0 Page 399 of 415 Page 399 of 414 LTR-SGDA-12-36, Rev. 3 NP-Attachment February 15, 2013 a,c,e Figure C-14 In-Plane Stability Ratio Map -Stabilized Tube -70% Power -2 AVBs Missing (Case 17)1814-AA086-M0238, REV. 0 Page 400 of 415 Page 400 of 414 LTR-SGDA-12-36, Rev. 3 NP-Attachment February 15, 2013 a,c,e Figure C-15 In-Plane Stability Ratio Map -Stabilized Tube -70% Power -3 AVBs Missing (Case 28)1814-AA086-M0238, REV. 0 Page 401 of 415 Page 401 of 414 LTR-SGDA-12-36, Rev. 3 NP-Attachment February 15, 2013 a,c,e Figure C-16 In-Plane Stability Ratio Map -Stabilized Tube -70% Power -4 AVBs Missing (Case 37)1814-AA086-M0238, REV. 0 Page 402 of 415 Page 402 of 414 LTR-SGDA-12-36, Rev. 3 NP-Attachment February 15, 2013 a,c,e Figure C-17 In-Plane Stability Ratio Map -Stabilized Tube -70% Power -4 AVBs Missing (Case 38)1814-AA086-M0238, REV. 0 Page 403 of 415 Page 403 of 414 LTR-SGDA-12-36, Rev. 3 NP-Attachment February 15, 2013 ace Figure C-18 In-Plane Stability Ratio Map -Stabilized Tube -70% Power -5 AVBs Missing (Case 45)1814-AA086-M0238, REV. 0 Page 404 of 415 Page 404 of 414 LTR-SGDA-12-36, Rev. 3 NP-Attachment February 15, 2013 a,c,e Figure C-19 In-Plane Stability Ratio Map -Stabilized Tube -70% Power -5 AVBs Missing (Case 46)1814-AA086-M0238, REV. 0 Page 405 of 415 Page 405 of 414 LTR-SGDA-12-36, Rev. 3 NP-Attachment February 15, 2013 a,c,e Figure C-20 In-Plane Stability Ratio Map -Stabilized Tube -70% Power -6 AVBs Missing (Case 53)1814-AA086-M0238, REV. 0 Page 406 of 415 Page 406 of 414 LTR-SGDA-12-36, Rev. 3 NP-Attachment February 15, 2013 a,c,e Figure C-21 In-Plane Stability Ratio Map -Stabilized Tube -70% Power -6 AVBs Missing (Case 54)1814-AA086-M0238, REV. 0 Page 407 of 415 Page 407 of 414 LTR-SGDA-12-36, Rev. 3 NP-Attachment February 15, 2013 a,c,e Figure C-22 In-Plane Stability Ratio Map -Stabilized Tube -70% Power -7 AVBs Missing (Case 60)1814-AA086-M0238, REV. 0 Page 408 of 415 Page 408 of 414 LTR-SGDA-12-36, Rev. 3 NP-Attachment February 15, 2013 a,c,e 7 Figure C-23 In-Plane Stability Ratio Map -Stabilized Tube -70% Power -8 AVBs Missing (Case 66)1814-AA086-M0238, REV. 0 Page 409 of 415 Page 409 of 414 LTR-SGDA-12-36, Rev. 3 NP-Attachment February 15, 2013 a,c,e Figure C-24 In-Plane Stability Ratio Map -Stabilized Tube -70% Power -9 AVBs Missing (Case 71)1814-AA086-M0238, REV. 0 Page 410 of 415 Page 410 of 414 LTR-SGDA-12-36, Rev. 3 NP-Attachment February 15, 2013 a,c,e Figure C-25 In-Plane Stability Ratio Map -Stabilized Tube -70% Power -10 AVBs Missing (Case 75)1814-AA086-M0238, REV. 0 Page 411 of 415 Page 411 of 414 LTR-SGDA-12-36, Rev. 3 NP-Attachment February 15, 2013 a,c,e Figure C-26 In-Plane Stability Ratio Map -Stabilized Tube -70% Power -12 AVBs Missing (Case 78)1814-AA086-M0238, REV. 0 Page 412 of 415 Page 412 of 414 LTR-SGDA-12-36, Rev. 3 NP-Attachment February 15, 2013 2 2 2 S ~ ~ z'C 2* ~ 2 Qj 9~A~i~( ~.-17 k-S 2 2 C~03 ,Ca E E V" V2: jaqwflN MOH R Figure C-27 Unit 2 SG 2E088 Plugging/Stabilization Map 1814-AA086-M0238, REV. 0 Page 413 of 415 Page 413 of 414 LTR-SGDA-12-36, Rev. 3 NP-Attachment February 15, 2013 3'-4 o AA-A A'A~3 A A>A: A Al AS A. A ~::,~- 's.-, m 0.Cd,£/Cq Cl'A~A ~ -, -A A>I -~ASSA: A CS'3/4 CA~4s>; ~A U:5 z2 ,=='5,. ~-C -- -~ ~ ~.-..C,. 'LA> ALALA >'5,-~ .5c->~:.* Al c~'~AAP 5 li-ISA SAW>SA',AS ~'Ail>AAS' i-~ [.2 '>0 A -C I!SC~ A-~ A A A~. A -I jaquwnN mok1 I Figure C-28 Unit 2 SG 2E089 Plugging/Stabilization Map 1814-AA086-M0238, REV. 0 Page 414 of 415 Page 414 of 414 LTR-SGDA-12-36, Rev. 3 NP-Attachment February 15, 2013 C-4 Conclusions It has been shown that in all cases the introduction of the stabilizer into the tubes reduces the stability ratio of that tube. It had been found that the stabilizer reduced the out-of-plane excitation ratio by approximately 7% on average and reduced the in-plane stability ratio by approximately 12% on average. It can also be concluded that the wear calculations from Section 7.0 remain conservative with the addition of the split cable stabilizer. The wear calculations are a function of the tube excitation ratio and therefore a reduction in the tube excitation ratio will also reduce the projected wear during operation. In summary, it has been found that the conclusions in the main body of the report remain valid and are conservative for tubes that have the split cable stabilizer installed. C-5 References C-1 LTR-SGDA-12-55, Rev. 1, "Documentation of Properties Associated with the AREVA Split Stabilizers to be Used at SONGS Unit 2," September 20, 2012.C-2 LTR-SGDA-12-56, "Effect of Installation of Split Cable Stabilizers in the Tube FIV Response at SONGS Unit 2," September 21, 2012.1814-AA086-M0238, REV. 0 Page 415 of 415 ENCLOSURE 7 Affidavit by MHI for L5-04GA567, Evaluation of Stability Ratio for Return to Service (Enclosure 1), and L5-04GA585, Analytical Evaluations for Operational Assessment (Enclosure

2)

MITSUBISHI HEAVY INDUSTRIES, LTD.AFFIDAVIT I, Jinichi Miyaguchi, state as follows: 1. I am Director, Nuclear Plant Component Designing Department, of Mitsubishi Heavy Industries, Ltd. ("MHI"), and have been delegated the function of reviewing the referenced documentations to determine whether they contain MHI's information that should be withheld from public disclosure pursuant to 10 C.F.R. § 2.390 (a)(4) as trade secrets and commercial or financial information that is privileged or confidential.

2. In accordance with my responsibilities, I have reviewed the following documentations and have determined that they contain MHI proprietary information that should be withheld from public disclosure.

Those pages containing proprietary information have been bracketed with an open and closed bracket as shown here "[ I" / and should be withheld from public disclosure pursuant to 10 C.F.R. § 2.390 (a)(4).MHI's documents-L5-04GA567 Evaluation of Stability Ratio for Return to Service-L5-04GA585 Analytical Evaluations for Operational Assessment SCE's documents-1 OCFR50.59 Evaluation, Screening NECP 800175663 Steam Generator Replacement Mstr ECP U2-1 OCFR50.59 Evaluation, Screening NECP 800175664 Steam Generator Replacement Mstr ECP U3 3. The information identified as proprietary in the documents have in the past been, and will continue to be, held in confidence by MHI and its disclosure outside the company is limited to regulatory bodies, customers and potential customers, and their agents, suppliers, and licensees, and others with a legitimate need for the information, and is always subject to suitable measures to protect it from unauthorized use or disclosure.

4. The basis for holding the referenced information confidential is that they describe unique design, manufacturing, experimental and investigative information developed by MHI and not used in the exact form by any of MHI's competitors.

This information was developed at significant cost to MHI, since it is the result of an intensive MHI effort.5. The referenced information was furnished to the Nuclear Regulatory Commission ("NRC") in confidence and solely for the purpose of information to the NRC staff.6. The referenced information is not available in public sources and could not be gathered readily from other publicly available information. Other than through the provisions in paragraph 3 above, MHI knows of no way the information could be lawfully acquired by organizations or individuals outside of MHI.7. Public disclosure of the referenced information would assist competitors of MHI in their design and manufacture of nuclear plant components without incurring the costs or risks associated with the design and the manufacture of the subject component. Therefore, disclosure of the information contained in the referenced documents would have the following negative impacts on the competitive position of MHI in the U.S. and world nuclear markets: A. Loss of competitive advantage due to the costs associated with development of technologies relating to the component design, manufacture and examination. Providing public access to such information permits competitors to duplicate or mimic the methodology without incurring the associated costs.B. Loss of competitive advantage of MHI's ability to supply replacement or new heavy components such as steam generators. I declare under penalty of perjury that the foregoing affidavit and the matters stated therein are true and correct to the best of my knowledge, information and belief.Executed on this /8 day of.. AJ"'Y ,2013.Jinichi Miyaguchi, Director-Nuclear Plant Component Designing Department Mitsubishi Heavy Industries, LTD Sworn to and subscribed 31-Before me this / day of -.0&, ,201o3 FEB, 82013 AMK04A A1ýA_, / , C;, , .\ i " ..... ".... ?. , .Notary Public My Commission Expires k'7 , X. IIVZ X. III/i 3x- -Xý: -7ý -XI -lx- -X. X. X.- ýK- X. X. X. -ý, Ix ýK- -X. X- X. ý;Il ýK- -X. X, -"k- ý;, ýSll -X. -xz N X. X. X. -X- X.ME 2.X-X.~~ ...... .. ._.. ... ......... .... ......./6 X.7 8 9 TK-----------------------

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I ........................ ........... ...... ............... .............10 12 13 t5/A'K'K iMIZJ 2 5 4f 2 ,~1 8 Fl................ .. .. .......... .......... ..°, 16 17 X -. ..... .. .. -- -.... ... ..... .. .. ... ... ... .. ... ... .. ... .... .... .. .. .. ... ... ...... ..... .... --- --- --/-K, 19 20'K 21 y ......... ................... -..-------.-.----.. .........'K-'K '__ _ _ _ _ __ _ _ _ _ _ 2__ __ _ __ _ ' Registered Number 3 1 Date FEB.18.2013 NOTARIAL CERTIFICATE This is to certify that JINICHI MIYAGUCHI , Director-Nuclear Plant Component Designing Department MITSUBISHI HEAVY INDUSTRIES, LTD has affixed his signature in my very presence to the attached document. .-K//' : ,..~ ~ ~~. ,......... ..' .. .".. .MASAHIKO KUBOTA Notary 44 Akashimachi, Chuo-Ku, Kobe, Japan Kobe District Legal Affairs Bureau (fAM2) ENCLOSURE 8 Affidavit by WEC for LTR-SGDA-12-36, Flow-Induced Vibration and Tube Wear Analysis of the San Onofre Nuclear Generating Station Unit 2 Replacement Steam Generators Supporting Restart (Enclosure

3)

Westinghouse100Wsigue W a.st in gh useWestinghouse Electric Company Nuclear Services 1000 Westinghouse Drive Cranberry Township, Pennsylvania 16066 USA U.S. Nuclear Regulatory Commission Direct tel: (412) 374-4643 Document Control Desk Direct fax: (724) 720-0754 11555 Rockville Pike e-mail: greshaja@westinghouse.com Rockville, MD 20852 Proj letter: CONO-1 3-16 CAW-13-3623 February 15, 2013 APPLICATION FOR WITHHOLDING PROPRIETARY INFORMATION FROM PUBLIC DISCLOSURE

Subject:

LTR-SGDA-12-36, Rev. 3 P-Attachment, "Flow-Induced Vibration and Tube Wear Analysis of the San Onofre Nuclear Generating Station Unit 2 Replacement Steam Generators" (Proprietary) The proprietary information for which withholding is being requested in the above-referenced report is further identified in Affidavit CAW-I 3-3623 signed by the owner of the proprietary information, Westinghouse Electric Company LLC. The affidavit, which accompanies this letter, sets forth tie basis on which the information may be withheld from public disclosure by the Commission and addresses with specificity the considerations listed in paragraph (bX4) of 10 CFR Section 2.390 of the Commission's regulations. Accordingly, this letter authorizes the utilization of the accompanying affidavit by Southern California Edison.Correspondence with respect to the proprietary aspects of the application for withholding or the Westinghouse affidavit should reference CAW- 13-3623 and should be addressed to James A. Gresham, Manager, Regulatory Compliance, Westinghouse Electric Company, Suite 428, 1000 Westinghouse Drive, Cranberry Township, Pennsylvania 16066.Very truly yours, JaesuA.tGresamp Manager Regulatory Compliance Enclosures CAW-13-3623 AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA: ss COUNTY OF BUTLER: Before me, the undersigned authority, personally appeared James A. Gresham, who, being by me duly sworn according to law, deposes and says that he is authorized to execute this Affidavit on behalf of Westinghouse Electric Company LLC (Westinghouse), and that the averments of fact set forth in this Affidavit are true and correct to the best of his knowledge, information, and belief:*James A. Gresham, Manager Regulatory Compliance Sworn to and subscribed before me this 15' day of February 2013 Notary Public /COMMONWEALTH OF PENNSYLVANIA Notarial soAw F StmegMa. % Notary Pu*ie Unift ThP. weme CW IMy corrmission 15"Me Aug. ?, 2016 KEMPE PENSMlAJIIA ASSOCIAlIOI OF NOUNzS 2 CAW-13-3623 (1) I am Manager, Regulatory Compliance, in Nuclear Services, Westinghouse Electric Company LLC (Westinghouse), and as such, I have been specifically delegated the function of reviewing the proprietary information sought to be withheld from public disclosure in connection with nuclear power plant licensing and rule making proceedings, and am authorized to apply for its withholding on behalf of Westinghouse. (2) I am making this Affidavit in conformance with the provisions of 10 CFR Section 2.390 of the Commission's regulations and in conjunction with the Westinghouse Application for Withholding Proprietary Information from Public Disclosure accompanying this Affidavit. (3) I have personal knowledge of the criteria and procedures utilized by Westinghouse in designating information as a trade secret, privileged or as confidential commercial or financial information. (4) Pursuant to the provisions of paragraph (b)(4) of Section 2.390 of the Commission's regulations, the following is furnished for consideration by the Commission in determining whether the information sought to be withheld from public disclosure should be withheld.(i) The information sought to be withheld from public disclosure is owned and has been held in confidence by Westinghouse.(ii) The information is of a type customarily held in confidence by Westinghouse and not customarily disclosed to the public. Westinghouse has a rational basis for determining the types of information customarily held in confidence by it and, in that connection, utilizes a system to determine when and whether to hold certain types of information in confidence. The application of that system and the substance of that system constitutes Westinghouse policy and provides the rational basis required.Under that system, information is held in confidence if it falls in one or more of several types, the release of which might result in the loss of an existing or potential competitive advantage, as follows: (a) The information reveals the distinguishing aspects of a process (or component, structure, tool, method, etc.) where prevention of its use by any of 3 CAW-13-3623 Westinghouse's competitors without license from Westinghouse constitutes a competitive economic advantage over other companies.(b) It consists of supporting data, including test data, relative to a process (or component, structure, tool, method, etc.), the application of which data secures a competitive economic advantage, e.g., by optimization or improved marketability.(c) Its use by a competitor would reduce his expenditure of resources or improve his competitive position in the design, manufacture, shipment, installation, assurance of quality, or licensing a similar product.(d) It reveals cost or price information, production capacities, budget levels, or commercial strategies of Westinghouse, its customers or suppliers.(e) It reveals aspects of past, present, or future Westinghouse or customer funded development plans and programs of potential commercial value to Westinghouse.(f) It contains patentable ideas, for which patent protection may be desirable. There are sound policy reasons behind the Westinghouse system which include the following: (a) The use of such information by Westinghouse gives Westinghouse a competitive advantage over its competitors. It is, therefore, withheld from disclosure to protect the Westinghouse competitive position.(b) It is information that is marketable in many ways. The extent to which such information is available to competitors diminishes the Westinghouse ability to sell products and services involving the use of the information.(c) Use by our competitor would put Westinghouse at a competitive disadvantage by reducing his expenditure of resources at our expense. 4 CAW-13-3623 (d) Each component of proprietary information pertinent to a particular competitive advantage is potentially as valuable as the total competitive advantage. If competitors acquire components of proprietary information, any one component may be the key to the entire puzzle, thereby depriving Westinghouse of a competitive advantage.(e) Unrestricted disclosure would jeopardize the position of prominence of Westinghouse in the world market, and thereby give a market advantage to the competition of those countries.(f) The Westinghouse capacity to invest corporate assets in research and development depends upon the success in obtaining and maintaining a competitive advantage.(iii) The information is being transmitted to the Commission in confidence and, under the provisions of 10 CFR Section 2.390, it is to be received in confidence by the Commission.(iv) The information sought to be protected is not available in public sources or available information has not been previously employed in the same original manner or method to the best of our knowledge and belief.(v) The proprietary information sought to be withheld in this submittal is that which is appropriately marked in LTR-SGDA-12-36, Rev. 3 P-Attachment, "Flow-Induced Vibration and Tube Wear Analysis of the San Onofre Nuclear Generating Station Unit 2 Replacement Steam Generators," dated February 15, 2013, for submittal to the Commission, being transmitted by Southern California Edison Letter and Application for Withholding Proprietary Information from Public Disclosure, to the Document Control Desk. The proprietary information as submitted by Westinghouse is that associated with the calculation of fluidelastic excitation of steam generator tubes and may be used only for that purpose. 5 CAW-13-3623 This information is part of that which will enable Westinghouse to: (a) Respond to Nuclear Regulatory Commission (NRC) Request for Additional Information regarding stability ratios calculated for certain anti-vibration bar (AVB) support conditions for the San Onofre Nuclear Generating Station Unit 2 steam generators. Further this information has substantial commercial value as follows: (a) Westinghouse plans to sell the use of similar information to its customers for the purpose of evaluating the impact of fluidelastic excitation on steam generator tube integrity.(b) Westinghouse can sell support and defense of the thermal hydraulic analysis of secondary side flow field in the steam generator shell.(c) The information requested to be withheld reveals the distinguishing aspects of a methodology which was developed by Westinghouse. Public disclosure of this proprietary information is likely to cause substantial harm to the competitive position of Westinghouse because it would enhance the ability of competitors to provide similar information and licensing defense services for commercial power reactors without commensurate expenses. Also, public disclosure of the information would enable others to use the information to meet NRC requirements for licensing documentation without purchasing the right to use the information. The development of the technology described in part by the information is the result of applying the results of many years of experience in an intensive Westinghouse effort and the expenditure of a considerable sum of money. 6 CAW-13-3623 In order for competitors of Westinghouse to duplicate this information, similar technical programs would have to be performed and a significant manpower effort, having the requisite talent and experience, would have to be expended.Further the deponent sayeth not. Proprietary Information Notice Transmitted herewith are proprietary and/or non-proprietary versions of documents furnished to the NRC in connection with requests for additional information regarding stability ratios calculated for certain anti-vibration bar (AVB) support conditions for the San Onofre Nuclear Generating Station Unit 2 steam generators. In order to conform to the requirements of 10 CFR 2.390 of the Commission's regulations concerning the protection of proprietary information so submitted to the NRC, the information which is proprietary in the proprietary versions is contained within brackets, and where the proprietary information has been deleted in the non-proprietary versions, only the brackets remain (the information that was contained within the brackets in the proprietary versions having been deleted). The justification for claiming the information so designated as proprietary is indicated in both versions by means of lower case letters (a) through (f)located as a superscript immediately following the brackets enclosing each item of information being identified as proprietary or in the margin opposite such information. These lower case letters refer to the types of information Westinghouse customarily holds in confidence identified in Sections (4)(ii)(a) through (4)(ii)(f) of the affidavit accompanying this transmittal pursuant to 10 CFR 2.390(b)(1). Copyright Notice The reports transmitted herewith each bear a Westinghouse copyright notice. The NRC is permitted to make the number of copies of the information contained in these reports which are necessary for its internal use in connection with generic and plant-specific reviews and approvals as well as the issuance, denial, amendment, transfer, renewal, modification, suspension, revocation, or violation of a license, permit, order, or regulation subject to the requirements of 10 CFR 2.390 regarding restrictions on public disclosure to the extent such information has been identified as proprietary by Westinghouse, copyright protection notwithstanding. With respect to the non-proprietary versions of these reports, the NRC is permitted to make the number of copies beyond those necessary for its internal use which are necessary in order to have one copy available for public viewing in the appropriate docket files in the public document room in Washington, DC and in local public document rooms as may be required by NRC regulations if the number of copies submitted is insufficient for this purpose. Copies made by the NRC must include the copyright notice in all instances and the proprietary notice if the original was identified as proprietary. Southern California Edison Letter for Transmittal to the NRC The following paragraphs should be included in your letter to the NRC: Enclosed is: 1. _ copies of LTR-SGDA-12-36, Rev. 3 P-Attachment, "Flow-Induced Vibration and Tube Wear Analysis of the San Onofre Nuclear Generating Station Unit 2 Replacement Steam Generators" (Proprietary)

2. _ copies of LTR-SGDA-12-36, Rev. 3 NP-Attachment, "Flow-Induced Vibration and Tube Wear Analysis of the San Onofre Nuclear Generating Station Unit 2 Replacement Steam Generators" (Non-Proprietary)

Also enclosed is the Westinghouse Application for Withholding Proprietary Information from Public Disclosure CAW-1 3-3623, accompanying Affidavit, Proprietary Information Notice, and Copyright Notice.As Item I contains information proprietary to Westinghouse Electric Company LLC, it is supported by an affidavit signed by Westinghouse, the owner of the information. The affidavit sets forth the basis on which the information may be withheld from public disclosure by the Commission and addresses with specificity the considerations listed in paragraph (b)(4) of Section 2.390 of the Commission's regulations. Accordingly, it is respectfully requested that the information which is proprietary to Westinghouse be withheld from public disclosure in accordance with 10 CFR Section 2.390 of the Commission's regulations. Correspondence with respect to the copyright or proprietary aspects of the items listed above or the supporting Westinghouse affidavit should reference CAW-13-3623 and should be addressed to J. A. Gresham, Manager, Regulatory Compliance, Westinghouse Electric Company LLC, Suite 428, 1000 Westinghouse Drive, Cranberry Township, PA 16066.}}