ML101530533

Steam Generator Tube Inservice Inspection Report for 2009 Refueling Outage

ML101530533
Person / Time
Site:	Surry
Issue date:	05/24/2010
From:	Gerald Bichof Virginia Electric & Power Co (VEPCO)
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
10-220
Download: ML101530533 (21)

Text

VIRGINIA ELECTRIC AND POWER COMPANY RICHMOND, VIRGINIA 23261.May 24, 2010 Attention Document Control Desk Serial No.10-220 U.S. Nuclear Regulatory Commission SS&L/TJN RO Washington, D. C. 20555-0001 Docket No. 50-281 License No. DPR-37 Gentlemen:

VIRGINIA ELECTRIC AND POWER COMPANY SURRY POWER STATION UNIT 2 STEAM GENERATOR TUBE INSERVICE INSPECTION REPORT FOR THE 2009 REFUELING OUTAGE Technical Specification 6.6.A.3 for Surry Power Station Units 1 and 2 requires the submittal of a Steam Generator Tube Inspection Report to the NRC within 180 days after Tavg exceeds 200°F following completion of an inspection performed in accordance with the Technical Specification 6.4.Q, Steam Generator Program.Attached is the Surry Power Station Unit 2 report for the 2009 refueling outage.If you have any questions or require additional information, please contact Mr. Trace J.Niemi at 757-365-2848.

Sincerely, G. T. Bischof Site Vice President Surry Power Station Attachment Commitments made in this letter: None Serial No.10-220 Docket No.: 50-281 copy: US Nuclear Regulatory Commission Region II Marquis One Tower 245 Peachtree Center Avenue N.E., Suite 1200 Atlanta, GA 30303 Ms. K. R. Cotton NRC Project Manager U. S. Nuclear Regulatory Commission One White Flint North Mail Stop 8 G9A 11555 Rockville Pike Rockville, Maryland 20852-2738 V. Sreenivas NRC Project Manager U. S. Nuclear Regulatory Commission One White Flint North Mail Stop 8H4A 11555 Rockville Pike Rockville, Maryland 20852-2738 NRC Senior Resident Inspector Surry Power Station Mr. R. A. Smith Authorized Nuclear Inspector Surry Power Station Serial No.10-220 SPS2 180 Day SG ISl Report bc page 1 of 1 bc: (electronic copy except *)G. T. Bischof -SPS B. L. Stanley -SPS B. A. Garber -SPS W. M. Adams -SPS J. R. Rosenberger

-SPS E. J. Turko -SPS T. M. Mayer-SPS R. W. Cross -ITC V. L. Armentrout

-ITC MSRC Coordinator

-ITC Records Management

-c/o Corp Licensing (G. L. Melton -IN2SE) (bc original)*

Corp Licensing (G. L. Melton) (w/o attachment)

CONCURRENCE:

See Station Correspondence Review and Approval Form ACTION PLAN: None VERIFICATION OF ACCURACY: 1. Areva Steam Generator Services Integrated Report, Surry Power Station -Unit 2, December 2009- 2R22, Revision 0, 12/9/09 2. Letter from Virginia Electric and Power Company to the USNRC dated September 30, 2009 (Serial No. 09-455B), "Virginia Electric And Power Company (Dominion), Surry Power Station Units 1 And 2, Proposed License Amendment Request, One-Time Alternate Repair Criteria for Steam Generator Tube Inspection/Repair for Units 1 And 2" 3. WCAP-17092-P, June 2009, Revision 0, "H*: Alternate Repair Criteria for the Tubesheet Expansion Region in Steam Generators with Hydraulically Expanded Tubes (Model 51 F)" 4. E. Turko 5/4/10 LotusNote to T. Niemi,

Subject:

RE: 180 day report R15 5. Engineering Challenge review 180 day SG report from the 2009 U2 RFO (ref.Engineering Log 4/7/2010 15:12)6. Unit 2 Control Room Narrative Log for 11/25/09, RCS temperature exceeds 200F COMMITMENTS (STATED OR IMPLIED): None CHANGES TO UFSAR, USAR, QA TOPICAL REPORT, OR ISFSI SAR: None Serial No.10-220 Docket No.: 50-281 Attachment 1 SURRY UNIT 2 STEAM GENERATOR TUBE INSERVICE INSPECTION REPORT FOR THE 2009 REFUELING OUTAGE SURRY POWER STATION VIRGINIA ELECTRIC AND POWER COMPANY

• : :,J ?.Serial No.10-220 Docket No.: 50-281 Attachment 1 Page 1 SURRY UNIT 2 STEAM GENERATOR TUBE INSERVICE INSPECTION REPORT FOR THE 2009 REFUELING OUTAGE The following information satisfies the Surry Power Station Technical Specification (TS) reporting requirement section 6.6.A.3. During the Surry Unit 2 fall 2009 (EOC22) refueling outage, steam generator (SG) inspections were completed in accordance with TS 6.4.Q for all three SGs.The Unit 2 SGs were in the 3 rd inspection period which had a duration of 60 Effective Full Power Months (EFPM). The fall 2009 outage was the last outage of two in the second half of the 3 rd period.TS 6.6.A.3 requires a SG Tube Inspection Report to be submitted to the NRC within 180 days following the unit Tavg exceeding 200 0 F. Unit 2 Tavg exceeded 200°F on November 25, 2009, therefore this report is required to be submitted by May 24, 2010. At the time of this inspection, the current SGs had operated for 268.5 EFPM since the first inservice inspection.

For EOC22, a one-time alternate tube repair criterion (ARC) was submitted to allow tubes with service-induced flaws located greater than 16.7 inches below the top of the tubesheet to not require plugging.Tubes with service-induced flaws located in the portion of the tube from the top of the tubesheet to 16.7 inches below the top of the tubesheet would be plugged upon detection.

Associated with the ARC is a requirement to perform a one-time Eddy Current Testing (ECT)-based measurement of Bottom of Expansion Transition (BET) location for each tube on both the hot leg and cold leg. No significant deviation from the assumed BET value was found during a historical review of ECT data.The report information is provided under each bold italicized TS 6.6.A.3 item shown below. A list of acronyms is attached at the end of this report.A report shall be submitted within 180 days after Tavg exceeds 200°F following completion of an inspection performed in accordance with the Specification 6.4.Q, "Steam Generator (SG)Program." The report shall include: a. The scope of inspections performed on each SG The initial eddy current examination scope is identified below in Table 1. The only scope expansions required were those necessary to bound foreign objects and foreign object related degradation, and to resolve ambiguous indications.

A detailed summary of the actual EOC22 ECT examination scope is provided in the final inspection status (Table 2).The following special interest rotating +PointTM probe inspection criteria were. also applied during the EOC22 outage: SG A Only" All bobbin "1 (indication)-codes"* All PLP, PVN, OVR, BLG, and LGV Serial No.10-220 Docket No.: 50-281 Attachment 1 Page 2* All DNT with "NEW" in Utill field (not found during previous inspections)

• Previous foreign-object related locations flagged for examination

• Tube locations which may have been damaged by foreign objects identified during the secondary side visual inspection (SSI)" Tube locations with visible damage as identified during the SSI* Bound (1 tube deep) all RPC-confirmed PLPs* Bound (1 tube deep) all newly reported non-AVB VOL and non-AVB WAR that could have been caused by a foreign object" All previously reported PITs (none), hot leg "A (anomalies)-Codes", LPS (loose part signal), LPM (loose part monitoring), and RPC-confirmed PLPs" All indications of tube wall loss previously reported and sized with an RPC probe (excluding AVB wear)" All tube regions which cannot be examined effectively with the bobbin probe due to data quality concerns* All NTE/PTE from the top-of-tubesheet down to and including the location of the expansion transition" The five largest voltage DNTs located between TEC and 07H+1.0"" A sample of hot leg MBM/MBH (20% or 20 tests whichever is less)SGs B & C" All previous OVR* Previous foreign-object related locations flagged for examination" Tube locations which may have been damaged by foreign objects identified during the secondary side visual inspection (SSI)" 'Tube locations with visible damage as identified during the SSI* Bound (1 tube deep) all RPC-confirmed PLPs" Bound (1 tube deep) all newly reported non-AVB VOL and non-AVB WAR that could have been caused by a foreign object" All previously reported PITs (none), hot leg "A-Codes", LPS, LPM, and RPC-confirmed PLPs" All indications of tube wall loss previously reported and sized with an RPC probe (excluding AVB wear,)" All NTE/PTE from the top-of-tubesheet down to and including the expansion transition region* In Tier 1 High Residual Stress tubes, examine the following:

• Hot leg tubesheet, full depth (per Table 1)* All current and previous H (history calls)-codes

• All current and previous S (previous H-codes retested in later outages)-Codes

• All previous A-Codes (hot and cold leg)* All current DNT, BLG, OVRs, LGV, and MBM/MBH* All AVB Wear Indications The primary side work scope also included a video / visual examination of all six channel heads (as-found / as-left), specifically including all plugs, as well as the divider plate weld region.

Serial No.10-220 Docket No.: 50-281 Attachment 1 Page 3 Tubesheet Overexpansions During previous outages, all hot leg and cold leg tubesheet overexpansions were identified using computer data screening (CDS) methods. These overexpansions are of interest because they are potential initiating sites for tube corrosion.

During the current outage, a random sample of tubesheet OXPs as well as all OVRs were examined with +PointTM probes. The OXP and OVR examination count is summarized below in Table 3 and Table 4. In total, 60% of the SG "A" hot leg OXPs, and 30%of the SG "A" cold leg OXPs were examined with +PointTM probes. Incidental

+PointTM sampling of OXPs in the hot legs of SGs "B" and "C" was also performed.

No OXP or OVR related degradation was identified.

Table 1 -EOC22 Planned ECT Examination Scope Scope SG A SG B SG C Bobbin probe: 100% Full Length $(except for row 1 and 2 ubends)Rotating Probe: 66% 58% 58%H/L Expansion Transition (TSH+/-3") Sample Sample Sample Rotating Probe: Tier 1 High Stress Tubes (TEH to TSH+3") N/A* 100% 100%Tier 1 High Stress Tubes (H/L Tube Supports) 100% 50%Rotating Probe: V-1 50% H/L Dents >2 Volts Rotating Probe: 100% Row 1 and 2 U-bends (From support 07C to 07H)Rotating Probe: C/L Periphery (50% five tubes deep, TSC+/-3")Rotating Probe: 50% H/L OXP Sample " (TSH-16.7" to TSH+3")Rotating Probe: 20 Largest Voltage C/L OXPs (TEC-1 6.7" to TSC+3")*There are no tier 1 high stress tubes in SG A Serial No.10-220 Docket No.: 50-281 Attachment 1 Page 4 Table 2 -E0C22 Actual ECT Examination Scope (Final Inspection Status)S/G A S/G B S/G C Scope Description Extent Plan Acq'd % comp % Plan Acq'd % comp % Plan Acq'd % Comp %.Bbbin Coil Examns...Full Length TEH/TEC 3041 3041 100 3041 100 C/L Candy Cane (Row 3) 7H /TEC 94 94 100 94 100 C/L Straight (Row 1-2) 7C /TEC 184 184 100 184 100 H/L Straight (Row 1-3) 7H /TEH 278 278 100 278 100 M cExamns -H/L Tubesheet (Full TEH/TSH 60 60 100 60 100 2 2 100 2 100 14 14 100 14 100 Depth)H/L Tubesheet TSH +/-3 TSH/TSH 2206 2206 100 2206 100 1939 1939 100 1939 100 1939 1939 100 1939 100 OIL Tubesheet (Full TEC/TSC 20 20 100 20 100 Depth)OIL Tubesheet TSC 528 528 100 528 100 (TSC +/-3)UbendRPC(R1-2) 7C*/7H 184 184 100 184 100 High Stress Tubes (TSP) Various 16 16 100 16 100 56 56 100 56 100"Spcial, Interest~__

__ __H/L Previous DNT>2V Various 129 129 100 129 100 57 57 100 57 100 46 46 100 46 100 H/L Previous Indications Various 20 20 100 20 100 4 4 100 4 100 7 7 100 7 100 H/L Bobbin Indications Various 23 23 100 23 100 C/L Previous DNT >2V Various 2 2 100 2 100 1 C/L Previous Indications Various 15 15 100 15 100 C/L Bobbin Indications Various 7 7 100 7 100 Ubend Previous Various 2 2 100 2 100 DNT >2V Ubend Previous Various 1 1 100 1 100 Indications Ubend Bobbin Various 7 7 100 7 100 Indications Previous Foreign Object Various 5 5 100 5 100 9 9 100 9 100 23 23 100 23 100 Bounding Tubes Various 34 34 100 34 100 13 13 100 13 100 69 69 100 69 100 I Total 6824 6824 100 6824 100 I 2040 2040 1 100 I 2040 I 100 I 2170 2170 1 100 2170 100 Support Serial No.10-220 Docket No.: 50-281 Attachment 1 Page 5 Table 3 -Rotating Probe OXP Exams SG-A SG-B SG-C (tubes/indications)

Hot Cold Hot Cold Hot Cold Number of OXPs Above NumberofOxamine 63/75 20/24 7/11 0/0 9/10 0/0 TTS-1 6.7" Examined ____ ________Total Number of OXPs 109/126 72/79 350 / 466 251 / 340 46 / 58 65/87 Above TTS-16.7" 1 1 Table 4- Rotating Probe OVR Exams SG-A SG-B SG-C (tubes/indications)

Hot Cold Hot Cold Hot Cold NumberofOVRs 3/3 0/0 1/1 0/0 5/5 4/4 Examined TotalNumber 3/3 0/0 1/1 0/0 5/5 4/4 of OVRs Secondary Side Listed below is a summary of the secondary side work performed in the Surry Unit 2 SGs during the EOC22 outage.A Deposit Minimization Treatment (DMT) cleaning process was applied to SGs A, B, and C as preventive maintenance to reduce the inventory of deposit material on the secondary side of SGs.Deposit inventory reduction helps reduce the potential for tube corrosion, tube support broach hole blockage, and steam pressure loss due to heat transfer surface fouling. DMT utilizes a low concentration of oxalic acid which acts as a complexing agent in the dissolution of iron oxide deposits.A final passivation step employs lower concentration oxalic acid and hydrogen peroxide.

The process results in very low corrosion rates for internal SG subcomponents.

SGs A, B, C" Post sludge lancing top of tubesheet foreign object search and retrieval (FOSAR) at the top of the tubesheet, in the annulus, and no-tube lane" Sludge sample retrieval for chemical analysis" Post sludge lancing quick look on top of tubesheet and baffle plates to determine lancing effectiveness

• Visual investigation of historical foreign objects SG C" Steam drum visual inspection to include all major sub components as described in the secondary side inspection procedure/plan

• Internal feed-ring visual inspection of selected J-nozzle interfaces

• Visual top of tube bundle inspection via the primary moisture separator risers Serial No.10-220 Docket No.: 50-281 Attachment 1 Page 6 b. Active degradation mechanisms found Degradation mechanisms targeted by the inspection plan included anti-vibration bar (AVB) wear, pitting, foreign object wear, tube support wear as well as stress corrosion cracking (SCC) at various locations within the SG tube bundle. Only AVB wear, foreign object wear, and tube support plate wear were detected during the current outage. No indication of corrosion degradation was observed during this inspection.

Lists of service induced indications are located in Section "d" of this report.A one-time ARC was incorporated into the Surry Technical Specifications, effective during the EOC22 outage and during the operating cycle subsequent to the EOC22 outage. This ARC specifies that tubes with service-induced flaws located greater than 16.7 inches below the top of the tubesheet do not require plugging.

Further, the ARC requires that tubes with service-induced flaws located in the portion of the tube from the top of the tubesheet to 16.7 inches below the top of the tubesheet be plugged upon detection.

No degradation was identified in the areas inspected.

c. Nondestructive examination techniques utilized for each degradation mechanism The inspection program focused on the degradation mechanisms listed in Table 5 and utilized the referenced eddy current techniques.

Table 5 -Inspection Method for Applicable Degradation Modes Classification Degradation Location Probe Type Mechanism Bobbin -Detection Existing Tube Wear Anti-Vibration Bars Bobbin or +PointTM -Sizing Flow Distribution Bobbin -Detection Potential Tube Wear Baffle +PointTM-Sizing Bobbin -Detection Existing Tube Wear Tube Support Plate BointTM -Sion+Pointr -Sizing Tube Wear Bobbin -Detection Existing (foreign objects) Freespan, TT-, TSP +PointM- Sizing Bobbin -Detection Existing Pitting TTS BointTM ection+Point m- Sizing OD Corrosion Hot Leg Top-of- +PointM- Detection Potential PWSCC Tubesheet

+Point T M-Sizing OD Corrosion Hot Leg Dent +PointM- Detection Potential PWSCC Locations

+PointTM-Sizing OD Corrosion Hot and Cold Leg +PointTM-Detection Potential PWSCC OVR and BLG +PointTM -Sizing OD Corrosion Row 1 and 2 +PointTM-Detection Potential PWSCC U-bends +PointTM -Sizing Serial No.10-220 Docket No.: 50-281 Attachment 1 Page 7 Table 5 -Inspection Method for Applicable Degradation Modes (continued)

Classification Degradation Location Probe Type Mechanism Freespan and Tube Bobbin -Detection Potential OD corrosion Supports +PointTM -Sizing Within-Tubesheet

+PointTM -Detection Potential PWSCC Overexpansions

+PointT -Sizing Crevices formed by +PointTM -Detection Potential OD Corrosion NTE/PTE +PointTM -Sizing Potential Tube Slippage Within Tubesheet Bobbin -Detection d. Location, orientation (if linear), and measured sizes (if available) of service induced indications As stated in the (b) response above, several wear type indications were noted. Tables 7, 8, and 9 provide the requested information for these indications.

AVB Wear Indications A total of 23 AVB wear indications in 17 tubes were identified in SG "A" (see Table 7). None of the identified flaws exceeded the Technical Specification plugging limit (40%TW) or the 30%TW preventive plugging limit for AVB wear, and none were plugged. The maximum indicated depth was 28%TW (reported in tube SGA R36 C62).Since 100% of the tubes in SG "A" received full-length bobbin examinations (except for row 1 and 2 u-bends) during the EOC22 outage, a direct comparison back to previous examination results is possible.

Newly reportable AVB wear was reported in SG "A" during this outage, while one of the previously reported wear indications was not reportable during this outage and was therefore classified as INR (indication not reportable).

The newly reportable indications do not indicate newly developed AVB wear but rather are the result of eddy current sizing uncertainty which caused some indications which were previously just below the 10% reporting criteria to be sized at greater than the reporting criteria.

A summary of these EOC22 AVB wear indications is identified in Table 6.Table 6 -EOC22 AVB Wear Results (New / INR)SG Total Number of New AVB Wear Total Number of INR Tubes / Indications Tubes I Indications A 8/11 1/1 Surry AVB wear growth has steadily decreased since its initial detection in the 1980s and no newly initiated AVB wear was identified during the EOC22 outage. No tubes required plugging due to AVB wear during this outage.

Serial No.10-220 Docket No.: 50-281 Attachment 1 Page 8 Table 7 -AVB Indications Depth (%TW) Upper Bound 2009 Projected AVB (ETSS 96004.1) Depth (%TW) 2012 Depth (%TW)SG Row Col No. 2006 2009 (for CM) (for OA)A 25 57 AV2 18 17 33.4 47.4 A 26 9 AV4 11 11 27.6 41.6 A 26 86 AV3 21 22 38.3 52.3 A 28 69 AV3 0* 10 26.7 40.7 A 29 70 AV2 11 11 27.6 41.6 A 30 64 AV2 0* 11 27.6 41.6 A 33 61 AV3 0* 18 34.4 48.4 A 33 61 AV4 0* 15 31.5 45.5 A 36 62 AV2 26 24 40.2 54.2 A 36 62 AV3 14 16 32.5 46.5 A 36 62 AV4 29 28 44.1 58.1 A 36 66 AV3 0* 10 26.7 40.7 A 38 57 AV1 0* 14 30.5 44.5 A 38 72 AV4 26 25 41.2 55.2 A 38 74 AV4 20 19 35.4 49.4 A 40 49 AV1 12 12 28.6 42.6 A 40 49 AV2 0* 10 26.7 40.7 A 40 49 AV3 10 11 27.6 41.6 A 40 65 AV2 22 21 37.3 51.3 A 40 65 AV4 0* 12 28.6 42.6 A 40 66 AV3 0* 10 26.7 40.7 A 44 35 AV2 0* 12 28.6 42.6 A 45 44 AV2 0* 12 28.6 42.6* Not reported in 2006. Used 0%TW as default depth.Notes: 1) Total Random Sizing Uncertainty at 95/50: 13.5 %TW 2) Upper Bound 2009 Depth: [0.97] x [Field Call] + [3.45] + [13.5]3) Fall 2012 Projected Depth: [Upper Bound 2009 Depth] + [(7.0%TW/Cycle) x 2 Cycles]

Serial No.10-220 Docket No.: 50-281 Attachment 1 Page 9 Table 8 -Surry Unit 2 AVB Statistical Summary SG A SG B SG C Combined Number of Tubes / Indications with AVB Wear 17/23 n/a n/a 17/23 Reported during the Current Outage Number of Tubes In-Service with AVB Wear (following the current outage)Total Number of Tubes Plugged during the 0 0 0 0 Current Outage Due to AVB Wear Total Number of Tubes Plugged to Date Due to 1 5 10 16 AVB Wear (following the current outage)Average Wear Rate of Repeat Indications 0.03 0.29 0.05 0.06 (%TW/cycle) 95/50 Wear Rate of Repeat Indications 1.7 1 0** 1.5 1.5 (%TW/cycle)

Conservative Average Wear Rate* 2.2 2.3 1.3 1.6 (%TW/cycle)

Conservative 95/50 Wear Rate* 7.5 4.8 7.5 7.0 (%TW/cycle)

__7.5_4.8 7.5 7.0 Inspection Data Used 2002, 2006, 1997, 2003, 2000, 2005, n/a (outage year) 2009 2008 2008 Number of Repeat Indication Data Points 24 7 68 99 Number of Data Points Including Repeat 36 15 80 131 and Newly Reported Indications

• 1) Includes growth assumption for newly reported indications based on 0%TW at previous inspection, 2) Negative indicated growth rates were set equal to zero,** Maximum value shown due to small number of data points.Non-AVB-Wear Volumetric DeQradation Forty-seven tubes with indications of volumetric degradation, all but two attributed to foreign object wear, were identified during the EOC22 examinations (see Table 9). Nine of these tubes were plugged (SG "A" = 4, SG "B" = 2, SG "C" = 3) because the measured indication depth exceeded the 40%TW plugging limit; one of the nine was also stabilized.

The two indications not attributed to foreign object wear were attributed to wear at a tube support plate intersection.

Serial No.10-220 Docket No.: 50-281 Attachment 1 Page 10 Table 9 -Summary of Non-AVB Wear Volumetric Degradation Identified Signal Present Max Axial Circ. Prior to Foreign Depth Length Length Initially Current Object In-Situ SG Row Col Location ETSS (%TW) i (in) Reported Outage? Cause Remaining?

Tested? Plugged?Yes. No signal TSP A 6 60 5H *0.67 96910.1 12%TW 0.35 0.42 2009 change Wear n/a No No since 2002.Yes. No A 17 16 TSH+0.06 27901.1 29%TW 0.35 0.50 2002 signal Foreign No No No change. Object Yes. No A 18 16 TSH+0 27901.1 24%TW 0.30 0.42 2002 signal Foreign No No No change. Object Yes. No A 32 27 TSC+0.08 27901.1 20%TW 0.27 0.45 2006 signal Foreign No No No change. Object Yes. No A 33 27 TSC+0.09 27901.1 24%TW 0.35 0.40 2006 signal Foreign No No No change. Object Yes. NoFoeg A 34 26 TSC+0.13 27901.1 40%TW 0.35 0.45 2006 signal Foreign No No Yes change.Yes. No signal Foreign No No No A 39 24 TSH+0.37 27901.1 19%TW 0.30 0.42 2009 change Object since 2006.Yes. No A 40 28 TSC+0.1 27901.1 41%TW 0.41 0.50 2006 signal Foreign No No Yes change. Object Yes. No A 40 29 TSC+0.13 27901.1 42%TW 0.44 0.47 2006 signal Foreign No No Yes change. Object A 42 52 TSC+0.29 27901.1 20%TW 0.38 0.45 2009 No Foreign No No No I_ I I I I I -I I O bject I Serial No.10-220 Docket No.: 50-281 Attachment 1 Page 11 Table 9 -Summary of Non-AVB Wear Volumetric Degradation Identified (cont.)Signal Present Axial Circ. Prior to Foreign Max Depth Length Length Initially Current Object In-Situ SG Row Col Location ETSS (%) (in) (in) Reported Outage? Cause Remaining?

Tested? Plugged?Yes. No signal Foreign No No No A 43 61 BPH+0.56 27901.1 22%TW 0.38 0.48 2009 change Object since 2002.Yes.Possible minor Foreign A 43 64 BPH+0.65 27901.1 24%TW 0.35 0.37 2009 signal Orect No No No change Object since 2002.A 46 47 BPH+0.67 27901.1 50%TW 0.38 0.48 2009 No Foreign Yes No Yes and (SD=44%TW) (SL=0.28")

Object stabilized Foreign 1 No Yes and A 46 48 BPH+0.66 27901.1 33%TW 0.44 0.45 2009 No Object Yes stabilized FObjeign Yes sabiizd B 21 11 2C*+0.76 27901.1 29%TW 0.32 0.40 2009 No Foreign Yes No Yes and Object stabilized Yes. N oeg 22 82 TSH+0.14 27901.1 55%TWo 0.41 0.56 2003 signal oNo No Yes (SD=47%TW) (SL=0.27")

change. Object Yes. No Foreign 23 82 TSH-0.01 27901.1 23%TW 0.30 0.37 2003 signal Orect No No No change. Object Yes. NoFoeg 36 26 TSC+0.02 27905.1 26%TW 0.40 0.40 2008 signalO Foreign No No No change. Object Yes. No Foreign B 36 27 TSC+0.17 27901.1 45%TW* 0.43 0.58 2008 signal Orect No No Yes change. Object Serial No.10-220 Docket No.: 50-281 Attachment 1 Page 12 Table 9 -Summary of Non-AVB Wear Volumetric Degradation Identified (cont.)Signal Max Axial Circ. Initially Present Foreign In-Situ SG Row Col Location ETSS Depth Length Length Prior to Cause Object Tested? Plugged?(%TW) (in) (in) Reported Current Remaining?

Outage?Yes. No B 37 27 TSC+0.14 27901.1 26%TW 0.38 0.45 2008 signal Foreign No No No change. Object Yes. No signal Foreign No No No C 28 71 TSH+0.31 27901.1 26%TW 0.36 0.48 2009 change Object since 1996.Yes. No Foreig I n C 32 36 BPH+0.56 27901.1 18%TW 0.25 0.40 2009 signal OeNo No No change. Object Yes. No C 33 17 TSH+2.68 27901.1 20%TW 0.33 0.42 2005 signal Foreign No No No change. Object Yes. No C 34 18 TSH+1 27901.1 22%TW 0.33 0.45 2005 signal Foreign No No No change. Object Yes. No C 34 20 TSH+0.93 27901.1 26%TW 0.33 0.45 2005 signal Foreign No No No change. Object Foreign 2 Yes and C 34 39 BPH+0.55 27901.1 31%TW 0.33 0.48 2009 No Object Yes No stabilized Yes. No Foreign C 34 74 TSH+0.13 27901.1 28%TW 0.33 0.42 2005 signal Object No No No change.Yes. No C 35 19 TSH+0.34 27901.1 31%TW 0.33 0.42 2005 signal Foreign No No No change. Object Yes. No C 35 22 TSH+1.08 27901.1 29%TW 0.36 0.45 2005 signal Foreign No No No change. Object Serial No.10-220 Docket No.: 50-281 Attachment 1 Page 13 Table 9 -Summary of Non-AVB Wear Volumetric Degradation Identified (cont.)Signal Present Max Axial Circ. Prior to Foreign Depth Length Length Initially Current Object In-Situ SG Row Col Location ETSS (%TW) (in) (in) Reported Outage? Cause Remaining?

Tested? Plugged?Yes. No C 35 30 TSH+0.13 27901.1 38%TW 0.33 0.45 2005 signal Foreign No No No change. Object Yes.No Foreign 2 Yes and C 35 37 BPH+0.56 27901.1 -25%TW 0.27 0.37 2005 signal Object Yes No change. stabilized C 35 39 BPH+0.53 27901.1 -26%TW 0.22 0.63 2009 No Foreign Yes No Yes and Object stabilized TSH+0.09 27901.1 26%TW 0.36 0.37 Yes. No C 35 69 TSH+0.13 27901.1 44%TW 0.38 0.45 2005 signal Foreign No No Yes Overall Dimensions 0.38 0.82 change. Object Yes. No Foreign 35 71 TSH+0.26 27901.1 41%TW** 0.41 0.48 2005 signal Object No No Yes change.27901.1 22TW 0.25 042 2009 No Foreign 2 Yes and 36 37 BPH+0.55 2 .Object Yes No stabilized Yes. No C 36 68 TSH+0.18 27902.1 27%TW 0.6 0.45 2005 signal Foreign No No No change. Object Yes. No signal Foreign C 37 34 TSH+0.03 27901.1 26%TW 0.33 0.45 2009 change Object No No No since 1996.Yes. No C 37 35 BPH+0.57 27901.1 31%TW 0.33 0.48 2005 signal Foreign No No No change. Object Yes. No C 37 54 TSH+0.19 27901.1 25%TW 0.36 0.45 2005 signal Foreign No No No I_ I_ I_ I_ __ I_ _change. Object Serial No.10-220 Docket No.: 50-281 Attachment 1 Page 14 Table 9 -Summary of Non-AVB Wear Volumetric Degradation Identified (cont.)Signal Present Max Axial Circ. Prior to Foreign Depth Length Length Initially Current Object In-Situ SG Row Col Location ETSS (%TW) (inl (in) Reported Outage? Cause Remaining?

Tested? Plugged?Yes. No 37 73 7C*-0.6 96910.1 14%TW 0.64 0.48 2005 signal TSP n/a No No change.Yes. No C 38 53 TSH+0.17 27901.1 22%TW 0.38 0.42 2005 signal Foreign No No No change. Object Yes. No C 38 54 TSH+0.18 27901.1 40%TWV 0.36 0.42 2005 signal Foreign No No Yes change. Object Yes. No C 44 42 TSH+0.16 27901.1 23%TW 0.33 0.42 2005 signal Foreign No No No change. Object Yes. No C 44 43 TSH+0.23 27901.1 26%TW 0.3 0.42 2005 signal Foreign No No No change. Object Yes. No C 44 47 TSH+0.09 27901.1 28%TW 0.33 0.39 2005 signal Foreign No No No change. Object TSH+0.3 27901.1 24%TW 0.36 0.42 TSH+0.3 27901.1 23%TW 0.33 0.42 2005 signal oNo No No C 45 4 TSH+0.77 27901.1 19%TW 0.3 0.34 205 sgna Object Overall dimensions 0.77 0.95 change.Yes. No C 45 47 TSH+0.24 27901.1 25%TW 0.33 0.42 2005 signal Foreign No No No chanae. Object SD=structurally significant depth SL=structurally significant length Support*2009 sizing technique was more conservative than that used previously Notes-1. Assumed to be present between R46C47 and R46C48.2. Assumed to be present Serial No.10-220 Docket No.: 50-281 Attachment 1 Page 15 e. Number of tubes plugged during the inspection outage for each active degradation mechanism Table 10 summarizes EOC22 tube plugging by cause. Note that as a condition for the approval of the one-time ARC, Surry committed to remove from service tubes having partial tubesheet expansion (PTE) or no tubesheet expansion (NTE). None of the Surry Unit 2 tubes have been identified as having PTEs, however 11 tubes with NTEs were plugged.Table 10- EOC22 Plugging Summary -Number of Tubes Plugged SG "A" SG "B" SG "C" Total AVB Wear 0 0 0 0 Foreign Object Wear >40%TW 4* 2 3 9 Foreign Object Present 3** 1** 6** 10"*NTE 0 4 7 11 Total 7 7 16 30*One of the four tubes was stabilized.

• • Stabilized.

f. Total number and percentage of tubes plugged to date Table 11 provides the plugging attributes and the percentage of tubes plugged through and including EOC22.Table 11 -Cumulative Plugging Tubes Installed Tubes Plugged To-Date SG "A" 3,342 30 (0.9%)SG "B" 3,342 18(0.5%)SG "C" 3,342 46 (1.4%)Total 10,026 94 (0.9%)g. The results of condition monitoring, including the results of tube pulls and in-situ testing None of the tube degradation identified in Surry Unit 2 SGs during the EOC22 outage violated the structural performance criteria; thereby providing reasonable assurance that none of these flaws would have leaked during a limiting design basis accident.

J :4 Serial No.10-220 Docket No.: 50-281 Attachment 1 Page 16 Based on the evaluations documented, all degradation identified during the fall 2009 inspection satisfied condition monitoring requirements for SG tube structural and leakage integrity.

Therefore, tube pulls and in-situ pressure testing were not necessary.

h. The effective plugging percentage for all plugging in each SG Since none of the Surry Unit 2 SG tubes have been sleeved, the effective plugging percentage is identical to the plugging percentages provided in the response in Section "f' of this report.i. For Unit 2 during Refueling Outage 22 and the subsequent operating cycle .... the primary to secondary leakage rate observed in each SG... during the cycle preceding the inspection which is the subject of the report During the cycle preceding EOC22, no measurable primary-to-secondary leakage (i.e., >1 GPD) was observed in any Unit 2 SG.j. For Unit 2 during Refueling Outage 22 and the subsequent operating cycle ... the calculated accident induced leakage rate from the portion of the tubes from below 16.7 inches from the top of the tubesheet for the most limiting accident in the most limiting SG. In addition, if the calculated accident induced leakage rate from the most limiting accident is less than 2.03 times the maximum operational primary to secondary leakage rate, the report should describe how it was determined.

The one-time ARC requires that the component of operational leakage from the prior cycle from below the 16.7 inch distance be multiplied by a factor of 2.03 and added to the total accident leakage from any other source and compared to the allowable accident induced leakage limit. Since there is reasonable assurance that no tube degradation identified during this outage would have resulted in leakage during an accident, the contribution to accident leakage from other sources is zero. Assuming that the prior cycle operational leakage of <1 GPD originated from below the 16.7 inch distance, and multiplying this leakage by a factor of 2.03, yields an accident induced leakage value of <2.03 GPD.This value is well below the 470 GPD limit for the limiting SG and provides reasonable assurance that the accident induced leakage performance criteria would not have been exceeded during a limiting design basis accident.k. For Unit 2 during Refueling Outage 22 and the subsequent operating cycle ... the results of the monitoring for tube axial displacement (slippage).

If slippage is discovered, the implications of the discovery and corrective action shall be provided.The one-time ARC requires routine monitoring for tube slippage within the tubesheet and any tubes showing evidence of slippage require plugging.

This condition could only occur if the tube severs circumferentially within the tubesheet, a condition which can be readily detected using bobbin probe inspection data. During the current outage inspection, this analysis was performed on both legs of all tubes in SG "A." No evidence of slippage was identified.

Slippage monitoring in SG "B" and SG "C" will be accomplished during the 2011 outage.

Serial No.10-220 Docket No.: 50-281 Attachment 1 Page 17 Acronyms AVB Anti Vibration Bar ARC Alternate Repair Criteria BET Bottom of Expansion Transition BLG Bulge BPH Baffle Plate Hot C, Column CM Condition Monitoring CMOA Condition Monitoring Operational Assessment C/L Cold Leg DEP Deposit DMT Deposit Minimization Treatment DNG Ding DNT Dent ECT Eddy Current Testing EFPY Effective Full Power Years EOC End of Cycle ETSS Eddy Current Technical Specification Sheets FB Fan Bar FOSAR Foreign Object Search and Retrieval GPD Gallons Per Day LGV Localized Geometric Variation H/L Hot Leg LPI Loose Part Indication MBH Historical Manufacturing Brandish Mark MBM Manufacturing Burnish Mark MRPC Motorized Rotating Pancake Coil NOP Normal Operating Pressure NTE No Tubesheet Expansion NQH Non-Quantifiable Historical Indication NQI Non-Quantifiable Indication OA Operation Assessment OD Outer Diameter OVR Over Roll OXP Over Expansion PLP Possible Loose Part PTE Partial Tubesheet Expansion PVN Permeability Variation PWSCC Primary Water Stress Corrosion Cracking% TW Percent Throughwall R Row RPC Rotating Pancake Coil SG Steam Generator SLG Sludge SAI Single Axial Indication SCl Single Circumferential Indication SSI Secondary Side inspection SVI Single Volumetric Indication Tavg Average Reactor Coolant System Temperature TEC Tube End Cold-leg TEH Tube End Hot-leg TSC Top of Tube Sheet Cold-leg TSH Top of Tube Sheet Hot-leg TSP Tube Support Plate TTS Top of Tubesheet TW Through Wall VOL Volumetric Indication WAR Wear Indication 95/50 95% probability and 5 0% confidence