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    SSOUTHERN CALIFORNIASDwight E. Nunn

    EO Vice PresidentAnEDISONINTERNATIONAL"' Company May 22, 2002

    U. S. Nuclear Regulatory Commission

    Attention: Document Control DeskWashington, D.C. 20555

    Subject: Docket Nos. 50-361 and 50-362

    Proposed Change Number NPF-10/15-543

    Exigent Steam Generator Technical Specification Change

    San Onofre Nuclear Generating Station

    Units 2 and 3

    Gentlemen:

    In accordance with theprovisions of10 CFR 50.90, Southern California Edison (SCE) is

    submitting an Exigent request for an amendment to SCE Licenses NPF-10 and NPF-15 to

    change the Technical Specifications for San Onofre Units 2 and 3. The proposed change

    specifically is to revise Technical Specification Steam Generator (SG) Tube Surveillance

    Program requirement 5.5.2.11.f.1 .h to more clearly delineate the scope ofthe SG tube

    inspection required in the tubesheet region. The basis for the proposed change is

    WCAP-1 5894, Revision 0, "NDE Inspection Strategy For the Tubesheet Region In SONGSUnits 2 and 3," enclosed.

    SCE believes that the existing San Onofre Units 2 and 3 Technical Specifications

    adequately delineate the scope ofthe San Onofre SG tube inspections. Nevertheless,

    becausethe NRC staffhas recently requested a clarifying Amendment, SCE is submitting

    the enclosed exigent Amendment request. (This was discussed with the NRC staffin

    teleconferences on May 14, 2002 and May 15, 2002.) An exigent Technical Specification

    change is needed to prevent a delay in the resumption ofoperation ofUnit 2 following the

    current refueling outage. Should the staff, however, conclude that no Amendment is

    necessary, SCE will agree to withdraw this Amendment request.

    SCE has determined that there are no significant hazards considerations associated with

    the proposed change and that the change is exempt from environmental review pursuant

    to the provisions of10 CFR 51.22 (c) (9).

    Enclosure 1 to this letter provides a description and evaluation ofthe proposed change,

    including copies ofthe appropriate Technical Specification pages from Units 2 and 3,

    marked up to show the proposed change. This description and evaluation includes SCE's

    determination that the proposed change does not involve a significant hazards

    consideration and is exempt from environmental review. Enclosures 2 and 3 are

    proprietary and non-proprietary versions, respectively, ofWestinghouse topical report

    WCAP-1 5894, Revision 0, "NDE Inspection Strategy For the Tubesheet Region In SONGSUnits 2 and 3."

    P.O. Box 128

    San Clemente, CA 92674-0128

    949-368-1480

    Fax 949-368-1490

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    Document Control Desk

    Because Enclosure 2 contains information proprietary to Westinghouse, it is supported by

    an Affidavit (Enclosure 4) signed by Westinghouse, the owner ofthe information. The

    Affidavit sets forth the basis on which the information may be withheld from public

    consideration by the Commission and addresses with specificity the consideration listed in

    paragraph (b)(4) of10 CFR Section 2.790 ofthe Commission's regulations.

    SCE requests exigent NRC review and approval as soon as possible but not later than

    June 12, 2002 to support Unit 2 entry into Mode 4 from the current refueling outage. Mode

    4 is currently scheduled for June 19, 2002. SCE is making no formal commitments that

    would derive from NRC approval ofthe proposed amendment.

    Ifyou have any questions regarding this request please contact me or Mr. Jack L. Rainsberry

    at (949) 368-7420.

    I declare under penalty ofperjury that the foregoing is true and correct.

    Sincerely,

    Executed on

    Vice President

    Enclosures:1.

    2.

    3.4.

    Description and No Significant Hazards Analysis for Proposed

    Change NPF-10/15-543AttachmentsA. Existing Technical Specification page, Unit 2

    B. Existing Technical Specification page, Unit 3

    C. Markup ofTechnical Specification page, Unit 2

    D. Markup ofTechnical Specification page, Unit 3

    E. Retyped Technical Specification page, Unit 2

    F. Retyped Technical Specification page, Unit 3Westinghouse Topical Report WCAP-15894-P

    Westinghouse Topical Report WCAP-15894-NPAffidavit for the Proprietary Westinghouse Topical Report

    cc: E. W. Merschoff, Regional Administrator, NRC Region IV

    A. B. Wang, NRC Project Manager, San Onofre Units 2, and 3

    C. C. Osterholtz, NRC Senior Resident Inspector, San Onofre Units 2 & 3

    S. Y. Hsu, Department ofHealth Services, Radiologic Health Branch

    May 22, 2002-2-

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    ENCLOSURE 1

    Description and No Significant Hazards Analysis

    for Proposed Change NPF-1 0/15-543San Onofre Nuclear Generating Station

    Units 2 and 3

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    DESCRIPTION AND NO SIGNIFICANT HAZARDS ANALYSIS

    FOR PROPOSED CHANGE NPF-10/15-543

    San Onofre Nuclear Generating Station Units 2 and 3

    EXISTING TECHNICAL SPECIFICATIONS

    Unit 2: See Attachment A

    Unit 3: See Attachment B

    PROPOSED TECHNICAL SPECIFICATIONS

    (highlight for additions)

    Unit 2: See Attachment C

    Unit 3: See Attachment D

    PROPOSED TECHNICAL SPECIFICATIONS(with changes)

    Unit 2: See Attachment E

    Unit 3: See Attachment F

    DESCRIPTION OF CHANGE

    1.0 Introduction

    Southern California Edison (SCE) proposes a revision ofTechnicalSpecification Steam Generator (SG) Tube Surveillance Program requirement

    5.5.2.11 .f.1 .h to clarify the extent ofthe SG tube inspections required in the SG

    tubesheet (TS). The Surveillance Program requirement 5.5.2.11 .f.1 .h provides

    a definition for tube inspection. The Surveillance Program requirement

    currently reads as follows:

    "Tube Inspection - An inspection ofthe SG tube from the point of entry (hot leg

    side) completely around the U-bend to the top support ofthe cold leg; and"

    The proposed change clarifies the scope ofthe tube inspection required for the

    region within the SG TS. The proposed change addresses the portion ofthe

    tube within the TS below the tube engagement area (TEA) length, as follows:

    "Tube Inspection - An inspection ofthe SG tube from the point of entry (hot legside) completely around the U-bend to the top support ofthe cold leg excluding

    the portion ofthe tube within the tubesheet (TS) below 5 inches from the

    secondary face ofthe TS."

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    2.0 Reason for the Proposed Change

    SCE performs San Onofre Unit 2 and 3 SG rotating coil eddy current tests in

    areas defined by the San Onofre Nuclear Generating Station (SONGS)

    Degradation Assessment. The extent within the TS of recent past inspections

    and ofthe upcoming, planned inspectionsis 5 inches into the hot leg TS.

    Recent conference calls were held with NRC staffmembers to discuss the

    planned San Onofre Units 2 and 3 SG tube inspections. During the

    teleconferences, the staffasked questions on the extent ofthe tube inspections

    that were being planned with a rotating probe within the TS region. The extent

    ofSCE's rotating plus point probe inspections in the TS region covers 5 inches

    (as a minimum) below the top ofthe hot leg TS. SCE will repair or plug on

    detection any tubes with indications ofcracking. The NRC requested that SCE

    clarify tube inspection criteria within the TS for this region of the tube.

    Consequently, SCE is proposing the enclosed change as an exigent Technical

    Specification change to clarify the current San Onofre Units 2 and 3 Technical

    Specification tube inspection extent.

    3.0 Safety Analysis

    The SGs at San Onofre Units 2 and 3 were manufactured by Combustion

    Engineering with a U-tube configuration. Each tube is secured in the TS above

    the lower plenum ofthe SG by an explosive expansion process (explansion).

    This process expands each tube over its entire length within the TS and forms

    an interference fit between the tube and TS. This interference fit forms the

    interface, which provides the structural and part ofthe leaktight boundary

    between the primary and secondary systems at each end of a SG tube.Located near the top ofthe TS is a region where the tube transitions from theTS hole diameter to that ofthe original tube

    An alternate tube repair criteria (referred to as W*) was developed by

    Westinghouse Electric Company for Westinghouse plants to permit tubes with

    predominantly axially oriented primary water stress corrosion cracking

    (PWSCC) in the WEXTEX TS expansions to remain in service. The W*

    analysis defines a W* length that would permit flaws to remain in service and

    assure adequate strength is available to resist the axial pullout loads

    experienced within the TS. The San Onofre Units 2 and 3 proposed change is

    for the purpose ofdefining the inspection extent only and is not requesting an

    alternate repair criteria as intended by W*.

    This SONGS specific analysis (WCAP-1 5894, Revision 0) "NDE Inspection

    Strategy For the Tubesheet Region In SONGS Units 2 and 3," is applicable to

    the SONGS Unit 2 and 3 SGs and defines the maximum TEA length in section

    8. For conservatism, and to provide assurance ofcomplete inspection ofthe

    TEA length, SONGS is defining the area ofinterest to be 5.0 inches. The

    presence ofthe surrounding TS prevents tube rupture and provides resistance

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    against axial pullout loads during normal and accident conditions. In addition,

    any primary-to-secondary leakage from tube degradation below the TEA length

    is an inconsequential contribution to the total leakage assumed for a steam line

    break (SLB) accident and may be considered negligible. Consequently, any

    tube degradation that may go undetected below the TEA would not affectstructural or leakage margins.

    Definitions:

    TEA (tube engagement area) length - The length oftubing below the top

    of-tubesheet ofthe explanded portion ofthe tube which must be

    demonstrated to have no detectable degradation and is defined in WCAP

    15894, Revision 0, section 8.

    Inspection Extent Uncertainty - The uncertainty associated with the actual

    probe location relative to the indicated location during data analysis ofthe

    recorded eddy current data.

    Inspection Extent - The minimum length oftubing below the hot leg top-of

    tubesheet to be inspected to determine completely and unambiguously if

    degradation is detected within the TEA length. The extent includes

    inspection extent uncertainty to provide assurance that the TEA length is

    completely inspected. The Inspection extent is 5 inches below the hot leg

    top-of-tubesheet.

    SONGS performs a Degradation Assessment to determine areas susceptible to

    degradation, the areas ofthe tubing to be inspected, and the appropriate eddy

    current techniques to detect and quantify degradation within each area. Inputdata needed for the subsequent Condition Monitoring and OperationalAssessment are considered in the Degradation Assessment.

    The SONGS SG inspection fulfills Technical Specification 5.5.2.11 .f.1 .hrequirements for inspecting SG tubing by performing 100 percent full-length

    inspection ofeach tube using a bobbin coil probe, with one exception. Thesmallest radius U-bends (rows 1, 2, and 3) are inspected with a rotating plus

    point probe, rather than a bobbin probe. Inthese small U-bends, the rotating

    plus point probe is a much better design for such changing geometry test

    conditions. To reduce the probability and consequences ofSG tube rupture or

    tube failure, the SONGS Degradation Assessment and critical area definition

    process identify additional inspections. SONGS performs these additionalinspections in critical areas using the rotating plus point probe to identify crack

    like indications that would not be easily identified with the bobbin coil probe.

    For future inspections, ifprobe development results in new types ofprobes

    which are equivalent or superior to the plus point rotating probe, SCE may

    evaluate these for possible use in this application.

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    The critical area ofthe tubes in the tube-to-tubesheet expansion in SONGS

    steam generators includes the TEA length. The TEA length is defined for

    SONGS Units 2 and 3 in WCAP-15894, Revision 0 considering the most

    stringent loads associated with plant operation, including transients and

    accident conditions, and with an additional margin provided by the use of3 X

    Normal Operating Differential Pressure

    The WCAP-15894, Revision 0 topical report does not entail an Alternate Repair

    Criteria. The WCAP topical report is used to define the length oftubing within

    the hot leg that should be inspected with a rotating plus point probe.

    Tube burst is precluded for cracks within the TS by the constraint provided by

    the TS. Thus, structural integrity is maintained by the TS constraint. However,

    a 360-degree circumferential crackor many axially oriented cracks could permit

    severing ofthe tube and tube pullout from the TS under the axial forces on the

    tube from primary to secondary pressure differentials. Section 4 ofWCAP

    15894, Revision 0 describes the testing that was performed to define the length

    ofnon-degraded tubing that is sufficient to compensate for the axial forces on

    the tube and thus prevent pullout. The operating conditions utilized in WCAP

    15894, Revision 0 were specific to SONGS and are summarized in Section 3.

    Operating experience has demonstrated negligible normal operating leakage

    from primary water stress corrosion cracking (PWSCC) in expansion transitions.

    PWSCC in explansions in the TS region would be even further leakage limited

    by the tight tube-to-tubesheet crevice and the limited crackopening permitted

    by the TS constraint. The SLB conditions provide the most stringent

    radiological hazards for postulated accidents involving loss ofpressure or fluid

    in the secondary system. WCAP-1 5894, Revision 0, Section 3.1.2 provides the

    justification to neglect the total SLB leak rate contributed by cracks below the

    TEA length. Therefore, rotating plus point probe inspection in the area below

    the TEA length is not necessary to preclude normal operating or accidentinduced leakage.

    In SONGS Operational Assessments, postulated cracking within the TEA length

    is conservatively included in the allowable leakage calculations and no credit is

    taken for the leak-limiting effect of the tubesheet.

    4.0 No Significant Hazards Consideration

    Southern California Edison (SCE) has concluded that operation ofSan OnofreUnits 2 and 3, in accordance with the proposed change to the TechnicalSpecifications, does not involve a significant hazards consideration. SCE's

    conclusion is based on its evaluation, in accordance with 10 CFR 50.91 (a)(1),

    ofthe three standards set forth in 10 CFR 50.92(c).

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    SCE is proposing to modify the San Onofre Units 2 and 3 Technical

    Specifications to revise the Technical Specification Steam Generator (SG)

    Tube Surveillance Program requirement 5.5.2.11 .f.1 .h to clearly define SG tube

    inspection scope. SCE's proposed change is to clarify the tube inspection to

    exclude the portion ofthe tube within the tubesheet below the tube engagement

    area(TEA) length. The analysis accounts for the reinforcing effect that the

    tubesheet (TS) has on the external surface of the SG tube within the TS region.

    The analysis shows that tube integrity and leakage below the TEA length

    remain within the existing design limits.

    1. Does the proposed change involve a significant increase in the

    probability or consequences ofan accident previously evaluated?

    Southern California Edison (SCE) proposes to modify the San Onofre

    Units 2 and 3 Technical Specifications to define the SG tube inspection

    scope. The San Onofre Nuclear Generating Station (SONGS)-specific

    analysis takes into account the reinforcing effect the TS has on the

    external surface of an expanded SG tube.

    Tube-bundle integrity will not be adversely affected by the

    implementation ofthe TEA tube inspection scope. SG tube burst or

    collapse cannot occur within the confines ofthe TS; therefore, the tube

    burst and collapse criteria ofdraft Regulatory Guide (RG) 1.121 are

    inherently met. Any degradation below the TEA length is shown by

    analyses and test results to be acceptable, thereby precluding an event

    with consequences similar to a postulated tube rupture event.

    Tube burst is precluded for cracks within the TS by the constraint

    provided by the TS. Thus, structural integrity is maintained by the TS

    constraint. However, a 360-degree circumferential crack or many axiallyoriented cracks could permit severing ofthe tube and tube pullout fromthe TS under the axial forces on the tube from primary to secondarypressure differentials. Testing was performed to define the length of

    non-degraded tubing that is sufficient to compensate for the axial forces

    on the tube and thus prevent pullout.

    In conclusion, incorporation ofthe TEA inspection scope into San Onofre

    Units 2 and 3 Technical Specifications maintains existing design limits

    and does not involve a significant increase in the probability or

    consequences ofan accident previously evaluated.

    2. Does the proposed change create the possibility of a new or

    different kind ofaccident from any accident previously evaluated?

    Tube-bundle integrity is expected to be maintained during all plant

    conditions upon implementation ofthe proposed tube inspection scope.

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    Use of this scope does not induce a new mechanism that would result ina different kind ofaccident from those previously analyzed. Even withthe limiting circumstances of a complete circumferential separation ofatube occurring below the TEA length, SG tube pullout is precluded andleakage is predicted to be maintained within the Final Safety Analysis

    Report limits during all plant conditions. Therefore, a possibility of a newor different kind ofaccident from any accident previously evaluated is notcreated.

    3. Does the proposed change involve a significant reduction in amargin ofsafety?

    Upon implementation of the TEA inspection scope, operation withpotential cracking below the TEA length in the explansion region of theSG tubing meets the margin of safety as defined by RG 1.121 and RG

    1.83 and the requirements ofGeneral Design Criteria 14, 15, 31, and 32.Accordingly, the proposed change does not involve a significantreduction in a margin ofsafety.

    4.0 Environmental Impact Consideration

    The proposed change does not involve a significant hazards consideration,a significant change in the types ofor significant increase in the amountsof any effluents that may be released offsite, or a significant increase inindividual or cumulative occupational radiation exposure. Therefore, theproposed change meets the eligibility criteria for categorical exclusion setforth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), anenvironmental assessment ofthe proposed change is not required.

    PCN543c

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    Attachment A

    (Existing Pages)

    SONGS Unit 2

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    Procedures, Programs, and Manuals5.5

    5.5 Procedures, Programs, and Manuals (continued)

    5.5.2.11 Steam Generator (SG) Tube Surveillance Program (continued)

    e) Imperfection - An exception to the dimensions,finish, or contour of a tube from that required by

    fabricationdrawings or specifications. Eddy

    current testing indications below 20% of thenominal tube wall thickness, if detectable, may beconsidered as imperfections;

    f) Repair Limit - The imperfection depth at or beyondwhich the tube shall be removed from service orrepaired and is equal to 44% of the nominal tubewall thickness; Sleeves shall be removed fromservice upon detection of service-induceddegradation of the sleeve material or any portionof the sleeve-to-tube weld.

    g) Preservice Inspection - An inspection of the fulllength of each tube in each SG performed by eddycurrent techniques prior to service to establish abaseline condition of the tubing. This inspectionshall be performed prior to initial MODE Ioperating using the equipment and techniquesexpected to be used during subsequent inserviceinspections. These examinations may be performedprior to steam generator installation. Similarly,for tube repair by sleeving, an inspection of thefull length of the pressure boundary portion ofthe sleeved area shall be performed by eddycurrent techniques prior to service. This

    includes pressure retaining portions of the parenttube in contact with the sleeve, the sleeve-totube weld, and the pressure retaining portion ofthe sleeve.

    h) Tube Inspection - An inspection of the SG tubefrom the point of entry (hot leg side) completelyaround the U-bend to the top support of the coldleg; and

    i) Unserviceable - The condition of a tube if itleaks or contains a defect large enough to affectits structural integrity in the event of an

    Operational Basis Earthquake, a loss-of-coolantaccident, or a steam line of feedwater line breakaccident as specified in Specification 5.5.2.11.e.

    (continued)

    Amendment No. 4-2-7, 140SAN ONOFRE--UNIT 2 5.0-18

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    Attachment B

    (Existing Pages)

    SONGS Unit 3

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    Procedures, Programs, and Manuals5.5

    5.5 Procedures, Programs, and Manuals (continued)

    5.5.2.11 Steam Generator (SG) Tube Surveillance Program (continued)

    e) Imperfection - An exception to the dimensions,finish, or contour of a tube from that required by

    fabrication drawings or specifications. Eddycurrent testing indications below 20% of thenominal tube wall thickness, if detectable, may beconsidered as imperfections;

    f) Repair Limit - The imperfection depth at or beyondwhich the tube shall be removed from service orrepaired and is equal to 44% of the nominal tubewall thickness; Sleeves shall be removed fromservice upon detection of service-induceddegradation of the sleeve material or any portionof the sleeve-to-tube weld.

    g) Preservice Inspection - An inspection of the fulllength of each tube in each SG performed by eddycurrent techniques prior to service to establish abaseline condition of the tubing. This inspectionshall be performed prior to initial MODE Ioperating using the equipment and techniquesexpected to be used during subsequent inserviceinspections. These examinations may be performedprior to steam generator installation. Similarly,for tube repair by sleeving, an inspection of thefull length of the pressure boundary portion ofthe sleeved area shall be performed by eddycurrent techniques prior to service. This

    includes pressure retaining portions of the parenttube in contact with the sleeve, the sleeve-totube weld, and the pressure retaining portion ofthe sleeve.

    h) Tube Inspection - An inspection of the SG tubefrom the point of entry (hot leg side) completelyaround the U-bend to the top support of the coldleg; and

    i) Unserviceable - The condition of a tube if itleaks or contains a defect large enough to affectits structural integrity in the event of anOperational Basis Earthquake, a loss-of-coolantaccident, or a steam line of feedwater line breakaccident as specified in Specification 5.5.2.11.e.

    (continued)

    Amendment No. ++& 132SAN ONOFRE--UNIT 3 5.0-18

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    Attachment C

    (Proposed Pages)

    (Redline and Strikeout)

    SONGS Unit 2

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    Procedures, Programs, and Manuals

    5.55.5 Procedures, Programs, and Manuals (continued)

    5.5.2.11 Steam Generator (SG) Tube Surveillance Program (continued)

    e) Imperfection - An exception to the dimensions,finish, or contour of a tube from that required byfabrication drawings or specifications. Eddycurrent testing indications below 20% of thenominal tube wall thickness, if detectable, may beconsidered as imperfections;

    f) Repair Limit - The imperfection depth at or beyondwhich the tube shall be removed from service orrepaired and is equal to 44% of the nominal tubewall thickness; Sleeves shall be removed fromservice upon detection of service-induceddegradation of the sleeve material or any portionof the sleeve-to-tube weld.

    g) Preservice Inspection - An inspection of the full

    length of each tube in each SG performed by eddycurrent techniques prior to service to establish abaseline condition of the tubing. This inspectionshall be performed prior to initial MODE 1operating using the equipment and techniquesexpected to be used during subsequent inserviceinspections. These examinations may be performedprior to steam generator installation. Similarly,for tube repair by sleeving, an inspection of thefull length of the pressure boundary portion ofthe sleeved area shall be performed by eddycurrent techniques prior to service. Thisincludes pressure retaining portions of the parent

    tube in contact with the sleeve, the sleeve-totube weld, and the pressure retaining portion ofthe sleeve.

    h) Tube Inspection - An inspection of the SG tubefrom the point of entry (hot leg side) completelyaround the U-bend to the top support of the coldleq excludinq the Dortion of the tube within thetubesheet (TS) below 5 inches from the secondaryface of the TSi n

    i) Unserviceable - The condition of a tube if itleaks or contains a defect large enough to affectits structural integrity in the event of anOperational Basis Earthquake, a loss-of-coolantaccident, or a steam line of feedwater line breakaccident as specified in Specification 5.5.2.11.e.

    (continued)

    Amendment No. 127, 140SAN ONOFRE--UNIT 2 5.0-18

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    Attachment D

    (Proposed Pages)

    (Redline and Strikeout)

    SONGS Unit 3

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    Procedures, Programs, and Manuals5.5

    5.5 Procedures, Programs, and Manuals (continued)

    5.5.2.11 Steam Generator (SG) Tube Surveillance Program (continued)

    e) Imperfection - An exception to the dimensions,finish, or contour of a tube from that required by

    fabrication drawings or specifications. Eddycurrent testing indications below 20% of thenominal tube wall thickness, if detectable, may beconsidered as imperfections;

    f) Repair Limit - The imperfection depth at or beyondwhich the tube shall be removed from service orrepaired and is equal to 44% of the nominal tubewall thickness; Sleeves shall be removed fromservice upon detection of service-induceddegradation of the sleeve material or any portionof the sleeve-to-tube weld.

    g) Preservice Inspection - An inspection of the fulllength of each tube in each SG performed by eddycurrent techniques prior to service to establish abaseline condition of the tubing. This inspectionshall be performed prior to initial MODE 1operating using the equipment and techniquesexpected to be used during subsequent inserviceinspections. These examinations may be performedprior to steam generator installation. Similarly,for tube repair by sleeving, an inspection of thefull length of the pressure boundary portion ofthe sleeved area shall be performed by eddycurrent techniques prior to service. This

    includes pressure retaining portions of the parenttube in contact with the sleeve, the sleeve-totube weld, and the pressure retaining portion ofthe sleeve.

    h) Tube Inspection - An inspection of the SG tubefrom the point of entry (hot leg side) completelyaround the U-bend to the top support of the coldleq excluding the portion of the tube within thetubesheet (TS) below 5 inches from the secondaryface of the TS.;-aned

    i) Unserviceable - The condition of a tube if it

    leaks or contains a defect large enough to affectits structural integrity in the event of anOperational Basis Earthquake, a loss-of-coolantaccident, or a steam line of feedwater line breakaccident as specified in Specification 5.5.2.11.e.

    (continued)

    Amendment No. 11-6 -132SAN ONOFRE--UNIT 3 5.0-18

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    Attachment E

    (Proposed Pages)

    SONGS Unit 2

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    Procedures, Programs, and Manuals5.5

    5.5 Procedures, Programs, and Manuals (continued)

    5.5.2.11 Steam Generator (SG) Tube Surveillance Program (continued)

    e) Imperfection - An exception to the dimensions,finish, or contour of a tube from that required byfabrication drawings or specifications. Eddycurrent testing indications below 20% of thenominal tube wall thickness, if detectable, may beconsidered as imperfections;

    f) Repair Limit - The imperfection depth at or beyondwhich the tube shall be removed from service orrepaired and is equal to 44% of the nominal tubewall thickness; Sleeves shall be removed fromservice upon detection of service-induceddegradation of the sleeve material or any portionof the sleeve-to-tube weld.

    g) Preservice Inspection - An inspection of the full

    length of each tube in each SG performed by eddycurrent techniques prior to service to establish abaseline condition of the tubing. This inspectionshall be performed prior to initial MODE 1operating using the equipment and techniquesexpected to be used during subsequent inserviceinspections. These examinations may be performedprior to steam generator installation. Similarly,for tube repair by sleeving, an inspection of thefull length of the pressure boundary portion ofthe sleeved area shall be performed by eddycurrent techniques prior to service. Thisincludes pressure retaining portions of the parent

    tube in contact with the sleeve, the sleeve-totube weld, and the pressure retaining portion ofthe sleeve.

    h) Tube Inspection - An inspection of the SG tubefrom the point of entry (hot leg side) completelyaround the U-bend to the top support of the coldleg excluding the portion of the tube within thetubesheet (TS) below 5 inches from the secondaryface of the TS.

    i) Unserviceable - The condition of a tube if itleaks or contains a defect large enough to affectits structural integrity in the event of anOperational Basis Earthquake, a loss-of-coolantaccident, or a steam line of feedwater line breakaccident as specified in Specification 5.5.2.11.e.

    (continued)

    SAN ONOFRE--UNIT 2 Amendment No.5.0-18

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    Attachment F

    (Proposed Pages)

    SONGS Unit 3

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    Procedures, Programs, and Manuals5.5

    5.5 Procedures, Programs, and Manuals (continued)

    5.5.2.11 Steam Generator (SG) Tube Surveillance Program (continued)

    e) Imperfection - An exception to the dimensions,finish, or contour of a tube from that required by

    fabrication drawings or specifications. Eddycurrent testing indications below 20% of thenominal tube wall thickness, if detectable, may beconsidered as imperfections;

    f) Repair Limit - The imperfection depth at or beyondwhich the tube shall be removed from service orrepaired and is equal to 44% of the nominal tubewall thickness; Sleeves shall be removed fromservice upon detection of service-induceddegradation of the sleeve material or any portionof the sleeve-to-tube weld.

    g) Preservice Inspection - An inspection of the fulllength of each tube in each SG performed by eddycurrent techniques prior to service to establish abaseline condition of the tubing. This inspectionshall be performed prior to initial MODE 1operating using the equipment and techniquesexpected to be used during subsequent inserviceinspections. These examinations may be performedprior to steam generator installation. Similarly,for tube repair by sleeving, an inspection of thefull length of the pressure boundary portion ofthe sleeved area shall be performed by eddycurrent techniques prior to service. This

    includes pressure retaining portions of the parenttube in contact with the sleeve, the sleeve-totube weld, and the pressure retaining portion ofthe sleeve.

    h) Tube Inspection - An inspection of the SG tubefrom the point of entry (hot leg side) completelyaround the U-bend to the top support of the coldleg excluding the portion of the tube within thetubesheet (TS) below 5 inches from the secondaryface of the TS.

    i) Unserviceable - The condition of a tube if itleaks or contains a defect large enough to affectits structural integrity in the event of anOperational Basis Earthquake, a loss-of-coolantaccident, or a steam line of feedwater line breakaccident as specified in Specification 5.5.2.11.e.

    (continued)

    SAN ONOFRE--UNIT 3 5.0-18 Amendment No.

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    ENCLOSURE 3

    Westinghouse Topical Report WCAP-1 5894-NP,

    Revision 0: "NDE Inspection Strategy For the

    Tubesheet Region In SONGS Units 2 and 3"

    (Non-Proprietary)

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    Westinghouse Non-Proprietary Class 3

    NDE Inspection StrategyFor the Tubesheet RegionIn SONGS Units 2 and 3

    Copyright 2002

    Westinghouse Electric Company LLC

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    NDE Inspection StrategyFor the Tubesheet Region

    In SONGS Units 2 and 3

    May 2002

    P.R. Nelson

    This document contains information proprietary to Westinghouse Electric Company LLC and Nuclear

    Services Business Unit; it is submitted in confidence and is to be used solely for the purpose for which it

    is furnished, then returned upon request. This document and such information is not to be reproduced,

    transmitted, disclosed or used otherwise in whole or in part without prior written authorization of

    Westinghouse Electric Company LLC and the Nuclear Services Business Unit.

    Westinghouse Electric Company LLC

    P.O. Box 355

    Pittsburgh, PA 15230-0355

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    EXECUTIVE SUMMARY

    Based on evaluation oftesting results, analysis, and supporting references, a conservative NDEinspection extent below the secondary face ofthe tubesheet (TTS) has been determined to be five

    inches for the San Onofre Nuclear Generating Station (SONGS) Units 2 and 3.

    An engineeringjustification for limiting the required inspection area to the upper region ofthe

    tubesheet on the hot leg side has been developed. This engineeringjustification was developed

    for two reasons:

    ", Flaws below five inches in this region are unlikely to be a safety concern (which was

    confirmed by the work performed for this report) and,

    "* Existing NDE methods necessitate optimized inspection within the area ofmost need and

    relevance.

    This report provides the SONGS specific information from a project conducted for the

    Combustion Engineering (CE) Owners Group (Reference 1).

    The inspection extent value offive inches has been derived based on a conservative assumption

    that a maximum number oftubes equal to [](c) Primary Water Stress Corrosion Cracking (PWSCC)

    susceptibility increases markedly with increasing temperature and may be assumed to only be

    prevalent in steam generator tubing on the hot leg side ofthe tube bundle. A review ofPWSCC

    history in CE designed units demonstrates that the assumption that less than [

    ](c) is a reasonable basis for specifyingthe inspection extent value. The inspection extent must be inspected by an adequate NDE

    inspection method to ensure that less than [

    ](c) within five inches ofthe TTS. The inspection extent assumes that all indications

    oftube degradation within the inspection extent will be repaired or plugged on detection.

    CE explanded and WEXTEX joints compare favorably. The W* ARC (for WEXTEX) values

    used as a figure ofmerit for benchmarking the results ofthis effort are inspection lengths of[ ](b). The [ ](b) value are differentiated by

    tubesheet flexure, which has been considered for the SONGS units.

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    TABLE OF CONTENTS

    1.0 INTRODUCTION ............................................................................................. 8

    1.1 Purpose .................................................................................................. . . 8

    1.2 CE Design "Explansion" Joint ............................................................... 91.3 WEXTEX Joint and W* .......................................................................... 9

    1.4 SONGS Plant Design ............................................................................. 10

    1.5 Testing Acceptance Criteria .................................................................. 10

    1.6 Overview ofApproach ........................................................................ 11

    1.7 Conservatisms in Results ...................................................................... 13

    1.8 Quality Assurance ................................................................................. 14

    1.9 Other Considerations ............................................................................. 14

    2.0 DEFIN ITIONS ................................................................................................. 18

    3.0 TECHNICAL APPROACH SUMMARY .................................................... 20

    3.1 Test Methods and Acceptance Criteria ................................................. 20

    3.1.1 Pullout Load Tests Methods and Criteria ................................. 20

    3.1.2 LeakRate Tests Methods and Criteria ...................................... 22

    3.1.3 In Situ Pressure Testing for Supplementary Pullout

    and Leak Rate ........................................................................... 26

    3.1.4 Tubesheet Deflection Analysis Method .................................... 26

    3.2 Elevated Temperature Tests .................................................................. 27

    3.2.1 Pullout Tests - Single Tube Mockups ..................................... 27

    3.2.2 LeakRate Tests - Single Tube Mockups ................................. 27

    3.3 Test Specimens ..................................................................................... 28

    3.3.1 Boston Edison Steam Generator ............................................... 283.3.2 Single Tube Mockups .............................................................. 29

    3.3.2.1 Tubesheet and Tubing Specifications ........................ 29

    3.3.2.2 Drilled Tubesheet Hole ............................................... 29

    3.3.2.3 Test Matrix Overview ............................................... 29

    4.0 PULL-OUT LOAD TESTS AND RESULTS ............................................... 44

    4.1 Boston Edison Steam Generator .......................................................... 44

    4.2 Single Tube Mockups .......................................................................... 45

    5.0 LEAK RATE TESTS AND RESULTS ........................................................ 51

    5.1 Surface Leak Rate Results ................................................................... 505.1.1 Boston Edison Steam Generator LeakRate Results ................. 51

    5.1.2 Single Tube Mockups LeakRate Results ................................. 52

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    TABLE OF CONTENTS (Cont'd.)

    6.0 TUBESHEET DEFLECTION ANALYSIS ................................................... 56

    7.0 OTHER FACTORS ........................................................................................ 58

    7.1 MDM Cutting Effects .......................................................................... 587.2 Explansion Taper ................................................................................. 58

    7.3 NDE Axial Position Uncertainty ........................................................... 58

    8.0 RESULTS EVALUATION ............................................................................ 59

    8.1 Tube Engagement Area Length Based on Burst Criteria ...................... 59

    8.2 Tube Engagement Area Length Based on Leakage Criteria ................. 59

    8.3 Tubesheet Dilation Correction Factor.................................................. 60

    8.4 Threshold Length for NDE Inspection ................................................. 60

    9.0 REFERENCES ............................................................................................... 61

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    LIST OF FIGURES

    Figure 1.1Figure 1.2

    Figure 1.3

    Figure 3.1

    Figure 3.2

    Figure 3.3

    Figure 3.4

    Figure 3.5

    Figure 3.6

    Figure 3.7

    Figure 3.8

    Figure 3.9

    Figure 3.10

    Figure 3.11

    Figure 3.12

    Figure 3.13

    Figure 4.1

    Figure 4.2

    Figure 4.3

    Figure 4.4

    Figure 4.5

    Figure 5.1

    Figure 5.2

    Figure 5.3

    Explansion Process Schematic ............................................................. 15

    Charge Assembly Shop Drawing ........................................................... 15

    Depiction OfExplansion During SG Manufacturing ........................... 16

    Load Cell Test Rig Schematic .............................................................. 33

    Windsor Load Cell Test Rig ................................................................. 34

    Windsor Load Cell Controls and Data Plotter ...................................... 35

    LeakRate Test Rig Schematic ............................................................. 36

    LeakR ate Test ...................................................................................... 37

    W indsor ISPT Test Rig ........................................................................ 38

    Elevated Temperature Test Single Tube Prior to Inserting into

    the BEMCO Test Chamber .................................................................... 39

    BEMCO Temperature Test Chamber ................................................... 39

    Boston Edison Scrapped Steam Generator .......................................... 40

    Boston Edison Steam Generator, Flow Distribution Plate Cut Out ..... 40

    Load Cell Test Rig Tube Pull Fixture ................................................... 41

    Single Tube Mockups .......................................................................... 42

    Single Tube Mockup Explansion Setup ............................................... 43

    Boston Edison SG Pull Data ................................................................. 49

    Single Tube Mockup 4, 2.5" Crevice, Ambient Pull ............................ 49

    Single Tube Mockup 6, 2.5" Crevice, Ambient Pull ............................ 50

    Single Tube Mockup 8, 3" Crevice, High Pressure Pull ....................... 49

    Rough Surface Finish Pullout Force vs. Joint Length ........................... 51

    Boston Edison Steam Generator Leak Data ........................................... 54

    Boston Edison SG and Single Tube Mockup Leak Data ...................... 55

    Rough Single tube mockups Leak Tests at RT and NOT ..................... 55

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    LIST OF TABLES

    Table 3-1 Tube Measurements Before And After Testing .................................... 30

    Table 3-2 Boston Edison SG Test Matrix ............................................................. 31Table 3-3 Single Tube Test Matrix ........................................................................ 32

    Table 4-1 Boston Edison SG Pull Test Data ........................................................ 47

    Table 4-2 Single Tube Mockup: Pull Test Data .................................................... 47

    Table 5-1 Single Tube Mockup: LeakTest Data @ Room Temperature ............. 53

    Table 5-2 Single Tube Mockup: LeakTest Data @ NOT ................................... 53

    Table 6-1 Single Tube Mockup Pull Test Data .................................................... 57

    APPENDICES

    A) Test Plan MatrixB) Boston Edison Steam Generator Test Data

    C) Single Tube - Tubesheet Mockup Tests Data

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    Section 1

    Introduction

    1.0 INTRODUCTION

    A testing program was conducted to provide a recommended NDE inspection extent for

    detecting potential cracking in the tubesheet region in the San Onofre Nuclear Generating Station(SONGS) Units 2 and 3 steam generators (SGs). The evaluation provided in this report utilizes

    the SONGS applicable information from a CE owners Group project recorded in Reference 1.

    SONGS Units 2 and 3 have the Combustion Engineering designed explosively expanded

    (referred to as explanded) tube-to-tubesheetjoints. A conclusion ofthis work is that CE

    designed explanded and Westinghouse designed WEXTEXjoints are quite similar. The

    Westinghouse explosive tube expansion (WEXTEX) alternate repair criteria (ARC) values are

    used as a figure ofmerit for benchmarking the results ofthis effort. Based on an evaluation of

    testing and analysis results, a conservative distance for nondestructive examination (NDE)

    inspection ofthe tubes in the SONGS SGs below the secondary face ofthe tubesheet, also

    referred to as the top ofthe tubesheet (TTS), has been determined to be five inches.

    Testing was performed using tubesheet mockups and the SG from a cancelled plant steam

    generator to determine the leakand burst limiting tube to tubesheetjoint length needed to assure

    operation within generic licensing and industry developed limits.

    1.1 Purpose

    An engineeringjustification for limiting the required inspection area to the upper region ofthe

    tubesheet has been developed. This engineeringjustification was developed for two reasons:

    "* Flaws deep in this region are not a burst or significant leakage concern.

    "* Existing NDE methods necessitate optimized inspection within the area ofmost need andrelevance.

    "* Based on testing ofrepresentative samples a defined inspection extent distance below the

    TTS is established. The threshold distance offive inches is based on the number oftubes

    in the steam generator.

    Babcock& Wilcox (B&W) designed plants have discovered tube cracks within the tubesheet

    region leading the NRC to issue Information Notice (IN 98-27) alerting the PWR industry to the

    events. The B&W tube-to-tubesheet joint design is a rolledjoint that has limited applicability to

    the CE design but highlighted the need to review inspection practices in this region.

    Some Westinghouse design plants have implemented alternate repair criteria, W*, to addresstube cracks in the tubesheet region. W* provides for leaving axial cracks in-service ifthey meet

    W* criteria. The inspection extent defined in this report is not intended tojustify leaving stress

    corrosion cracks in the inspection extent in-service.

    References 2 and 1 provide industry consensus requirements for inspection. Rotating probes

    such as the +Point probe have traditionally been used in the range oftwo inches above and below

    the TTS to inspect the explansion transition region. Several MRPC probes are qualified for

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    detection ofcracks in the tubesheet region but would add significant cost and time to outage

    schedules to inspect the remaining twenty plus inches oftubesheet region. In general, industry

    practice is to assume undetected flaws are present only ifthe particular flaw mechanism is

    detected. The case presented in this report is that the presence ofundetected flaws in the

    tubesheet region below the threshold distance criteria are inconsequential from a tube burst andleakage standpoint. Reasonable assurance ofdetection offlaws in the region above a threshold

    distance will be provided using a qualified detection technique (e.g. +Point).

    1.2 CE Design "Explansion" Joint

    Beginning in 1961, Combustion Engineering pioneered the use ofexplosive expansion for steam

    generator tubesheetjoints, termed "explansion". The desired design features were to provide a

    cost-efficient method for closing the tube to tubesheet gap over the full length with sufficient

    pullout strength, leak tightness and without excessive residual stress in the tube.

    Figure 1.1 is a conceptual schematic ofthe explansion process. Figure1.2 is a shop drawing of

    the charge assembly used in the explansion process and Figure 1.3 depicts a typical explosive

    expansion setup in the manufacturing plant. The installation processes for expansionjoints were

    reviewed in detail to support this effort. Combustion Engineering explansion process

    development/review reports and qualification reports (3, 4, 5, 6) demonstrate that process

    controls support the position that CE explansionjoints are ofconsistent high quality and radial

    force in all installedjoints is within a reasonable variance. This was verified by the results from

    the Boston Edison (BE) SG tube pull tests. Incomplete explansions have been detected in

    operating units, but are a fraction ofa percent ofall tubejoints in-service and are detected and

    application ofthe criterion would not be applied to those tubes.

    A gun drill process was used for drilling the SONGS units tubesheet holes. Reaming ofthe

    tubesheet hole, as had been the industry practice for rolledjoints, was considered unnecessary

    and undesirable for the explansion process. The surface finish ofthe tubesheet hole was required

    to not exceed 250 micro-inches (AA) ofroughness.

    W* was developed based on two radial zones to credit less tubesheet flexure for the radial zone

    nearest the steam generator shell. Only one radial zone was considered for tle CE designed SG

    tube threshold distance. This is because the tubesheets in the SONGS units experience less

    flexure near the stay cylinder and the shell due to the support provided by these parts ofthe

    steam generator.

    1.3 WEXTEX Jointand W*

    The WEXTEXjoint is a full depth explosively expandedjoint used in some operating

    Westinghouse design plants. The process for installing the WEXTEXjoint is similar to that used

    for the CE designedjoints. After the tube is placed in the tubesheet, the tube end is rolled and

    welded in-place. The tube is then expanded into the tubesheet hole by an explosive cord over the

    full length ofthe tubesheet.

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    Section 1Introduction

    Although the CE and WEXTEX processes are similar, there are some differences in the resulting

    joint. All CEjoints were installed in a controlled manufacturing shop. Some Westinghouse units

    had WEXTEXjoints installed in the field where processes can be harder to control than in a

    manufacturing shop. WEXTEX units were constructed utilizing low temperature mill annealed

    A600 tubing rather than the high temperature mill annealed tubing used in CE designed units.The WEXTEX units have experienced more PWSCC indications than the CE designed SGs.

    Also, it has been shown that the WEXTEX expansion may leave a small tapered region at the top

    ofthe tubesheet (refer to Figure 1.4), while there has been no evidence ofany such effect in the

    CE explansionjoints.

    The NRC has reviewed and approved the use ofthe W* ARC for leaving cracked tubes in

    service that meet the W* criteria. The W* criteria implemented by some units utilizes two

    threshold distances dependent on tube radial position. These values were a useful reference for

    comparison to the values derived in this work.

    1.4 SONGS Design Considerations

    Westinghouse designed tubesheets react to a postulated main steam line break(MSLB) event in a

    similar way to the CE designed tubesheets despite a significant design difference in the thickness

    oftubesheets. Early in the design ofCE plants, it was decided to add a stay cylinder central to

    the tubesheet to stiffen the tubesheet and allow the use ofa less thickplate. Westinghouse

    designed SGs do not use stay cylinders to add out ofplane stiffness to the tubesheet. A

    difference in the tubesheet response to MSLB event between CE and Westinghouse designed

    units is that the maximum flexure occurs at different radial positions (i.e., circular zones).

    A flexure and concomitant tubesheet hole dilation effect onjoint contact was determined for the

    SONGS units and is reported in Section 6 ofthis document.

    Both SONGS units have Alloy 600 high temperature mill annealed (HTMA) tubes with the same

    material property specifications and a wall thickness of48 mils.

    1.5 Testing Acceptance Criteria

    Testing in the course ofthe determination ofa sufficient tube engagement length in the tube to

    tubesheetjoint satisfied two primary concerns: pullout force and leak rate. The acceptance

    criteria applicable to the CE design used as a basis for these test parameters are the structural

    integrity burst pressure for pullout load and the MSLB accident induced leak rate.

    A 100% throughwall 3600 extent circumferential PWSCC flaw condition was conservatively

    mocked up for testing by cutting tested tubes in the tubesheet specimens. These manufactured

    flaws are recognized to be substantially less leak tight than either axial or circumferentially

    oriented flaws at the same locations. Operating experience ofplants with identified PWSCC

    flaws has shown that leakage is not a concern (21).

    Pullout force as a function ofjoint length is determined to demonstrate that a tube severed some

    distance into the tubesheet (i.e. ofa specificjoint length) will not pullout ofthe tubesheet and

    therefore will not present a burst tube condition. Pullout force is used synonymously with

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    Section 1

    Introduction

    blowout force as referred to in the historical records. Structural integrity per historical approach

    and discussion between industry and NRC leaders is defined as the ability ofa tube to withstand

    pressure ofthree times the normal operating primary to secondary differential pressure

    (3NODP). A 3NODP value of4410 psid was used in this work. The pullout load value of2000

    lbfused in testing was derived from the 3NODP value of4410 psid acting on the area oftheinside diameter ofthe tubesheet hole [

    ](b). The threshold value for pullout is less than the

    threshold length for leaks so the threshold length for leaks determines the threshold length for

    inspection Details ofthe pullout load testing and criteria are provided in Section 3.1.1.

    Leakrate as a function ofjoint length was determined in order to demonstrate that an assumed

    number of100% throughwall tube flaws would not exceed the leakrate criterion The leak rate

    criterion was derived from an MSLB accident induced leakrate limit of0.5 gpm per steam

    generator, which is bounding based on the traditional limiting condition for operation (LCO)

    limit for event initiation. The Standard Review Plan (22) specifies that the LCO leakage limit

    would result in one-fifth ofthe 1OCFR100 dose limit.

    [ ](c).

    No tubes have been pulled to confirm PWSCC but the explansion is a full depthjoint that makes

    ODSCC unlikely. [

    ](c).

    To provide allowance for leakage from other defect types, particularly in operational assessment

    calculations, the contribution ofleakage from tubesheet region flaws was conservatively limited

    to [ ](c). Operational assessment calculations include

    assumptions for undetected flaw populations and determine acceptable plant run-time based in

    part on acceptable EOC leakage. Thejoint length leak rate (determined by testing) multiplied by

    the number oftubes assumed to be defective that results in a leak rate less than or equal to the

    leakrate criteria of[ ](c) is the threshold length for leaks. Details ofthe leakrate test

    methods and criteria are provided in Section 3.1.2.

    1.6 Overview ofApproach

    A parametric approach was used for testing the pressure, temperature, and explansion contact

    force effects to consider the key contributions tojoint integrity. Two types oftests were

    conducted: pullout load and leak rate. Both test types were conducted on two test beds applicable

    to the SONGS units:

    "* The Boston Edison canceled plant as-built steam generator

    "* Single tube to tubesheetjoint mockups (collars)

    The test beds are described in the Section 3.3 ofthis report.

    This workhad several major steps:

    1. Develop a preliminary test plan for pullout and leak rate testing.

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    Section 1Introduction

    2. Develop acceptance criteria for pullout and leak rate.

    3. Pull and Leaktest Boston Edison SG tubejoints as a benchmark to as-built plants.

    4. Pull and Leak test single tube to tubesheetjoint mockups (collars) at various pressures

    and temperatures.

    5. Verify that mockup collars are representativeofBE SG (i.e., as operating SGs).

    6. Determine the effect oftubesheet hole dilation under MSLB conditions.

    7. Calculate inspection lengths (threshold length for inspection) from the test results.

    Other considerations that factored into the uncertainties in the development ofthreshold length

    were:

    "* Joint contact force at the explansion transition

    "* Joint contact force changes during a MSLB

    "* NDE axial position uncertainty

    NDE probe axial position uncertainty is not explicitly considered in this report. The uncertaintyisjudged to be a minor effect and may be handled in the same way that utilities consider position

    uncertainty in the current tubesheet region inspection scope. Uncertainty in axial flaw position as

    measured by NDE probe is considered to be covered within the conservatisms applied in the

    results reported in this report.

    A reduction injoint contact force at the expansion transition is addressed in the W* topical report(1_0). [

    ].(b)

    Visual inspection ofseveral sectioned specimens indicates that a taper is not present in the CE

    explansionjoint. A taper ofseveral tenths ofan inch wouldbe visually observable but no taper

    was observed in single tube mockup specimens examined by microscope. This supports the

    information provided in Reference 4 indicating that CE explansionjoints do not have a taper

    effect.

    The metal disintegration machining (MDM) process ofcutting the artificial flaws usedin the pull

    and leaktesting provides conservatism in that the tube material pulled away from the tubesheet

    wall such that all measuredjoint lengths are considered conservative by several tenths ofan inch.

    Under MSLB conditions, the differential pressure across the tubesheet causes tubesheet flexure

    and dilation ofthe tubesheet hole. Dilation ofthe hole reduces the contact force in the region of

    dilation. The other side ofthe tubesheet actually compresses, but it is not in the range ofinterest.

    Reduced contact in thejoint may increase existing leakage and reduces the resistance to pullout.

    I](b) A compensating effect occurs as primary to secondary

    pressure increases. Increasing differential pressure induces axial and hoop stresses on the tube

    ID. The hoop stress due to internal pressure is nominally twice the axial stress in magnitude

    resulting in a diametric expansion ofthe tube approximately one mil at MSLB differential

    pressure. This tends to mitigate the effect ofthe tubesheet hole opening at and near the tubesheet

    surface.

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    Tubesheet hole surface roughness was addressed in the fabrication oftubesheet mockups and

    visual inspection ofthe roughness in the Boston Edison steam generator and several single tube

    mockups. Tubesheet mockup holes were fabricated by drilling to represent the CE design

    applicable to SONGS. The drilledholes are referred to as rough bore holes in some parts ofthis

    report representing the gun drill process. Smoothness beyond the roughness specification criteria

    of250 micro-inches was identified in early process development reports (3, 4, f) as not desirable

    for explandedjoints. There is expected to be variability in tubesheet hole roughness in

    operating steam generators. The variability is best characterized by the Boston Edison steam

    generator results and appears to be a small factor. NDE measurements for each test were

    recorded for comparison.

    Leakrate testing was conducted using a very small capacity positive displacement pump, high

    accuracy pressure gauge, recording equipment, and associated tubing. Pump strokes were

    counted measuring nominally 0.6 milliliters per pump stroke, over a defined test period of

    approximately forty minutes, providing a minimum detectable leak rate ofapproximately 5x10-6

    gpm per tube. Ifno strokes were recorded, one stroke was assumed. In most cases, the test logs

    indicate that seepage was observable at the tube - tubesheet interface even though no pump

    stroke occurred. Leakage from the manufactured flaws in tests would not experience as large a

    pressure drop across the flaw as would be expected in any SCC flaw in the tubesheet region. The

    test leakrate reported accounts only for thejoint length pressure drop and not the pressure drop

    across the flaw. This can be a significant conservatism depending on the flaw size and location.

    Details ofthe results are provided in Section 4.0 ofthis report. Evaluation ofthe results is

    provided in Section 8.

    1.7 Conservatisms in Results

    A number ofconservatisms have been employed which ensure that the results reported are

    reasonable for safe operation. The conservatisms are also addressed in more detail in the other

    sections ofthis report but are listed here to highlight the combined effect on results.

    Conservatisms used in this work are:

    "* A 360', 100% throughwall circumferential cut represents a limiting flaw form for pullout

    and leaktesting.

    " Use ofan MDM tool to cut the flaw results in a large width flaw providing little or no

    flow resistance compared to SCC.

    "* Tube draw-back due to MDM cutting heat up and contraction ofthe tube is not credited

    in the measuredjoint length. There was no evidence that MDM cutting resulted in

    solidification at the tube-tubesheet interface.

    "* Only partial credit is taken for the increase in tube-to-tubesheet contact force due

    differential thermal expansion between the tube and tubesheet.

    "* Only partial credit is taken for the increase in tube-to-tubesheet contact force due to from

    the internal pressure in the tube during NOP.

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    "* Tubes used in single tube mockup tests have material properties at the upper end ofthe

    yield specification at 54 ksi per CMTR (18). The higher yield strength tubing would

    result in a lower tube-tubesheet contact from the explansion process. This can have a

    significant effect on pullout force and leakrate (8).

    "* No credit is taken for corrosion ofthe tubesheet in the tubesheetjoint."* Choked flow effects under MSLB conditions are not considered.9 1

    ](C)

    1.8 Quality Assurance

    This workwas completed under the requirements ofthe Westinghouse Quality Assurance

    Program M(_. QA documentation for the Boston Edison steam generator was not retrieved from

    Westinghouse information archives, but is reasonably assumed to meet all requirements

    regarding tube material specifications and the tubejoint installation process.

    1.9 Other Considerations

    Corrosion ofthe carbon steel tubesheet probably occurs even with the minute amount ofair and

    moisture trapped in the tubesheetjoint after explansion. Corrosion would tend to increase the

    friction between the tube and tubesheet impeding both pullout and leakage. Operating steam

    generators would have more corrosion in thejoint than the mockups fabricated for this work. No

    explicit credit is taken for corrosion in the tubesheetjoint. However, corrosion ofthejoint may

    explain some ofthe variability in results in the single tube mockup leak rate tests. In particular,

    leak rates tended to decrease as more tests were done on a given mockup indicating an increasing

    flow resistance over time after the initial test. Red rust (iron oxide) was observed at the top ofthesingle tube mockup in some tests that were run later in the testing program.

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    WCAP 15894-NP Page 15 of 67Section 1

    Introduction

    Figure 1.1

    Explansion Process Schematic

    Figure 1.2Charge Assembly Shop Drawing

    &PLud~Ifi MAW ASSEflLY

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    4,-N Page 16 of67

    Section 1

    Introduction

    Figure 1.3Depiction ofExplansion During SG Manufacturing

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    Section 1Introduction

    Figure 1.4

    WEXTEX Joint Expansion Taper Concept

    STaper

    WEXTEX

    S: Transition

    i " "F"- .

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    Section 2Definitions

    2.0 DEFINITIONS

    ARC - Alternate repair criteria are approvals by NRC to utilize specific criteria for repairdecisions based on detection offlaws.

    Single tube mockup - Tubesheet mockups were fabricated from tubesheet bar stockmaterial

    SA-508, Class 3. The machined bar stockin which a tube was explosively expanded was referred

    to in this project as a collar.

    EOC - End ofthe operating cycle

    Joint - The tube and tubesheet contact surface area created by the explansion process.

    Leakage criteria [

    ](c)

    LCO - Technical specifications limiting condition for operation.

    MSLB - The design basis event known as main steam line break.

    NODP - Normal operating differential pressure. RCS pressure minus SG pressure at normal fullpower operating conditions.

    3NODP = 4410 psid. Three times the NODP is the governing performance criterion for tube

    integrity for the SONGS SGs for this evaluation.

    Pullout force - The force required to overcome thejoint static and sliding friction such that tube

    movement within the tubesheet may occur.

    Pullout force criterion - The load value of2000 lbfderived from a 3NODP value of4410 psid

    acting on the area ofthe inside diameter ofthe tubesheet hole [](a)

    POD - Probability ofdetection based on the ability ofan NDE technique to indicate the presence

    ofa flaw.

    Rough Bore - The machined surface on the inside diameter ofeach rough bore single tube

    mockup was drilled on a lathe to a surface roughness not greater than 250 micro- inches (AA) to

    mockup the gun-drilled tubesheet hole surface.

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    Section 2Definitions

    Taper- The theoretically incomplete contact near the top ofthejointjust below the explansion

    transition. [

    ](b)

    Tube Engagement length- The tube to tubesheetjoint length below the TTS that provides a

    sufficient contact force to preclude pull out at 3NODP and leakage at MSLB pressures.

    TTS - Top ofthe tubesheet

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    Section 3

    Technical Approach Summary

    3.0 TECHNICAL APPROACH SUMMARY

    This is a summary ofthe approach used for collecting and evaluatingthe data orom which the

    recommendations are derived. Detailed test apparatus, test procedures, technique description,

    and data tables are provided in the references.

    As part ofthe test design, it was decided that a parametric approach would be used to identify the

    contributions ofthe three components ofjoint force due to explansion, temperature and pressure.

    All materials were procured and methods/procedures were executed under Combustion

    Engineering Nuclear Power (CENP) quality requirements.

    All Alloy 600 tubing used for the mockups was selected to be in the upper range ofthe 35 to 55

    ksi yield strength to bound tubing installedin operating steam generators. All tubes were from

    the same heat ofmaterial and had yield strength of54 ksi. Use oftubing at the upper end ofthe

    yield strength ranges provides conservatism injoint contact force (.8). As the Boston Edison

    tubing information was not available for review it was assumed to be nominally in the mid-range

    and attendant larger variability in properties, i.e., throughout the range ofthe CE procurement

    specification.

    3.1 Test Methods and Acceptance Criteria

    Acceptablejoint length was determined by testing for two categories ofconcern: pullout load

    and leakrate. Pullout load and leak rate testing data were compared to industry accepted criteria

    Q(1).

    The tube - tubesheetjoint length needed to ensure that both pullout (burst) and leakage criteria

    are met are provided in this report. The length needed to ensure both criteria are met is

    dominated in all cases by the threshold length defined by the leakage criterion.

    3.1.1 Pullout Load Tests Methods and Criteria

    Pullout testing was conducted in laboratory facilities in Chattanooga, Tennessee and in Windsor,

    Connecticut using calibrated load cells (16, 17). Pullout testing is reported in Section 4 as the

    force required to move the tube in the tubesheet hole against the sliding friction. Data is reported

    in units ofpounds- force (lbf.).

    Figure 3.1 is a schematic representation ofthe load cell used for the pull tests. Figure 3.2 is a

    photograph ofthe load cell apparatus used in the tests conducted in Windsor. Figure 3.3

    illustrates the data logging and process control equipment used in the Windsor tests. Chattanooga

    load cell equipment was essentially the same.

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    Section 3

    Technical Approach Summary

    The pull test results were directed toward establishing the threshold length below which a

    completely severed tube would not be ejected from the tubesheet. Mockups with varying

    engaged lengths oftubing were tested in accordance with Procedure 00-TP-FSW-001, Rev. 01.

    The engaged lengths for rough hole mockups were 2, 2.5, 3, 3.5 and 4 inches.

    The equipment for the pull tests in the Chattanooga and Windsor laboratories were similar and

    both were calibrated to accepted standards. For the tests performed in Chattanooga, a mechanical

    gripper secured the upper end ofthe tube to the load cell. A tight fitting mandrel inside the tube

    prevented the gripper from deforming the tube at the gripper location and a bracket secured the

    mockups to the piston that applied the load. For the tests performed in Windsor, a retention plate

    with a threaded hole was used to secure the upper end ofthe tube to the load cell and a similar

    plate was used to secure the single tube mockup to the crosshead. Threaded plugs that had a

    means ofallowing water to enter and exit the tube were welded to the upper end ofthe tube and

    to the lower end ofthe single tube mockup. The threaded portion ofthe plugs were screwed into

    the threaded hole ofthe two retention plates. Whena

    pressurizedtest was conducted, the tube

    was filled and pressurized with water through holes that were drilled in the plug. X-Y plotters

    were used to record load versus crosshead displacement.

    After the specimen was secure in the test machine, loads were applied at a fixed crosshead

    displacement rate in the Windsor tests and at a manually adjusted load in the Chattanooga tests

    until the severed tube was pulled from the tubesheet. The load at which first slippage ofthe tube

    in the tubesheet occurred and the maximum load during the test were noted and recorded. A plot

    ofload versus crosshead displacement was also obtained for each mockup tested. In the

    Chattanooga tests, the slope ofthe ascending load vs. time curve varied as the rate at which the

    hydraulic pump pressure regulator screw was adjusted. This was done manually and intentionally

    slowly so as not to miss the data readings. Once the tube began to move, the pressure regulatorwas not adjusted any more, unless the tube stopped moving. In most cases, the maximum force

    was achieved after the tubes had moved some distance.

    The pressurized specimens had welded plugs ofthe same type as the high temperature leak rate

    specimens. During the pull tests, these specimens had an internal pressure of2575 psi + 100 -0

    psi to determine ifinternal pressure would affect the loads required to displace the specimens

    from the tubesheets.

    An accumulator with a 3000 psig rating and a three gallon capacity or a positive displacement

    pump were used to maintain pressure during tests.

    For the hydrostatic test approach, a nitrogen gas bottle was used to apply pressure to the

    accumulator. A system to collect the leakage from the mockup was used to insure that the

    amount ofspillage onto the test machine was minimized. The mockups were pressurized to the

    specified pressure before starting the test and the pressure was maintained until approximately

    one-halfinch oftubing remained in the mockup, at which time pressure was reduced to 0 psig.

    The data acquisition system monitored mockup pressure throughout the test.

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    Section 3Technical Approach Summary

    The pullout load criterion is based on 3NODP. The 3NODP value is 4410 psid based on SONGS

    data:

    NODP 1470 psid3NODP 4410 psid

    Pullout is based on the tube burst criteria of3NODP because it was conservatively assumed for

    this work (consistent with W*) that the tube is completely severed and can move axially up

    under a pressure load. Ifthe severed tube can exit the tubesheet, system effects and off-site dose

    consequences would be the same as a postulated guillotine tube burst. The 3NODP criterion is

    consistent with NEI 97-06 requirements (11) and is conservative relative to the criterion of1.4

    times the MSLB differential pressure (including accounting for the larger dilation ofthe

    tubesheet holes). Because the MSLB is the most probable event that would cause a tube to be at

    risk for pullout and because the MSLB criterion is a fixed value whereas 3NODP increases

    margin as steam generator pressure degrades over the operating life ofthe plant due to plugging,etc., the 3NODP criterion is considered as very conservative for use in this test program.

    The pull force is dependent upon the contact force, contact area, coefficient offriction, and in

    general, the tribology. Pullout at 3NODP for these tests is recorded as a function ofjoint length

    and tube surface roughness. The force (F) required on a 0.75" nominal diameter tube equivalent

    to 4410 psid is:

    Tube area = 7r 0.758" / 2)2 = 0.451 in.2

    F = 4410 lbf/in * 0.451 in. =- 2000 lbf. (1989 lbfrounded up)

    Pullout force was applied using two different load cell processes. The Chattanooga load cellapplied a manually adjustable constant load process. The Windsor load cell was applied in a

    constant displacement rate process. The test plan called for two single tube mockup specimens to

    be tested in Chattanooga as a cross-reference between the Chattanooga and Windsor load cell

    tests to show that the test setups would provide comparable results. The difference in processes

    results in some variability in the results as indicated by the two rough bore single tube mockup

    specimens (specimens 20 and 21) tested in Chattanooga and the remainder ofthe rough bore

    single tube mockup specimens tested in Windsor.

    Pullout testing was conducted after leak rate testing on the majority ofthe specimens. A few

    specimens had pull tests without leak tests. Measurements were taken on the Boston Edison SG

    before and after leaktesting from a fixed reference point to determine tube movement. Table 3-1illustrates that thejoint was not measurably disturbed at the leak test pressure (i.e. MSLB

    pressure).

    3.1.2 LeakRate Tests Methods and Criteria

    Leak rate is a function ofdifferential pressure. Empirical data is necessary for understanding the

    leakrate as a function ofjoint length but the Poiseuille equation (L2) provides an expression that

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    Section 3

    Technical Approach Summary

    approximates the fundamental relationship between the length ofthe tubesheetjoint and leak

    rate:

    dP= 64 L p v

    2

    Re D 2g,

    Where:

    Re = Reynolds number

    D in this case, the diameter difference between the tube and tubesheet

    p = fluid density

    g= gravitational constant

    L - joint length

    v = fluid velocity or flow rate

    dP = differential pressure at MSLB

    For the leak rate tests conducted in this project, all ofthe terms in the equation are essentially

    constant except thejoint length and flow rate. Therefore, it can be stated that the flow rate varies

    inversely as the square root ofthejoint length. This relationship indicates that flow rate should

    reduce quickly over a very sltortjoint length and then flatten out over longerjoint lengths. This

    set oftests did not attempt to establish experimentally or analytically the knee ofthe curve or a

    usable formulation to cover alljoint lengths. This relationship is conservative with respect to

    expected flow conditions in the event ofa MSLB. During a MSLB event the maximum

    differential pressure (the flow forcing function) will occur when the steam generator pressure is

    approaching atmospheric pressure. Any primary coolant leaking from tubesheetjoints into

    atmospheric pressure will undoubtedly flash to steam and create a choked flow condition. Thechoked flow condition is not considered in this project but is an additional conservatism in the

    development ofthe thresholdjoint length. The purpose ofthese tests was to determine a

    sufficient joint length that satisfied the criteria and provided a cost-effective NDE inspection

    length.

    The leak rate criterion is based on the generic allowable leakage technical specification limiting

    condition for operation of0.5 gpm per steam generator. Operational assessment calculations

    include assumptions for undetected flaw populations and determine acceptable plant run-time

    based in part on acceptable EOC leakage. [

    ](c)

    Each tube has twojoints - the hot leg and the cold leg sides. PWSCC is a temperature driven

    cracking mechanism and hot-legjoints will be the predominate number oftubejoints affected

    over time. On this basis, only the hot- legjoints are considered in the development ofthreshold

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    Section 3

    Technical Approach Summary

    length for inspection. Leakrate is considered cumulatively for all tubejoint leaks in the steam

    generator. Therefore, the test results provided on a singlejoint basis are multiplicative ofthe

    number oftubes assumed to be leaking. [

    ](c) This approach is very conservative as explained in Section 1.5.

    Leakrate testing was used to determine thejoint length (i.e. the threshold length for leakage) for

    acceptable leakage at MSLB conditions from through-wall defects located within the tubesheet

    region. This phase ofthe program used the tube-tubesheet joint mockups and cut tubes in the

    scrapped Boston Edison steam generator. A test procedure U(3), was developed and used for

    both types oftests.

    Figure 3.4 is a schematic diagram ofthe leak rate test system. The testing system consisted of:

    "* An air operated positive displacement pump (Haskel model MS 110),"* A calibrated pressure gauge (0 to 10,000 psi),

    "* A calibrated pressure transducer (0 to 7,500 psi range),

    "* Data acquisition system (including DATAQ signal conditioner/processor and a

    computer),"* A reservoir ofdemineralized water, a high pressure hose with a mechanical plug/seal,

    and

    * Ancillary tubing and valves

    It was not necessary to adjust leakrates for accident conditions. Appendix D ofthe EPRI Steam

    Generator In Situ Guidelines (26) calls for a correction to account for the difference in materialproperties at room and operating temperature. The factors tha