ML063170025

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TSTF 449 SG Tube Integrity LAR - MD0209/MD0210
ML063170025
Person / Time
Site: Prairie Island  
(DPR-042, DPR-060)
Issue date: 11/09/2006
From: Mahesh Chawla
NRC/NRR/ADRO/DORL/LPLE
To: Vincent D
Nuclear Management Co
Mahesh Chawla, LPL3-1, 415-8371
References
TAC MD0209, TAC MD0210, TSTF-449
Download: ML063170025 (3)


Text

From:

Mahesh Chawla To:

DALE.Vincent@nmcco.com Date:

11/09/2006 3:51:13 PM

Subject:

TSTF 449 SG Tube Integrity LAR - MD0209/MD0210

Dale, Following are the staff comments on your revised TS pages for TSTF 449 Amendment. Let me know if NMC would like to discuss these in a tele-conference. Thanks
1. In 5.5.8.c.2.b.1 and 5.5.8.c.2.b.2, it appears that the second from the last sentence should be modified (This 1.07-inch span (not including eddy current uncertainty) is referred to as the F*

region.) I believe this sentence should be modified to indicate that "This 1.07-inch span (when increased for eddy current uncertainty) is referred to as the F* region." The corresponding change should also be made to the EF* section. The reason for the change is that the F*

region definition is used to indicate that all tubes with flaws in this region should be plugged or repaired. As currently written, one could interpret the sentence as the F* region does not include eddy current uncertainty (which is not the correct interpretation).

2. In 5.5.8.c.2.c, they should add "....as an alternative tot he depth based criteria in Specification 5.5.8.c.2(a)(1). This will make it similar to the F* criterion writeup (but more appropriately it clarifies that these alternate repair criteria can only be applied to the non-sleeved portion of the tube).
3. In 5.5.8.d.3.a, the last sentence is awkward. I would suggest the following: The region of these tubes below the F* and EF* regions do not need to be inspected unless there is a sleeve (or portion of a sleeve) that extends below the F* or EF* region.
4. In 5.5.8.d.3.c, they should confirm that the Spec referenced is 5.5.8.c.2(c) since I could not read portions of the spec in the hard copy that I have.
5. It is not clear why they deleted 5.5.8.d.3.d. Our preference is that they retain it (as modified based on our previous comments).
6. In 5.6.7.a.10, the specification referenced should be 5.5.8.d (not 5.5.8.d.3(a)). Our suggestion would make it consistent with their current spec. Their proposal limits their current reporting requirement.
7. In the first paragraph on B 3.4.14-2, they do not include the last sentence that the TSTF indicated should be included. Namely, "The LCO requirement to limit primary to secondary LEAKAGE through any one SG to less than or equal to 150 gallons per day is significantly less than the conditions assumed in the safety analysis." Is there a reason for this?
8. In the 3rd paragraph in the LCO section on page B 3.4.19-3, they should remove the

"(sleeves)" qualifier on repairs since it is not needed. In addition, it is not clear that the last sentence is complete. We would recommend something like the following: The tube-to-tubesheet weld is not considered part of the tube, nor is the region of the tube below the F* and EF* region (provided no sleeve extends below the F* and EF* region in which case the sleeve is part of the tube), nor the portion of the original tube wall between the sleeve joints.

9. We still have the issue with respect to the F*/EF* criteria and the cold leg.

>>> Mahesh Chawla 11/02/2006 3:39:04 PM >>>

>>> "Vincent, Dale M." < Dale.Vincent@nmcco.com > 11/02/2006 10:47 AM >>>

Mac, here is another markup of TS pages which responses to comments

provided by email on August 29, 2006 and October 25, 2006.

CC:

Kenneth Karwoski; Yamir Diaz-Castillo Mail Envelope Properties (455394C1.3EA : 2 : 35476)

Subject:

TSTF 449 SG Tube Integrity LAR - MD0209/MD0210 Creation Date 11/09/2006 3:51:13 PM From:

Mahesh Chawla Created By:

MLC@nrc.gov Recipients Action Date & Time nmcco.com Transferred 11/09/2006 3:51:52 PM DALE.Vincent (DALE.Vincent@nmcco.com) nrc.gov OWGWPO03.HQGWDO01 Delivered 11/09/2006 3:51:14 PM YCD CC (Yamir Diaz-Castillo) nrc.gov OWGWPO04.HQGWDO01 Delivered 11/09/2006 3:51:23 PM KJK1 CC (Kenneth Karwoski)

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