ML17331A941
| ML17331A941 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| Issue date: | 08/16/1993 |
| From: | Fitzpatrick E INDIANA MICHIGAN POWER CO. (FORMERLY INDIANA & MICHIG |
| To: | NRC OFFICE OF ADMINISTRATION (ADM) |
| References | |
| FRN-58FR35985, RTR-NUREG-1477 58FR35985, AEP:NRC:0508Z, AEP:NRC:508Z, NUDOCS 9308200033 | |
| Download: ML17331A941 (5) | |
Text
FORD I I
REGULAT INFORMATION DISTRIBUTIOh~STEM (RIDS)
ACL'CESSION NBR:9308200013 DOC.DATE: 93/08/16 NOTARIZED: NO DOCKET I FACIL:50-315 Donald C.
Cook Nuclear Power Plant, Unit 1, Indiana M
05000315 50-316 Donald C.
Cook Nuclear Power Plant, Unit 2, Indiana M
05000316 AUTH.NAME AUTHOR AFFILIATION FITZPATRICK,E.
Indiana Michigan Power Co. (formerly Indiana 6 Michigan Ele RECIP.NAME RECIPIENT AFFILIATION Division of Freedom of Information
& Publications Services
SUBJECT:
Submits comments on draft NUREG-1477, "Voltage-Based I
Interim Plugging Criteria for SG Tubes-Task Group Rept."
NUREG recommendations do not take into consideration plants D
that are operating w/interim plugging criteria.
S DISTRIBUTION CODE:
DS09D COPIES RECEIVED:LTR /
ENCL Q SIZE: Z
/
TITLE: SECY/DSB Dist: Public Comment on Proposed Rule (PR)-Misc Notice;Reg G
F NOTES:
RECIPIENT ID CODE/NAME INTERNAL: OG~CD 1 5-B-1 8 cRE Ol MES/DS IR COPIES LTTR ENCL RECIPIENT ID CODE/NAME OGC/SAIP15-B-18 RES DIR
'ES/PMPDAS COPIES LTTR ENCL EXTERNAL: NRC PDR 02 0
NOTE TO ALL "RIDS" RECIPIENTS:
PLEASE HELP US TO REDUCE WASTE! CONTACT THE DOCUMENT CONTROL DESK.
ROOM P I-37 (EXT. 504-2065) TO ELIMINATEYOUR NAME FROM DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEED!
TOTAL NUMBER OF COPIES REQUIRED:
LTTR 7
ENCL
Indiana Michigan Power Company P.O. Box 16631 Cotumbus, OH 43216 QP&
USNRC OFFI('r-I"
<"'"""STRE"'"'93 AGO 17 P3:24 S~n) deaf(.
IIHtMSIHSl AEP:NRC:0508Z Donald C. Cook Nuclear Plant Units 1 and 2
Docket Nos.
50-315 and 50-316 License Nos.
DPR-58 and DPR-74 DRAFT NUREG-1477 COMMENTS Rules and Review Directives Branch Division of Freedom of Information and Publication Services Office of Administration U. S. Nuclear Regulatory Commission Washington, D.C.
20555 August 16, 1993 gentlemen:
We appreciate the opportunity to comment on the draft NUREG-1477, "Voltage-Based Interim Plugging Criteria for Steam Generator Tubes Task Group Report".
Our review of the draft NUREG-1477 was done in con)unction with the EPRI Ad-hoc Committee on Steam Generator Alternate Repair
- Criteria, of which we are members.
The committee solicited,
- reviewed, and consolidated our and other committee member comments which were then forwarded to you by EPRI.
In addition we are cognizant of the comments recently forwarded to you by Westinghouse Electric Corporation.
Overall we are in accord with both sets of comments and are hopeful they will resolve a number of NRC issues with interim and alternate plugging criteria for outside diameter stress corrosion cracking at support plate intersections.
A number of industry comments relate to NUREG recommendations the industry considers longer term issues which would be addressed under the Steam Generator Degradation Specific Management program and not as part of an interim plugging criteria.
However, the more immediate concerns for plants such as Donald C.
Cook are those NUREG recommendations requiring more tube pull samples, not allowing use of motorized rotating pancake coil (MRPC) testing to disposition indications, unnecessarily restrictive requirements regarding probe response characteristic and probe diameter, need for fuel cycle to cycle approval of interim plugging criteria, changes in probability of deletion (POD) requirements and leak rate calculation methodology.
ssosaoooss 9SO8le PDR NUREG l477 C
I (f-,
J r
Rules and Review Directives Branch AEP:NRC:0508Z We believe the NUREG recommendations do not take into consideration the plants that are operating with an interim plugging criteria.
We at Donald C.
Cook Nuclear Plant have applied the industry recommended inspection guidelines and operational
- changes, defined the degradation based on past tube pull samples and eddy current testing, limited tube degradation growth rate, and demonstrated favorable tube inspections results.
The NUREG should make provisions for these actions already completed under an interim plugging program.
This is an important aspect to consider knowing that the review cycle for the Steam Generator Degradation Specific Management program can conceivably take up to 24 months and plants could need a continuance of the interim plugging criteria.
If you have any questions regarding these
- comments, please feel free to contact Mr. J.
Jensen at (614) 223-1975.
Sincerely, Vice President cc:
A. A. Blind Bridgman J.
R. Padgett G. Charnoff NFEM Section Chief J.
B. Martin Region III NRC Resident Inspector Bridgman
0'
~ 8 f
/
1 4
+
~