ML17341B361
| ML17341B361 | |
| Person / Time | |
|---|---|
| Site: | Saint Lucie, Turkey Point, 05000000 |
| Issue date: | 09/01/1982 |
| From: | Schmidt A FLORIDA POWER & LIGHT CO., STEAM GENERATOR OWNERS GROUP |
| To: | Eisenhut D Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 8209080348 | |
| Download: ML17341B361 (9) | |
Text
ACCESSION NBR:
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P.O. BOX 529100 MIAMI,FL33152 September 1,
1982 FLORIDAPOWER 8 LIGHTCOMPANY Mr. Darrell Eisenhut Director of Licensing U.S. Nuclear Regulatory Commission Washington, D.C.
20555
Dear Mr. Eisenhut:
My letter of August 18, 1982 transmitted to you a copy of our initial correspondence with U.S. Pressurized Water Reactor owners relative to pro-posed steam generator generic requirements that you presented in our meeting of July 29, 1982.
We have received comments on those proposed requirements from participants in the July 29, 1982 meeting and sent them to all PWR owners for their review and further comment.
I have enclosed a summary of the comments sent to all PWR owners to keep you informed of our progress.
However, I want to emphasize that these comments are just a first step, intended to facilitate the review and comments by all PWR owners.
As additional comments are obtained, discussed, and resolved, there are likely to be changes in the enclosed summary.
Very truly yours, Ai D. Schmidt Chairman SGOG Executive Committee ADS/nfb Attachment "0 Om HM XO
>0 am GO'G) l N'nm OIQ',
OO'N:
BIQO ClUl~
%O cc:
D. Adams, Louisiana Power S Light R. Acosta, Florida Power S Light J. Berga, EPRI - Washington Office S. Brown, EPRI - NDE Center A. Curtis, Rochester Gas a Electric R. Garnsey, C.E.G.B.
S. Green, EPRI - SGPO G. Lainas, NRC J. Lang, EPRI SGPO W
- Layman, EPRI NSAC D. Love, Arkansas Power a Light R. Mecredy, Rochester Gas 6 Electric L. Parscale, Arkansas Power 6 Light R. Shell, TVA B. Snow, Rochester Gas 6 Electric A. Sudduth, Duke Power Company T
- Tramm, Commonwealth Edison L. White, Rochester Gas a Electric T. Ziegler, TVA PEOPLE... SERVING PEOPLE
CP:
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DRAFT COMMENTS ON DRAFT NRC REQUIREMENTS II.1 Prevention and Detection of Loose Parts and Forei n Ob ects General Comment:
The frequency of occurrence and the potential tube degradation associated with the secondary side debris in S/G's makes it prudent to perform secondary side inspections at the next scheduled refuel-ing outage for operating plants and prior to start-up for plants under construction.
Suggested wording for the "REQUIREMENT" section:
During the next scheduled refueling outage, perform secondary side visual examination of the entire periphery (and tube lane),
at and above the tubesheet, using an appropriate visual tech-nique such as fiber optics or TV camera.
0 Additional inspections/corrective actions (if required) should be site specific and should be appropriate and consistent with the findings of the secondary side visual examinations.
'However, should these examinations reveal secondary side tube wear, a
secondary side LPMS shall be installed and operated on each S/G.
0 Review current QA/QC procedures and improve as appropriate to preclude introduction of foreign, objects in S/G primary/secondary sides.
II.4 Improved Eddy Current Techniques Requirements 1 ~
~
~ and discriminating among multiple defects" should be deleted from text.
(Error on NRC's part) 4.
The emphasis on wear type defects is overplayed.
The significant issue is the presence of long/gradual discontinuities which can be missed with the differential coil. It will be difficult in practice to generate a conservative standard; the defect mechanism must exhibit a known regularity in its growth before a standard can be identified.
II.S Primary to Secondary Leakage Limit No Comment.
II.7 Secondary Mater Chemistry Program It should be made clear that plants shut down for steam generator repairs would be required to commit to a water chemistry program, but not to act-ually implement the program, prior to restart.
Further, unless the repairs are due to corrosion phenomenon, no commitment should be required.
h
II.S Condenser Inservice Inspection Program As with II.7, plants shut down for steam generator repairs would be required to commit to, but not to implement, a condenser inspection program prior to restart.
Further, unless the corrosion was related to a condenser
- problem, no commitment should be required.
More definition of the condenser inspection program is needed in order to assess its impact.
IIF 9 Upper Inspection Ports General Comment:
The requirement to add upper inspection, ports on S/G's should be evaluated on a case-by-case basis for all plants.
Discussion:
Upper inspection ports are a minimal value on a generic basis such that a backfit requirement, independent of a plant specific problem, is not tech-nically justified, nor is it cost effective'rom an inspection standpoint, the only meaningful use for upper inspection ports is to monitor flow slot hourglassing (as a
warning to U-bend cracking at the apex of row 1 tubes due to displacement of the U-bend "legs" )
This problem is unique to the Westinghouse
- design, so a requirement to include all recir-culating S/G's is not appropriate.
Additionally, this problem can/has been dealt with effectively in alternate ways, i.e., eddy current testing of tight radius U>>bends and preventive plugging of row 1 tubes.
- Thus, the upper ports are of very minimal benefit even with S/G's having the flow. slot configuration.
Other U-bend problems (i.e., tube cracking at the transition between the bend and the straight portion of the tube) would have to be detected using eddy current methods.
Obviously, a visual inspection would not detect this condition.
The only real benefit of additional ports would be to assist in removing tubes (should a condition develop which would necessitate a tube pull) ~
However, this should be a plant specific consideration because:
1 ~
low probability of this occurrence, 2.
a pre-established upper port may not be located in the appropriate location to address, a future problem, 3.
initial cost is significantly high (Note:
1976 dollars; approximate cost in excess of
$200,000 to add 1 upper inspec-tion port at Turkey Point Unit 4) such that with the high time value of money, '"front end" implementation of upper ports becomes wastfully expensive.
This is probably also true for a pre-operational plant, but must also be looked at on a case-by-case basis because the costs will be related to where the plant is in their construction/start-up sequence.
This will obviously affect the cost of the modification, and more significantly, could affect schedule.
III.1 ~ 1 RCS Pressure Control During SGTR This requirement is vague and should be revised prior to issuance as written.
This requirment could result in a very extensive analytical and procedure revision effort, which is not warranted.
At the July 29 meeting, the NRC stated that the objective of this require-ment was to ensure that the 1/2 hour assumed for equalization of primary and secondary pressure was met.
Rather than set an arbitrary goal for the elapsed time to primary system depressurization, it is suggested that the goal be stated in terms of radioactivity releases to the environment.
The ability of a given plant to achieve the initial primary cooling, depressurization of the primary below the secondary safety valve liftpressure, and the isolation of the affected steam generator prior to overfilling the unit could then be evaluated.
The objective would be to show that the release limit for that particular unit and site should not be exceeded.
III.1.3.
1 Safety In'ection Signal Reset No Comment.
III.1. 3. 2 Containment Isolation and Reset No Comment.
V.1 ~ 4 Standard Technical Specification Limit for Coolant Iodine Activity No comment on the first requirement.
The additional requirement for low pressure plants is without basis.
First, the basis for the current Ginna specification is extremely conservative and assumes that all RCS iodine was released to the environment.
- Secondly, analyses are currently being per-formed by RGaE relating to this issue.
- Thus, any requirement would be premature at this time.
Thirdly, a requirement such as imposed here could have a substantial impact.
A number of plants have, in the past, exceeded the proposed NRC special limit.
The existence of such a reduced limit in those cases would have had severe financial impact, including a requirement for additional fuel purchases to replace leaking fuel and reduce a plant output -or additional outage time while waiting for fuel delivery NRC Proposed Actions
'hese proposed activities could have significant impact on utilities.
For
- example, several steam generator sleeve designs are complete at this time.
NRC guidance on sleeve design at this time could have severe financial
. impact on the utilities wishing to use sleeves.
Additional information and technical interchanges between the NRC and industry would be helpful in assessing the potential impact of the proposed actions.
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