ML18051A264

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Submits Comments on Draft Final Rept for Value Impact Analysis of Recommendations Re Steam Generator Tube Degradations & Rupture Events,Per Generic Ltr 82-32
ML18051A264
Person / Time
Site: Palisades, Midland  Entergy icon.png
Issue date: 01/07/1983
From: Lauren Gibson
CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To: Eisenhut D
Office of Nuclear Reactor Regulation
References
20434, GL-82-32, LSG-1-83, NUDOCS 8301110552
Download: ML18051A264 (2)


Text

consumers Power company .. Frederick W Buckman Executive Director of Nuclear Activities General Offices: 1945 West Parnall Road, Jackson, Ml 49201 * (517) 788-1486 January 7, 1983 LSG 1-83 Mr Darrell G Eisenhut Director of Licensing US Nuclear Regulatory Commission Washington, DC 20555 MIDLAND ENERGY CENTER PROJECT COMMENTS ON DRAFT FINAL REPORT VALUE-IMPACT ANALYSIS OF RECOMMENDATIONS CONCERNING STEAM GENERATOR TUBE DEGRADATIONS AND RUPTURE EVENTS FILE 0921 SERIAL 20434 REFERENCE Potential Steam Generator Related Generic Requirements (Generic Letter 82-32)

Your letter of December 9, 1982 requested comments on the "Value-Impact Analysis of Recommendations Concerning Steam Generator Tube Degradations and Rupture Events prepared by SAL We concur with the approach of performing value-impact analysis of potential requirements and generally concur with the r.esults of this analysis with the following comments:

  • 1. As noted in the Major

Conclusions:

"Public Risk from steam generator tube rupture *was assessed and found to be so low that it has a completely negligible contribution to the value-impact comparisons." Based on this conclusion, it would seem appropriate to issue the Steam Generator Requirements as "Guidelines" rather than "Requirements" since it is not a safety issue but one of economic impact.

  • 2. The NRC should require each licensee or applicant to prepare and implement a program based on the guidelines but tailored to their own set of circumstances and plant history.
3. There should be a mechanism for the periodic review of the program to make any necessary adjustments based on results.

One example of why programs should be plant specific concerns secondary side visual inspection. This inspection introduces a risk of tube corrosion associated with moist/dry, non-inerted layup of the secondary side. For ~ oO I 8301110552 830i07 ...

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2 plants that have no history of secondary side loose parts, such an inspection might result in a negative benefit.

A second example has to do with eddy current methods. These should be tailored to the particular plant and plant history, with recognition that a certain flexibility needs to be allowed to accomodate changing technology.

With respect to secondary water chemistry control, we can only re-emphasize the need to tailor the program to the specific plant needs.

We appreciate the opportunity to comment on this draft final report.

Louis S Gibson, Section Head Nuclear Safety & Analysis Section Midland Safety & Licensing Department CC DBMiller, Midland JRSchepers DJVandeWalle oc0183-1505al31