ML18087A654

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Forwards Comments on Science Applications,Inc 820923 Draft Final Rept, Value-Impact Analysis of Recommendations Re Steam Generator Tube Degradations & Rupture Events, Per Generic Ltr 82-32
ML18087A654
Person / Time
Site: Salem  PSEG icon.png
Issue date: 01/13/1983
From: Liden E
Public Service Enterprise Group
To: Varga S
Office of Nuclear Reactor Regulation
References
GL-82-32, NUDOCS 8302020280
Download: ML18087A654 (2)


Text

PS~G Public Service Electric and Gas Company P.O. Box 236 Hancocks Bridge, New Jersey 08038 Nuclear Department January 13, 1983 Director of Nuclear Reactor Regulation

u. S. Nuclear Regulatory Commission 7920 Norfolk Avenue Bethesda, Maryland 20014 Attention:

Mr. Steven A. Varga, Chief Operating Reactors Branch #1 Division of Licensing

Dear Mr. Varga:

COMMENTS.ON NRC GENERIC LETTER 82-32 POTENTIAL STEAM GENERATOR RELATED GENERIC REQUIREMENTS SALEM GENERATING STATION UNIT NOS. 1 AND 2 DOCKET NOS. 50-272 AND 50-311 We have reviewed the September 23, 1982 SAI draft final report, "Value-Impact Analysis of Recommendations Concerning Steam Generator Tube Degradations and Rupture Events".

Attached are our comments on selected sections.

If you have any further questions, we will be pleased to discuss them with you.

Attachment 83o20202so 930113 PDR ADOCK 05000272 p

PDR The Energy People Very truly yours, E. A. Liden Manager - Nuclear Licensing and Regulation 95-2168 (5M) 10-82

r COMMENTS ON NRC GENERIC LETTER 82-32 VALUE-IMPACT ANALYSIS OF RECOMMENDATIONS CONCERNING STEAM GENERATOR TUBE DEGRADATIONS AND RUPTURE EVENTS Value-Impact Analysis by SAI addressed 12 specific requirements proposed by the NRC in July, 1982~ as a means of upgrading steam generator operation and surveillance to reduce tube failure and extend steam generator service life.

In general, it appears that Salem Generating Station is already essentially in compliance with most of the proposed requirements and we have no basic disagreements with the analysis developed by SAI.

Our comments are as follows:

2.

Inservice Inspection

c.

Supplemental Sampling We do not know what the number of limiting tube failures is for Salem and therefore, cannot comment in detail.

We would be opposed to increasing the supplementary sample size to 100% as a standing requirement, when degradation can be identified with specific areas of the tube bundle.

e.

Unscheduled ISI Should a tube leak develop of sufficient magnitude to require shutdown and plugging, we believe that an inspection should be made at that time to ensure against potential failure of other tubes in that steam generator.

4.

Upper Inspection Ports We agree that upper inspection ports would not provide sufficient improvement in monitoring support plate distortion to justify their installation.

Furthermore, they would be completely inadequate for monitoring cracking of row 1 U-bends, which is one of the reasons why they were originally proposed.