ML20076E852

Comments on Matl Presented by NRC at 830706 Meeting W/Steam Generator Owners Group Re NRC Latest Position on Steam Generator Generic Requirements.Proposal for 100% Insp of Untested Tubes Should Be Deleted

ML20076E852
Person / Time
Site:	Satsop, Washington Public Power Supply System
Issue date:	08/19/1983
From:	Mazur D WASHINGTON PUBLIC POWER SUPPLY SYSTEM
To:	Eisenhut D Office of Nuclear Reactor Regulation
References
NUDOCS 8308250026
Download: ML20076E852 (2)

Text

f Washington Public Power Supply System P.O. Box 968 3000 GeorgeWashington Way Richland, Washington 99352 (509)372 5000 56 4 0 August 19, 1983 Mr. D. G. Eisenhut, Director Division of Licensing U.S. Nuclear Regulatory Commission Washington, D.C.

20555

Subject:

COMMENTS ON PROPOSED STEAM GENERATOR REQUIREMENTS On July 6, 1983, the NRC staff met with the Steam Generator Owner's Group to discuss the staff's latest position on Steam Generator Generic Requirements.

We have reviewed the material presented by the staff as it would apply to our WNP-1 (B&W) and WNP-3 (CE) plants and offer the following comments for your consideration:

1.

We are concerned over the impact of the Supplemental Tube Inspection Plan which would involve NRC projected implementation costs of $1.7M for WNP-3 and $4.9M for WNP-1. These added costs are to be offset by NRC estimates of avoided costs ranging from

$1.3M to 5.4M.

The bases for the value impacts do not appear to consider items such as the cost of added downtime or the fact that the seven man rem increased exposure is to a limited pool of eddy current inspectors.

To remain within annual dose limits, added downtime or plant modification to reduce exposure for the extra inspection could be required.

The Supply System considers that for a Babcock and Wilcox reactor, the value impact of supple-mental tube inspection will be unfavorable.

We recommend that the staff proposal for 100% inspection of remain-ing (i.e., not tested) tubes in the affected Steam Generator be deleted. The appropriate inspection would appear to be a statistical sample of sufficient size to assure that a specified level of con-fidence can be achieved.

8308250026 830819 PDR ADOCK 05000460

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r D. G. Eisenhut Page Two August 19, 1983 COMMENTS ON PROPOSED STEAM GENERATOR GENERIC REQUIREMENTS 2.

Condenser Inservice Inspection Program (CISIP) should not be re-quired by license conditions.

The major concern is the ability to achieve and maintain good secondary water chemistry.

CISIP may be proposed as part of an overall plan to control chemistry which con-siders all areas with cleanup systems and coolant treatment.

i We request clarification on whether the water chemistry requirements stated in the draft plan are steady state or absolute limits. As absolute limits, they form restrictive licensing conditions.

3.

Full length tube inspections are voluntarily conducted at many plants but that does not form the basis for a requirement to inspect all cold legs. The staff should perform a cost benefit analysis for this new requirement to determine if there is an in-crease in safety commensurate with the added cost of plant inspection.

i l

Very truly yours, h

D. W. Ma (MD387) l Managing Director cc: SJ Green (EPRI)

V Stello (NRC)

JJ Ray (ACRS) l l