ML20211A167

Comments Supporting Comment Transmitted by NEI , Transmittal of Industry Comments on Draft Reg Guide DG-1074, Steam Generator Tube Integrity

ML20211A167
Person / Time
Site:	Calvert Cliffs
Issue date:	07/30/1999
From:	Cruse C BALTIMORE GAS & ELECTRIC CO.
To:	NRC OFFICE OF ADMINISTRATION (ADM)
References
FRN-64FR3138, RTR-REGGD-XX.XXX, TASK-*****, TASK-RE 64FR3138-00017, NUDOCS 9908230210
Download: ML20211A167 (3)

Text

._ _ _ _

'* [hf CHARLES H. CRUSE Vice President -

Baltirnore Gas an Calvert Cliffs Nuc

'e Company

[' cd Nuclear Energy j#p,p/g <

Lb1650 Calven Cliffs Parkwa[ p us y, Mar >GS92g

~

gqj 410 495-4455 f/f 2: g

/7 RULES &

us $$RMCH July 30,1999 U. S. Nuclear Regulatory Commission Washington, DC 20555 ATfENTION: Rules and Directives Branch Office of Administration

SUBJECT:

Calvert Cliffs Nuclear Power Plant Unit Noc.1 & 2; Docket Nos. 50-317 & 50-318 Transmittal of Comments on Draft Regulatory Guide DG-1074, " Steam Generator Tube Integrity" In the Federal Register (January 20,1999), the NRC issued Draft Regulatory Guide DG-1074 for public comment. Baltimore Gas and Electric Company (BGE) has participated in an industry effort with Nuclear Energy Institute (NEI) to collect and transmit comments. Based on our participation and review of this collective effort, BGE endorses the comments transmitted by NEI letter dated June 29,1999,

" Transmittal ofIndustry Comments on Draft Regulatory Guide DG-1074."

In addition to the NEl transmittal, it should be further emphasized that the issuance of DG-1074 for public comment does not reflect the current state of the industry /NRC discussion of NEI 97-06, " Steam Generator Program Guidelines," and its supporting generic license change package. The NRC has recognized this joint effort as the best path to a successful resolution of steam generator program issues.

Considering the extensive nature of the industry comments and the progress of the joint NRC/ Industry effort, it is BGE's position that no further effort be expended in modifying DG-1074; neither by industry nor the NRC.

1 In performing a review of the industry comment package, BGE recommends that the NRC focus on several important areas considered principal concerns and contentions. These include:

In late 1998, the NRC agreed that the best path to a successful resolution of the questions surrounding steam generator program requirements was through approval of a generic license change package implementing the requirements of NEl 97-06 and its referenced Electric Power Research Institute (EPRI) Guidelines. DG-1074 does not reflect the current positions of the NRC or the industry on key issues. As a result, accepting the positions expressed by DG-1074 would result in a loss of six months of productive work on resolution of steam generator program requirements. Similarly, the potential for conflict and confusion that arises with parallel industry

..nnnMH 9908230210 990730 5 PDR ADOCK 05000317 H PDR

, 3-Rules and Directives Branch July 30,1999 Page 2 and NRC guidance documents is obvious. The recent focus has been on the industry guidance and should remain there. As stated previously, no further effort should be expended in modifying DG-1074; neither by industry nor NRC. It should be deleted from all NRC lists of publications.

l DG-1074 is not clear on the issue of severe accidents and risk-informed methods. The draft regulatory guide repeatedly makes reference to " risk-informed" approaches in the context of" core damage severe accident" analysis and calls for a " risk assessment" to be performed, while in other j areas it states that the intent is to ensure that steam generator tubes "are capable of performing their intended safety functions consistent with the licensing basis." This seems to infer that severe accident risk assessment is part of the licensing / design basis of the plant. This is clearly not the case previously and represents a major backfit in regulation.

• DG-1074 requirements contain excessive conservatism, given the safety margins currently contained in each plant's licensing basis. The treatment of analysis inputs and analysis variability goes well beyond typical design analysis for Reactor Coolant System pressure boundary components as governed by American Society of Mechanical Engineers (ASME) Code. This excessive conservatism is considered punitive, is not performance based, and is contrary to a goal established at the beginning of the review of steam generator regulation.

I e The ' draft regulatory guide contains an inconsistent level of detail. DG-1074 provides very detailed guidance in some instances, while in other situations the guidance is at such a high level that the desired licensee action is unknown. For example, the Non-Destructive Examination Data Acquisition and Analysis regulatory position is so detailed concerning plant procedures that it includes requirements for procedures that regulations do not even dictate be implemented, e.g., independent two-party analyses. Detailed guidance such as this detracts from the real intent of the guidance-to ensure that steam generator tube integrity is maintained. On the other hand, where risk is discussed in the draft guide, a typical statement such as, "The staff encourages i licenses to follow risk-informed approaches . . ." can be found. The industry continues to wrestle with understanding the conditions requiring consideration of severe accident risk, the method of l l

assessment, and criteria by which tojudge success or failure. i e Many of the requirements in DG-1074 do not meet the intent of a performance-based regulation. l For example, the draft guideline includes requirements that go well beyond what is required for i plants applying NRC and ASME Code-approved repair criteria for repair on detection.- Many of the requirements included in the draft guide are taken from previous NRC staff documents and positions regarding submittals for alternative repair criteria. In these special cases, such prescription may be appropriate, but this type of prescriptive guidance in a regulatory guide is inconsistent with the attributes of performance-based regulation.

Should you have questions regarding this matter, we will be pleased to discuss them with you.

l Very truly yours, CHC/GT/ dim l

l

Rules and Directives Branch July 30,1999 Page 3 e

cc: R. S. Fleishman, Esquire Resident inspector,NRC J. E. Silberg, Esquire R. I. McLean, DNR S. S. Bajwa, NRC D. J. Modeen, NEl A. W. Dromerick, NRC J. H. Walter, PSC H. J. Miller, NRC

.