ML18089A313

Comments on NRC Proposed Steam Generator Program Requirements.Secondary Side Visual & full-length Tube Insp Conducted.Chemistry Parameter Control Ranges Used Insufficient Period to Determine Tube Adequacy

ML18089A313
Person / Time
Site:	Salem
Issue date:	08/18/1983
From:	Mittl R Public Service Enterprise Group
To:	Eisenhut D Office of Nuclear Reactor Regulation
References
NUDOCS 8308250276
Download: ML18089A313 (11)

Text

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Public Service Electric and Gas Company P.O. Box 236 Hancocks Bridge, New Jersey 08038 Nuclear Department August 18, 1983 Mr. Darrell G. Eisenhut Director - Division of Licensing U.S. Nuclear Regulatory Commission Washington, D.C. 20555

Dear Mr. Eisenhut:

COMMENTS ON REQUIREMENTS OF THE NRC PROPOSED STEAM GENERATOR PROGRAM As an active member of the Steam Generator Owners Group, we received a copy of the NRC Proposed Steam Generator Program. We have reviewed the potential requirements outlined in the program and offer the following comments:

Item 1.1 - Secondary Side Visual Inspection.

With respect to visual inspection of the secondary side, the Salem Units have performed this one time inspection in accordance with initial guidelines previously developed by the NRC. The one time visual inspection being proposed in this program should there-fore not be repeated for any units which have previously performed such examination according to these initial guidelines.

Item 2.2 - Full Length Tube Inspection.

The requirement for full length tube inspection does not adequately reflect the problems associated with this inspection. The degree of difficulty in perform-ing the inspection is roughly proportional to the tightness of the tube curvature. Such U-bend inspec-tion difficulties include increased probe wear, re-peated entry into the channel head for adjustment or repair of the eddy current testing equipment, or the use of smaller probes which produce less than optimum signals. Though early detection can be enhanced by full length inspection of steam generator tubes, inspection of U-bends from rows 10 through 1 are especially troublesome and will significantly increase the time for inspection as well as the Occupational Radiation Exposure (ORE). At an average cost of Tho l=no.-'"'" o,...,...~1~

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Darrell G. Eisenhut 8/18/83

$15,000 per man rem, this could more than double the costs which factor into the NRC value impact conclu-sions. These costs do not include replacement power costs associated with extended outage time due to this additional inspection.

Because of these difficulties, any new requirements established should allow the utility sufficient flexi-bility to exercise judgement in the selection of tubes requiring full length inspection. For example, re-quired full length inspection should be limited to tube rows where degradation has been observed in previous inspections or in similar tubes in other steam genera-tors of like design, fabrication history and operating environment. Allowances should be made for deleting specific tubes or tube rows after repeated inspections show no signs of degradation.

Item 4.0 - Upper Inspection Ports.

We are in agreement with the NRC proposed deletion of the upper inspection port requirement based on the value impact analysis performed by SAI and on ,subse-quent comments provided by the industry.

Item 6.0 - Secondary Water Chemistry and Condenser Inservice Inspection Programs.

Control of condenser in-leakage is an important item in maintaining proper secondary water chemistry. However, we see no legitimate reason to impose condenser inspec-tions since each utility should determine the means by which it will meet feedwater chemistry limits. Each utility should have sufficient economic incentives to maintain tight condensers. In addition, most utilities have installed full flow demineralizers (thereby main-taining proper secondary water chemistry despite con-denser in-leakage).

The NRC estimated cost impact of $1.3 million over an average 24 year plant life is too low. Direct labor costs to implement these programs would be much higher, probably at least double this cost impact estimate.

We recommend that the NRC proceed with caution in imposing chemistry guidelines as a mandatory require-ment. The existing Stearn Generator owners Group chemistry parameter control ranges have been used for only one year - an insufficient period to determine their adequacy.

Darrell G. Eisenhut 8/18/83 We appreciate the opportunity to comment on these proposed requirements.

Very truly yours,

?/Mr R. L. Mi ttl General Manager -

Nuclear Assurance and Regulation RJT:df CC: Victor Stello, Jr.

Harold R. Denton BA18 1-3

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~:.*~- . MAt~ASER

• r ~EGU!J\TllRY AFF~IRS UUClEF.R ASSUR/.MCE t. nEGt;'.. ?. ilGH PUBLIC SERVICE ELECTRIC AND GAS COMPANY J. G. HEClUiAGEL ENGINEERING AND CONSTRUCTION DEPARTMENT

- AUG 1 7. 1983 NOiED .:-.-*. -. :,>j~:.;-"" * * * * * * * * **.*

REFER TO *.. ~~ J. * .* * * * .... * ...* DATE: July 18, 1983

~OPIES ., *.*. ,... * * * * * * * * * * * * * **.* RESPONSE DUE: July 27, 1983 t=ILE. *oc*.*_.. o:*.-.. .:~.--__- *.* * * * *** ' ** * * *

.. TO: R. R. Bast Gei1G12I Manager .t'""

.General Manager Engineering /.0J])f -~

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. I FROM: T. J. Martin Vice President - Engineering and Constructior;i;; ., "* ,,,.--,.-]

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SUBJECT:

STEAM GENERATOR OWNERS GROUP II (SGOG)

RE: EXECUTIVE COMMITTEE MEETING WITH REFER To __i

~E: EJM NRC STAFF ON JULY 6, 1983 r.2~

The NRC Staff requested a meetin.g with SGOG II anl ~~R~-1---

0 FILE representatives to discuss steam generator tube~rupture events and programs under.taken* by SGOG to resolve and mi ti-gate steam generator problems.

Outstanding unresolved Safety Issues A-3, A-4, and A-5 are a growing concern of the NRC Staff, and they have developed a tentative Staff position to get these issues off the out-standing list. They used this briefing.meeting to piesent the evolving Staff position and are soliciting meaningful comments from SGOG. The spokesman for SGOG agreed to provide comments on proposed program.

Attached*to this memo is a copy of NRC Standard Review Plan Draft, Program Development, the transparency used by the NRC Staff at the meeting, and SGOG II's proposed response and schedule. (SGOG response transparencies were only used at SGOG II owner representatives meeting,held July 13 and 14, 1983.)

After a heated discussion at the Owners Group meeting, it was agreed.that:

1. SGOG had committed to respond to the NRC_p...r...o_p_o__s_e_d_

program and, therefore, a response would have to

. . 'be made .

2. While SGOG represents a good cross section of the industry, it. could not and should not speak for every utility. Should contact AIF on this subject.

The AIF Power Plant Design, Construction and Opera-tions Committee will be advised of these latest developments and secure *industry 1 s comments on entire program. (Joe Williams, Vice President -

Nuclear Energy, Florida Power & Light, was desig-2-02 nated to make contact with the AIF.)

To R. R. Bast 7/18/83 Within these parameters, the owners agreed to the chair preparing a SGOG response which would:

1. Stress the industry initiative taken by the Owners Group to resolve technical problems.

2. Limit comments to the NRC ~n the NRC program to the technical aspects which fall within the scope of the SGOG. If a utility has technical comments to incorporate in this response, send them to ~tan Green, EPRI, by July 29. Stan Green will coordinate and draft a response.

3. Within this framework, provide the NRC with alternate suggestions to meet their technical objectives.

4. Caution. the NRC on the use of SGOG guidelines on water chemistry for regulation purp6ses as this is a guide a*nd has limited field verification"

5. That each SGOG utility provide individual responses to all *aspects of the NRC proposed program* in let-ters to D. Eisenhut, i.e., program procedures, inspection costs, leakage limits, NDE, etc.

(Copies to members of SGOG II by August 8.)

The proposed draft response from the Chairman of SGOG will be sent to each member for his review and immediate comments (i.e., telephone comments, etc.)

Action Required:

• lo Engineering Department to provide me with specific technical written comments to incorporate in SGOG's response.

2. Engl.neering and Nuclear Departments to review planned program and establish PSE&G's position, which should then be submitted to R. L. Mittl, General Manager -

Nuclear Assurance and Regulation, for transmittal to D. Eisenhut.

3. R. L. Mittlshould provide information to R. M. Eckert.

for AIF discussion. 9/r?,*

4. Adherence to time schedule for comments to SGOG Chairman via Stan Green,. EPRI (as soon as possible), and utility comments on entire prog~am directly to the NRC by August 8, 1983.

TJM:bwc

To R. R. Bast 7/18/83

- Attachments:

Standard Review Plan*

Program Development (NRC)

NRC Meeting Transparencies Owners Group Transparencies Owners Group Membership List Owners Group Membership Attendance List CC General Manager - Nuclear Assurance and Regulation/

Consulting Mechanical Engineer

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-J- . .

PUBLIC SERVICE ELECTRIC AND GAS COMPANY NUCLEAR DEPARTMENT DATE: August 4, 1983 RESPONSE DUE:

TO: R. L. Mittl General Manager - Nuclear Assurance and Regulations FROM: D. J. Jagt Asst. General Manager - Nuclear Engineering

SUBJECT:

STEAM GENERATOR OWNERS GROUP II EXECUTIVE COMMITTEE MEETING WITH NRC STAFF ON JULY 6, 1983 Pursuant to the letter from T. J. Martin, dated July 18, 1983 on the above subject, please find attached hereto the comments from the Nuclear Department for transmittal to the NRC before August 8, 1983.

Gei;cral Manager ~-i

/

REFER TO _ _ _ _ i DC tWi RPD COPIES _ _ __,. FILE MRD:edh Attachment CC: Vice President - Engineering and Construction General Manager - Nuclear Support General Manager - Nuclear Operations General Manager - Nuclear Services Manager - Systems Engineering Manager - Nuclear Licensing and Regulation Manager - Nuclear Site Maintenance MAffASER ..

Consulting Mechanical Engineer REGliLATOlW AFFt.lxS M. Bandeira HUCL.Eli.R l.SSUi'\AliCE t. RE6iiL4 m;q A. Graham J. C. F.ECKWAGEL M. Danak FK16 1 NOiEO REi'E'R A~ ~ .'.~

fo:Z'.3.:. .. . ...

83 COPiES ....................... .

UPPER INSPECTION PORTS:

The NRC is right in generically deleting the upper inspection port requirement based on the value impact analysis performed by SAI and subsequent comments from the industry.

Through license change request 82-20 to docket 50-311, PSE&G had requested to delete the license condition C-15.b to the Salem Unit 2 license which required installation of steam generator upper inspection ports. Through amendment 17 to the facility license, the NRC has permitted to delay the installation of the inspection_ ports until the second refueling outage. Now that the NRC has deleted the generic

.. requirement for the inspection ports, we believe and request that the Salem 2 license condition requiring installation of the ports be deleted.

Upper inspection ports are a*minimal value on a generic basis such that a backf it requirement, independent of a plant specific problem, which has not occurred at Salem Units 1 or 2, is not technically justified, or cost effective.* Both Salem Units have been following the secondary side chemistry guidelines developed by the EPRI and Owner's Group and the Salem Unit 2 has been adhering to those guidelines since the initial startup.

SECONDARY SIDE VISUAL INSPECTION:

Salem Units have performed the one time visual inspection of steam generator secondary sides following the-initial guidelines developed by the NRC. Now that the NRC is concluding the steam generator requirements, the one time visual inspection need not be repeated for plants which performed such examination following the initial guideline.

FULL.LENGTH TUBE INSPECTION:

The requirement for full length tube inspection is excessively vague and does not adequately reflect the problems associated with this inspection. The degree of difficulty to perform the inspection and the quality of the eddy current data obtained from the U-bend is roughly proportional to the tightness of the bend radius. Attempts to inspect U-bends from rows 10 on down to row 1 are especially troublesome.

The need.to inspect both hot and cold legs is now well supported by the discovery of new failure mechanisms in the past two or three years. However, straight length portions can be inspected quickly and easily without undue probe wear, FK16 2

2 -

repeated entry into the channel head for adjustment or repair of the ET equipment, or use of reduced - size probes that

• p~oduce less than optimum signals. The only increase in personnel exposure and outage time over existing Tech Spec requirements comes from a one time set-up and disassembly of the probe pushing equipment_ on the cold leg side of the channel head. Essentially complete inspection of a steam generator (100% of ihe tubes) can be performed without.

creating an unusual burden for the Utility if inspections are limited to just the straight length portions.

Need for inspecting U-bends is also well recognized. Because of the difficulty in inspecting the tighter bends and the relative value of the test results, however, any new rules established should provide sufficient flexibility to permit the utility to exercise some judgment in the tubes selected for full length inspection. For instance, required inspection should be limited to tube rows where degradation has been

• observed in previous inspections or on other steam generators of like design, fabrication history and operating environment, and allowances should be made for deleting specific tubes or tube rqws after repeated examinations* show no signs of degradation.

CONDENSER INSERVICE INSPECTION:

Wfth adequate secondary water chemistry control, there should be-no need for the NRC to.become involved with a condenser ISI program. Each Utility should have sufficient economic incentives to maintain tight condensers.

STANDARD REVIEW PLAN 5.4.2.1:

The SRP is a mixture of requirements for design of new plants and o"ld plants. Compliance with current codes, inspection criteria, material properties and design would be difficult and at times impossible for the operating Units.

MRD:edh FK16 3

,, M~NASER

~!GULATOR'r' AFFT\liiS HutLEAR ASSURANCE f, RESv~ilG!t J. C. P.ECKNAGEL

• e PUBLIC SERVICE ELECTRIC AND GAS COMPANY . GeiiClcl Manager ,.;

ENGINEERING AND CONSTRUCTION DEPARTMENT R. L. l'J.!.T.~L ~J

.~Al'" 5 ~983 DATE: August 11, 119ID '--f*-W*H~

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NOiED ** * * * ** *1 RESPONSE DUE:  ;\ i i r-~ ~

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R. L. Mittl RErrn lo COPIES

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RFJ E.JM FILE t2 JCR

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pofl General Manager - N_uclear Assurance and Regulation ~

FROM: R. R. Bast General Manager - Engineering

SUBJECT:

NRC STANDARD REVIEW PLAN FOR STEAM GENERATORS The following conunents supplement those submitted by the

• :Nuclear Department as a PSE&G position on the draft of the

NRC SRP for Stearn Generators *

. We will be glad to discuss the integration of these conunents with you as you finalize the NRC letter.

. ~ ~ GJS/carn *

UIJµ,r attachment

SECONDARY WATER CHEMISTRY AND CONDENSER IN-SERVICE INSPECTION PROGRAM PSE&G has establishea a seconaary water chemistry program equal to or better than the EPRI/SGOG guidance chemistry parameter control ranges. Control of condenser in-leakage is an important item in maintaining this water control.

However, we see no legitimate reason to impose condenser inspection since each utility should determine the means by which it will meet the feedwater chemistry limits.*

The cost impact of 1.3 million dollars for an average 24 year plant life is too low. Direct labor costs to implement these programs would be much higher, probably at least double.

SUPPLEMENTAL AND FULL LENGTH TUBE INSPECTIONS Benefits of early detection can be enhancea by full length inspection of the steam generator tubes. However, the difficulties of complete inspection of the shorter radius "U" bend sections from rows 10 to 1 will increase the ORE

_and time for inspection significantly. At .an average *cost of $15,000 per man rem, this could more than double the ..

- - ~costs in the value impact.: conclusions. ---------* -* - -