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| 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 | | 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 |
| *' . | | *' . |
| * r UUClEF.R ASSUR/.MCE | | * r UUClEF.R ASSUR/.MCE |
| : t. nEGt;' .. ?. ilGH . . J. G. HEClUiAGEL PUBLIC SERVICE ELECTRIC AND GAS COMPANY ENGINEERING AND CONSTRUCTION DEPARTMENT | | : t. nEGt;' .. ?. ilGH . . J. G. HEClUiAGEL PUBLIC SERVICE ELECTRIC AND GAS COMPANY ENGINEERING AND CONSTRUCTION DEPARTMENT |
| -AUG 1 7. 1983 NOiED .:-.-*. -. | | -AUG 1 7. 1983 NOiED .:-.-*. -. |
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| STEAM GENERATOR OWNERS GROUP II (SGOG) RE: EXECUTIVE COMMITTEE MEETING WITH REFER To __i EJM NRC STAFF ON JULY 6, 1983 The NRC Staff requested a meetin.g with SGOG II FILE representatives to discuss steam generator events and programs under.taken* | | STEAM GENERATOR OWNERS GROUP II (SGOG) RE: EXECUTIVE COMMITTEE MEETING WITH REFER To __i EJM NRC STAFF ON JULY 6, 1983 The NRC Staff requested a meetin.g with SGOG II FILE representatives to discuss steam generator events and programs under.taken* |
| by SGOG to resolve and mi gate steam generator problems. | | by SGOG to resolve and mi 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 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: | | 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 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_ | | : 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 tions Committee will be advised of these latest developments and secure *industry 1 s comments on entire program. (Joe Williams, Vice President | | 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 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.) | | -Nuclear Energy, Florida Power & Light, was desig-2-02 nated to make contact with the AIF.) |
| ** " .. To R. R. Bast Within these parameters, the owners agreed to the chair preparing a SGOG response which would: 7/18/83 1. Stress the industry initiative taken by the Owners Group to resolve technical problems. | | ** " .. To R. R. Bast Within these parameters, the owners agreed to the chair preparing a SGOG response which would: 7/18/83 1. Stress the industry initiative taken by the Owners Group to resolve technical problems. |
| : 2. Limit comments to the NRC 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 Green, EPRI, by July 29. Stan Green will coordinate and draft a response. | | : 2. Limit comments to the NRC 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 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. | | : 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 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: | | : 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 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. | | * 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. | | : 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. | | : 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 directly to the NRC by August 8, 1983. TJM:bwc | | 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 directly to the NRC by August 8, 1983. TJM:bwc |
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| ==SUBJECT:== | | ==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 MRD:edh Attachment REFER TO ____i DC RPD tWi COPIES ___ _,. FILE *!' --,.,, ,. / CC: Vice President | | 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 MRD:edh Attachment REFER TO ____i DC RPD tWi COPIES ___ _,. FILE *!' --,.,, ,. / 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 Consulting Mechanical Engineer M. Bandeira A. Graham M. Danak FK16 1 MAffASER .. REGliLATOlW AFFt.lxS HUCL.Eli.R l.SSUi'\AliCE | | -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 Consulting Mechanical Engineer M. Bandeira A. Graham M. Danak FK16 1 MAffASER .. REGliLATOlW AFFt.lxS HUCL.Eli.R l.SSUi'\AliCE |
| : t. RE6iiL4 m;q J. C. F.ECKWAGEL NOiEO ' .. REi'E'R fo:Z'.3.:. . . . . .. COPiES ....................... . | | : t. RE6iiL4 m;q J. C. F.ECKWAGEL NOiEO ' .. REi'E'R fo:Z'.3.:. . . . . .. 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. | | .. 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. |
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Category:CORRESPONDENCE-LETTERS
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[Table view] Category:INCOMING CORRESPONDENCE
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Rept Summarizes Results of Radiological Environ Surveillance Program for 1998 ML18107A2511999-04-27027 April 1999 Submits 30-day Fuel Clad Temp Rept for Salem Generating Station,Units 1 & 2.Rept Describes Changes to Calculated Peak Clad Temp (PCT) for Plant Large & Small LOCA & Small Break LOCA Analyses ML18107A2371999-04-26026 April 1999 Forwards Corrected Response to NRC RAI Re Licensee Request for Change to TS Permissible Enrichment Values for New Fuel Storage.Incorrect Attachment Was Provided with Util 990412 Ltr to Nrc.Encl Supersedes 990412 Submittal ML18107A2631999-04-26026 April 1999 Provides Clarification on Licensing & Design Basis for 125 Vdc Battery Margins for Sgs & HCGS for Meeting SBO & Loca/ LOOP Loading Requirements ML18107A2411999-04-22022 April 1999 Forwards Draft Revised Pages 4.1 & 4.2 of Nuclear Business Unit Emergency Plan for Hope Creek & Salem Generating Stations.Changes Are Noted in Italics ML18107A1841999-04-14014 April 1999 Forwards PSEG Annual Rept for 1998, & PECO Annual Rept for 1998. Stockholders Annual Rept of Each Owner & Cash Flow Statements Showing 1998 Actual & 1999 Projected Cash Flow with Explanation Encl ML18107A1981999-04-12012 April 1999 Responds to 990312 RAI Re Request for Change to TSs Permissible Enrichment Values for New Fuel Storage,Which Was Submitted on 990202 ML18107A1691999-04-12012 April 1999 Forwards Proprietary & non-proprietary Epips,Including Rev 17 to EPIP 807,rev 1 to NC.EP-EP.ZZ-0801(Q) & Rev 2 to NC.EP-EP.ZZ-0806(Q) & Revised EPIPs Table of Contents. Proprietary Info Withheld ML20205K4541999-04-0808 April 1999 Forwards Revised Info Re 990330 NRC Nuclear Power Reactor Licensee Financial Qualifications & Decommissioning Funding Assurance Status Rept ML18106B1491999-04-0505 April 1999 Forwards Drafts of Proposed Changes to Pages 4.1 & 4.2 of Emergency Plan,Which Are Contained on Page 4.2 & Noted in Italics & Underlined ML20205F8981999-03-31031 March 1999 Provides Info Re Status of Decommissioning Funding for LGS, Units 1 & 2,PBAPS,Units 1,2 & 3 & Sgs,Units 1 & 2,per Requirements of 10CFR50.75(f)(1) ML18106B1431999-03-31031 March 1999 Forwards Pse&G Rept on Financial Min Assurance for Period Ending 981231 for Hope Creek,Salem,Units 1 & 2 & Pbaps,Units 2 & 3,IAW 10CFR50.75 ML18107A2201999-03-30030 March 1999 Forwards Final Exercise Rept for 980303,full-participation Plume Exposure Pathway Exercise & 980505-07, full-participation Ingestion Pathway Exercise of Offsite Radiological Emergency Response for Salem & Hope Creek 1999-09-08
[Table view] Category:UTILITY TO NRC
MONTHYEARML18095A4881990-09-17017 September 1990 Requests Regional Waiver of Compliance from Tech Spec 3.6.2.3, Containment Cooling Sys. Waiver Requested in Order to Allow Replacement of Containment Fan Cooler Unit Motor #22 W/O Requiring Plant Shutdown ML18095A4901990-09-13013 September 1990 Provides Supplemental Info Applicable to Clarification of 10CFR50,App R Exemption Request Re Fire Suppression Sys for Panel 335,per NRC Request ML20059E6821990-09-0404 September 1990 Forwards Info Re Temporary Mod to Security Plan Concerning Protected Area.Info Withheld ML18095A4641990-08-31031 August 1990 Forwards Revised Response to NRC Bulletin 88-004 Re Potential pump-to-pump Interaction.Util Pursuing Permanent Solution to Issue & Will Implement Appropriate Permanent Field Change by End of Unit 1 10th Refueling Outage ML18095A4621990-08-31031 August 1990 Provides Revised Response to Generic Ltr 89-13, Svc Water Problems Affecting Safety-Related Equipment. Only HXs Exhibiting Unsatisfactory Test Results Will Be Inspected & Possibly Cleaned ML18095A4431990-08-30030 August 1990 Forwards Salem Generating Station Semiannual Radioactive Effluent Release Rept,Jan-June 1990 & Rev 6 to Odcm. ML18095A4531990-08-30030 August 1990 Forwards RERR-28, Salem Generating Station Semiannual Radioactive Effluent Release Rept for Jan-June 1990 & Revised Odcm.W/O Revised ODCM ML18095A4391990-08-29029 August 1990 Forwards Semiannual Rept Re fitness-for-duty Performance Data for 6-month Period Ending 900630,per 10CFR26.71(d).Rept Includes Testing Results,Random Testing Program Results & Confirmed Positive Tests for Specific Substances ML18095A4421990-08-28028 August 1990 Clarifies 900710 Request for Amends to Licenses DPR-70 & DPR-75,changing Sections I & M.Under Proposed Change,Section I Should Be Changed to Read Section 2.J for License DPR-70 & Section M Changed to Read Section 2.N for License DPR-75 ML20059B6611990-08-22022 August 1990 Confirms That 10 Anchor/Darling Model S350W Swing Check Valves Installed at Plant,Per NRC Bulletin 89-002.All 18 Valves Inspected & Retaining Block Studs Replaced W/Upgraded Matl.No Crack Noted on Any Studs Which Were Replaced ML20059C2861990-08-21021 August 1990 Provides Correction to 900810 Response to Request for Addl Info Re Util Request for Restatement of OL Expiration Dates ML18095A4151990-08-10010 August 1990 Forwards Response to Request for Addl Info Re Reinstatement of OL Expiration Dates Based on Original Issuance of Ols. Advises That Correct Expiration Date for OL Proposed to Be 200418 ML18095A4091990-08-0909 August 1990 Forwards Responses to NRC Comments Re Plant Simulator Certification for 10CFR55.45(b)(2),per 891228 Ltr ML18095A4061990-08-0808 August 1990 Forwards Corrected marked-up Pages for Tech Spec Table 3.3-11 Re Subcooling Margin Monitor & Reactor Vessel Level Instrumentation Sys,Per 900223 Ltr.Administrative Changes Made as Indicated ML18095A3861990-07-30030 July 1990 Forwards Listing of Station Blackout Major Audit Items Resolution Scope,Per Station Blackout Schedule Commitment ML18095A3661990-07-26026 July 1990 Forwards Decommissioning Repts for Hope Creek,Peach Bottom & Salem Nuclear Generating Stations ML18095A3761990-07-26026 July 1990 Forwards Decommissioning Repts & Certification of Financial Assurance for Plants ML18095A3721990-07-24024 July 1990 Forwards Rept & Certification of Financial Assurance for Decommissioning for Plants,Per 10CFR50.75 ML18095A3751990-07-18018 July 1990 Provides Status of Commitments Made to NRC by Util in 900109 Ltr Re NUREG-0737,Item II.D.1,per 900628 Telcon ML18095A3741990-07-18018 July 1990 Provides Supplemental Info Re Facility sub-cooling Margin Monitor ML18095A3611990-07-18018 July 1990 Responds to NRC Bulletin 90-001, Loss of Fill-Oil in Transmitters Mfg by Rosemount. ML18095A3621990-07-18018 July 1990 Forwards Corrected Tech Spec Page 3/4 3-5 for License Change Request 89-12 Submitted on 891227 & 900521 ML18095A3591990-07-13013 July 1990 Corrects Typo in 900702 Response to Generic Ltr 90-04 Re Schedule for Completion of Remaining Open Items ML18095A3471990-07-11011 July 1990 Responds to NRC 900611 Ltr Re Violations Noted in Insp Repts 50-272/90-14 & 50-311/90-14.Corrective Actions:Directive from Radiation Protection Mgt to All Radiation Protection Personnel Issued Re Control of Compliance Agreement Sheets ML18095A3451990-07-10010 July 1990 Forwards Addl Info Re License Change Request 89-03 Re Reactor Trip Sys Instrumentation ML18095A3461990-07-10010 July 1990 Responds to NRC 900608 Ltr Re Violations Noted in Insp Repts 50-272/90-12 & 50-311/90-12.Corrective Actions:Assessment of ECCS & Component Performance Undertaken & ECCS Flow Testing Procedure Upgraded to Address Human Factors ML18095A3491990-07-10010 July 1990 Forwards Jn Steinmetz of Westinghouse 900614 Ltr Re Reassessment of Util Response to Bulletin 88-002 ML18095A3481990-07-10010 July 1990 Submits Supplemental Rept Identifying Root Cause of Missed Commitment & Corrective Actions to Assure Future Compliance Re Implementation of Mods to Facility PASS ML18095A3441990-07-0909 July 1990 Provides Written Notification Re Change in Calculated Peak Clad Temp,Per 900606 Verbal Notification ML18095A3281990-07-0202 July 1990 Responds to NRC 900530 Ltr Re Violations Noted in Insp Repts 50-272/90-09 & 50-311/90-09.Corrective Actions:Util Intends to Use Nuclear Shift Supervisor as Procedure Reader & EOP, Rev 2 Under Development ML18095A3301990-07-0202 July 1990 Responds to Generic Ltr 90-04 Re Status of Licensee Implementation of Generic Safety Issues.Table Describing Status of Generic Safety Issue Implementation Encl ML18095A3391990-06-29029 June 1990 Forwards Correction to 890913 License Change Request 88-09, Consisting of Tech Spec Page 3/4 4-13 ML18095A3221990-06-28028 June 1990 Provides Supplemental Info Re 900223 Proposed Revs to Tech Specs for Reactor Vessel Level Instrumentation Sys.Tables 3.3-11a & 3.3-11b Should Be Combined Into Single Table ML18095A3231990-06-28028 June 1990 Responds to NRC 900518 Ltr Re Violations Noted in Insp Repts 50-272/90-10,50-311/90-10 & 50-354/90-07.Two Noncited Violations Disputed.Util fitness-for-duty Program Exceeds Part 26 Requirements for Positive Blood Alcohol Limits ML18095A3241990-06-28028 June 1990 Forwards Retyped Pages to 871224 License Change Request 87-15 & Modified,Per 900620 Ltr ML18095A3211990-06-26026 June 1990 Requests 30-day Extension Until 900730 to Provide Completion Schedule to Resolve Audit Findings Re Station Blackout ML18095A3161990-06-25025 June 1990 Forwards Supplemental Info Re Response to Generic Ltr 88-14. All Committed Actions Complete as of 900613 ML18095A3141990-06-25025 June 1990 Provides Schedule Change for Implementation of Control Room Mods.Schedule Modified to Address Overhead Annunciator Human Engineering Discrepancies During Phase III ML18095A3201990-06-25025 June 1990 Responds to NRC 900524 Ltr Re Violations Noted in Insp Repts 50-272/90-11 & 50-311/90-11.Corrective Actions:All Overdue Operations & Maint Procedure Files Reviewed for Outstanding Rev Requests & Procedure Upgrade Program Initiated ML18095A3001990-06-20020 June 1990 Provides Addl Info Re Application for Amend to Licenses DPR-70 & DPR-75 Concerning Turbine Valve Surveillance Interval,Per 900320 Request.Util Adding Direction to Personnel If Unnacceptable Flaws Found ML20043H6221990-06-20020 June 1990 Provides Supplemental Info Re NRC Bulletin 88-008 for Fifth Refueling Outage.Detailed Test Rept Being Prepared to Document Results of Each Individual Insp Re Insulation, Hangers & High Energy Break Areas ML18095A2991990-06-20020 June 1990 Forwards Westinghouse Affidavit Supporting 900412 Request for Withholding Proprietary Info from Public Disclosure Per 10CFR2.790 ML18095A2721990-06-0808 June 1990 Responds to NRC 900329 Ltr Re Weaknesses Noted in Insp Repts 50-272/90-80 & 50-311/90-80.Corrective Actions:Fire Doors Placed on Blanket Preventive Maint Work Order & Damaged Fire Doors Will Be Repaired Immediately ML18095A2711990-06-0606 June 1990 Submits Info in Support of 900522 Verbal Request for Relief from Requirements of ASME Section XI ML18095A2611990-06-0101 June 1990 Forwards Corrected Operating Data Rept, Page for Apr 1990 Monthly Operating Rept ML18095A2521990-06-0101 June 1990 Forwards Application in Support of Request for Renewal of NJPDES Permit NJ0005622,per Requirements of Subsection 3.2 of Plant Environ Protection Plan,Nonradiological ML18095A2591990-06-0101 June 1990 Forwards Corrected Unit Shutdown & Power Reductions, Page for Apr 1990 Monthly Operating Rept ML18095A2411990-05-30030 May 1990 Submits Special Rept 90-4 Addressing Steam Generator Tube Plugged During Fifth Refueling Outage.Plugging Completed on 900516.Cause of Tube Degradation Attributed to Normal Wear Due to Erosion/Corrosion Factors ML18095A2431990-05-30030 May 1990 Informs of Util Plans Re Facility Cycle 6 Reload Core, Expected to Achieve Burnup of 16600 Mwd/Mtu.All Postulated Events within Allowable Limits Based on Review of Basis of Cycle 6 Reload Analysis & Westinghouse SER ML18095A2531990-05-29029 May 1990 Provides Addl Info Re End of Life Moderator Temp Coefficient.Feedback Used in Steam Line Break Has No Relationship to Full Power Moderator Density Coefficient 1990-09-04
[Table view] |
Text
- I( _,-*.
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 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 ing the inspection is roughly proportional to the tightness of the tube curvature.
Such U-bend inspec-tion difficulties include increased probe wear, 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.-'"'"
8308250276 830818 PDR ADOCK 05000272 G PDR. 95-2168(SOM)11-82 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 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 bility to exercise judgement in the selection of tubes requiring full length inspection.
For example, 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 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 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 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 taining proper secondary water chemistry despite 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 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
- t. nEGt;' .. ?. ilGH . . J. G. HEClUiAGEL PUBLIC SERVICE ELECTRIC AND GAS COMPANY ENGINEERING AND CONSTRUCTION DEPARTMENT
-AUG 1 7. 1983 NOiED .:-.-*. -.
- * * * * * * * **.* REFER TO * .. J. * .* * * * .... * ...*
., *.*. ,... * * * * * * * * * * * * * **.* t=ILE. *oc*.*_. .. o:*.-..
- DATE: July 18, 1983 RESPONSE DUE: July 27, 1983 .. TO: R. R. Bast .General Manager Engineering Gei1G12I Manager .t'"" . I /.0J])f -
FROM: T. J. Martin Vice President
-Engineering and Constructior;i;;
., "* ,,,.--,.-] .Ju 1-. i ':J 1::::t:*0
SUBJECT:
STEAM GENERATOR OWNERS GROUP II (SGOG) RE: EXECUTIVE COMMITTEE MEETING WITH REFER To __i EJM NRC STAFF ON JULY 6, 1983 The NRC Staff requested a meetin.g with SGOG II FILE representatives to discuss steam generator events and programs under.taken*
by SGOG to resolve and mi 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 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 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 Within these parameters, the owners agreed to the chair preparing a SGOG response which would: 7/18/83 1. Stress the industry initiative taken by the Owners Group to resolve technical problems.
- 2. Limit comments to the NRC 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 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 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 directly to the NRC by August 8, 1983. TJM:bwc
- .. ' .. To R. R. Bast -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 7/18/83
' l.* *; ..... ' .. -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 MRD:edh Attachment REFER TO ____i DC RPD tWi COPIES ___ _,. FILE *!' --,.,, ,. / 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 Consulting Mechanical Engineer M. Bandeira A. Graham M. Danak FK16 1 MAffASER .. REGliLATOlW AFFt.lxS HUCL.Eli.R l.SSUi'\AliCE
- t. RE6iiL4 m;q J. C. F.ECKWAGEL NOiEO ' .. REi'E'R fo:Z'.3.:. . . . . .. 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
- 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
.. , .. . ,_:,-,,
- AFFT\liiS HutLEAR ASSURANCE f,
NOiED ** * * * ** *1 REr!R *...
COPiES **************.*****.***
.. .-:*-*-******-*:*" *"'\-'.':'
..
- .. I ** ' ** TO: PUBLIC SERVICE ELECTRIC AND GAS COMPANY .. GeiiClcl Manager ,.; ENGINEERING AND CONSTRUCTION DEPARTMENT R. L. DATE: RESPONSE DUE: August 11, 1 1 9ID
- \ i i l RErrn lo ---i DE
- E.JM t2 RFJ JCR R. L. Mittl COPIES FILE *-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 24 year plant life is too low. implement these programs would at least double. dollars for an average Direct labor costs to be much higher, probably 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 .. --
in the value impact.: conclusions.
*
-* --