ML18093B067

IMC 0327 Steam Generator Tube Primary-to-Secondary Leakage

ML18093B067
Person / Time
Issue date:	11/01/2018
From:	Andrea Johnson NRC/NRR/DMLR/MCCB
To:
Johnson A
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ML18094A253, ML18304A287	List:
References
CN 18-037, DC 18-008
Download: ML18093B067 (13)

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Issue Date: 11/01/18 1 0327 NRC INSPECTION MANUAL MCCB INSPECTION MANUAL CHAPTER 0327 STEAM GENERATOR TUBE PRIMARY-TO-SECONDARY LEAKAGE Effective Date: January 1, 2019 0327-01 PURPOSE To provide guidance to inspectors on overseeing pressurized water reactors (PWRs) with known steam generator (SG) tube primary-to-secondary leakage. 0327-02 OBJECTIVE To assist inspectors in assessing licensee actions taken in response to SG tube primary-to-secondary leakage. 0327-03 APPLICABILITY This manual chapter is applicable to any PWR with SG tube primary-to-secondary leakage. 0327-04 DEFINITIONS There are no special definitions in this manual chapter. 0327-05 RESPONSIBILITIES AND AUTHORITIES 05.01 Director, Division of Inspection and Regional Support (DIRS). Establishes and monitors the execution of the inspection program feedback process. 05.02 Chief, Reactor Inspection Branch (IRIB). Responsible for periodic updates to IMC 0327. 05.03 Chief, Chemical, Corrosion, and Steam Generator Branch (MCCB). Responsible for the content of IMC 0327. 0327-06 REQUIREMENTS There are no requirements in this document. This document is for guidance only.

Issue Date: 11/01/18 2 0327 0327-07 GUIDANCE 07.01 Background While SG tubes often leak (i.e., experience ligament rupture of part through-wall degradation) before they burst (i.e., experience unstable failure) this is not always the case, and the possibility exists for burst with little or no observed leakage. For the cases where primary-to-secondary leakage can be detected, licensees have an opportunity to prevent tube burst by detecting primary-to-secondary leakage early and taking corrective action, such as plugging or sleeving. Routine leakage monitoring with adequate shutdown limits can afford early detection and response to increasing leakage and thereby serve as an effective means for reducing the probability of SG tube burst. Having near-real-time leakage information available to control room operators, along with appropriate alarm set points and corresponding action levels, can help operators promptly and appropriately respond to a developing situation. 07.02 Sources of Primary-to-Secondary Leakage Primary-to-secondary leakage is ordinarily caused by degraded tubes, plugs, or sleeves. To determine possible sources of leakage, it is important to review what is known about the component materials and condition of the SGtest SG Tube Inspection Report(s) should provide details regarding the condition of the SGs and the existing degradation mechanisms. Although operating experience may provide insights as to possible sources of degradation, sources of leakage cannot be reliably identified while the reactor is in operation. Therefore, leakage should be treated in accordance with available guidance. Components fabricated from mill-annealed Alloy 600 (600MA) are highly susceptible to environmentally assisted degradation processes, such as outside diameter stress corrosion cracking (ODSCC) and primary water stress corrosion cracking (PWSCC). In plants with 600MA tubing, leakage is more likely due to an environmentally assisted corrosion process (e.g., ODSCC or PWSCC) or a repair process that exhibits some leakage (e.g., leak-limiting sleeves or plugs). In contrast, mechanical degradation due to wear, fatigue cracks from vibration, and damage from loose parts are the most probable causes of leakage in plants with thermally treated Alloy 600 (600TT) and Alloy 690 (690TT) tubing, but these forms of degradation can also contribute to leakage in older plants with 600MA tubing. The operating experience with 600TT and 690TT components has been significantly better than the operating experience with Alloy 600MA, especially with regard to environmentally assisted degradation. To date, there has been only a limited amount of environmentally assisted degradation in 600TT components and there has been no known environmentally assisted degradation in 690TT components. Cracking has been reported for some Westinghouse plugs manufactured out of Alloy 600TT. Industry experience with flawed plugs is discussed in NRC Information Notice (IN) 94-87, and NRC Bulletin 89-01, including two supplements. Most licensees have replaced the Alloy 600TT plugs with Alloy 690TT plugs. It is also possible to have flaws in the welds that are used to install tube sleeves, and some sleeve designs are leak-limiting rather than leak-tight.

Issue Date: 11/01/18 3 0327 07.03 Leakage Detection Methods Most plants have radiation monitoring systems that monitor condenser off-gas, SG blowdown, and the main steam lines. The condenser off-gas is monitored to identify the presence of radioactive gases removed from steam condensate. The SG blowdown is monitored to identify non-volatile radioactive species in the SG bulk water (excluding once-through SGs). The main steam lines are monitored to detect volatile gases, and in some cases Nitrogen 16 (N-16), carried from the SGs via the main steam lines. Grab samples are also commonly used, such as: reactor coolant samples (to quantify the source term), SG blowdown samples (to detect non-volatile radioactive species in liquid), and condenser off-gas samples (to detect noble gas and other volatile species removed from steam condensate). Other common grab samples include condensed main steam (to detect noble gas and other volatile species carried over with main steam) and condensate (to detect soluble species such as tritium and iodine). In addition, blowdown filters and ion exchanger columns are used to detect particulates and ionic species from liquid streams. Although no single monitor should be expected to fulfill all monitoring roles, some monitoring methods have demonstrated particular value in certain situations. Continuous control room display of key radiation monitor trends (e.g., SG blowdown, condenser exhaust, N-16 monitor of leak rate and change in leak rate over time) gives operators real-time information that can be used to respond safely to the full range of primary-to-secondary leakage. Use of N-16 monitors installed on or near steam lines has become increasingly common in the industry as a supplemental means of monitoring leakage. These monitors exhibit short time response to changes in leak rate and are very useful to operators, provided their limitations are understood. However, the short half-life for N-16 presents some problems in the ability of the detector to measure leak rate. Changes in power level and characteristics of the leak itself (location and type of leak) will affect the N-16 concentration reaching the detector. Once the reactor trips, N-16 quickly decays and no longer provides a radionuclide source for measuring leakage. Also, due to the high energy of the gamma rays emitted by N-16 decay, detectors may be affected by nearby steam lines in addition to the one they are mounted to. This can make it difficult to estimate total leakage or apportion leakage among the SGs based on N-16 alone. It is prudent for the monitoring program to include provisions for detection of primary-to-secondary leakage during low power or plant shutdown conditions. This program should ensure that means are available to detect SG tube leakage whenever primary system pressure is greater than secondary system pressure, including hot shutdown and plant startup, when normal means of detecting leakage might be limited or unavailable. For instance, the radionuclide mix is altered following plant shutdown so condenser off-gas monitors may be questionable during startup, since they are calibrated for a specific radionuclide mix, based on power operation. In addition, N-16 monitoring is not considered reliable at low power since lower levels of N-16 are available to trigger detector response during a tube leak. Plants spend a relatively small fraction of time in low power or hot shutdown conditions; however, it is prudent to have techniques and procedures available to detect a rapidly developing leak under those conditions. If a tube leak develops, operators should have reasonable time to respond to the situation before the plant reaches full power operation, when the consequences of a tube leak would be magnified.

Issue Date: 11/01/18 4 0327 The technical specifications include a limiting condition for operation limit with respect to the allowable primary-to-secondary leak rate, beyond which a prompt and controlled shutdown must be initiated. The limit is unit-specific, but it is no greater than 568 liters per day (150 gallons per day (gpd)) through any one SG. Guidance to the industry is provided by the Electric Power Research Institute (EPRI) in Steam Generator Management Program: PWR Primary-To-Secondary Leak Guidelines Revision 4(ADAMS Accession No. ML12065A095 Non-proprietary; ML15098A475 Proprietary). Detection capability and measurement uncertainties are discussed in the guidance, as well as the characteristics of certain monitoring methods. This is useful to licensees in determining the adequacy of specific parts of their monitoring system and the effectiveness of the combination of methods used. 07.04 Guidance from Industry SG Initiative The industry currently relies on industry-developed guidelines to evaluate the significance of primary-to-secondary SG tube leakage. In the fall of 1997, the Nuclear Strategic Issues Advisory Committee, a committee consisting of the chief nuclear officers from the nuclear utilities, voted to adopt NEI 97-Guidelines. (Revision 3 ADAMS Accession No. ML111310708). This commitment is in the form of an industry initiative and is an internal commitment between NEI members to take the agreed upon position. The industry informed the NRC by NEI letter dated December 16, 1997, of their commitment to implement the industry SG initiative described in NEI 97-06. Each licensee committed to evaluate its existing SG program and where necessary, revise and strengthen program attributes to meet the intent of the guidance provided in NEI 97-06, by no later than the first refueling outage starting after January 1, 1999. In accordance with NEI 97-06, the SG management programs must address primary-to-secondary leak monitoring. Since adopting NEI 97-06, the industry has used the EPRI Steam Generator Management Program: PWR Primary-To- to assist in developing plant-specific procedures to manage small amounts of leakage within the context of their SG management program. The guidelines address management considerations, monitoring methods and equipment, leak rate calculations, operational response and data evaluation. The guidelines were developed in a manner observed leakage experience, and are intended to reduce the probability of tube ruptures under normal and faulted conditions. The current version of the EPRI Steam Generator Management Program: PWR Primary-To-Secondary Leak Guidelines Revision 4 was implemented in July 2012. The guidelines direct the licensee to implement a monitoring program that accounts for plant design, SG tube degradation, and previous leakage experience. In addition, these guidelines recommend action levels defined by limits on the leak rate and the rate of change of the leak rate. The action levels provide a framework that licensees can use to formulate preplanned operator actions based on specified leakage indications. The objective for the normal operating leak rate limit or rate of change limit is to establish a reasonable likelihood that the plant is shut down before the tube could burst under either normal or faulted conditions. The operating leakage experience, together with the analytically based burst pressure versus normal operating leak rate trends, provide the bases for a recommended leakage limit.

Issue Date: 11/01/18 5 0327 07.05 Assessing the Significance of the Leakage The EPRI Steam Generator Management Program: PWR Primary-To-Secondary Leak Guidelines Revision 4use various operating conditions, leakage-assessment methodologies, radiation-monitoring conditions, and leakage-monitoring conditions, to assess the significance of SG primary-to-secondary leakage and direct appropriate actions. Specific conditions and actions are listed in Section 3 of these guidelines, some of which are listed below. Section 3.2.1 lists four operating conditions for which station-based actions are required, based on SG primary-to-secondary leakage: Modes 3 and 4: The period of operation during plant heatup or cooldown Mode 1 and 2 Non-Steady State: The period of operation during reactor startup, shutdown, or low power operations outside the site-specific definition of steady-state operation Steady State Power Operations: The Mode 1, steady-state plant condition, as defined in site-specific documents Power Transients: The period of operation with power transients outside the site-specific definition of steady-state operation that is not associated with startup The specific operating modes listed above are defined by plant technical specifications or other regulatory guidance. Section 3.2.2 lists two radiation-monitoring conditions: Continuous Radiation Monitor: This condition is when there are one or more radiation monitors available, which meet the following requirements: - Continuous operation with an alarm function available in the Control Room, AND - The monitor is capable of detecting leakage of 30 gpd and higher, AND - The monitor output is correlated to gpd for continuous monitoring. No Available Continuous Radiation Monitor: This condition is when there are no continuous radiation monitors. Section 3.2.3 lists two leakage-monitoring conditions and three action levels, for plant actions based on observed primary-to-secondary leakage: Normal Monitoring: The condition in which detected leakage is less than 5 gpd Increased Monitoring: The condition in which leakage has been detected but is not in a range that can be accurately monitored by most online radiation monitors, does not necessarily indicate imminent risk to steam generator tube integrity, but warrants additional attention Issue Date: 11/01/18 6 0327 Action Level 1: The plant condition in which leakage has increased to a condition that requires frequent monitoring by the radiation monitoring system with periodic benchmarking by laboratory analyses Action Level 2: The plant condition in which leakage has increased to a condition indicating that the underlying flaw has grown to an undesirably large size and it is mandatory that the unit be shut down in a planned manner Action Level 3: The plant condition, which indicates that the leakage is increasing rapidly and it is mandatory that the unit be promptly shut down to protect the unit from tube rupture Section 3.3 lists two leakage-assessment methodologies that can be used to respond to primary-to-secondary leakage during power operation: Constant Leakage: Under the constant leakage methodology, site specific procedures and expectations are developed, which ensure Action Levels are implemented based only on leakage rate. Rate of Change: Under the rate of change methodology, site-specific procedures and expectations are developed, which ensure Action Levels are implemented based on an evaluation of the leakage rate and the rate of change in leakage. There are many possible actions that licensees are directed to take in response to SG primary-to-secondary leakage; see the EPRI Steam Generator Management Program: PWR Primary-To-Secondary Leak Guidelines Revision 4 for specific recommended actions based on specific plant conditions. Based on historical operating experience, it is suggested that the NRC resident inspectors and regional staff use an informal screening criteria of 3 gpd or greater for increased involvement by NRC headquarters staff when SG primary-to-secondary leakage is identified. This is not meant to be an absolute threshold, because there may be instances where something unusual about the leakage, or other conditions, warrant the region wanting headquarters staff involvement before leakage reaches 3 gpd. If a licensee reports levels of primary-to-secondary leakage exceeding 3 gpd to the resident inspector or regional staff, the Division of Operating Reactor Licensing (DORL) in the Office of Nuclear Reactor Regulation (NRR) should be informed. The DORL project manager will inform the Chemical, Corrosion, and Steam Generator Branch (MCCB) staff. Key items the MCCB staff are concerned about include: 1. The rate of change of the leakage, to assess how quickly the situation is changing 2. Whether the leakage rate has been confirmed by two independent radiation monitors (i.e., trend in the same direction with the same order of magnitude). 3. Whether the licensee primary-to-secondary leak monitoring program has a well-documented set of policies and procedures that are being used to respond to the leakage event 4. Whether there is any plant history that provides insight into the cause of the primary-to-secondary leak Issue Date: 11/01/18 7 0327 When leakage exceeds 3 gpd, parameters that inspectors can consider in assessing the significance of the leakage are the effectiveness of licensee procedures, equipment, and practices for monitoring and responding to primary-to-secondary leakage. For example, the adequacy of procedures and equipment, to provide real-time information on leak rate and its rate of change, could be assessed. The appropriate setting of alarm set points on the radiation monitors that are used for detecting primary-to-secondary leakage (e.g., condenser air ejector, N-16) to alert operators of any increasing leak rate could be assessed. In addition, the adequacy of emergency operating procedures, availability of systems and components, and operator training for response to SG tube ruptures could also be assessed. Inspection activities associated with primary-to-secondary leakage are walk downs, and IP 71111.or technical decision making activities and to pursue any operability concerns. Note: The NRR staff occasionally receives notification of extremely low levels of leakage (e.g., <1 gpd). Tof NRR staff with the licensee. This is because many plants have experienced this level of leakage during a full cycle, and it is difficult to determine the source of the leakage at that level. Often, small levels of leakage will persist for the rest of the operating cycle for some plants. While these small levels of leakage do not require increased interaction by NRR staff, the licensee still needs to evaluate and attempt to determine the source of the leakage. The following section discusses some of the typical questions that inspectors can pursue with the licensee when leakage is reported. The MCCB staff is available if further support is needed. 07.06 Questions to Gain Additional Information about the Leakage Questions should focus on how the licensee is monitoring the leakage, evaluating the potential sources of leakage, and what the past inspection results and in-situ testing information tell them about the condition of their SGs. It is useful for the inspector to understand how the licensee detected the leakage, and what the leakage history for this unit (and the specific SG) was for previous outages. There are various advantages and disadvantages of various monitoring techniques, which can affect the quantity of leakage reported. After shutdown, the licensee may observe evidence of leakage from post-shutdown visual inspections of the tubesheet face. Additional information may be available from secondary-side leak tests performed early during outages to identify leaking tubes. To conduct these tests, nitrogen pressure is applied to the water inventory in the secondary side of the SGs and maintained for an extended period (often for days). If the visual inspections reveal any observed dampness or drops of water from the tubesheet face, tubes in that area need to be evaluated carefully with appropriate inspection methods. Sometimes plants experience very low levels of leakage with no clear cause identified. Small changes in low levels of leakage can be due to changes in monitoring equipment, either putting new equipment in service or recent calibrations of the existing equipment. In the past, the staff was informed of small changes of observed leakage that directly correlated to putting new detection equipment in service. This led to a step increase in the very small amount of leakage Issue Date: 11/01/18 8 0327 observed. This could also be observed after calibrating equipment, or any other major change that would reset the baseline readings. The inspector should recognize that although reliable identification of the leakage source is not possible while the plant is operating, insights might be obtained by discussing with the licensee the SG tube examination findings from the eddy current testing during the last outage, in-situ The inspector can ascertain information on the degradation modes being experienced by the SGs. For example, tube wear from anti-vibration bars (AVB) can have a significant through-wall extent, even in replaced SGs that have not been in service many years. Plants have qualified sizing techniques for AVB wear, so indications of wear are sometimes left in service for the next operating cycle. For any reported active degradation modes, the inspector can ask the licensee about in-situ pressure test results from previous outages. If the licensee had trouble satisfying the performance criteria of the in-situ pressure test, it may indicate that the flaws were deeper than sized by the SG eddy current tests. Some plants also have known loose parts in the affected SG that they have not been able to retrieve, which they have identified through techniques such as FOSAR (foreign object search and retrieval). In some cases, the licensees will plug tubes around a loose part that they are unable to retrieve, to reduce the chance of tube rupture from the loose part during the next cycle. It should also be noted that it is not practical for licensees to shut down plants at low levels of leakage. In fact, sustained leakage below 10 gpd in some older plants with 600MA tubing is not unusual. As noted above, when plants shut down, leakage tests are used to identify leaking tubes. Some plants that shut down with low leakage levels found it very difficult to determine the source of the leakage. with low levels of known primary-to-secondary leakage is limited. In summary, obtaining background information about operating and inspection experience may provide useful insights regarding the significance of ongoing primary-to-secondary leakage. Because reliable identification of the leakage source is difficult while the plant is operating, the conservative manner by monitoring the leakage and being prepared to implement plant shutdown, consistent with EPRI guidelines. 0327-05 NRC Generic Communications and Regulatory Guidance a. USNRC IN 94-87: Alloy 600 Used for Westinghouse Mechanical Plugs for Steam Generator Tubes, (December 1994) b. USNRC IN 94-43-to-Secondary Steam Generator Leak c. USNRC IN 91-43 Increases in Primary-to- d. USNRC Bulletin 89-01 Issue Date: 11/01/18 9 0327 e. USNRC Regulatory Guide 1.97-Water-Cooled Nuclear Power Plants to Assess Plant and Environs Conditions During and Following an f. USNRC Regulatory Guide 1.45 Table 1 provides a summary of forced outages from 1990 to 2014, due to SG tube leaks. References to NRC documents that contain more information about the events are provided for many of the events listed in Table 1. Table 1: Tube Leak Forced Outages at US PWRs Plant Name (Tube Material) Date Leak Rate (gpd) Cause Reference St. Lucie 1 (600MA) Jan. 1990 3 Foreign Object TMI 1 (600MA) Mar. 1990 1440 Fatigue NRC IN 91-43 Millstone 2 (600MA) May 1990 Cracked Plug North Anna 2 (600MA) Aug 1990 40 Cracked Plug Oconee 2 (600MA) Nov. 1990 130 Fatigue Shearon Harris (600MA) Nov. 1990 50 Loose Part Maine Yankee (600MA) Dec. 1990 1440 PWSCC NRC IN 91-43 San Onofre 1 (600MA) Apr. 1991 150 Sleeve Joint Event Notification20860 Millstone 2 (600MA) Apr. 1991 70 U-bend SCC Preliminary Notification (PN) 1-91-030 Millstone 2 (600MA) May 1991 70 Tube Sheet Circumferential Crack EN 21077 McGuire 1 (600MA) Jan. 1992 250 Freespan Crack PN 2-91-002 NRC IN 94-62 Issue Date: 11/01/18 10 0327 Plant Name (Tube Material) Date Leak Rate (gpd) Cause Reference ANO 2 (600MA) Mar. 1992 360 Tube Sheet Circumferential Crack PNs 4-92-018, 081A, EN 22975 NRC INs 92-80 & 94-62 Prairie Island 1 (600MA) Mar. 1992 144 Roll Transition Zone Axial Crack McGuire 1 (600MA) May 1992 5 Stress Corrosion Cracking Morning Report (MR) 3-92-0255, PN 23400 Prairie Island 1 (600MA) Sep. 1992 187 Likely Inter-granular stress corrosion cracking (IGSCC) MR 3-92-0255, PN 3-92-048 McGuire 1 (600MA) Nov. 1992 250 Trojan (600MA) Nov. 1992 200 Sleeve Weld Circumferential Crack PN 5-92-035, EN 24569 Palo Verde 2 (600MA) Mar. 1993 240 Upper Bundle Freespan IGSCC PN 5-93-009, -009A, -009B, 009C, -009D, EN 25255, NRC INs 93-56, 94-43 & 94-62 Kewaunee (600MA) Jun. 1993 100 Leaking Plug MR 3-93-0167 McGuire 1 (600MA) Aug. 1993 185 - 200 Sleeve Failure PN 2-93-038, EN 25990, NRC INs 94-05 & 94-43 Palo Verde 3 (600MA) Sept 1993 Freespan crack MR 5-93-0066, PN 5-93-017 McGuire 1 (600MA) Oct 1993 185 Circumferential crack in sleeved tube PN 2-93-053 Braidwood 1 (600MA) Oct. 1993 300 Freespan Cracks PN 3-93-061, NRC Information Notice 94-62 Issue Date: 11/01/18 11 0327 Plant Name (Tube Material) Date Leak Rate (gpd) Cause Reference San Onofre 3 (600MA) Nov. 1993 50 Loose parts degradation and leaking welded plugs MR 5-93-0081, PN 5-93-020 Farley 2 (600MA) Nov. 1993 MR 2-93-0132 Licensee Event Report (LER) 364/1993-003 McGuire 1 (600MA) Jan. 1994 100 Leaking Sleeve PN 2-94-003, EN 26665 Oconee 3 (600MA) Mar. 1994 144 Fatigue PN 2-94-014, EN 26967 S. Texas 1 (600MA) Mar. 1994 160 Leaking Plug PN 4-94-005A, EN 26859 Zion 2 (600MA) Mar. 1994 1440 Tubesheet Crevice Inter Granular Attack Outside Diameter EN 26901 Oconee 2 (600MA) Jul. 1994 144 Fatigue PN 2-94040 Maine Yankee (600MA) Jul. 1994 50 Circumferential Crack PWSCC MR 1-94-0079, EN 27587, NRC IN 94-88 Zion 1 (600MA) Feb. 1996 Foreign object PN 3-96-009 Byron 2 (600TT) Aug. 1996 120 Loose Part PN 3-96-049, MR 3-96-0106 Vogtle 1 (600TT) May 1996 Foreign object PN 2-96-041, EN 30555 ANO 2 (600MA) Nov. 1996 65 Axial Crack PN 4-96-061, EN 31344 McGuire 2 (600MA) June 1997 66 ODSCC at TSP PN 2-97-033 Oconee 1 (600MA) Nov. 1997 400 2 Welded Plugs PN 2-97-065, -065A, EN 33458 Issue Date: 11/01/18 12 0327 Plant Name (Tube Material) Date Leak Rate (gpd) Cause Reference Farley 1 (600MA) Dec. 1998 90 2 Freespan Cracks LER 3481998007 Indian Point 2 (600MA) Feb. 2000 210,240 146 gallons per minute U-bend Crack EN36695, NRC IN 2000-09 Byron 2 (600TT) June 2002 80 Loose Part NRC IN 2004-10 Comanche Peak 1 (600MA) Sep 2002 52 Axial ODSCC Crack in the U-bend NRC IN 2003-05 Palo Verde 2 (690TT) Feb 2004 11 Fabrication Damage (Packaging Screw) PN IV-4-007, NRC IN 2004-16 Harris (690TT) May 2004 10 Loose Part NRC IN 2004-17 Arkansas Nuclear One 2 (690TT) Mar 2005 30 Loose Part NUREG-1841 San Onofre 3 (690TT) Jan 2012 >75 gpd Tube-to-tube Wear PN IV-12-003 Augmented Inspection Team Report (ML12188A748) HB Robinson 2 (600TT) Mar 2014 38 Loose Part PN II-14-004, NUREG-2188 END Issue Date: 11/01/18 Att1-1 0327 Attachment 1 Revision History for IMC 0327 Commitment Tracking Number Accession Number Issue Date Change Notice Description of Change Description of Training Required and Completion Date Comment Resolution and Closed Feedback Form Accession Number (Pre-decisional, Non-public Information) 10/11/2001 Initial issuance as TG 9900 Tube Primary-to- ML032661079 09/09/2003 CN 03-033 Revision to remove inspector actions for leakage greater than 3 gallons per day. The inspector actions have been moved to IP 71111.08, Inservice Inspection Activities. Section 9900 is only for inspector guidance. ML18093B067 11/01/18 CN 18-037 Tube Primary-to-IMC 0327. References to Primary-To-within this document were revised from Revision 2 to Revision 4. Extensive changes were made to this document, because of the multiple revisions that had occurred to the referenced EPRI guidelines. As this is a technical guidance document, there are no inspection requirements contained within it and this document. None ML18094A274 9900-2273 ML18109A204