ML20029D825

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Comment Supporting Elimination of Proposed 5-yr Implementation Schedule & Believes That Current Programs Adequate to Maintain Containment Integrity
ML20029D825
Person / Time
Site: North Anna  Dominion icon.png
Issue date: 04/29/1994
From: Bowling M
VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.)
To:
NRC OFFICE OF THE SECRETARY (SECY)
References
FRN-59FR979, FRN-61FR41303, RULE-PR-50 59FR979-00022, 59FR979-22, AC93-2-026, AC93-2-24, AC93-2-25, AC93-2-26, NUDOCS 9405100158
Download: ML20029D825 (3)


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April 29, 1994 BRirhUll Secretary of the Commission Serial No.94-051 l U.S. Nuclear Regulatory Commission NL&P/GSS R0 Attn: Docketing and Service Branch Washington, D.C. 20555 Gentlemen:

COMMENTS ON PROPOSED RULE CODES AND STANDARDS l SUBSECTIONS IWE AND IWL l in the January 7,1994 Federal Register, the NRC requested comments on the proposed rule to amend its regulations to incorporate the 1992 Edition of the ASME Code with the 1992 Addenda of Subsections IWE, " Requirements for Class MC and Metallic Liners for Class CC Components of Light-Water Cooleo Power Plants" and IWL, Requirements for Class CC Concrete Components of Light-Water Cooled Power Plants." The purpose of the proposed rule is to specify inspection requirements to ensure that containments maintain minimum accepted design wall thicknesses and prestressing forces.

We strongly support the elimination of the proposed five year implementation schedule and feel that the current programs are adequate to maintain containment integrity. Additionally, we endorse the comments sent separately to the NRC by the Nuclear Energy Institute and offer thn attached comments associated with the implementation of Subsections IWE arid IWL. Please note that there are several areas identified where the implementatiori of the code will be impractical. The resolution of these areas should be part of the rulemaking.

We appreciate the opportunity to make comments on the proposed rule, if you l have any questions, please contact us. j l

Very truly yours,  ;

f Ymj 1 l

M. L. Bowling, Manager l Nuclear Licensing and Programs j 9405100158 940429 PDR PR 50 59FR979 PDR flb i J

cc: Mr. Ron Simard Manager, industry Coordinator Nuclear Energy Institute 1776 Eye Street Suite 300 Washington, D. C. 20006-3706

9 CODES AND STANDARDS FOR NUCLEAR POWER PLANTS SUBSECTIONS IWE AND IWL PROPOSED RULE The following comments are associated with the implementation of Subsections IWE and IWL. As indicated, the differences between the code requirements and the existing programs would make implementation complicated. It is recommended that thece areas be taken into consideration and resolved prior to the issuance of the proposed rule.

1. Subsection IWL is initiated with the structural integrity test in lieu of the commercial operation date. This means IWL would have a different interval than the rest of the code. Additionally, the rulemaking does not address when the utility is to update the IWL code.
2. Section IWL-2310(b) requires VT-3C visual examinations to be conducted. The purpose is to determine the general structural condition of the concrete surfaces of containment by identifying areas of concrete deterioration and distress. The acceptance criteria includes the ability to locate a discrepancy of a lower case character height of approximately 1/10". Th'is criteria is considered impractical for all the containment concrete. It is recommended that the general visual examinations described in IWE be considered.
3. Section IWL-2310 requires the qualification for concrete examination personnel (VT-1C and VT-30) in accordance with IWA-2300. However, there are no industry Level lil's for VT-1C and VT-3C.
4. The rulemaking indicates that licensees are not to submit plans. It is recommended that the rulemaking provide guidance for the processing of relief requests and when they should be implemented.
5. The rulemaking indicates that the requirements of IWE and IWL are necessary to provide detailed visual examinations. These requirements are currently provided by Appendix J. If the requirements of Subsections IWE and IWL are imposed, then the visual examination requirements in Appendix J should be deleted.
6. Category E-D, note 1 in the 1993 Addenda of IWE adds a statement to coincide the inspection of seals and gaskets with component disassembly. It is recommended that the rulemaking teference this addenda.
7. iWE-5240 and IWE-5210 seems to mandate VT-2 examination requirements for Appendix J tests. It is recommended that this area be evaluated to determine if this was the intent of the code to require the qualification of Appendix J personnel.