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Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARLR-N980595, Comment Supporting Proposed Rules 10CFR50,52 & 72 Re Changes,Tests & Experiments.Pse&G Supports Comments Submitted by NEI in Their Ltr1998-12-21021 December 1998 Comment Supporting Proposed Rules 10CFR50,52 & 72 Re Changes,Tests & Experiments.Pse&G Supports Comments Submitted by NEI in Their Ltr LR-N980588, Comment on Proposed Rule 10CFR50.65 Re Monitoring Effectiveness of Maint at Npps.Util Agrees with General Principle Behind Proposed Rulemaking,But However,Concerned That Proposed Rule Contain Language Open to Interpretation1998-12-14014 December 1998 Comment on Proposed Rule 10CFR50.65 Re Monitoring Effectiveness of Maint at Npps.Util Agrees with General Principle Behind Proposed Rulemaking,But However,Concerned That Proposed Rule Contain Language Open to Interpretation ML18106A8731998-09-15015 September 1998 Comment on Draft NUREG-1633 Re Assessment of Use of Potassium Iodide (Ki) as Protetive Action During Severe Reactor Accidents. Believes That NUREG Should Provide Balanced Discussion on Benefits & Risks of Use of Ki ML18106A8811998-09-15015 September 1998 Comment Opposing Draft NUREG-1633, Assessment of Use of Potassium Iodide as Protective Action During Severe Reactor Accidents. Believes That Discussion Contained in SECY-98-061 Should Be Included in Draft NUREG ML20153G3141998-06-29029 June 1998 Transcript of 980629 Public Meeting Re Peach Bottom Unit 1, Decommissioning Status in Delta,Pa.Pp 1-65.Reporter Certificate Encl ML20249B9981998-06-22022 June 1998 Exemption from Requirements of 10CFR70.24 Re Criticality Accident Requirements. Exemption Authorized LR-N980284, Comment on PR-50 Re IEEE Std 603-1991 for Salem & Hope Creek Generating Stations.Lack of Adverse Comments to Draft RG Should Not Have Been Construed as Endorsement to IEEE 603-19911998-06-12012 June 1998 Comment on PR-50 Re IEEE Std 603-1991 for Salem & Hope Creek Generating Stations.Lack of Adverse Comments to Draft RG Should Not Have Been Construed as Endorsement to IEEE 603-1991 ML20247M8801998-05-19019 May 1998 Confirmatory Order Modifying Licenses Effective Immediately. PECO Energy Co Shall Complete Final Implementation of Thermo-Lag 330-1 Fire Barrier Corrective Actions at Peach Bottom Atomic Power Station,Units 2 & 3 LR-N980149, Comment on Proposed Rule 10CFR50 Re Industry Codes & Stds. Comments Address Use of Engineering Judgment,Limitations on Use of Later ASME III Code Editions for Weld Leg Dimensions & Seismic Analysis1998-03-30030 March 1998 Comment on Proposed Rule 10CFR50 Re Industry Codes & Stds. Comments Address Use of Engineering Judgment,Limitations on Use of Later ASME III Code Editions for Weld Leg Dimensions & Seismic Analysis ML20216G0321998-03-0404 March 1998 Comment Re Draft RG DG-1071, Std Format & Content for Post- Shutdown Decommissioning Activities Rept. Recommends That Draft RG Be Revised to Accommodate Situations Similar to That Described for Unit 1 ML20198J0931997-12-18018 December 1997 Order Approving Application Re Merger Between Atlantic Energy Inc,& Delmarva Power & Light Co ML20151L5181997-08-0505 August 1997 Order Prohibiting Involvement in NRC Licensed Activities (Effective Immediately) Re SL Nevin Deliberately Falsifying Records of RECW Sample Documentation on 960207 ML20151L3671997-08-0505 August 1997 Order Prohibiting Involvement in NRC Licensed Activities (Effective Immediately).Orders That SA Blacklock Prohibited from Engaging in Activities Licensed by NRC for 5 Yrs from Date of Order ML18102B4361997-07-0707 July 1997 Comment Opposing NUREG-1606, Proposed Regulatory Guidance Re Implementation of 10CFR50.59 (Changes,Tests or Experiments). Util Endorses Comments Submitted by Nuclear Energy Inst ML20203H6891997-06-0202 June 1997 Transcript of 970602 Enforcement Conference in King of Prussia,Pa ML20132A8961996-12-0606 December 1996 Comment Supporting Pr 10CFR50, NRC Draft Ps on Restructuring & Economic Deregulation of Electric Utility Industry ML20113C6631996-06-24024 June 1996 Comments on Proposed Rule 10CFR50 Re Financial Assurance Requirements for Decommissioning Nuclear Power Reactors ML20115H7061996-06-0404 June 1996 Submits Addl Info to Support Petition for Rulemaking PRM-72-3 Re Amend to SAR ML20084H9251995-06-0202 June 1995 Comment Opposing Proposed Change in State Cooperative Agreements Program Concerning NRC Intention to Reduce Scope of Work.Believes That NRC Should Maintain Environ Monitoring Program & Find Other Ways to Reduce Duplicative Svcs ML20083N3971995-04-26026 April 1995 Comment Supporting Proposed GL, Pressure Locking & Thermal Binding of Safety-Related Power-Operated Gate Valves ML20081B3811995-03-0101 March 1995 Comment Supporting Proposed Suppl 5 to GL 88-20, IPEEE for Severe Accident Vulnerabilities ML20134K5021995-02-24024 February 1995 Transcript of 950224 Enforcement Conference in King of Prussia,Pa Re C Vondra.Pp 1-136 ML20134K4971995-02-0808 February 1995 Transcript of 950208 Enforcement Conference in King of Prussia,Pa Re L Reiter.Pp 1-64 ML20134K4791995-02-0808 February 1995 Transcript of 950208 Enforcement Conference in King of Prussia,Pa Re V Polizzi.Pp 1-115 ML20134K4511995-02-0808 February 1995 Transcript of 950208 Enforcement Conference in King of Prussia,Pa Re Plant.Pp 1-93 ML20080G8321995-02-0606 February 1995 Comment Opposing Proposed Rule 10CFR50 Re Shutdown & low-power Operations for Npp.Encourages NRC to Reevaluate Regulatory Analyses in Light of Higher Costs.Concludes That Addl Rules on Shutdown & Low Power Operations Not Necessary ML20077L8631995-01-0303 January 1995 Comment Supporting Proposed Rules 10CFR2,51 & 54 Re NPP License Renewal.Util of Belief That Proposed Rev Reflect Positive Effort Towards Establishing Regulatory Process Requirements for Continued Operation of Nuclear Facilities ML20132B2281994-08-0202 August 1994 Transcript of 940802 Enforcement Conference in Salem,Nj W/Salem Senior Nuclear Shift Supervisor Involved in 940407 Event ML20067C1591994-02-17017 February 1994 Comments on NUREG/CR-5884 Re Analyses of Decommissioning for Ref PWR Power Station ML20058K7381993-12-0303 December 1993 Memorandum & Order CLI-93-25.* Commission Denies State of Nj Petition for Leave to Intervene & Request for Adjudicatory Hearing Filed on 931008.W/Certificate of Svc.Served on 931203 ML20059L3201993-11-24024 November 1993 Exemption from Training Requirements of 10CFR50.120 Re Establishment,Implementation & Maintenance of Training Program ML20059B0301993-10-22022 October 1993 NRC Staff Response to Commission Questions Posed W/Respect to State of New Jersey Petition for Leave to Intervene & Request for Hearing.* Denies Petition to Intervene & Request for Hearing.W/Certificate of Svc & Notice of Appearance ML20059B1111993-10-20020 October 1993 Philadelphia Electric Co Response to NRC 931014 Order.* State Failed to Demonstrate Entitlement to Hearing to Challenge Util Amend to Permit Util to Receive Shoreham Fuel ML20059A4581993-10-14014 October 1993 Order Requesting Answers to Two Questions Re State of Nj Request for Immediate Action by NRC or Alternatively, Petition for Leave to Intervene & Request for Hearing. Operations Plans for Marine Transportation Withheld ML20057G2141993-10-14014 October 1993 Order.* Requests for Simultaneous Responses,Not to Exceed 10 Pages to Be Filed by State,Peco & Lipa & Served on Other Specified Responders by 931020.NRC May File by 931022. W/Certificate of Svc.Served on 931014 ML20059B1291993-09-14014 September 1993 Affidavit of Jh Freeman.* Discusses Transfer of Slightly Used Nuclear Fuel from Shoreham Nuclear Power Station to Limerick Generating Station.W/Certificate of Svc & Notice of Appearance ML20056G4121993-08-31031 August 1993 Comment Supporting Proposed Rule 10CFR2 Re Review of 2.206 Process ML18100A5591993-08-26026 August 1993 Comment Opposing Proposed Rule Re Whistleblower Protection ML20045D8121993-06-14014 June 1993 Comment Supporting Proposed Rules 10CFR50 & 54 Re FSAR Update Submittals. ML20126F2721992-12-21021 December 1992 Comment Endorsing Positions & Comments of NUMARC & BWROG Re Draft GL, Augmented Inservice Insp Requirments for Mark I & Mark II Steel Containments,Refueling Cavities & Associated Drainage Sys ML20095B2411992-04-10010 April 1992 Comment on Draft NUREG-1449, Shutdown & Low-Power Operation at Commercial Nuclear Power Plants in Us ML20091Q8661992-01-31031 January 1992 Comment Opposing Draft NUREG-1022,Rev 1, Event Reporting Sys,10CFR50.72 & 50.73,Clarification of NRC Sys & Guidelines for Reporting ML20072T2421991-04-11011 April 1991 Comment Re Proposed Change to 10CFR50.55A Re Inservice Testing of Containment Isolation Valves.Proposed Rule Should Be Revised to Allow Plants within Last 12 Months of Current Interval to Substitute Deferred Rv Shell Exams ML20062C6561990-10-22022 October 1990 Affidavit Requesting Withholding of Summary Rept on Evaluation of Recirculation Nozzle to Safe End Weld Indication & Proposed Disposition to Permit Unit 1 Cycle 4 Operation, from Public Disclosure,Per 10CFR2.790 ML20246J4521989-08-30030 August 1989 Memorandum & Order (Terminating Proceeding).* Terminates Proceeding Per Settlement Agreement Between Limerick Ecology Action,Inc & Licensee.W/Certificate of Svc.Served on 890831 ML20246F0121989-08-25025 August 1989 Memorandum & Order CLI-89-17.* Staff Authorizes Issuance of Full Power License to Licensee to Operate Unit 2 After Requisite Safety Findings Under 10CFR50.57 Completed. W/Certificate of Svc ML20246F1471989-08-25025 August 1989 Settlement Agreement.* Certificate of Svc Encl ML20246F1011989-08-25025 August 1989 Joint Motion for Termination of Proceedings.* Board Moved to Accept Encl Settlement Agreement,Dismiss Limerick Ecology Action,Inc (Lea) Contention W/Prejudice,Dismiss Lea as Party to Proceeding & Terminate Proceeding ML20246E3431989-08-22022 August 1989 Opposition of Intervenor Limerick Ecology Action,Inc to Motion by Licensee Philadelphia Electric Co to Set Schedule for Discovery & Hearing.* Requests That Schedule Be Replaced W/More Reasonable Schedule,As Proposed.W/Certificate of Svc ML20246C0271989-08-18018 August 1989 Notice of Appointment of Adjudicatory Employee.* Informs That D Nash Appointed as Commission Adjudicatory Employee to Advise Commission on Issues in Proceeding.W/Certificate of Svc.Served on 890818 1998-09-15
[Table view] Category:PUBLIC COMMENTS ON PROPOSED RULES & PETITIONS FOR
MONTHYEARLR-N980595, Comment Supporting Proposed Rules 10CFR50,52 & 72 Re Changes,Tests & Experiments.Pse&G Supports Comments Submitted by NEI in Their Ltr1998-12-21021 December 1998 Comment Supporting Proposed Rules 10CFR50,52 & 72 Re Changes,Tests & Experiments.Pse&G Supports Comments Submitted by NEI in Their Ltr LR-N980588, Comment on Proposed Rule 10CFR50.65 Re Monitoring Effectiveness of Maint at Npps.Util Agrees with General Principle Behind Proposed Rulemaking,But However,Concerned That Proposed Rule Contain Language Open to Interpretation1998-12-14014 December 1998 Comment on Proposed Rule 10CFR50.65 Re Monitoring Effectiveness of Maint at Npps.Util Agrees with General Principle Behind Proposed Rulemaking,But However,Concerned That Proposed Rule Contain Language Open to Interpretation ML18106A8811998-09-15015 September 1998 Comment Opposing Draft NUREG-1633, Assessment of Use of Potassium Iodide as Protective Action During Severe Reactor Accidents. Believes That Discussion Contained in SECY-98-061 Should Be Included in Draft NUREG ML18106A8731998-09-15015 September 1998 Comment on Draft NUREG-1633 Re Assessment of Use of Potassium Iodide (Ki) as Protetive Action During Severe Reactor Accidents. Believes That NUREG Should Provide Balanced Discussion on Benefits & Risks of Use of Ki LR-N980284, Comment on PR-50 Re IEEE Std 603-1991 for Salem & Hope Creek Generating Stations.Lack of Adverse Comments to Draft RG Should Not Have Been Construed as Endorsement to IEEE 603-19911998-06-12012 June 1998 Comment on PR-50 Re IEEE Std 603-1991 for Salem & Hope Creek Generating Stations.Lack of Adverse Comments to Draft RG Should Not Have Been Construed as Endorsement to IEEE 603-1991 LR-N980149, Comment on Proposed Rule 10CFR50 Re Industry Codes & Stds. Comments Address Use of Engineering Judgment,Limitations on Use of Later ASME III Code Editions for Weld Leg Dimensions & Seismic Analysis1998-03-30030 March 1998 Comment on Proposed Rule 10CFR50 Re Industry Codes & Stds. Comments Address Use of Engineering Judgment,Limitations on Use of Later ASME III Code Editions for Weld Leg Dimensions & Seismic Analysis ML20216G0321998-03-0404 March 1998 Comment Re Draft RG DG-1071, Std Format & Content for Post- Shutdown Decommissioning Activities Rept. Recommends That Draft RG Be Revised to Accommodate Situations Similar to That Described for Unit 1 ML18102B4361997-07-0707 July 1997 Comment Opposing NUREG-1606, Proposed Regulatory Guidance Re Implementation of 10CFR50.59 (Changes,Tests or Experiments). Util Endorses Comments Submitted by Nuclear Energy Inst ML20132A8961996-12-0606 December 1996 Comment Supporting Pr 10CFR50, NRC Draft Ps on Restructuring & Economic Deregulation of Electric Utility Industry ML20113C6631996-06-24024 June 1996 Comments on Proposed Rule 10CFR50 Re Financial Assurance Requirements for Decommissioning Nuclear Power Reactors ML20115H7061996-06-0404 June 1996 Submits Addl Info to Support Petition for Rulemaking PRM-72-3 Re Amend to SAR ML20084H9251995-06-0202 June 1995 Comment Opposing Proposed Change in State Cooperative Agreements Program Concerning NRC Intention to Reduce Scope of Work.Believes That NRC Should Maintain Environ Monitoring Program & Find Other Ways to Reduce Duplicative Svcs ML20083N3971995-04-26026 April 1995 Comment Supporting Proposed GL, Pressure Locking & Thermal Binding of Safety-Related Power-Operated Gate Valves ML20081B3811995-03-0101 March 1995 Comment Supporting Proposed Suppl 5 to GL 88-20, IPEEE for Severe Accident Vulnerabilities ML20080G8321995-02-0606 February 1995 Comment Opposing Proposed Rule 10CFR50 Re Shutdown & low-power Operations for Npp.Encourages NRC to Reevaluate Regulatory Analyses in Light of Higher Costs.Concludes That Addl Rules on Shutdown & Low Power Operations Not Necessary ML20077L8631995-01-0303 January 1995 Comment Supporting Proposed Rules 10CFR2,51 & 54 Re NPP License Renewal.Util of Belief That Proposed Rev Reflect Positive Effort Towards Establishing Regulatory Process Requirements for Continued Operation of Nuclear Facilities ML20067C1591994-02-17017 February 1994 Comments on NUREG/CR-5884 Re Analyses of Decommissioning for Ref PWR Power Station ML20056G4121993-08-31031 August 1993 Comment Supporting Proposed Rule 10CFR2 Re Review of 2.206 Process ML18100A5591993-08-26026 August 1993 Comment Opposing Proposed Rule Re Whistleblower Protection ML20045D8121993-06-14014 June 1993 Comment Supporting Proposed Rules 10CFR50 & 54 Re FSAR Update Submittals. ML20126F2721992-12-21021 December 1992 Comment Endorsing Positions & Comments of NUMARC & BWROG Re Draft GL, Augmented Inservice Insp Requirments for Mark I & Mark II Steel Containments,Refueling Cavities & Associated Drainage Sys ML20095B2411992-04-10010 April 1992 Comment on Draft NUREG-1449, Shutdown & Low-Power Operation at Commercial Nuclear Power Plants in Us ML20091Q8661992-01-31031 January 1992 Comment Opposing Draft NUREG-1022,Rev 1, Event Reporting Sys,10CFR50.72 & 50.73,Clarification of NRC Sys & Guidelines for Reporting ML20072T2421991-04-11011 April 1991 Comment Re Proposed Change to 10CFR50.55A Re Inservice Testing of Containment Isolation Valves.Proposed Rule Should Be Revised to Allow Plants within Last 12 Months of Current Interval to Substitute Deferred Rv Shell Exams ML20246H8141989-07-0505 July 1989 Comment Supporting Proposed Rule 10CFR50, Acceptance of Products Purchased for Use in Nuclear Power Plant Structures,Sys & Components ML20247A2971989-04-0404 April 1989 Comment Supporting Proposed Rule 10CFR50 Re Ensuring Effectiveness of Maint Programs for Nuclear Power Plants ML20235T1861989-02-24024 February 1989 Comment Supporting Proposed Rule 10CFR50 Re Ensuring Effectiveness of Maint Programs for Nuclear Power Plants, Extension of NRC Authority to BOP Portion of Plant & Misapplication of Adequate Protection Std of Backfit Rule ML20195H0331988-11-21021 November 1988 Comment on Proposed Rule 10CFR26 Re Fitness for Duty Program Which Includes Random Drug Testing.Util Strongly Favors 180- Day Period for Implementation of Rule & 360-day Implementation Period for Random Drug Testing ML20205Q2061988-10-28028 October 1988 Comment Opposing Petition for Rulemaking PRM 50-52 Re Exemption of Financial Qualifications of Applicants from Review of OL Applications.Petition Presents No Compelling Reason to Amend Current Rules ML20195E6501988-10-24024 October 1988 Comment Supporting Petition for Rulemaking PRM 50-52 Re NRC Reinstatement of Financial Qualifications of Util as Consideration in Operating Licensing Hearings for Electric Utils ML20205L7931988-10-20020 October 1988 Comment Opposing Proposed Rule 10CFR20 Re Onsite Incineration of Radwaste Oil ML20205A7691988-10-0606 October 1988 Comment on Petition for Rulemaking PRM 50-52 Re Potential Shutdown of Facility.Petition Should Receive Fair Hearing & Admit Use of Poor Judgment in Issuing Final Rule on 840812 ML20205N9841988-10-0606 October 1988 Comment Supporting Petition for Rulemaking PRM-50-52 Re Necessity for Financial Stability of Utils Involved in Nuclear Power ML20155E8931988-10-0303 October 1988 Comment on Proposed Rule 10CFR50.54(w)(5)(i) Re Amending Implementation Schedule for Stabilization & Decontamination Priority & Trusteeship Provisions of Property Insurance Regulations.Nrc Initiated Exemptions Expected Before 881004 ML20154R6491988-09-25025 September 1988 Requests Extension of Comment Period on Proposed Rule 10CFR52 Re Reactor Licensing ML20153F9681988-08-17017 August 1988 Comment Opposing Proposed Rule 10CFR50 Re Licensee Flexibility During Natl Crisis.Deferral of Issuance of Final Rule Until Proper Implementation Guidance Formulated Encouraged ML20151G0031988-07-19019 July 1988 Comment on Proposed Rule 10CFR50 Re Cooperation W/States at Commercial Nuclear Power Plants & Other Facilities. Suggests Rev to Policy to Grant Same Rights & Responsibilities to All States within 10 Miles of Plant ML20196B9211988-06-0808 June 1988 Comment Supporting Proposed Rule 10CFR50 Re Emergency Planning & Preparedness Requirements for Nuclear Power Plant Fuel Loading & Initial Low Power Operations ML20155C5171988-05-23023 May 1988 Comment Opposing Proposed Rule 10CFR50 Re Emergency Planning & Preparedness Requirements for Nuclear Power Plant Fuel Loading & Initial Low Power Operations.Emergency Planning Should Be in Full Force During Low Power Operation ML20154G1421988-04-20020 April 1988 Comment Opposing Proposed Rules 10CFR50 & 73 Re Policy Statement on Nuclear Power Plant Access Authorization Program.Nrc Should Establish Program Mutually Agreed Upon Between Union & Util,Per Hope Creek & Salem Programs ML20154G4601988-04-18018 April 1988 Comment Opposing Proposed Rule 10CFR50 Re Notification of Inspector Visits to Facility ML20196F5941988-02-24024 February 1988 Comment Supporting Proposed Rule 10CFR62 Re Emergency Access to Low Level Radwaste Disposal Sites.Believes Proposed Criteria Well Developed & Will Be Effective in Maintaining Control of Amount of Radwaste Sent to Sites ML18093A6331988-02-0101 February 1988 Comment Supporting Proposed Rule 10CFR50 Re Proposed Policy Statement on Integrated Schedules for Implementation of Plant Mods JPN-87-051, Comment Opposing Draft NUREG-1150, Reactor Risk Ref Document. Reduced Uncertainty in Risk Assessment Found to Be Significant W/Respect to NUREG-1150.NUREG Also Does Not Consider Value of Operator Actions.Addl Comments Encl1987-09-28028 September 1987 Comment Opposing Draft NUREG-1150, Reactor Risk Ref Document. Reduced Uncertainty in Risk Assessment Found to Be Significant W/Respect to NUREG-1150.NUREG Also Does Not Consider Value of Operator Actions.Addl Comments Encl ML20235T0211987-09-25025 September 1987 Comments on NUREG-1150, Reactor Risk Ref Document. Detailed Review Should Be Performed to Assure That Statements Made in NUREG-1150 & Supporting Analyses Have Same Basis ML20235C0901987-09-15015 September 1987 Comment Opposing Util Request for Amends to Licenses DPR-44 & DPR-56 Which Would Excuse Util from Requiring Senior Operator Licenses for Plant Manager & for Superintendent of Operations ML20151B3641987-02-24024 February 1987 Comment Opposing Proposed Rule 10CFR50 Re Licensing of Nuclear Power Plants Where State &/Or Local Govts Decline to Cooperate in Offsite Emergency Planning ML20235T1391987-01-26026 January 1987 Comments on Draft NUREG/CR-4550,Vol 3 Re Accident Sequence Characterization.Believes Analysis Should Be Corrected to More Realistically Estimate Core Damage Frequency ML20235T0681986-09-0202 September 1986 Comments on Draft NUREG/CR-4696 Re Containment Venting Analysis for Plant.Rept Contains Number of Factual Errors & Misrepresents Info Provided by Util.Requests Opportunity to Review Revised Draft Before Final Rept Published ML20235T0851986-07-18018 July 1986 Comments on Draft NUREG/CR-4696 Re Containment Venting Analysis for Plant.Conclusion Re Zero Probability of Successfully Venting Following Station Blackout Totally Misleading 1998-09-15
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! PIIILADELPIllA ELECTRIC COMPANY,[7[87Y((O NUCLEAR GROUP HEADQUARTERS [ g 955-65 CHESTERBROOK BLVD.
WAYNE. PA 19087-5691 28 M I:40 ,
(215) MO-6000 December 21, 1992 NUCLEAR SLRVICES DEPARTMENT Chief, Rules and Directives Review Branch U.S. Nuclear Regulatory Commission Washington, DC 20555
Subject:
Comments Concerning the Nuclear Regulatory Commission's Draft Generic Letter, " Augmented Inservice Inspection Requirements for Mark I and Mark II Steel Containments, Refueling Cavities, and Associated Drainage Systems" (57FR54860)
Gentlemen:
This letter is being submitted in response to the Nuclear Regulatory Commission's (NRC's) request for comments concerning the draf t Generic Letter, " Augmented Inservice Inspection Requirements for Mark I and Mark II Steel Containments, Refueling Cavities, and Associated Drainage Systems" (57FR54860).
Philadelphia Electric Company appreciates the opportunity to comment on this draft Generic Letter, and therefore, offers the attached comments for consideration by the NRC. However, we consider that there is no need to issue this Generic Letter, and tnerefore endorse the positions and comments of the Nuclear Management and Resources Council (NUMARC) and Boiling Water Reactor Owner's Group (BWROG).
If you have any questions, please do not hesitate to contact us.
Very truly yours,
/ 5 G. J Beck Manager Licensing Section Attachment 23 199 921221 MISC 57FR54860 PDR l I
e ATTACl! MENT COMMENTS ON DRAFT GENERIC LETTER,
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"AUGMEllTED INSERVICE INSPECTION REQUIREMENTS FOR MARK I AND MARK II STEEL CONTAINMENTS, REFUELING CAVITIES, AND ASSOCIATED DRAINAGE SYSTEMS" e
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ATTACHMENT Philadelphia Electric Company -
Comments on NRC Draft Generic Letter
- Drywell (1), page 54863 Does the inspection of the refueling cavity, spent fuel pools, and drains from these areas and the sand cushion area apply to the Mark II containment?
The Mark II containment does not have an air gap or a sand cushion. Also, the Mark II containment liner is not a free standing structure and, therefore, does not have the same structural integrity requirements as does the Mark I containment.
What specifically is meant by the terms " joints" and " seals" of the refueling cavity, equipment pool, and spent fuel pool? .
Is it only those " joints" and " seals" whose leakage would communicate directly with the gap that would have to be inspected and tested?
- Drywell (2), page 54863 Does the inspection of the drain lines from the fuel pools and above the sand cushion seal plate apply to the Mark II containment?
As previously stated, the Mark II containment does not have an air gap or a sand cushion.
- Drywell (3), page 54863 Does the inspection of the sand-filled drains leading from the sand cushion apply to the Mark II containment? As stated above, the Mark II containment does not have an air gap or a sand cushjon.
Does the inspection of the sand-filled drains leading from the sand cushion apply to Mark I containments which-utilize a sealed send cushion?
We suggest that 'here cannot be a correlation drawn from sand. .
camples taken . rom the sand cushion and corrosion on the l drywell wall. Nnditions in the drain lines may not be the same as the conditions on 6.he drywell wall. With respect to i the insertion of carbon steel specimens, we recommend not-performing this action unless there is evidence of leakage from the drain lines. Also, we suggest that removal of the apecimens every six months is too frequent.to obtain a valid l
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Indication of corrosion. We suggest that if leakage is present in the drain lines and insertion of the carbon steel specimens is appropriate, that they be withdrawn and inspected once every refueling outage.
- Drywell (4), page 54863 Do the ultrasonic testing (UT) thickness measurements of the drywell shell apply to the Mark II containment? As stated in previous comments, the Mark II containment does not have an air gap or a sand cushion.
Requiring UT inspections if any water is detected appears to be restrictive. Carbon steel is expected to exhibit some corrosion. Most designs accommodate a defined amount of corremion. We suggest that inspections be required when the corrosion rate of the specimen exceeds the design allowablo corrosion rate of the liner. The corrosion rate of the steel specimen noods to be provided.
If UT inspections are required to be performed, we suggest that the schedule, frequency, and extent of examinations of the seal joint between the sand cushion seal plate and the outside drywell shell be defined.
We suggest that clarification be included on when UT thickness measurements are required for the areas of the drywell shell where gap forming material has been left behind.
- Torus (1), page 54863 We suggest the extent of the shell face inspection be provided. Does the inspection require 100% of the surface above and below the water to be visually inspected, or can a sample area satisfy the inspection requirements?
- Torus (3), page 54863 What is the recommended initial frequency for subsequent UT and visual inspections?
- Torus (5), page 54863 We suggest that " representative locations" be included when defining the location where sample coupons be placed. - We suggest that the wording, ...should be placed at the waterline at least one in each bay (between two successive saddle supports...,") is too restrictive.
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9 General Comments We suggest that the minimum specified implementation time of six months after issuance of the Generic Letter is .,
insuf ficient time to develop, submit, and receive approval for an alternate monitoring program for containment corrosion.
We suggest that the qualification requirements for personnel who perform the specified examinations be defined.
,y 3
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