ML20126F272

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

ML20126F272
Person / Time
Site:	Peach Bottom, Salem, Hope Creek, Limerick
Issue date:	12/21/1992
From:	Beck G PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:	NRC OFFICE OF ADMINISTRATION (ADM)
References
FRN-57FR54860 57FR54860-00004, 57FR54860-4, NUDOCS 9212300199
Download: ML20126F272 (5)

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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.

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