ML20209F246

Request Addl Info Re Relief Request CRR-01 Through CRR-11 for Plant,Units 2 & 3.RAI Undtd

ML20209F246
Person / Time
Site:	Peach Bottom
Issue date:	07/15/1999
From:	Buckley B NRC
To:	PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
References
NUDOCS 9907150279
Download: ML20209F246 (1)

Text

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. e4 fp ;27 [ l Additional Information Needed for the Staff's Review of Relief requests CRR-01 Through CRR-11 Peach Bottom Atomic Power Station, Units 2 and 3

1. Relief Request CRR-02, " Alternative Requirements for Qualification and Verification of NDE Personnel" in the basis for alternative section, the licensee states that the development and administration of a second program based on CP-189 would not enhance safety or quality, and would constitute a burden, particularly in developing a second written practice, tracking of certifications, and duplication of paperwork. It is the staff's understanding that inclusion of these standards in the 1992 Edition and later Edition and Addenda of the Code suggests that it is an experience-based improvement over SNT-TC-1 A. Also, it is a consensus (ANSI) standard. The licensee needs to explain how the requirements of Subarticle IWA 2300 (1992 Edition and Addenda) for qualifying NDE personnel for containment examination will be implemented. It is not clear to the staff that this relief request is applied to the current ten year inspection interval or to all future inspection intervals.

2. Relief Requests CRR-03," Alternative Criteria for Preservice of Reapplied Paint and Coatings," and CRR-04," Alternative Criteria for Visual Examination of Paint or Coating Prior to Removal" In the basis for alternative section for these two relief requests, the licensee states that the PECO Energy Coatings Program is to be used for examining and verifying the {

adequacy of coatings, and will provide adequate level of safety and quality. With respect 1 to this program, the licensee needs to provide the following information related to the protective coating used inside the containment:

A. Standards, procedures or guidelines used for (a) surface preparation, application, surveillance, and maintenance activities for protective coatings, and (b) documenting the quality and condition of reapplied paint.

B. Maintenanco activities including reworking of degraded coating, removing of degraded coating to sounding coating, preparing the surface, applying new coating, and verifying the coating quality.

3. Relief Request CRR-05, " Alternative Criteria for VT-2 Visual Examination Following repair, Replacement, or Modification" In the proposed alternative criteria section, the licensee states that in addition, examinations following repairs or replacements on containment components will be performed in accordance with PECO Energy Repair / Replacement Specification M-679.

The staff would like know some details about this program.

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