ML20210A495

Package Consisting of Questions & Comments Re PBAPS Submittal,Dtd 980813,in Support of Discussion on Listed Items

ML20210A495
Person / Time
Site:	Peach Bottom
Issue date:	07/22/1999
From:	NRC
To:
References
NUDOCS 9907220118
Download: ML20210A495 (2)

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/zo/M Questions and Comments Regarding the Peach Bottom Atomic Power Station Submittal Dated 8/13/98

1. The Peach Bottom ISI Program identifies numerous Code Cases adopted by the utility that have not been approved for use. Although approval may be pending per Rev.12 of Reg. Guide 1.147, the licensee must submit a Request for Alternative for each Code Case that has not been approved by inclusion in Reg. Guide 1.147.

The Request for Alternative must also include the licensee's basis for the proposed alternative, which demonstrates that the proposed alternative provides an '

acceptable level of quality and safety in accordance with the requirements of 10CFR50.55a(a)(3)(i).

2. The licensee's basis for Proposed Alternative RR-17 does not state the hardship of compliance, it is not clear how the licensee's proposed alternative (to monitor acoustic and temperature instruments on the relief valve tail pipes) provides any -

assurance of structuralintegrity. Therefore, the proposed alternative will not be authorized. The licensee should revise and resubmit this request providing more  ;

detailed information which demonstrates: (a) that the proposed alternative provides an acceptable level of quality and safety in accordance with 10CFR50.55a(a)(3)(i) or, (b) that compliance with the specified requirements would result in hardship or unusual difficulty without a compensating increase in quality and safety in i accordance with 10CFR50.55a(a)(3)(ii).

3. In Request for Alternative RR-27, the licensee proposed that the Code required sampling rate be applied to all Category C-F-2 welds regardless of nominal piping wall thickness, except that only surface examinations will be performed on welds in piping <3/8 inch nominal wall thickness. The staff believes that examinations should be performed on welds < 3/8 inch nominal wall thickness. The licensee's proposed alternative would result in fewer volumetric examinations being performed. Also, the licensee has not provided a basis for performing only surface examinations. The licensee needs to address whether or not volumetric examinations can be performed on welds <3/8 in nominal wall thickness? The licensee also needs to address how performing only surface examinations would provide adequate assurance of structuralintegrity since most degradation mechaniams occur from the ID.

4. In conference call of 5/13/99, the licensee was asked why the inaccessible welds in penetrations listed in Request for Relief RR-28 were selected for examination.

The licensee stated that they were selected because they consider the containment penetration to be an anchor point, therefore these welds are at terminal ends. The licensee's proposed alternative states that examinations will be performed on the first accessible pipe weld outside each penetration that has an inaccessible weld inside. Please document the selection criteria for welds to be examined in lieu of inaccessible welds as discussed in the conference call.

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Questions and Comments Regarding the Peach Bottom Atomic Power Station Submittal Dated 8/13/98

5. In Request for Alternative RR-32, the licensee proposed performing visual VT-3 i

examinations of bolts removed from leaking bolted connections. However, since there are no Code acceptance criteria for VT-3 examinations, the staff requires that a VT-1 examination be performed on the bolt selected for examination. The licensee needs to revise and resubmit the relief to conform to Code case N-566-1 and the additional commitment to perform a VT-1 examination as described above.

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