ML20211A972

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Forwards Request for Addl Info Re Third 10-year Interval Inservice (ISI) Insp Program Plan for Plant,Units 2 & 3
ML20211A972
Person / Time
Site: Peach Bottom  Constellation icon.png
Issue date: 08/20/1999
From: Buckley B
NRC (Affiliation Not Assigned)
To: Hutton J
PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
References
TAC-MA4008, TAC-MA4009, NUDOCS 9908240181
Download: ML20211A972 (5)


Text

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Mr. J:mes A. Hutton Director-Licensing, MC 62A-1 PECO Energy Company August 20, 1999 Nucle:r Group Hrdqu;rtirs Correspondence Control Desk P.O. Box No.195

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Wayne, PA 19087-0195

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION REGARDING PEACH BOTTOM ATOMIC POWER STATION, UNITS 2 AND 3 THIRD 10-YEAR INTERVAL INSERVICE INSPECTION PROGRAM PLAN REQUESTS FOR RELIEF (TAC NOS. MA4008 AND MA4009)

Dear Mr. Hutton:

Based on our evaluation of your submittal dated August 13,1998, on the above subject material, we find that additional information, as delineated in the enclosure, is required to continue our review. On August 18,1999, we discussed these issues with members of your staff and a 30-day response from receipt of this letter was mutually acceptable. In addition, to expedite the review process, please provide a copy of your response to the NRC contractor, Idaho National Engineering and Environmental Laboratory (INEEL), at the following address:

Mr. Michael T. Anderson, INEEL Research Center,2151 North Boulevard, P.O. Box 1625, Idaho Falls, Idaho 83415-2209.

Sincerely, ORIGINAL SIGNED BY:

Bartholomew C. Buckley, Sr. Project Manager, Section 2 Project Directorate i Division of Licensing Project Management g 4 ( 9 2 O Office of Nuclear Reactor Regulation Docket Nos. 50-277 and 50-278

Enclosure:

Request for Additional Information cc w/ encl: See next page DISTRIBUTION:

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NAME BBuckley/rsl WBr1W JClifford DATE 08/2(J/99 08/F]/99 08 % ) /99 08/ /99 08/ /99 9908240181 990820

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't WASHINGTON, D.c. 20565-0001 August 20, 1999 Mr. James A. Hutton Director-Licensing, MC 62A-1 PECO Energy Company Nuclear Group Headquarters Correspondence Control Desk P.O. Box No.195

. Wayne, PA 19087-0195

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION REGARDING PEACH BOTTOM ATOMIC POWER STATION, UNITS 2 AND 3 THIRD 10-YEAR INTERVAL INSERVICE INSPECTION PROGRAM PLAN REQUESTS FOR RELIEF (TAC NOS. MA4008 AND MA4009)

Dear Mr. Hutton:

Based on our evaluation of your submittal dated August 13,1998, on the above subject i

material, we find that additional information, as delineated in the enclosure, is required to continue our review. On August 18,1999, we discussed these issues with members of your staff and a 30-day response from receipt of this letter was mutually acceptable. In addition, to i

expedite the review process, please provide a copy of your response to the NRC contractor, idaho National Engineering and Environmental Laboratory (INEEL), at the following address:

Mr. Michael T. Anderson, INEEL Research Center,2151 North Boulevard, P.O. Box 1625,

. Idaho Falls, Idaho 83415-2209.

Sincerely, kof re ed 0. W

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Bartholomew C. Buckley, Sr. Project Manager, Section 2 Project Directorate l Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket Nos. 50-277 and 50-278

Enclosure:

Request for Additional j

information cc w/ encl: See next page '

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3 Peach Bottom Atomic Power Station, i

Units 2 and 3 cc:

J. W. Durham, Sr., Esquire Chief-Division of Nuclear Safety

. Sr. V.P. & General Counsel PA Dept. of PECO Energy Company Environmental Resources 2301 Market Street, S261 P.O. Box 8469 Philadelphia, PA 19101 Harrisburg, PA 17105-8469 PECO Energy Company Board of Suprevisors ATTN: Mr. J. Doering, Vice President -

Peach Bottom Township Peach Bottom Atomic Power Station R. D. #1 1848 Lay Road Delta, PA 17314 Delta, PA 17314 Public Service Commission of PECO Energy Company Maryland ATTN: Regulatory Engineer, A4-5S Engineering Division Peach Bottom Atomic Power Station Chief Engineer Chief Engineer 6 St. Paul Center 1848 Lay Road Baltimore, MD 21202-6806 Delta, PA 17314 Mr. Richard McLean Resident inspector Power Plant and Environmental U.S. Nuclear Regulatory Commission Review Division Peach Bottcm Atomic Power Station Department of Natural Resources P.O. Box 390 B-3, Tawes State Office Building Delta, PA 17314 Annapolis, MD 21401 Regional Administrator, Region l Dr. Judith Johnsrud i

U.S. Nuclear Regulatory Commission National Energy Committee 475 Allendale Road Sierra Club King of Prussia, PA 19406 433 Orlando Avenue State College, PA 16803 Mr. Roland Fletcher Department of Environment Manager-Financial Control & Co-Owner 201 West Preston Street Affairs Baltimore, MD 21201 Public Service electric and Gas Company i

A. F. Kirby,111 P.O. Box 236

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External Operations - Nuclear Hacocks Bridge, NJ 08038-0236

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Delmarva Power & Light Company P.O. Box 231 Manager-Peach Bottom Licensing Wilmington, DE.19899 PECO Energy Company Nuclear Group Headquarters PECO Energy Company Correspondence Control Desk Plant Manager P.O. Box No.195 Peach Bottom Atomic Power Station Wayne, PA 19087-0195 1848 Lay Road Delta, PA 17314

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REQUEST FOR ADDITIONAL INFORMATION THIRD 10-YEAR INTERVAL INSERVICE (ISI) INSPECTION PROGRAM PLAN PEACH BOTTOM ATOMIC POWER STATION. UNITS 2 AND 3 PECO ENERGY COMPANY DOCKET NOS. 50-277 AND 50-278 1.

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 structural integrity. Therefore, the proposed alternative cannot be authorized as written.

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 10 CFR 50.55a(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 accordance with 10 CFR 50.55a(a)(3)(ii) and justify the assurance of structural integrity that the alternative provides.

2.

In Request for Alternative RR-27, the licensee proposed that the Code required sampling size 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 volumetric examinations should be performed on welds <3/8-inch nominal wall thickness that are substituted for i

piping with wall thickness >3/8-inch. The licensee's proposed alternative would result in 1

fewer volumetric examinations being performed under Code rules on piping with wall thickness >3/8-inches. Since most degradation mechanisms occur from the ID of the piping, the licensee needs to provide a basis of why performing only surface examinations verses a volumetric examination provides an equivalency or how its

. alternative provides an acceptable level of quality and safety provided by the Category C-F-2 weld grouping stipulated by the Code.

3.

In a conference call of May 13,1999, 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 docurnent the selection criteria for welds to be examined in lieu of inaccessible welds as discussed in the conference call.

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Enclosure

Y.

L.

- 4.

In Request for Alternative RR-32, the licensee proposed performing visual VT-3 examinations of bolts removed from leaking bolted connections. However, since there are no Code acceptance criteria for VT-3 examiaations, a VT-1 examination needs to be performed on the bolt selected for examination. In order for the staff to find the licensee's proposed alternative acceptable, the licensee needs to demonstrate that their l

proposed alternative provides an acceptable level of quality and safety. One means that the staff would find acceptable is to have the inspection conform to the requirements of l

Code Case N-566-1, including a commitment to also perform a VT-1 examination.

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