PLA-3568, Comments Supporting Proposed Rule 10CFR50 Incorporating 1986 -1988 Addenda & 1989 Editions of ASME Boiler & Pressure Vessel Code,Section Iii,Div 1 & Section Xi,Div 1,by Ref Into 10CFR50.55a

Comments Supporting Proposed Rule 10CFR50 Incorporating 1986 -1988 Addenda & 1989 Editions of ASME Boiler & Pressure Vessel Code,Section Iii,Div 1 & Section Xi,Div 1,by Ref Into 10CFR50.55a

ML20073B115
Person / Time
Site:	Susquehanna
Issue date:	04/08/1991
From:	Keiser H PENNSYLVANIA POWER & LIGHT CO.
To:	Chilk S NRC OFFICE OF THE SECRETARY (SECY)
References
FRN-56FR3796, FRN-57FR34666, RULE-PR-50 56FR3796-00026, AD05-2-048, PLA-3568, NUDOCS 9104240034
Download: ML20073B115 (2)

Text

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, Pennsylvania Power & Light Company p

Two North Ninth Street

• Allentown, PA 181011179

• 2151774 $151

'91 FR 22 P 3 49 Harold W. Keiser Senior Vice Prest 00nt-Nuclear

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216/774 4194 '

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APR 8 199)

Mr. Samuel J. Chilk Secretary of the Commission U.S. Nuclear Regulatory Commission Washington, DC 20555 ATTENTION: Docketing and Service Branch SUSQUEHANNA STEAM ELECTRIC STATION COMMENTS ON PROPOSED RULE - REVISION TO 10 CFR 50.55A Docket Nos. 50-387 Pl.A-3568 fitES R41-2. A17-1.1 and 50-388

Dear Mr. Chilk:

Pennsylvania Power & Light Company (PP&L) is submitting comments in response to the proposed rule incorporating the 1986 Addenda, 1987 Addenda, 1988 Addenda and 1989 Editions of ASME Boiler and Pressure Vessel Code,Section III, Division 1 and Section XI, Division 1, by reference into 10CfR50.55a (55 Federal Register 53220 - December 27,1990).

PP&L supports the addition of later addenda and editions of the ASME Boiler and Pressure Vessel Code, Sections !!! and XI to 10CFR50.55a. However, we would request that the Commission consider the following:

A clearer definition of " essentially 100%" would help licensees assess RPV shell weld examination limitations so inspection alternatives could be evaluated. If based on the total length of RPV shell welds approximately 90%

examination coverage for all the RPV shell welds would be accomplished, it is  !

not clear that this 90% examination coverage would be acceptable in accordance '

with the proposed revision. For example, two longitudinal shell welds having only 22% examination coverage from the outside of the vessel, but could be 100% examined from the inside of the vessel may not be acceptable under the l

l 9104240034 910408 PDR PR 50 56FR03796 PDR I Y l

f.

2- FILES R41-2, Al? ll PLA-3568  ;

Mr. Samuel J. Chilk i 1

proposed rule change even though the overall examination coverage is 90% based on the total length of all RPV shell welds, and would be " essentially 100Y .

A clearer understanding of what is meant by " essentially 100'6" is needed.

Very truly yours.

Q v ,

llDk H. W. Keiser cc: NRCDocumentControlDesk(original)

NRC Region I Mr. G. S3 Barber, NRC Sr. Resident inspector Mr. J. J. Raleigh, NRC Project Manager

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