BECO-85-186, Requests Change to Previous Commitment to Complete Breakwater Survey Following Major Storm.Complete Survey Unnecessary Expense Unless Initial Walkdown Indicates Need. Annual Breakwater Survey Will Continue to Be Performed

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Requests Change to Previous Commitment to Complete Breakwater Survey Following Major Storm.Complete Survey Unnecessary Expense Unless Initial Walkdown Indicates Need. Annual Breakwater Survey Will Continue to Be Performed
ML20205G909
Person / Time
Site: Pilgrim
Issue date: 10/16/1985
From: Harrington W
BOSTON EDISON CO.
To: Vassallo D
Office of Nuclear Reactor Regulation
References
BECO-85-186, NUDOCS 8511130381
Download: ML20205G909 (2)


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,k BOOTON EDISDN COMPANY S00 5DvLsTON STREET BDSTON, MASSACHUSETTS 02199 WILLIAM D. HARRINGTON samesa vses pasessaw mue6 san -

October 16, 1985 BECo 85 186 Mr. Domenic B. Vassallo, Chief Operating Reactors Branch #2 Division of Licensing Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D. C. 20555 License DPR-35 Docket 50-293 Main Breakwater Survey Commitment Reduction

References:

(1) Boston Edison (BECo) letter to Mr. T. A. Ippolito (NRC) dated September 28, 1979 (2) BECo letter to Mr. T. A. Ippolito dated April 10, 1980 (3) BECo letter to Mr. T. A. Ippolito dated December 17, 1980 (4) BECo letter to Mr. T. A. Ippolito dated March 30, 1981

Dear Sir:

Due to significant damage to the PNPS breakwater following the major storm of 1978, Boston Edison Company (BECo) committed to perform an annual survey intended to demonstrate that the breakwater has not degraded, or is near to-degrading, to a point where it cannot perform its designed function, i.e.,

protecting the service water pumps from heavy seas.

In addition to the annual survey, BECo is currently committed to perform a full survey when the breakwater is subjected to two consecutive hours or' more of continuous wind speeds greater than or equal to 50 M.P.H.

After the most recent storm, Gloria, a walkdown was performed using the most recent photographic data for comparison to field conditions. The effort indicated that, although Gloria easily exceeded our " major storm" criteria, the. breakwater had sustained no significant damage.

8511130381 851016 PDR ADOCK 05000293 P PDR O

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180STON EDISON COMPANY Mr. Domenic B. Vassallo, Chief October- 16, 1985 Page 2.

In light of the results of the Gloria walkdown and of surveys conducted subsequent to a previous " major. storm", and since disabling damage to the breakwater would be catastrophic and. easily detected by a visual survey and walkdown, BECo believes that a complete survey following a " major storm" is an unnecessary expense unless the initial walkdown indicates a need for one.

Therefore,' BECo wishes to change our previous commitment relative to a " major storm" as follows:

o Replace the post " major storm" complete survey with a survey consisting of a walkdown and most recent photo comparison to field conditions; o the results of this walkdown/ photo comparison will be submitted to the NRC; o Should the walkdown/ photo comparison indicate the need to survey, a survey will be conducted in accordance with current commitments and r-procedures.

BEco will continue to perform its annual breakwater survey in conformance to its-previous commitments and current procedures.

BECo has postponed conducting the remainder of the post-Gloria survey-pend kg NRC approval.of the commitment change proposed in this submittal. He believe this proposal provides assurance of breakwater integrity while reducing survey

- costs.

Should you wish further information on this issue, please contact us.

Very truly yours, fn W. D. Harrington PMK/kmc i

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