BECO-92-105, Forwards Semiannual Rept for long-term Program,Including Schedules for a & B Regulatory Items & Commitment Descriptions.Progress Continued on Generic Ltr 91-14 Re Emergency Communications & Generic Ltr 91-05

Forwards Semiannual Rept for long-term Program,Including Schedules for a & B Regulatory Items & Commitment Descriptions.Progress Continued on Generic Ltr 91-14 Re Emergency Communications & Generic Ltr 91-05

ML20127C965
Person / Time
Site:	Pilgrim
Issue date:	08/31/1992
From:	Richard Anderson BOSTON EDISON CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
BECO-92-105, GL-91-05, GL-91-14, GL-91-5, NUDOCS 9209110049
Download: ML20127C965 (66)

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,- a M BOSTON EDISON Pan, Nudum Pow staton Doo y HiH Road riyrnDutti, Mpnnthusetts 02369 Roy A. Anderson Senior Vice Prescent - Nuclear August 31, 1992 BECo 92- 105 U.S. Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 License DPR-35 Docket 50-293 LONG TERM PROGRAM: SEMI-ANNUAL REPORI This letter provides the semi-annual report for the Long arm Program (LTP) in accordance with Section V. A of the " Plan fer the Long Term Program - Pilgrim Nuclear Power Station". Attachment 1 includes schedules for the A and B regulatory items. Attachment 2 includes commitment descriptions, progress since the last update, and summaries of changes. '

'In addition to Schedule A and B items, we are implementing plant betterment

modifications and activ; ties. These additional items, identified in Schedule C, are included in Attachment 3. They are outside the regulatory scope of the Long Term Program and are exempt from the license conditions imposed on Schedule B items. Schedule C ite

ns are combined with Schedule A and B items to derive integrated schedules for all work activities included in the Long Term Program.

Our next refueling outage (RF0 #9) is scheduled to commence on April 3, 1993 with a planned duration of approximately nine weeks. Also, a mid-cycle outage (MCO #9) for modifications and surveillances is scheduled to commence on October 24, 1992 with a planned duration of 30 days.

Progress has continued on the majority of Schedule A and Schedule B items.

Completed Item _s 1

• NRC Emergency Communications (Generic Letter 91-14) l-l + Licensee Commercial-Grade Procurement and Dedication Programs (Generic Letter 91-05)

Schedule Revisions

• Implementation of 10CFR20 Requirements

• Emergency Response Data Syster.

• Detailed Control Room Design Review jt l,_ Ih[O 9209110049 920831 / d PDR ADOCK 05000293 "

R pop _

BOSTON EDISON COMPANY U. S. Nuclear Regulatory Commission Page 2

• Corrective Actions to Address Small Bore Piping Weld issues Dew Schedule B ltems

• Class 1 Piping Seismic 02mping Ratio Analysis

• Reactor Water Cleanup System Piping Replacement

• Electrical Distribution System functional Inspection (EDSFI) HVAC Resolution ,

• 125 V Battery Charger Replacement R.

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. Anderson -

t Attachments -

c1c/6804 cu Mr. R. Eaton, Project Manager Division of Reactor Projects - I/11 Orfice of Nuclear Reactor Regulation Mail Stop: 1401 U. S. Nuclear Regulatory Commission 1 White Flint North '

11555 Rockville Pike Rockville, MD 20852 U. S. Nuclear Regulatory Commission Region 1 475 Allendale Read King of Prussia, PA 19406 Senior NRC Resident Inspector Pilgrim Nuclear Power Station l

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Attachment 1 f.^ycijfE Page 5 of 5 L'E G _E N D-l SCHEDVLC 3ARS REPORTED PRDGRESS -F- . EVENT' Q WORKING SCHEDULE I 1. '

l ATTACHMENT 2 Schedules A and B Index ,

J.TP Sqbrdalq Title Pace #

A ATWS Rule Compliance 1 A Station Blackout Rule 4 A Maintenance Rulo 8 A 10CFR20 Standards for Protection Against Radiation 10 A Emergency Response Data System 12 B Detailed Control Room Design Review 13 8 Regulatory Guide 1.97 17 B Seismic Verification Program (GL 87-02) 21 B Physical Security Improvements 23 8 Thinning of Pipe Walls (Bulletin 87-01) and Erosion / Corrosion Induced Pipe Thinning (GL 89-08) 27 8 ladividual Plant Examination of Severe Accident Vulnerabilities (GL 88-20, Supplement 1) 30 8 Vendor Interf ace Project Plan (VETIP) (GL 83-28, item 2.2) 32 B Safety Related MOV Testing (GL 89-10) 35 B Root Lause of Weld Failures 38-B Rosemount Transmitters (Bull 00-91) 41 B Salt Service Water System Piping 43 B Licensee Commercial - Grade Procurement (GL 91-05) 45 B NRC Emergency Communications (GL 91-14) 47 B Individual Plant Examination - External Events (GL 88-20, Supplement 4) 48 B~ Degraded Voltage 50 B Class 1 Piping Seismic Damping Ratio 51 B RWCU Piping Replacement 52 8 .EDSFI HVAC 53 B Battery Charger (125V) Replacement- Sa L

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ATTACHMENT 2 SCHEDULE A  ;

ALWS RULE COMPLIANCE (LTP 283)

Commitment Description The ATWS Rule 10CFR50.62, requires modifications to the Standby Liquid Control System, Alternate Rod Insertion and Reactor Recirculation Pump i Trip by the second refueling outage from June 26, 1984 (i.e., RF0 #8 for BEco).

BEco implemented the Standby Liquid Control System modification in RF0 #7. '

The Technical Specification changes for Standby Liquid Control System were approved by the NRC on August 5, 1987 (Amendment #102). The ARl/RPT modifications were implemented in 1980 in response to NVREG-460, as directed by the NRC.

The NRC requested additional information regarding ARl/RPT modifications  !

by Reference 4 to determine compliance with this rule. BEco submitted its '

response via Reference 5. The diversity of ARI is yet to be resolved with the BWROG, NRC and licensees, as identified in the meeting notes from the NRC (Peference 6). All other items are resolved. The NRC Safety Evaluation Report issut.- June 6,1989 (Reference 7) accepted BECo's design except for diversity. Based on the need for additional time to change from the existing Rosemount trip units and relays, the NRC determined an extension of time-to fully comply with the diversity requirements would be

. acceptable. Another alternative discussed in the SER would be to request an exemption from the diversity requirement. The SER states the NRC staff will provide additional guidance on the diversity issue shortly and requests BECo provide a schedule for resolution when the additional NRC staff guidance is provided. Concurrently, BECo sought to resolve the diversity issue through the BWR Owner's Group.

The NRC has since resolved the diversity issue through issuance of a generic position to the BWROG in Reference 8 that also requested licensees to propose a schedule for achieving compliance with the diversity requirement. This resolution of the diversity issue was rade available to us by our NRC Project Manager on October S, 1990.

BEco has reviewed the staff's position on the diversity requirement, the NRC generic position presented to the BWROG in Reference 8, and the existing diversity afforded by'the Pilgrim Ar,1 system (as presented to the NRC staff in a meeting on December 9,1989). In accordance with the SER (Reference 7), our resolution of the diversity issue includes replacement of Rosemount trip units and an exemption request for actuation relays.

Our Reference 9 letter provided the basis for the exemption request and a commitment to replace the Rosemount trip units with General Electric trip L units during the mid-cycle outage. Since Reference 9, our mid-cycle outage has been rescheduled to October 1992, i

l Page . ;, 54 m

ATTACHMENT 2 (Continued)

SCHEDULE A In Reference 10, the NRC approved our proposed resolution of the ATWS/ARI diversity issue.

References

1) 10CFR50.62

2) BECo Letter 85-140 dated August 7, 1985

3) NRC Letter from Mr. H.R. Denton to BWROG Chairman dated August 19, 1985

4) NRC Letter dated September 27, 1987

5) 1100 Letter 88-073, dated April 27, 1988

6) MC Letter to BEco, dated January 9,1989.

7) NRC Letter to BEco, dated June 6, 1989

8) NRC Letter to BWROG Chairman,_ dated September 20, 1990

9) BECo Letter 91-021, dated February 25. 1991

10) NRC Letter to BEco, dated May 7, 1991 Commitment Historv/ Progress Progress and Summary of Changes - March 1989 to February 1990 BEco complies with the rule in all areas except diversity. As stipulated in the NRC SER (Ref. 7) on this issue, a schedule for resolution of the diversity issue will be developed following receipt of additional NRC

. guidance, or an exemption request from the diversity requirement will be submitted.

Progress and Summary of Changes - February 1990 to November 1990 i Absent the specific NRC guidance, but based on the Reference 8 NRC denial of the BWR Owners Group appeal on diversity, we are presently planning to purchase trip units and relays to address diversity for Pilgrim Station.

A separate BEco letter outlining further details and implementation schedules is planned for submittal in the near future.

i Progress'and Summary of Changes December 1990 to February 1991 1 _ Based on the Referenca 9 loter providing our resolution for achieving diversity for Pilgrim Stat: m, we plan to replace Rosemount trip units with General Eles.ric trip .r.its during the mid-cycle outage in 1992. No actions are plannA for .eplacement of actuation relays-based on our

. exemption request, 4 0 submitted via Reference 9.

l Progress ~and Summary of Changes'- March 1991 to August 1991 In Referance 10, the NRC granted our exemption request for actuation relays and accepted our proposed' schedule for replacing Rosemount trip units with General Electric trip units during the 1992 mid-cycle outage.

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This replacement is on schedule for completion during the 1992 mid-cycle outage.

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4 ATTACHMENT 2 (Continued) e SCHE 0VLE A-t Progress and Summary of Changes - August 1991 to February 1992 Replacing Rosemount trip units with General Electric trip units is on schedule for completion during the 199? mid-cycle outage.  ;

Progress and Summary of Changes --March 1992 to August 15, 1992

.. Replacing-Rosemount' trip. units with_ General Electric trip units is on schedule for completion during the 1992 mid-cycle outage, j t

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. _ . . - _ __ _ _ _ __._ i . - - . . . _ _ _ _

ATTACHMENT 2 (Continued)

SCHEDULE A

_SIATION BLACK 0UT RULE (SB0J (LTP #043)

Commitment Description 1he rule required a submittal by April 17, 1989, providing:

• a specified station blackout duration witn justificatior ;

• a description of procedures for SB0 events and recovering from them

• a list of proposed modifications and schedule including procedures for meeting the 580 duration BECo responded in Reference 2. A schedule for completion of modifications will be determined and submitted within 30 days following receipt of an NRC notification accepting BEco's proposed design. 10CFR 50.63(c)(4) requires the completion within 2 years of notification by NRC that the proposed design _is acceptable or provide an explanation and a justification if the schedule will exceed 2 years.

BECo received the NRC Safety Evaluation Report (Reference 6) on February 25, 1991. An initial response describing SBO-related modifications planned for RF0 #8 was submitted on March 26, 1991 via Reference 7.

In Reference 8, we provided an implementation schedule of RF0 #9 for the remaining equip:nent and procedure modifications, and a schedule for resolving inn NRC Safety Evaluation Report recommendations based upon NRC's acceptance of our justification for 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> SB0 duration.

l Tht. SB0 equipment modifications completed in RF0 #8 included the installation of protective relays required to connect the SBn Diesel Generator to the 23KV circuit entering PNPS, to enable load testing of the Alternate AC source during station operation. Additional modifications to enable the operators to energize the shutdown buses with power from the SB0-Diesel Generator within 10 minutes of a SB0 event are scheduled for RF0 #9. In earlier correspondence, we indicated the modifications would permit the operators to energize the shutdown buses from the Control Room.

This may not be necessary to meet the requirement for power from the SB0-Diesel Generator within 10 minutes of a SB0 event. The remaining equipment and associated procedure modifications are based upon the previously-described commitments to comply with the Station Blackout Rule l- by designating Pilgrim's SB0 Diesel Generator as the Alternate AC source.

as defined in 10 CFR 50.2.

, In Reference 8, we also supplied additional information supporting our l conclusion that Pilgrim should remain in the P2 site characteristic group with a SB0 duration of 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. NRC's concurrence was requested by August 1, 1991, so that we could resolve the SER recommendations by December

! 1991, based upon the 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> SB0 duration and the 10 CFR 50.2 requirements l ;for an Alternate AC source. The NRC issued a Supplemental Safety Page 4 of 54 m

ATTACHMENT 2 (Continued)

ECHEDULE A Euluation report, dated January 15, 1992 AReference 9) stating that PNPS is a P3 plant with a 580 duration of B hours. The SSE requested a 3

schedule for the rtsolutior, of open issues within 30 days of receipt of the letter.

Re_fstenc_c3

1) 10CFR50.63 (53FR23203, dated June 21,1988)

2) BECo Letter 89-057, dated April 17, 1989

3) NUMARC Letter to NUMARC Board of Directors, dated January 4, 1990

4) BECo Letter 90-044, dated March ?8, 1990

5) BECo letter 90-106, dated August 31, 1990 ,

b) NRC Letter dated February 13, 1991 [

7) BECo Letter 91-042, dated March 26, 1991  !

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8) BEco Letter 91-074, dated June 3, 1991 NRC Letter dated January 15, 1992

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10) BEco Letter 92-017 dated February 26, 1992 11)- NRC Letter 92-057 dated March 5, 1C92 Commitment Histor_Y/ProQress Progress and Summary of Changes - March 1989 to February 1990 As part of the Safety Enhancement Program, BEco has installed a 3rd diesel to provide emergency power during station blackout (580) periods. In compliance with the rule, a letter was transmitted to NRC on April 17, 1989 committing to Jesignate this 3rd diesel as an Alternate AC Source and to implement a ser'es of modifications to enable the starting and loading of the 3rd diesel from the Control Room within 10 minutes of an SB0.

These modifications will be scheduled upon receipt of a NRC SER.

The NRC review of BEco's submittal generated several questions that were discussed in a telephone call on December 20, 1989. Since then, the NRC via NUMARC has requested all Licensees to re-confirm the level of conformance to the NUMARC SB0 guidelines used by the Industry to develop rule compliance.

10CFR50.63(C)(4) requ;res the submittal of a schedule for completion of a SB0 modifications within 30 days of NRC notification that our proposed modifications are acceptable. This submittal must include an explM ation of the schedule and a justification if the schedule does not piniue completion of the modifications within two years of the nntification.

In our April 17, 1989 letter providing the details of our proposed modifications, we projected an RF0 #8 completion date in anticipation of receiving an NRC acceptance notification shortly after the April 17, 1989, submittal. This not beitg the case, we no longer plan to complete these modifications by RF0 #8. A schedule for completion will not be available until the receipt of the NRC notification.

Page 5 of 54

f 6, 4w_da- g u ad - h.R -4&R2- ,as--e- 4-,-e-,- A - e, sek.pw & 4 aB, -a4<,',u+s.

n l ATIACHMENT 2_(Continued)

SCHEDlllE A -j Progress and Summary of Changes - February 1990 to November 1990 in response to the Reference 3 NUMARC request, we submitted information to the NRC (Reference 4) describing modifications we intend to make to qualify the 3rd diesel as an alNrnate AC source u defined in 10CFR50.?.

A prompt NRC review and Safety Evaluation Report was again requested in order that completion of the modification cou N be accomplished by RF0 #8, t

Other applicable supplemental information O " = .nse to the NUMARC

-request was prepared and submitted to the tc' via Reference 5.

Progress and Summary of Changes - December 1990 to February 1991 BECo received the NRC's February 13, 1991 Safety Evaluation- on February 25, 1991. We will review the Safety Evaluation an provide an initial response by March 27, 1991 and a detailed schedulc by June 1,1991.

Progress and Summary of Changes - March 1991 to August 1991 An' initial response to the Reference 6 NRC Safety Evaluation Report was submitted on March 25, 1991 (Reference 7) describing SB0 related modificatien planned for RF0 #8.

As described in the Reference 7 response, installation of protective relays to allow load testing of the Alternate AC source during station operation were:completeJ during RF0 #8.

! In Reference 8, we provided an implementation schedule of RF0 #9 for the remaining equipment and procedure modifications, and a schedule of December.1991 for resolving the Safety Evaluation Report rec: mendations.

We also.suppi'ed additional information supporting ou conclusion that Pilgria should remain in the P2 site characteristic group o th a 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> SBO. duration. NRC's concurrence was requestec' by August- 1991 so that we could resolve the SER recommendations by December 1991, based upon the 4 hout _ SB0 duration and the 10 CFR 50.2 requirements for an alternate AC sourca. The NRC response has not been received. We will provide a revised schedule-for-resolving the SER recommendations after receipt of

.the NRC response.

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Progress and Summary c Changes-- August 1991 to February 1992 A Supplemental: Safety Evaluation Report was issued on January 15, 1992, stating that Pilgrim Station is a P3 plant with an 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> 580 duration. A -

schedule for' resolving additional SER recommendations was requested within

'30 days of BEco's receipt. In Reference 10 we responded with the following schedule commitments:

L L +- By RF0 #9, complete modifications and testing to energize the

! shutdown buses within 10 minutes of a SBO.

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• By 1992 MCO, complete an assessment on the effects of ventilation for an 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> SB0 duration.

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ATTACHHENT 2 (Conti?aed)

SCHLDULEJ Progress and Summary of Changes - March 1992 to August 15, 1992

• A plant design change for the modification to energize the shutdown buses from the control room within 10 minutes of an SB0 event has been prepared at:d is scheduled for implementation in Rf0 9.

• We have implemented an Emergency Diese) Generator Reliability program.

• We are in the final review stage for the assessment on the effects of ventilation for an 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> SB0 duration.

These actions are consistent with the commitment dates above. -

F Page 7 of 54

ATTACHMENT 2 (Continued)

EClLE.DULE 6 tiAINTENMLCE RULE (LTP #584)

Commitment DescriptioJ1 10CFR50.65 " Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants " was issued as a final rule on July 10, 1991 (Reference 1). Licensees are required to have in place by July 10, 1996, a progran, capable of monitoring the overall continuing effectiveness of their maintenance programs to ensure that safety related and certain non-safety related structures, systems, and components are capable of performing their intended functions; failures of non-safety related equipment will not occur which could prevent the fulfillment of safety related functions; and failures resulting in scrams and unnecessary -

actuations of safety related systems are minimized.

The rule has a five year implementati.a schedule with supporting regulatory guide dcvelopment and promulgation expected within the first two years. This schedule allows three years for licent :e development beyond the time that final guidance is expected to be "ai h ble.

References

1. Federal Register Vol. 56 No.132, dated July 10, 1991 Commitment History / Progress Progress and Summary of Changes - March 1991 to August 1991 A program for ensuring compliance with the maintenance rule is being developed and will be provided in the next regular report for the LIF.

Progress and Summary of Changes - August 1991 to February 1992 Our implementation approach for the maintenance rule consists of two major aspects:

• A program to monitor the performance of specified structures, systems and components (SSCs) against established goals, and

+ Use of the reliability centered maintenance (RCM) concept to upgrade the Stati-on's preventive maintenance program.

De mlopment of our monitoring program is esolving in concert with the guidance documents being established by NUMARC and the NP.C. The NUMARC guidance is being established to address four areas: selection of SSCs to be covered by the rule; goal setting and performance monitoring; demon;trating equipment functionality by inherent SSC characteristics or by appropriate preventive maintenance; and the removal of plant systems from service without affecting overall plant safety. We understand the NRC guidance will describe acceptable methods for Licensees to monitor the overall continuing effectiveness of their maintenance activities, while offering flexibilities in establishing goal setting, monitoring, and preventive maintenance activities.

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ATTACHMENT _2 (Continued)-

SCHEDULE _a I The RCM' program commenced in January 1992 with the formal establishment of an RCM team. The EPRI " Work Station" RCM sof tware was selected for use in RCH system analysis. RCM team training on this software and RCH methodology;was completed-in January 1992.

The RCM program scope identifies and prioritizes 47 plant systems, each ,

requiring approximately 16 weeks of work. A number of systems will be l worked in parallel. Completion of the identified program scope is- i scheduled for May 1994.  ;

- Progress and: Summary ~of Changes:- March 1992 to August- 15,1992 1 PNPS;is. continuing withfa preventive. maintenance-program upgradeLutilizing-  ;

RCH methodology. An additional-: system has been added to~the RCM program.

-scope bringing the total numberj of systems > to 48. The analysis of-three systems has been completed. .The; identification of SGC's.within the scope p of the maintenance rule is underway and'. scheduled for'cotapletion in 1992.

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ATTACHMENT 2 (Continued)

SCHEDULE A 10CFR20 STANDARDS FOR PROTECTION AGAINST RADIATION (LTF #551)

Commitment Description In Reference 1, the NRC issued a revision to the 10CFR20 requirements,

" Standards for Protection Against Radiation." These revisions became effective on June 20, 1991, and are required to be implemented by January 1, 1993, in their entirety. Licensees have the choice of implementing the new requirements in their entirety prior to January 1, 1993, with notification to the NRC, or continuing with the existing requirements until January 1, 1993, after which they must adopt the new requirements, implementation of selected por . ions of the revised rule is not allowed prior to the January 1, 1993 deadline. -

The revised rule changes the existing radiation protection requirements and practices, accounting of occupational exposures, maintenance of exposure records, General Employee Training, and Health Physics training.

The NRC is also revising certain Regulatory Guides and istuing new Regulatory Guides to provide regulatory positions and guidance f or implementing the revised requirements, in reference 2, the NRC proposed delaying the implementation date for the a revisions to 10CFR20 until January 1, 1994.

References

1. Federal Register Vol. 56 No, 98, dated May 21, 1991

2. 57FR21216 Extension of Implementation Date, Proposed Rule, dated May 19, 1992 Commitment Histor_Y/ Progress _

Progress and Summary of Changes - March 1991 to August 1991 -

A program is being developed to ensure compliance with the revised requirements within the prescribed implementation schedule and will be provided in the next regular report for the LTP.

Progress and Summary of Changes - August 1991 to February 1992 Selected personnel in the Nuclear Organization were trained in the requirements of the revised 10CFR20, and program elements for the implementation of the requirements have been developed. These are: a new system for Radiological Information Management, revision and development of new procedures, development of training module and training of personnel, and equipment evaluation for potential modifications. These elements are in various stagas of implementation. Additionally, we worked with NUMARC in the development of comments on several draft regulatory guides issued by the NRC in the October / November 1991 time frame. We are continuing our effort for the implementation of the requirement by using NRC guidance from draft regulatory guides.

Implementation of the final rule is on schedule for completion by January 1, 1993.

Page 10 of 54

1 1

1 ATTACHMENT 2 (Continued)

SCHEDULE _a Progress and Summary of Changes e; March 1992 to August 15,1992 _

We are'. continuing . implementation of various; elements of the Radiation .

Protection Program requirements' to comply with.the revised 10CFR20. '

. plan to be in full compliance with 10CFR20. requirements by the NRC . We proposed new schedule of-January 1, 1994.

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ATTACHMENT 2 (Continued)

SCHEDULE A EMERGENCY RESPONSE DATA SYSTEM (LTP #579)

Commitment Description Per Referente 1, the NRC issued a final rule requiring all operating nuclear power facilities to participate in the Emergency Response Data System (ERDS) program. Participation in the ERDS program entails a direct near real-time electronic data link between the plant's onsite computer system and the NRC Operations Center that provides for the automated transmission of a limited data set of selected parameters during a declaration of an ALERT or higher emergency classification.

The rule required an ERDS implementation program plan to be developed and -

submitted to the NRC by October 28, 1991. Implementation of the ERDS must be complete by February 13, 1993, or before initial escalation to full power, whichever comes later. In P.eference 2, we provided a schedule for August 31, 1992, for ERDS implementation.

References

1. Federal Register Vol. 56, No. 156, dated August 13, 1991.

2. BEco Letter 2.91.146 dated October 25, 1991.

3. BECo letter 2.92.003 dated January 13, 1992.

Commitment History / Pro 9 raja ,

Progress and Summary of Changes - March 1991 to August 1991 An ERDS implementation program pian will be submitted by October 28, 1991.

Progress and Summary of Changes - August 1991 to February 1992 Our LRDS Implementation Program Plan was submitted via Reference 2, with August 31, 1932, as our project completion date, s

The ERDS Data Point Library was submitted via Reference 3.

ERDS completion is on schedule for August 31, 1992.

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Progress and Summary of Changes - March 1992 to August 15, 1992 The acceptance test for ERDS between BECo and the NRC's contractor, NUS -

Halliburton, was successfully completed on August 20. The subsequent final test between BECo and the NRC has not been successfully completed.

The NRC is troubleshooting the software and hardware. Project completion is expected by September 30, 1992.

Page 12 of 54

ATTACHMENT 2 (Continued)

SCHEDULE B DETAILED CONTROL ROOM DESIGN REVIEW (G.L.82-331 (LTP #299, 300, 327, 328, 375)

Commitment Description References 6, 7, and 8 provided a DCPDR Supplementary Summary Report with update information, panel enhancement program information, and a revised DCRDR program plan, respectively. Reference 9 revised the schedule commitments for enhancements to three control panels singled out by BECo for completion ahead of the others.

A final DCRDR Summary Report, Reference 10, was submitted on November 30, 1990. This summary report included detailed scope and schedules for the -

remainder of DCRDR issues to be implemented at Pilgrim Station, summarized as follows: ,

Complete installation of control room ceiling lighting improvements (LTP 375) by December 31, 1991.

Complete remaining " Category 7" HEDs (non-engineered actions) by March 31, 1992. '

Complete control panel enhancements (LTP 300 plus portion of LTP 328) by end of RF0 9.

Complete control panel improvements (balance of LTP 328) by end of RF0 9 (outage portion) and December 31, 1993 (on-line portion).

Begin installation of replacement annunciator in RF0 9 (completion date to be established)(LTP 327). _

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Referencer

1) NUREG 0737: Item I.D.1

2) BECo Letter 84-159, dated September 24, 1984

3) NRC Letter 85-157, dated May 16, 1985

4) NRC Letter 86-002, dated January 6, 1986

5) BECo Letter 87-008, dated January 20, 1987

6) BECo letter 89-064, dated May 2, 1989 7)- BECo Letter 89-102, dated July 6, 1989

8) BECo Letter 89-112, dated July 24, 1989

9) BECo Letter 90-008, dated January 11, 1990

10) BEco Letter 90-147, dated November 30, 1990

11) BECo Letter 91-099, dated July 31, 1991

12) NRC Letter 92-178, dated July 13, 1992 Commitment History /Procress Progress and Summary of Changes March 1989 to February 1990 Submit Supplementary Summary Report - Complete i

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ATTACHMENT 2 (Continued)

SCHEDULE B Progress anc' Summary of Changes - February 1990 to November 1990

- The final DCRDR Summary Report was submitted November 30, 1990.

- As a result of ongoing human factors evaluations, the scope of control room panel enhancements has expanded beyond those committed in Ref. 7 The on-line portion is planned to be completed by June 30, 1992; the outage portion is planned for completion by the end of RF0 #9. The extent of enhancements to be performed in RF0 #8 and those to be performed on a later schedule are detailed in the November 30, 1990 Final DCRDP. Summary Report submittal . The next LTP update will reflect the revised scope and schedule of the summary report.

- We have determined improvements to control room lighting can be implemented on line. Therefore, we are revising the previous completion date of the end of RF0 #8 to completion by December 31, 1991. We plan to install the lighting improvements on-line before RF0 #8. However, in the event they are not completed before RF0 #8, we will complete them by December 31, 1991.

Progress and Summary of Changes - December 1990 to February 1991 Currently, work to accomplish the items listed in Reference 10 is on schedule.

Progress and Summary of Changes - March 195? to st 1991

'he following improvements were implemented vring RF0 #8:

• Installed welded patches to restore all main control panels to uniform flat, flush, smooth surface suitable for painting and for installation of improvements. ,

• Repainted all control panels in main operating area, and began ef fort to repaint the "back panels."

• Replaced labels and installed new mimics and demarcations on 10 panels, plus revisions to mimics and labels on additional panels.

• Completed removal of abandoned equipment from Main Control panels.

• Replaced approximately 325 switch escutcheons and 200 switch handles.

• Rewired or replaced 17 switches, continuing a program to achieve uniform switch positions and patterns.

• Rearranged 3 groups of switches and 3 groups of indicator? to achieve more logical arrangement.

• Installed an additional set of scram and MSIV indicators on Panel C905.

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l ATTACHMENT 2 (Continued)

SCHEDULL_B

= Replaced 6 meter scales with scales improved in readability; more to be installed on line, after RF0 #8.

In Reference 11, we notified the NRC that we will not be implementing switch rearrangements for the Safety Relief Valves. The work to accomplish the remaining Reference 10 items is on schedule.

Progress and Summary of Changes - August 1991 to February 1992

= Planned construction of improved ceiling lighting was completed by December 1991. Post-work testing was completed in January 1992.

Post-work testing identified the need for one additional fixture in the back panel area that will be installed during the next report period.

• Procedure revisions and other non-engineered corrective actions in

" Category 7" were completed except for one HED relating to an E0P display space. An improved E0P display stand is expected to be installed by June 30, 1992.

. Installation of control panel enhancements (labels, mimics, domarcation) were continued in the control room and simulator.

• Efforts continue on the preparation of design packages for panel improvements to be installed in the 1992 Mid-cycle Outage and in RF0 9 (1993).

• We continued the signal-by-signal review of annunciator system and initiated the planning effort to establish scope and schedule for the annunciator upgrade.

1

+ Plans are being made to finish re-painting the Control Room back panels with a target completion date of September 1,1992.

+ Installation of improved instrument scales continued in RF0 #8. Some of the instrument scales originally scheduled for replacement in RF0 8 were not installed because of emergent technical issues. It is expected that the scale replacement program will be completed by the end of RF0 9 as originally scheduled.

Progress-and Summary of. Changes - March 1992 to August 15, 1992

• - Completed installation of one additional light fixture in control room ceiling which completes physical work on control room lighting.

• Completed installation of E0P support stands in control room and simulator which completes Category 7 actions, as previously planned.

• Completed installation of control panel labels, mimics, and demarcations on control room panels in original (LTP 300) scope, as planned, including marking of RG 1.97 devices.

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ATTACHMENT 2 (Continued)

SCHEDULE B a Completed preparation of engineering .hange packages for CRDR modifications to be implemented in 1992 mid-cycle outage and in RF0 9, as planned.

• Initiated detai'ed design of annunciator replacement project.

• Continued re-painting of control room panels and began repainting of simulator panels. All front panels and the majority of the back panels are now complete.

• Conducted task analysis and prepared conceptual designs of panel C7 redesign in preparation for decision on scope and final design. The changes related to Panel C7 are as follows: ( a '. ' redesign of Panel C7, referred to in Reference 10, Appendix 0 as Package 16; (b) .

redesign N2-portion of C904, Package 20; (c) Replace Kaye Recorder, Package 22; and (d) rewire C7 switches (no package number). As previously docrnented in _ Reference 12, .this work will be done in MC094 due to the long lead time for the design and procurement of the new panel.

• The folicwing establishes schedules for two items: (a) Replacement of instrument scales is now expected to be completed by-the end of RF0 9. (b) The " priority paging" modification (Page III-18 of Reference 6) was installed in 1989.- We are re-evaluating the adequacy of the priority paging' feature as well as possible changes to toe basic Gai-Tronics configuration. If more extensive modifications are undertaken, the scope and schedule will be provided in' the next LTP update-le wr.

• Colored zone markings on instrument scales as described in Reference 10 (Paj 'II-16) and the use of Light Emitting Diodes (LEDs) to renlace indicator light bulbs continue to be wor ked as elective actions being done as part of the DCRDR project. .

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ATTACHMENT 2 (Continued)

SCHEDULE B REGULATORY 00101 1.97 (G. L.82-331 (LTP #305, 326, 377)

Commitment Description Generic Lettet 82-33 required each licensee to review the accident monitoring instrumentation available at their facility and to compare this instrumentation with the recommendations of Regulatory Guide 1.97. The results of BEco's review and comparison for PNPS was provided by Reference 2, with a projected project completion schedule-by RF0 #8. ,

A summary of compliance submitted to the NRC in Reference 8 restated compliance information previousiy submitted, provided new information for specific variables, and identified open items requiring additional work by BECo. Based on the extent of open items for this project, the project completion schedule was changed to RF0 #9. This revised project completion schedule was contingent upon NRC approval of both our summary of compliance and the BWR Owner's Group position on neutron flux monitoring-capability.

In the February 28, 1991 LTP Update, we rescinded the schedule for

!> completion of the project .because we had not then received NRC approval of our summary of compliance <

The NRC safety evaluation report (Reference 11) has since been received.

Although this safety evaluation report is not complete, the remaining open-or unraveled issues are expected to be resolved in time to support project completion by RF0 #9. Therefore, the schedule for project completion by the end of.RF0 #9 is reinstated.

L Project- completion by RF0 #9 is based upon expected NRC acceptance of the BWR Owners' _ Group appeal on neutron flux monitoring capability. If the

-NRC does not accept this appeal, addressing this issue at PNPS will L require a-revised project completion schedule.

References

1) NRC Generic Letter 82-33, dated December 17, 1982

2) BECo Letter 84-187, dated November 1, 1934

-3) _NRC_ Letter 85-372, dated December 12,- 1985

4) _BEco Letter 87-021, dated February 10,-1987 L 5) NRC Letter 89-044, dated January 24, 1989

6) -BECo Lett_er 89-053, dated April-11, 1989

_7); .BEco Letter 90-005, dated January 11, 1990 L _8) BEco Letter 90-010, dated January 15, 1990 9)- BEco Letter 90-049, dated April 5, 1990

10) BWROG Letter to NRC, BWROG-90107, dated August 20, 1990

11) NRC Letter 91-070, dated March 13, 1991-

'12) ~BECo Letter 91-040, dated March 20, 1991

13) BECo Letter'91-066, dated May 13, 1991

14) .NRC Letter 92-167, dated June' 23, 1992 (Inspection 92-06)

Page 17 of 54

ATTACHMENT 2 (Continued)

SCHEDUtE B Commitment History / Progress Progress and Summary of Changes - March 1989 to February 1990 Schedule revised.

BECo responded to the NRC request for additional information (Reference 5) on April- 11, 1989 and supplied the information for instrumentation monitoring effluent radioactivity and status of standby power on January 11, 1990. In addition, a summary of compliarice with updated information for specific variables and open items requiring additional work was provided on January 15, 1990. We are presently awaiting NRC disposition of remair.ing open issues.

Based on the scope of open items identified in our recent summary of

, compliance submittal, dated January 15, 1990, and the re-allocation of l BEco resources to accommodate the prioritization of the other LTP issues, L the project completion schedule is revised from RF0 #8 to RF0 #9. This

revised project completion schedule is subject.to change based on the

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! NRC's review of both our summary of complitnce and the BWR Owners' Group l

position on neutron flux monitoring capability. ,

Progress and-Summary of Changes - March 1990 to November 1990 In anticipation of the NRC's issuance of a safety evaluation _ report for Regulatory Guide 1.97 compliance at PNPS, BLtc provided an updated summary of compliance to the NRC on April 5,1990 (Reference 9). This update provided the results of our seismic. verification program for Regulatory Guide .l.97 Category I for primary containment isolation valve -indication and seismic Category 2' equipment at-PNPS, and provided new information on certain-compliance details and exceptions. The BWR Owners' Group submitted a request to the NRC (Reference 10) to appeal the requirement for a post-accident ne'utron monitoring system that complies with Regulatory Guide 197. The Raplatory Guide 1.97 project scope will accommodate the results of the NRC's decision on this appeal. If the appeal _is rejected, the addition of work to procure and install a post-accident neutron monitoring system at PNPS t:ill require a revised project completion schedule.

l Progress: ard Summary.of Changes - December 1990 to February 1991 i

During RF0 #8, additional- safety-related power supplies will be installed for containment isolation valve position switches on the radwaste collection and drywell equipment sumps. A testing and analysis program to L provide the basis for Environmer.tal Qualification of Regulatory Guide 1.97 l equipment at Pilgrim is in progress. Additional samples of cable will be j obtained early in 1991 for testing and evaluation. Laboratory testing of L cable and other components is being conducted at Wyle Laboratories. This l testing program will be completed in 1991.

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ATTACHMENT 2 (Continued) l l

SCHEDVLE B l

Additional actions will be planned and scheduled af ter receipt of NRC l response to the Reference 9 submittal.

Progress and Summary of Changes - March 1991 to August 1991 On '. arch 13, 1991, the NRC issued a safety evaluation report (SER) of our coaformance to Regulatory Guide 1.97 (Reference 11). This SER found the majority of our identified deviations from full compliance to be accaptable, with exceptions for certain aspects of redundancy and separation, electrical interfaces, channel availability, quality assurance, and servicing, testing, and calibration. In addition, several of our deviations identified in References 9 and 12 bave not yet been reviewed-by the NRC in this 5ER- .

Concurrent with the receipt of the NRC SER, we submitted an update of our summary of compliance (Reference 12). This update provided additional information on _our compliance with design and qualificai. ion criteria and the status of standby power and other energy sources important to safety.

In addition, this update included a new deviation concernirg the monit; 'ing of- noble gasas and vent flow rates through the main stack.

We responded to thr NRC SER with an additional update to our summar3 of compliance dated May' 13, 1991 (Reference 13). This update provided the requested commitment to provide the redundancy and separation recommended by Regulatory Guides 1.97 and 1.75 for those portions of instrumentation being upgraded to conform with Category 1 criteria. Other changes to our summary of compliance were included to address the other open issues in the NRC SER, with the exception of electrical interfaces. In a telephone i conversation on April 29, 1991, we discussed this open issue with the NRC and their-reviewer. .The NRC stated the design at PNPS appeared to be acceptable for a plant of-our vintage, but they requestea a formal submittal-.to_ cupport this possible conclusion. Additional information on the electrical isolation design at PNPS will be stiomitted to the NRC to

support further NRC-review of the acci,;tability of our current design.

During RF0 #8, additional safety-related power supplies were installed for containment-isolation valve position switches on the radwaste collection j- and drywell equipment sumps, This modification completes the actions required for LTP Item 301.

The samples of electrical cable needed to complete the testing and L

analysis program for environmental qualification have been obtained. The laboratory testing of these cable samples and other components is still l

-underway at Wyle_ Laboratories. The testing portion of this program is

! still expected to be completed in 1991'.

L With the receipt of the NRC SER, the schedule for project ccmpletion by L the end of-RF0 #9 is reinstated. Although this SER is not complete, the remaining open or unraveled issues are expected to be resolveo in time to l

Page 19 of 54 ,

ATTACHMEN1 2 (Continued)

. SCHEDULE B support project completion by RF0 #9. This schedule is based upon the expected NRC acceptance of the BWR Owners' Group appeal on_ neutron flux monitoring capatility. If the NRC does not accept this appeal, addressing this issue at PNPS will require a revised project ccmpletion schedule.

Progress and Summary of Chances - August 1991 to February 1992

. Wyle laboratory testing of electrical cable samples is partially

. complete and is expected to be completed by June 30, 1992.

• The following modifications were designed and arc scheduled for implementation during the 1992 Mid-Cycle Outage:

llormal Ranae RPV Level Recordef_s (PDC 90-19): lhis modification will replace the existing level signal input to LR1001-604A, B Pen #2 from LT263-120A, B via L1253-121A, B with a qualified level signal from t.T263-72A, B via E/1263-72A,B. A shunt

- resistor will be added to the input circuit of the recorders to accommodate the change in input voltages. A new cable will be pulled through existing conduit between Panels C171 and C22338.

. RHR Heat Exchanaer Flow (PDC 90-53): This modificatinn will replace the following four thermocouples (Type T) with Pyco equivalent fype T environmantally qualified thermocouples:

TE1045A,8 & TE1047A,B.

. Tocus Pressure Indication (PDC 90-07): Th;s moditication will add a redundant Torus Bottom Pressure Transmitter (PT1001,-69A) with remote indication (pit.001-69A and PR1001-09) on C903. The new transmitter will be installed at an existing torus penetration, ,

• Post Accident Effluent Samplino (PDC 92-05): This modification will provide shielding for effluent sample holders as spec r ed in NUREG-0737, Table II.F.1-2 and R.G. 1.97.

• Completed laboratory testing of Microswitch limit switches for thermal, seismic, radiation, cycling and functional requirements.

. Initiated completion af remaining RF0 #9 scheduled modifications.

Progress and _ Summary of Changes - Februwy 1992 to August - 15,1992

. Wyle laboratory testing _of. electrical cable samples was not completed by June 30, 1992. It is progressing and is expected to be completed by October 1992.

. Completed 'ngineering for RF0 :r9 modifications.

• Completert the NRC R.G.1.97 Inspection and have no follcw-up action items.

Page 20 ot 54

ATTACHMENT 2 (Continued)

SCHEDUll B SEISHIC VER_lFICATION PROGRAM (G. L.87-021 ( P #410)

Commitment Description As a member of the Seismic Qualification Utility Group (SQUG), BFCo plans to implement the seismic verification program at PNPS through the Generic Implamentation Procedure (GlP) developed by SQUG. Reference 2 provided an initial series of activities planned to occur during Operating Cycle 8 in 1989 and 1990. These activities were to: develop a safe shutdown equipment list; locate, assemble, and/or recreate original design basis seismic documentation for the above-identified equipment. provide training for our walkdown team members; and commence the walkdown in accessible areas. The schedule fcr completion of these activities was revised via -

our February 20, 1990 LTP update, to Operating Cycle 9 in 1991 Cd 1992.

However, as stipulated in our Reference 2 submittal, the suct .j ul completion of these activities within these time frames depen _

• largely upon the SQUG/NRC disposition of the SER open issues.

The revised schedule for these activities and for final completion of the seismic verification program is being developed and will be submitted as required by Reference 4.

References

1) NRC Letter 87-078, Generic Letter 87-02, dated February 19, 1987

2) BEco Letter 88-145, dated October 11, 1988

3) NRC Letter 89-223, dated June 7, 1989

4) NRC Letter 92-138, Generic Letter 87-02, Supplem d 1, dated May 22, 1992 Commitment History / Progress ,

Progress and Summary of Changes - March 1989 to February 1990 A. Develop safe shutdown equipment list - Schedule Revised B. Recreate original seismic design basis documentation - Schedule .

Revised C. Training and commence walkdown of accessible areas - Schedule Revised The schedule for performing these three items was revised from Cycle 8 to Cycle 9 as a result of our re-assessment of the work to be performed for this seismic issue, with respect to the generic work scope for other similar existing and emerging seismic issues. By incorporating the similarities of work scope for each of the below listed issues into one set of physical activities, we can best optimize our rosources. Other seismic issues include:

• Seismic Design Basis (USI A-40)

• Eastern Seismicity and Seismic Design Margins External Events (seismic) for Individual Plant Examinations Page 21 of 54

ATTACHMENT 2 (Continued)

SCHEDULLB Progress and Summary of Changes - February 1990 to November 1990 m

" A revised schedule for implementation of the seismic verification program will be developed after issuance of the NRC SER resolving the GlP open issues.

Progress and Summary of Changes - December 1990 to February 1991 No changes from M nravious report period.

Progress and Summary of Changes - March 1991 to August 1991 A schedale for implementation of the seismic verification program will be -

developed after issuance of the NRC SER resolving the GIP open issues.

Progress and Summary of Changes - August 1991 to February 1992 A schedule for implementation of the seismic verification program will be developed after issuance of the NRC SER resolving the GIP open issues.

• Progress and Summary of Changes - March 1992 to August 15, 1992 Reference 4, issued the final NRC SER (SSER No. 2) resolving the GIP open issues and superceded all previous NRC SER documents A response containing the following information will be made by September 21, 1992:

• A statement whether we commit to use both the SQUG commitments and the implementation guidance provided in GIP-2 as supplemented by the SSER No. 2 for the resolution of USI A-46.

• A plant-specific schedule for the implementation of the GIP and ~

submission of a report summariziag the results of the USI A-46 review.

• Detailed description of the procedures and criteria used to generate the in-structure responsa spectra.

Page 22 of 54

ATTACHMENT 2(Continued)

SCHEDULE B EUYSICAL SECURIIY IMPROVEMENTS (LTP #029)

Commitment Description In response to NRC-inspection findings, and as a plant betterment activity, BEco committed to replace the security computer and improve certain security activities. This includes miscellaneous perimeter improvements (completed in December 1989), installation of new security computer facilities, a new security computer and access control system, and a backup power supply.

f,eferences t

1) NRC Letter 85-119, dated April 30, 1985 (RER Report)

2) 1&E Inspection Report 86-08 dated 5/29/86 Cqmmitment History / Progress l Progress and Summary of Changes - March 1989 to February 1990 A. Misc. perimeter improvements - Complete B. Facilities change to house new computer - On Schedule for completion by December 31, 1990.

C. Backup power supply changes - Schedule revised D. Develop & install new computer & access control equipment - On  !

Schedule for completion by December 31, 1991. l The schedule for backup power supply completion was revised from L ecember -

1990 to June 1991. This change was made to properly reflect the actual l integration of this activity with respect to the remaining security l improvement activities.

l Progress and Summary of Changes - February 1990 to November 1990 i

! -* Facilities change to house new computer - Schedule revised from December 31, 1990 to December 31, 1991.

• - Backup power supply changes - Schedule revised .from June 1991 to

' December 31, 1991.

• Develop & install new computer and access control equipment - On schedule for completion by December 31,-1991.

g- .

• System cutover of alarms and access control will be in full operation by June ~30, 1992.

l These changes in schedule are the result of unanticipated delays encountered during construction such as the procurement of materials to relocate existing fire water lines, removal of asbestos during building demolition, and contaminated material handling.

l Page 23 of 54

ATTACHMENT 2 (Continued)

SCHEDULE _B Progress and Summary of Changes - December 1900 to February 1991 Based on improvements undertaken to address NRC evaluations of our security perimeter conducted in 1990, and recent events in the Persian Gulf, we have re-focused our efforts involving physical security improvements to include additional work activities aimed at strengthening perimeter security. Inese additional activities will be completed in 1991 and include:

Upgrading the E-Field to a Series 5000 Installing a new Video Capture System Enhancing site lighting The integration of these activities with the present LTP activities necessitate changes to the projected completion dates. Progress summary and schedule changes are as follows:

• Construction has begun on a new facility to house the naw security system computer. Renovations to the bottom floor of the Main Cate House have also begun. This is part of the revised security facilities scope. This work will continue through 1992; thus, the completion date is changed from December 31, 1991 to December 31, 1992.

• A new backup power supply (diesel generator) has been ordered, and expected delivery is March 1991. Final completion of installation is revised to December 31, 1992 to coinc.ide with the computer facilities upgrade schedule.

• Performance acceptance testing of the new security computer system at the manufacturer's facilities has identified system problems that have delayed delivery. Delivery is anticipated within the next several months; therefore, staging and cummencement of training and security operating procedure revisions are planned for 1991. The final completion date for the computer and access control equipment is changed to December 31, 1992.

• - The system cutover of alarms and access control operational completion date is similarly revised to December 31, 1992 to accommodate the above schedule revisions.

Progress and Summary of Changes - March 1991 to August 1991

-

• Construction of a new facility to house the new security system l computer is on schedule for completion by December 31, 1992.

L Page 24 of 54

ATTACHMENT 2 (Continued)

SCHEDULE B

• The new backup power supply (diesel generator) was received on July 19, 1991. Inst;.llation is on schedule for completion by December 31, 1992.

• Delivery of the new security computer system has been delayed and is not anticipated until early 1992. The final completion date of the computer and access control equipment is on schedule for December 31, 1992.

• System cutover of alarms and access control operational is on schedule for completion by December 31, 1992.

• We are shifting the implementation schedule from 1991 to 1992 for -

upgradino the E-Field to a Series 5000. This revision is based on resource re-allocations for 1991 necessitated by work scope increases on other non security tasks during RF0 #8. The installation of a new Video Capture System and enhancement of site lighting remain on schedule for completion during 1991.

Progress and Summary of Changes - August 1991 to February 1992

• Construction of a new facility to house the new security system computer is on schedule for completion by December 31, 1992.

• Installation of the new backup power supply (diesel generator) is on schedule for completion by December 31, 1992.

• The security computer manufacturer has been unable to meet all of the .

contractur:1 obligations to deliver the specified system on schedule.

Ua are currently evaluating new manufacturers to complete the ~

software requirements for the security computer system. Selection of -

a new manufacturer is expected by April 1992 at which time an implementation schedule will be prepared. This delay also affects the system cutover of alarms and access control operations. A new schedule for these items will be provided in our next LTP semi-annual update.

• Upgrade of the E-Field is complete.

• Installation of the Video Capture System is complete.

• All construction work on the enhancement of the site lighting is complete. During post work testing, we discovered 2 areas (lights) that did not meet the light intensity requirements. One area (light) was corrected in January 1992. The remaining area (light) was completed in February 1992.

Page 25 of 54

ATTACHMENT 2 (Continued)

SCHEDULE B Progress and Summary of CL non- - March 1992 to August 15, 1992

+ Construction of a new facility to house the new security system computer is on schedule for completion by December 31, 1992.

• Installation of the new backup power supply (diesel generator) is on schedule for completion by December 31, 1992.

• TF security computer manufacturer was unable to meet contractural obligations to provide the specified system. All involvement with this vendor has been terminated and we are currently evaluating proposals from new manufacturers to supply the specified system.

Selection of a new manufacturer is expected in September 1992 at which time an implementation schedule can be prepared. This action also affects the access control system upgrade and system cutover of alarms . Resources are being expended to support completion'by December 31, 1993 or sooner if possible. This will be clarified in our next submittal after selection of a computer manufacturet.

Page 26 of 54

ATTACHMENT 2 (Continued)

SCHEDULE B BULLETIN 87-01. THINNING OF PIPE WALLS & GENERIC LETTER 89-08 EROSION / CORROSION INDUCED PIPE THINNING (LTP #005)

Coinmitment Description in response to Bulletin 87-01, BEco (Reference 1) committed to develop criteria for determining how frequantly to make thickness measurements and jevelop a datacase for monitoring erosion / corrosion. As a result of the issuance of Generic Letter 89-08 (Reference 2) and BEco's response (Reference 3), we committed to develop a formal procedure for implementation of a long-term erosion / corrosion monitoring program based on the guidelines developed by NUMARC and to conduct initial inspections during RF0 #8. In Reference 4, the NRC confirmed the acceptability and -

schedule of BECo's planned actions to be taken in response to Generic Letter 89-08.

In the development of the program, we decided to implement a specification for use during RF0 #8 defining the criteria for determining frequency of thickness measurements, the erosion / corrosion data base, and the locations and frequencies of inspections.

Development of a formal long-term erosion / corrosion monitoring program remains as an activity and will be completed by February 28, 1992.

Beferences

1) BECo Letter 87-159, dated October 2, 1987

2) NRC Generic Letter 89-08, dated May 2, 1989

3) BECo Letter 89-107, dated July 21, 1989

4) .NRC Letter, dated April 30, 1990

5) NRC Letter 92-196, NRC Inspection 50-293/92-12 dated July 17, 1992 _

Commitment History / Progress Progress and Summary of Changes - March 1989 to February 1990 The Bulletin 87-01 scope of work has been revised to incorporate the additional NRC guidance provided in Generic letter 89-08,

" Erosion / Corrosion Induced Pipe Thinning". Our Generic Letter response commitment to develop an erosion / corrosion monitoring procedure by October 31, 1990 was based on the need to complete the procedure development prior to conducting the physical inspections during the next refueling outage.

Due to unforeseen emergent issues regarding the Salt Service Water System and the allocation of resources needed to address the istues, the schedule was revised for completion to December 31, 1990. This change does not affect the ability to conduct inspections planned for RF0 #8.

l Page 27 of 54

l 1

l ATTACHMENT 2 (Continued) )

S_CHEDUl.E B Progress and Summary of Changes - February 1990 to November 1990

-A. - Develop criteria and data base for long-term erosion / corrosion monitoring is on schedule for completion by December 31, 1990.

B. Conductiinitial inspections is on schedule for RF0 #8.

-Progress and Summary of Changes - December 1990 to February 1991 ,

A. _ Develop criteria and-data base for long-term erosion / corrosion inonitoring is complete.

B. Conduct initial inspections is on schedule for RF0 #8.

Progress and Summary of Changes - March 1991 to August 1991 Initial inspections were_ conducted during RF0 (18. The Erosion / Corrosion inspection requirements related to RF0 #8 were defined in Specification M-577. The specification identified over 30 locations to be inspected via

, UT examination. -The piping locations selected for initial inspection during RF0 #8 constitute an estimated sampling (approximately 10% of the

- population) of the most highly susceptible areas of the following four plant systems. .

1. 1 Extraction Steam Piping - 8 Inspection Points

--Moisture Separator Piping - 8 Inspection Points 2.

3. Feed Water Piping .2 Inspection-Points

'4. Heater Drains ~and Vents - 11 Inspection Points ,

Pr_ior to-RF0 #8 two leaks were identified and temporarily. repaired on the Extraction Steam and Moisture Separator systems.

The results of the RF0 #8 E/C inspections were as follows:

~

I

1. _. Extraction Steam Piping -~ 8 original inspection. points resulted in ;l

. failure, 4 additional points inspected resulting in 3 failures.

-2. Moisture Separator Piping - 8. original inspection points resulted in 3 failures.

L. 3. Feed Water Piping - 2 original inspection points resulted iii no failures'.

p L 4. . Heater Drains and _ Vents - 11 original-inspection points resulted in no failures.

Based on an evaluation of the inspections that failed the-acceptance

-criteria-(several locations fat or below minimum wall requirements) and

considering that 2_ through wall leaks existed prior to RF0 #8, it was determined that large- scale piping replacement with a naterial less ~

susceptible to Erosion / Corrosion was the most effective option. The replacement material chosen was lW. chromium, M% molybdenum, alloy steel L -pipe.

Page 28 of 54

l 1

ATTACHMENT 2 (Continued)

SCHEDUi.E B The scope of the work completed during RF0 #8 included the following plant modifications:

• Replacement of 200 feet of 12 inch pipe and insulation on the 8th Stage Extraction Ste.; System in the condenser bay.

• Replacement / modification of 2 feedwater heater nozzles (E104A/B) on the 8th Stage Extraction Steam System in the condenser bay.

• Replacement of 2 turbine nozzles safe ends on the lith Stage Extraction Steam System inside the 'B' condenser.

• The temporary modification of 2 turbine nozzles safe ends on the llth Stage Extraction Steam System inside the 'A' condenser.

• The replacement of 700 feet of 6 inch pipe and insulation on the Noisttere Separator Drain System in the condenser bay.

• The replacement of 2 valve station headers on the Mo'sture Separator System; the post weld heat treating of over 100 welds and the restoration of all associated pipe supports and check valves.

The- above results will be factored into the f .velopment of our long term erosion / corrosion program, presently scheduled for completion by February 28, 1992.

Progress and Summary of Changes - August 1991 to February 1992 Development of the long term erosion / corrosion program description is complete. The program description includes provisions for identifying the specific inspection requirements for the 1992 mid-cycle and RF0 #9 outages, identifying the basis and methodology for implementing our erosion / corrosion program, and including administrative controls (i.e.,

procedures) that assure the NUMARC guidelines are satisfied and the structural integrity of E/C susceptible systems is maintained.

The implementing Nuclear Organization Procedure (NDP) will be completed by April 15, 1992.

Progress and Summary of-Changes - March 1992 to' August 15, 1992 The implementing Nuclear Organization Procedure was-issued. In July, the NRC conducted an audit of our E/C program and issued an inspection report

-(50-293/92-12).. The inspection concluded that we have a'well planned and l documented Erosion / Corrosion program in place. No examinations are planned for the October mid-cycle outage due to its short schedule. We are currently planning to examine approximately 100 locations for Erosion / Corrosion in RF0 9.

Page 29 of 54

ATTACHMENT 2 (Continued)

SCHEDUE B GENERIC LETTER 88-20. SUPPLEMENT 1. INDIVIDUAL PLANT EXAMINATION OF SEVERE ACCIDENT VULNERABILITIES (LTP #488, 567) i Cone.itment DescriDtioQ in response to GL 88-20 (Ref. 1) and its Supplement I (Ref. 2), BECo provided a program plan for completing an Individual Plant Examination (IPE) for severe accident vulnerabilities for Pilgrim Station (Ref. 3).

The schedule for completion was deferred to the February 1990 LIP update.

The NRC confirmed the acceptability of our program plan and requested we identify the milestones and schedule for completing the IPE and submitting the resu:+s (Ref.-4).

Our scheow for completing the IPE as originally proposed in the February

'1990 LTP update was October 1, 1991, with the results to be submitted by December 15, 1991. This schedule was revised in our December 1990 LTP update to completion and submittal by April 30, 1992.

l This schedule was revised to September 1992 in previous LTP updates.

t - Significant . milestones include:

• Initiating Event Data Review

• Preliminary Event Tree Development

• Fault Tree Development & Quantification Event Tree _Quantification

. -Containment Event Tree Development & Quantification References

1) Generic Letter 88-20, dated November 23, 1988

2) Generic Letter 88-20,. Supplement #1, dated August 29, 1989

-3) BECo Letter 89-159, dated October 27, 1989

'4) NRC Letter 90-006, dated January 10, 1990-

5) NRC Generic Letter 88-20, Supplement #2, dated April 4, 1990

6) NRC Letter 92-060, dated March 6, 1992

_7) - lNRC Letter 92-159, dated _ June 16, 1992 Commitment History /Proaress Progress and Sumn,ary of Changes - February 1990 to November 1990 Dur Schedule for IPE is being revised from completion by October 1,1991 and submittal by- December 15, 1991 to c..npletion and submittal by April 30, 1992.

These changes in schedule are being made to accommodate the involvement of additional BEco personnel in the development and quantification of the IPE which is consistent with the Generic Letter 88-20 guidance.

Page 30 of 54

ATTACHMENT 2 (Continued)

SCHEDULE B Progress and Summary of Changes - December 1990 to February 1991 IPE is on schedule for completion and submittal to NRC by April 30, 1992.

Progress and Summary of Changes - March 1991 to August 1991 IPE is on schedule for completion and submittal to NRC by April 30, 1992.

Progress and Summary of Changes - August 1991 to February 1992 We are revising the IPE completion date from April 1992 to September 1992.

In building the Modular Accident Analysis Program (MAAP) computer parameter file, we discovered certain modeling concerns that have necessitated extensive interaction with the computer code's developer.

Also, as cur experience with MAAP matured, we realized our original estimate of the number of simulations required was below the number necessary to assure completeness.

Since our program was established to use BEco personnel to the maxim'im extent possible, resolution of MAAP problems by BECo personnel instead of contractors has contributed to the delay of the April 1992 completion.

Progress and Summary of Change - March 1992 to August 15, 1992 IPE is on schedule for completion and submittal to the NRC by September 30, 1992.

Page 31 of 54

ATTACHMENT 2-(Continued)

SCHEDULE B GENERIC LETTER 83-28. ITEM 2.2 (PART 2) VENDOR INTERFACE (PROGRAMS FOR ALL OJ11ER SAFETY RELATED COMPONENTS 1 (LTP #303)

Commitment Descriptioll In response to Reference 1, BECo committed (Ref. 3) to complete an evaluation of existing vendor interface activities and identify recommendations for improvement. This was accomplished as of August 28, 1989. As a result-of this evaluation,-BEco is: (1) enhancing formal and informal vendor interface elements and, (2) implementing a new and more comprehensive Plant Equipment Technical Information Library. Our schedule for completion is projected as December 31, 1992.

Generic Letter 90-03 (References 4 & 5) clarified the elements of an equipment manufacturer interface program and requested licensees to review and modify, if necessary, their present equipment manufacturer interface program. Written confirmation of actions taken or planned to be taken was required.

Our Reference 6 response confirmed that the elements of the equipment manufacturer interface program prescribed in Generic Letter 90-03 are included in the existing scope of our Vendor Equipment Technical Information Program (VETIP).

This project involves the establishment of an enhanced vendor interface

-program that' includes: a) All SR components within the NSSS scope of su_paly, and b) Other key SR components not included in al. The program related to a) will-provi,o for and ensure the receipt of all updates to instruction and maintenance manuals, technical information bulletins, revised test procedures, and updated replacement parts information. The program related to b) is intended to be a good faith, documented effort to periodically contact the vendors of other key, SR components (such as batteries, cooling _ water pumps, valve operators, diesel generators, SR electrical switchgear) and obtain any technical information applicable to this equipment. The Project Plan and revised administrative procedures, are patterned after INP0 Good Practice DE-102 in order to meet these

. requirements.

Based on the scope, schedule and resource estimates provided in the j: current revision of the Project Plan, we expect that when completed, the l . Equipment Technical Information Library will consist of_ approximately 250 SR/NSSS manuals (plus up to 450 NSR manuals) comprising over 4500 technical bulletins.

.We expect to complete at least the total scope of Safety Related and Nuclear Steam SJpply System manuals over the next two years.

i i

l Page 32 of 54 l

.. l

\

ATTACHMENT 2 (Continued)

SCHE 0J E B Referengea

1) HRC RAI dated May 4, 1988

2) NRC SER dated July 18, 1988

3) BECo Letter 88-140, dated September 28, 1988

4) NRC Generic Ietter 90-03, dated March 20, 1990

5) NRC Generic Letter 90-03, Supplement 1, dated May 14, 1990

6) BEco letter 90-115, dated October 1, 1990 Cotsillmst History /Proaron Progress and Summary of Changes - March 19R9 to February 1990 The Equipmen+ Technical Information reogram ic on schedule for completion by December 31, 1991.

Progress and Summary of Changes - February 1990 to November 1990 The Equipment Technical Information Program completion schedule is being revised from December 31, 1991 to December 31, 1992.

This revised schedule is based on our most current review of resource availability and the relative priority of this project to other projects planned during 1991 and 1992.

To date the project has reviewed approximately 120 manuals and catalogued / indexed over 4500 technical bulletins that comprise the current library of approximately 800 naneals (safety related, non-safety related, and Nuclear Steam Supply System). We expect to complete at least the total scope of safety-related and Nuclear Steam Supply System manuals (600) over the next two years.

Progress and Summary of Change; - December 1990 to February 1991 Ihe Equipment Technical Information Program is on chedule for completion by December 31, 1992.

Progress and Summary of Changes - March 1991 to August 1991 1" safety-related and Nuclear Steam Supply System scope of the Equipment la hnical Information Program is on schedule for completion by December 31, 1992. The number of manuals in this category is approximately 250.

The 600 manuals as discussed above in the November 1990 Summary of _

Changes, was based on a total of approximately 1700 manuals expected to be developed. Although the volume of information will remain the same, the number of total manuals will be limited to approximately 750. Of tha 750 manuals, approximately 250 will comprise the safety-related and Nuclear Steam Supply Systen manuals.

Progress and Summary of Changes - August 1991 to February 1992 The safety-related and Nuclear Steam Supey System scope of the Equipment Technical Information Program is on schecule for completion by December 31, 1992.

Par;e 33 of 54 i

. _ _. _ .. _ .. _ _ . . _ _ _ _ _ _ _ .. _ _ _ .. _ . - .. . . _ . _ ._ .= ._ .

i ATTACHMENT 2 (Continued)

SCHEDULE B Progre>s'and Summary of Changes'--March 1992 to August 15, 1992 Th safety-related and Nuclear Steam Supply System scope of the Equi.3 ment Technical information Program is on schedule for completion by Decem)er

,. 31, 1992..-

t e

t b

e i

i::

(

Page 34 of 54. .

_ . . . _ . . _ . - - . . . . . . . _ . . . . _ . - . . . _ , - . . . . . _ - _ _ _ . ~ . . . . _ _ _ _ . -

i ATTACHMENT 2 (Continued)

ECHEDULE B J

G MRIC LETTER 89-M. SAFETY-RELATED MOV 1ESTING AND SURVERLANCE. (L1P #487)

Cpmmitment Delqfj.plio.n l Generic Letter 89-10 (Ref. 1) expands the scope of the motor operated valve program required by NRC Bulletin 85-03 and its Supplement, to l include additional testing, inspecting, and maintenance for all safety-related motor operated valves.

P our Reference 2 response to the Generic Letter, we committed to develop a program to enhance the maintenance, analysis, and testing already being conducted on MOVs at Pilgrim. The Generic. Letter calls for the development of this program within 1 year w one refueling outage from the date of the letter, whichever is later. For BEco, this schedule translates to RF0 #8. Our plan was.to begin a design basis review of MOVs in the first quarter of 1991 and to begin testing in RF0 #9. Based on .

resource constraints in 1990, we revised the design basis review schedule  ;

to commence in the last quarter of 1991. This revision continues to support our commitment to begin testing in RF0 #9 and supports our program development schedule. We anticipate the testing will require three refueling outages, based on the extent of-known scope. Additional scope determinations as a- result of NUMARC and BWROG involvement will be fcctored into. our final scope aM schedule as appropriate.

Reference 6 requested Licensees to perform a plant specific safety assessment to determine if generic safety assessments performed by the NRC staff and the BWR Owners' Group are applicable. If MOVs are discovered with potential deficiencies of greater significance than the HPCI, RCIC, and RWCU MOVs, planned activities to address the generic letter were to be re-prioritized accordingly. Notification within 30 days of receipt of

. Supplement 3 was required verifying a plant-specific safety assessment was performed and identifying whether there were MOVs with deficiencies of -

greater safety significance than in the HPCI, RCIC, and RWCU systems. An additional notification within 120 days of receipt was also requested to provide the critoria reflecting operating experience and the latest test data applied in determining whether deficiencies exist in the HPCI, RCIC, and RWCU MOVs.

In our Reference 7 letter, we concluded the subject valves in the HPCI,

'RCIC, and RWCU systems were capable of performing their_ safety function to  :

provide containment isolation-in the event of a line break outside ,

containment- . This subm'ttal provided our 30 and 120 day response to the generic letter and precluded having to perform a plant specific ofety assessment. We also committed in Reference 7 to conduct diagnostic

! testing'on the Reactor Water Cleanup (RWCU) M0-1201 2 valve during RF0 #8.

We expanded our planned RF0 #8 testing to . lude 2 additional valves:

.RWCU M0-1201-5 and Closed Cooling Water M0-4010 A.

- The NRC 1* ed a Request for Add!tional Information (RAI) (Reference 10)

L~ after rev. ewing our Reference 7 and 8 responses to GL 89-1C Supplement 3. '

BEco ; . ponded to the RL on August 29, 1991-(Ref. 11).

Page 35 of 54

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i ATTACHMENT 2 (Continued) i SCHEDULE B .

1 During the week vF Mare:b 3-13, 1992, the NRC conducted an inspection of the PNPS GL 89-10 M0V program. As a result of this inspection Boston l Edison committed to resubmit the GL 89-10, Supplement 3, responce and acce. orate the schedule for priority 1 valves to have the GL 8910 actions completed by the end of RF0 10. RF0 10 is scheduled for 1995.

Rehrencei

1) Generic letter 89-10, dated Junc 28, 1989

2) BEco Letter 90-13, dated January 15, 1990

3) NRC Letter dated June 7, 1990, Response to Generic letter 89-10

4) NRC Letter dated June 13, 1990, Supplement I to Generic letter 89-10

5) NRC Letter dated August 3, 1990, Supplement 2 to Generic Letter 89-10

6) NRC Letter dated October 20, 1990, Supplement 3 to Generic Letter 89-10

7) BECo letter 90-158 dated December 17, 1990

8) BECo Letter 91-022, dated February 26, 1991

9) NRC Letter dated April 1, 1991, Meeting Summary BECo/NRC

10) NRC Letter dated June 24, 1991, RAI regarding CL 89-10 Supplement 3

11) BEco Letter 91-111, dated August 29, 1991

12) NRC Letter dated February 18, 1992, Closure of GL 89-10, Supplement 3

13) HRC. Letter dated February 12, 1992, Generic Letter 89-10 Supplement 4

14) NRC Letter dated June'3, 1992, Inspection 50-293/91-80 Motor Operated Valve Inspection.

15) NRC Letter dated May 5, 1992, Motor Operated Valve Inspection at PNPS

-(NRC-Inspection Report 50-293/92-80. ,

BECo Letter 92-044, Revision to GL 89 10, Supplement 3, Response

~

16)

Commil_ ment Histp_ry/ Progress Progress and Summary of Changes - February 1990 to November 1990

- - Begin a design bar.ls review of MOVs is on schedule for first quarter of 1991. '

Begin testing is on schedule for RF0 #9 (completion within 3 refueling outages).

- 30 day notification in accordance with Generic letter 89-10, Supplement 3 is planned for submittal by December 13, 1990.

- 120 day notification efforts are planned for submittal by March 13, 1991.

Progress and Summary of Changes - December 1990 to February 1991

- The schedule for commencement of design basis reviews of MOVs is being changed from the first quarter of 1991 to the last quarter of 1991. This schedule revision continues to support our commitment to begin testing in l RF0 #9.

l.

Begin testing is on schedule for RF0 #9 (completion within 3 refueling outages).

- 30 day and 120 day notifications are complete.

- 3 safety related valves are en schedule for diagnostic testing during RF0

1. 8 (M0-1201-2, 1201-5, and 4010A).

Development of a Program Plan is on schedule for completion by May 1, 1991.

p Page 36 of 54

ATTAcitMENT 2 (Continued)

SCHEDULE _B Progress and Summary of Changes - March 1991 to August 1991

- Commencement of design basis reviews of MOVs is on schedule for the last quarter of 1991.

- Begin testing is on schedule for RF0 #9 (completion within 3 refueling cutages).

- Diagnostic testing of MO-1201-2, 1201-5, and 4010A was conducted during RF0 #8. In addition to this testing, we completed diagnostic testing on the remaining GL 89-10 Supplement 3 MOVs (4 valves) and on another 10 safety related MOVs.

Development of a Program Plan is complete.

Progress and Summary of Changes - August 1991 to February 1992

- Design basis reviews of MOVs continue to support our commitment to begin testing in RF0 #9.

- Testing is on schedule to begin in RF0 #9 (completion within 3 refueling outages).

-- Procedures are in preparation describing design basis review methodology, control of switch settings, and degraded voltage analysis. Additionally, a Nuclear Organization Procedure establishing our MOV program is in final review.

- The schedule for static testing of MOVs has been accelerated and some testing will be done during our mid-cycle outage prior to RF0 #9.

- MOVs tested using MOVATS test equipment were reviewed and have been retested using more accurate diagnostic test equipment or been reviewed to ensure there is sufficient margin.

Progress and Sum. nary of Changes - March 1992 to August 15, 1992-

- Design basit, reviews of MOVs continue to support our commitment to begin c testing in RF0 #9.

Testing is on schedule to begin RF0 #9.

GL 89-10 activities will be completed for priority 1 valves by the end of RF0 #10.

- Reference 16 submitted a revision to GL 89-10, Supplement 3, response (Reference 8).

- Nuclear Organization Procedure 92M1 " Motor Operated Valve Program" has been approved.

- . Procedures describing design basis review methodology and control of switch settings are approved. Draft procedures for degraded vnltage of motors are being revised to include temperature effects on available torque. AddP ional procedures are being developed as necessary.

Page 37 of 54

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ATTACHMENT 2 (Continued)

SCHEDVLE B ltiMEliENT ROOT- CAUSEJ_ND CORREATIVE ACTIONS TO ADQRIL55 CAUSES_OF WFLD FA.LLURE (LTP #31, 292, 400)

Commitment Descripti_oD  !

Provide operator access to RHR Vent Valves, Low Pressure Emergency Core l Cooling System (LPECCS) Vibration Monitoring, replace RHR Discharge  !

Pressure Switches (Low Pressure Alarm), collect data on throttling globe '

and gate valves that could cause erosion and vibration problems and determine if alternatives are required. Review of methods to establish MOV thrust will be performed as part of our Generic Letter 89-10, Motor Operated-Valve Testing effort.

Reference BECO Letter 88-140, dated September 28, 1988 (Appendix 10 Items #01-013-01 & #03-916-06), '

.Cgomm3Aent HistoryR_togtgsJ Progress and Summary of Changes - March 1989 to February 1990 On Schedule for RF0 #8.

Progress and Summary of Changes - February 1990 to November 1990 Operator access to RHR Vent Valves is on schedule for completion by RF0 H8.

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- LPECCS Vibration Monitoring is on schedule for completion by RF0 #8.

Investigate alternatives to throttling globe and gate valves and review methods to establish MOV thrust are on schedule fo completion by RF0 #8.

- Replace RHR Discharge Pressure Switches (Low Pressure Alarm) is on schedule for completion by RF0 #8. '

Progress and Summary of Changes - December 1990 to February 1991 l - -

l' Operator access to RHR Vent Valves is en schedule for completion by RF0  ;

'h8.

- One area has bean determined to require a permanent modification to

facilitate venting. Re-routing of the vent lines for valves 10-H0-397/398 L will be performed during RF0 #8.

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- LPECCS Vibration Monitoring is installed. Additional monitoring will be performed during RF0 8.

1 - Collect data on throttling globe and gate valves that could cause erosion

-and vibration problems will be performed during RF0 #8.

Page 38 of 54

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i ATTACHMENT 2 (Continued) i Klif&VLE B - .

Evaluate collected data on throttling globe and gate valves to determine if alternatives are required will be performed post RF0 8.

Review of methods to establish M0V thrust will be performed as part of our

Generic letter 89-10, Motor Operated Valve Testing effort (t1P #487). l l

- Replace RHR Discharge Pre:,sure Switches (Low Pressure Alarm) is on  !

schedule for completion by RF0 #8.

Progress and Summary of Changes - March 1991 to August 1991 Operator access to RHR Vent Valves is complete Re-routing of the vent lines for valves 10-H0-397/398 is complete.

Additional LPECCS vibration monitoring was performed during RF0 #8. The ,

LPECCS vibration monitoring system was activated-to monitor during the '

shutdown cooling mode. The system was set to continuously monitor various accelerometer locations to trigger an alarm upon high vibration due to a l water hammer event or valve cavitation. No system activation occurred at '

the. established setpoints and no failure of vent or drain welds were  :

. discovered ~during the last operating cycle. We attribute this reduction in_ water hammer events to the-activities undertaken to enhance venting capabilities as mentioned above and changes made to operator venting instructions such as backflushing to remove any steam bubbles prior to venting. Therefore, we intend to continue the monitoring during the ,

present fuel cycle with lower setpoints. .More attention will uow be focused on vibration related to steady-state flow and valve _ cavitation.

Steady state' vibration data will be recorded from each data point with the system operating in the torus cooling and mixing modes at various flow rates. An analysis of this steady-state vibration will then be performed.

Based 'on the~ results of the analysis, additional vibration surveys of the i piping system may be performed using portable vibration instrumentation.

During the next mid-cycle outage, similar monitoring will be performed with the system in the shutdown cooling mode. Once the vibration under these conditions has been analyzed, we will determine the need for any

-alternative activities. -

' Replace RHR Discharge Pressure Switches (Low Pressure _ Alarm)'is complete.

l Progress and Summary of Changes - August 1991. to February 1992 Vibration monitoring has been conducted since RF0 #8 for ten monitoring - 4 locations -identified as areas of particular interest .by previous ,

investigations. Based upon preliminary moni h ring to date, the trigger E level for alarming and data acquisition was b wered. Previously, tho

? system was set-to trigger on potentially high level transients caused by l . water hammer events. In the absence of.any of these transients, the alarm levels are now set;to detect lower vibration levels indicative of valve throttling and/or cavitation. Monitoring and data recording of these ten '.

locations will continue. Particular attention 4 'l be given to shutdown-cooling, suppression pool cooling', and surveil M ee' testing, i Page 39 of 54

_ __ , _ _ _-J

ATTACliMLNT 2 (Continued)

SCHEDULLC Progress and Summary of Changes - March 1992 to August 15, 1992 Monitoring and data recording of the ten locations is-continuing.

Shutdown cooling, suppression pool cooling, and surveillance testing monitoring will be performed during MCO 9. The need for alternative j activities will be determined once the vibration under these conditions -

has been analyzed. Corrective actions previously taken appear successful-'

no failures occurred during this report period.~

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ATTACHMENT 2 (Continued)

SCHEDUtE B

[LRC BUILEIJR._90-01: t&$_S 0F FlLL-0ILJN TRANSMITTERS MANUFACTURED BY ROJEJ 0UtiLIRC_. (LIP #319) .

Commitment DescrioljJ;!D The NRC Bulletin identified safety concerns associated with Rosemount transmitters, Model 1153, Series B, Series D and Model 1154, due to failures resulting from fill-oil leakage. The Bulletin required licensees to iientify these models utilized in safety-related and A1WS applications and implement specific actions. The actions include replacement of trannmitters identified from the smpect lot, development of a basis for continued operation and implementa .on of an enhanced surveillance program.

As stated in our response to Bulletin 90-01, we identified Model 1153, Series B, Series D and Model 1154 Rosemount transmitters installed in safety-related and ATWS applications and implemented an Enhanced Surveillance Program for monitoring transmitter performance. The monitoring program consists of operational data trendings, calibration data trendings, and process noise analysis including sluggish transmitter responses. Also, operability acceptance criteria for each transmitter application has been established. The surveillance program will continue until industry resolution is achieved either through NRC or NUMARC.

References

1) NRC Bulletin 90-01, dated March 9, 1990

2) BECo Letter 90-085, dated July 11, 1990, Response to NRC Bulletin 90-01.

Commitment History /Pronress _

Progress and Summary of Changes - March 1990 to November 1990 The Rosemount Transmitter Enhanced Surveillance Program is in place and will continue until industry resolution (resolution expected by first quarter of 1991).

Progress and Summary of Changes - December 1990 to February 1991 ,

The Rosemount Transmittec Enhanced Surveillance Program will continue until industry resolution occurs.

Progress and Summary of Changes - March 1991 to August 1991 In May 1991, NUMARC issued Report #91-02 to the NRC summarizing PSI-month and failure data for Rosemount transmitters. The NUMARC report reconnended the oil-loss concern should be focused on the subset of 1 installed Rosemount models 1153 and 1154 normally pressurized to greater than 250 PSI but not beyond the applicable threshold PSI-month recommended Page 41 of 54

ATTACHMENT 2 (Continued)

SCHE 0QLL1 by the manufacturer.- Additionally, Rosemount issued Amendmert #3 to the i

-Master Suspect I.ist on July 3,1991. Our review of this list identified three Rosemount transmitters in drywell pressure applications which are ,

not in the RPS or ESF systems and are pressurized normally below 250 PSI. 1 We are presently evaluating this data for application to our surveillance program. Any reductions in program scope will be transmitted to the NRC .t under separate cover. We plan to continue monitoring Rosemount transmitter performance until industry resolution occurs.

Progress and Summary of Changes - August 1991 to February 1992  ;

Rosemount issued Supplement #4 to the-Master Suspect List in December 1991. Our review identified no new transmitters installed in the plant  :

that fall into the highly suspect list lot. We are continuing to. monitor Rosemount transmitter performance until industry resolution occurs.

l Progress .and Summary of Changes. -' March 1992 to August 15, 1992 l '

! We are-continuing to monitor Rosemount transmitter performance until l- cindustry; resolution. occurs. . None failed during this' report period.

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ATTACHMENT 2 (Continued)

SCHEDULE [i ENRIC_Lf1TER 89-13. sal.T SERVICE WALE _R SYSLG (LTP #253, 473) ,

i Commjtment Descriptioh  !

Generic Letter 89 13 required licensees to review and evaluate the ,

adequacy of the service water system and all safety related heat exchangers. The review ideniified a number of enhancements to the PNPS programs and procedures. As a result, BEco committed via Referente 2 to the following:

• Prior to end of Rf0 #8, modify the RBCCW heat exchanger test procedures to include an analytical model to calculate RBCCW heat exchanger performance at test and design conditions (complete).

Conduct tests with modified procedures during Cycle 9.

• Prior to end of RF0 #9, modify the RHR heat exchanger test proceditres to include an analytical model to calculate RHR heat exchanger performance at test and design conditions. Conduct tests with modified procedures during Cycle 10.

• Develop a regular maintenance / test program on heat transfer capability of the remaining heat exchangers by Rf0 #9.

• Conduct a Single failure Analysis for the RBCCW subsystem by end of Rf0 #8. (Complete) l

• Prior to end of Rf0 #8, upgrade the licensed operator trainir,g module to include a loss of all service water. (Complete)

Credit was also taken in Reference 2 for the SSW piping inspection and replacement program already underway at Pilgrim, which henceforth will te i.itegrated as part of our Generic Letter 89-13 implementation efforts.

l Refetengn i

1)- Generic Letter 89-13, " Service Water System Problems Affecting Safety-Related Equipment"

2) BEco letter 2.90.047, dated April 2, 1990, " Response to Generic l Letter 89-13" Commitment History /lroaress Progress and Sammary of Changes - March 1990 to November 1990 The licensed operator training module upgrade is complete.

There are no changes to the other above-described commitments and schedules.

Page 43 of 54

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I ATTACHMENT 2 (Continued) 3.0M.LLB Progress and Summary of Changes - December 1990 to February 1991 4

A' single failure analysis of the RBCCW subsystem has been performed.

There are no changes to the other above-described commitments and schedules.

Progress and Summary of Changes - March 1991 to August 1991 RBCCW heat exchanger test procedures have been modified to include an analytical model to calculate RBCCW heat exchanger performance at test and design conditions.  !

In addition, activities associated with SSW piping inspection and replacement are being integrated under our GL 89-13 effort. Further I inspections of the SSW pipino will be scheduled during each planned mid-cycle or refueling. outage of sufficient duration. It remains our intention to replace SSW piping when the inspection of piping shows that to be necessary.

Progress and Summary of Changes August 1991 to February 1992 Efforts to enhance the Salt Service Water System are proceeding as indicated in our response to Generic letter 89 13. There are no changes to the above-described commitments.

Progress and Summary of Changes - March 1992 to August 15, 1992 A' decision was made to replace the buried-SSW piping with corrosion-resistant titanium. Five Plant Design Change Packages were prepared to-facilitate _ replacement of the pipe. Construction of a pipe vault at the

. intake' structure is in progress. Replacement activities will continue through MC09.and.RF09. Above ground piping will be routinely examined by non-destructive technology (typically UT) and will be replaced as _

required. ' Efforts to enhance the SSW system are proceeding as indicated above.

Page 44'of 54

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ATTACHMENT 2 (Continued)

SCHQl)1LH GENERif_LEJ1ER 91-05d1CENSEE COMMERC_LAL - GRADE PROCUP.MNT AND_DEDICATIOM ER0 GRAMS (LTP #587)

Commitment _QpjLcrip_t_foji instances of counterfeit and fraudulently marketed vendor oroducts heightened the NRC's concerns for licensees' capability to assure the quality of procured products and to reduce the likelihood of the use of counterfeit or fraudulent products in nuclear power plants. Generic Letter 89-02 (Reference 1) provided details on some of the elements of programs the NRC considers to be effective in providing the capability tn detect counterfeit or fraudulently marketed products and in assuring the quality of vendor products. For example, an effective commercial-grade --

dedication program should include provisions to demonstrate that a dedicated item is suitable for safety-related applications. For a licensee to adequately establish suitability, certain key activities should be performed, as appropriate, as part of the dedication process.

The NRC encouraged industr" working group efforts to develop guidance in these areas. Generic Let t 39-02 also conditionally endorsed the i dedication methods describeo in EPRI UP-5652 " Guideline for the Utilization of Commercial-Grade Items in Nuclear Safety-Related Applications."

NUMARC took a lead role on this issue and developed and issaed to the industry a document entitled "Compr-hensive Procurement 1..itiative" (Reference 2). Issued on behalf of the industry, this document commits licensees to assess their procurement programs and take specific action to enhanct; or upgrade the programs, where needed, by July 1,1992.

Generic Letter 91-05 (Reference 3) clarified the dedication approaches described in Generic Letter 89-02 and notified the industry of the NRC -

staff's pause in conducting procurement inspection and enforcement activities. The pause is intended to allow 1icensees sufficient time to fully understand and implement guidance developed by industry for procurement improvements and commercial-grade dedication programs.

Generic letter 91-05 also endorsed the NUMARC procurement initiative and milestones and ecovided additional guidance regarding commercial-grade procurement and dedication programs considered acceptable to meet regulatory requirements.

ReleJ"eJLce_s

1) Generic letter 89-02, dited March 21, 1989 '

2) NUMARC documer,t " Comprehensive Procurement Initiative," dated June 28, 1991

3) Generic Le+.ter 91-05, dated April 9, 1991 s

I Page 45 of 54

, ATTACHMENT 2 (Continued)

SCHEDULLE Commitment History /Progres_1 j Progress and Summary of Changes - March 1991 to August 1991 BEco personnel have attended NUMARC workshops on industry precurement initiatives. . Efforts to identify and implement procurement improvements  :

are scheduled ror completion by July 1, 1992. .

Progress and Summary of Changes - August 1991 to February 1992 l Current work to implement required procurement improve)ents is on schedule for completion by July 1,1992.

Progress and Summary of Changes - March'1992 to August 15, 1992

~

The procurement improvements identifjed through the industry (NUMARC) initiative have been completed.

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ATTACHMENT 2 (Continued)

SCHEDULE B GDifRIC_ LETTER 9)-14 EMERGENCY TELECOMMUNICATIONS Lommitmeat Description Per Generic Letter 91-14, the NRC is upgrading the telephone system

-currently used for the Emergency Notification System (ENS), the Health Physics Network (HPN) and other c:mmunication networks. This new system will be installed by the NRC by March 1992.

To sepport the NRC, we a"e required to provide telephone lines for the Control Room, Technical Scpport Center, cnd the Emergency Operations facility. The current automatic dialing tNS (red phone) will be replaced by new :.'ephones requiring the user to dial specific NRC numbers; therefore, procedure changes are required. This work and system testing is planned for completion by July 1992 proviJa the NRC installs its FTS 2000 lines in March 1992.

References

1) NRC Gtneric Letter 91-14, dated September 23, 1991 Commitment History /Procress Progress and Summary of' Changes - August 1991 to February 1992 The facilities-have been evaluated and we have determined there are l currently sufficient . telephone-lines to each facility. We-are still J L determining what procedures will have to be modified. Completion is on  !

I schedule for July 31, 1992, provided the NRC installs its FTS 2000 lines in March 1992. 1 l

Progress and Summary-of Changes - March 1992 to August 15, 1992  !

1 This project was completed on June 16th and the one month test was successfully completed on' July 22, 1992.

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-g w ,9

l ATTACHMENT 2 (Continued) 5.QtEDUlE B GMGlcETlER 88-20 Supplement 4, Individual Plant Examination - External Events ( LTP #488, 567)

Com {tment Dascrlptiorl l In response to GL 88-20 Supplement 4 (Ref. 1), BECo provided a program l plan for completing an Individual Plant Examination of External Events  !

(IPEEE) for ;evere accident vulnerabilities for the Pilgrim Nuclear Power  :

Station (Ref. 2). The IPEEE scope will include seismic events, internal fires, high winds, external floods, and transportation and nearby f acility accidents.

Our schedule for completing the IPEEE anu submitting the results is July 1, 1994. Significant milestones include:

• Initiate Fire PRA tasks

• Initiate Seismic PRA tasks

• Initiate remaining external event tasks

• Screening walkdowns for fire and seismic

• Final seismic walkdowns

• Complete fire PRA

• Complete remaining external events

• Complete Seismic PRA

• Integrate IPE/IPEEE The NRC confirmed the acceptability of our schedule and program plan in Reference 3.

Bef.eLeges.

1) Generic Letter 88-20, Supplement 4, dated June 20, 1991

2) BECo Letter 91-155, dated December 24, 1991

3) NRC Letter 92-?59, dated June'16, 1992 Commitment History / Progress Progress and Summary of Changes - August 1991 to February 1992 Pilgrim Station is a USI-A-46 plant and a rember of the Se'smic Qualification Utility Group (SQUG). Because of the similarities of the A-l 46 and seismic IPEEE programs, we intend to conduct walk 60wns at the same time to avoid repetition of essentially the same work-within a short time span. TLis is consistent with the Generic Letter 83-20, Supplement 4, ,

guidance t:iat states; "USI-A-46 should be coordinated with the IPEEE so the objectives of both activities may be accomplished with a single walkduwn effort." However, the anticipated Supplemental Safety Evaluation Report (SSER) on the SQUG's Generic Implementation Procedure (GIP) for resolution of USI-A-45 has not been made available within the October 1991 time frame, as expected by the NRC when Supplement 4 was issued. The issuance of the SSER will affect the achievement of the above-planned walkdown tasks and ultimately the IPEEE completion date. The final issuance date, the centent of the SSER, and the r9 solution of open issues, will be factors in establishing a program schedule for conducting the seismic-IPEEE.

Page 48 of 54

ATTACHMENT 2 (Continued)

SCHEDUl.E B Progress and Summary of Changes - March 1992 to August 15, 1992 IPEEE is on schejule for completion and submittal to the NRC by July 1, 1994.

Page 49 of 54

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ATTACHMENT 2 (Lontinued)

SCHEDULE B REGRAD.E0_LQlJME (LTP #015)  ;

Commi_tment Description Boston Edison Company letter BECo 91-102 identified that selected loads at the 480V and 120V levels of the PNPS AC distribution system may not i receive sufficient voltage during a degraded grid condition at the existing degraded voltage relay setpoints. Compensatory measures involving the use of the PNPS emergency diesel generators were implemented  !

during-August 1991 to ensure PNPS's AC distribution system vill not be susceptible to potential problems on the 345kV grid. Corrective actions were committed for implementation no later than RF0 #9.

fleferences

1) BECo Letter 91-102, dated August 9, 1991 2)- BEco Letter 92-058, dated June 30, 1992 Commitment History /Proaress Progress and Summary of Changes - August 1991 to F .bruary 1992 Our Schedule C iwm #015 effort preliminarily identified the following modifications now included under this Schedule B commitment for RF0 #9:

• Installation of four. 480-120V voltage regulating transformers as replacements for fixed tap tv.nsformers.

• Replacement of approximately 35 control power transformers in 480 L

volt mator control center control circuits.

• Upgrading to Class IE of load shed logics to 16 drywell unit coolers.

• Increasing the size of feeder cables to 3 motors and 2 heater banks. '

• At least 2 regulating transformers will.be installed by 1992 MC0 in support of Detailed Control Room Design Review modifications.

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The proposed modifications listed above are based on load flow / voltage drop analysis of turbine trip and LOCA scenarios conducted as part of the Degraded -. Voltage Study effort.

l Progress and Summary of Changes - March.1992!to August 15, 1992 Three plant design change ' packages have beentissued for the transrormer 4

, modifications' indicated.in the preceding paragraphs. The change packages

_for the drywell cooler and. feeder cables are proceeding on schedule.

l An rnalyses by Westinghouse is being prepared that will show the new SSW _

pump motors can. start at voltage levels expected at the motor- terminals during-a. degraded voltage ~ event. Consequently the need to replace cable to this motor is eliminated.

Page 50 of 54

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I A1TACHMENT 2 (Continued) )

_SCJtEDU1Lfl ]

i CLASS I PIPING SEISMIC DAMPING RATIO (LTP #599)

Ro.mmitment Descriptio0

)

1 In Reference 1,.BEco committed to re-evaluate two changes to the Final Safety Analysis Report (FSAR) in which certain Class I piping seismic j damping ratios were increased and NRC approval for the damping ratio l changes was not sought under 100FR50.59. Planned actions include-identification of stress analyses where the higher damping ratioc were  ;

used, resulution of descrepancies between the existing design and the regulatory guidelines, development of enhanced design specifications for piping and supports, and. systematic-review of safety grade piping systems-to demonstrate conformance with the appropriate specification. These activities are planned for completion by Rf0 #9.

References

1) BEco letter 92-014, dated February 21, 1992 Gq!nmitment Hist. prs /Proaress Progress and Summary of Changes . March 1992-to August 15, 1992 We are presently re evaluating the effects of using Code. Case N-411 damping ratios with_the design basis seismic response. spectra in the-analysis of safety-related piping systems. The conservatisms of our original design damping ratios and response spectra will be compared to conservatin of the more recent seismic damping ratios of Code Case N-411 when used_in conjunction with the response spectra-of Reg'ulatory Guide 1.60. .The Scram Discharge piping will be thelfirst system to be re-analyzed with this rrivised amplified response spectra.

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ATTACHMENT 2 (Continued)

SCHEDU.1L3

[LWCU PIPING REPLACEMENT (LTP #600)

Cpmmitment Descriptiori Generic letter 88-01 was issued to address Intergranular Stress Corrosion Cracking (ICSCC) in stainless steel pipe materials. BEco replaced the recirculation system and IGSCC susceptible material in the drywell. BECo responded to the NRC and committed tc comply with Generic Letter 88-01 except for the RWCU system between valves 1201-5 and 1201-80. This response was rejected by the NRC Safety Evaluation of the BEto Generic Letter 88-01 response (NRC Letter 1.90.104, 4/26/90). BECo responded (BECo letter 2.90.140,11/15/90) by stating the following for the non-safety portion of the RWCU system: "We will perform an inspection of 10%

of these welds during each refueling cycle. If a flaw is discovered in the 10% sample and 1GStr is determined as the probable cause, another 10%

will be inspected. If an IGSCC induced flaw is discovered in the second 10% sample, no further inspections will be conducted. The identified flaws will be repaired and plans will be made to replace RWCU non-code piping in subsequent refueling outages."

It, SCC susceptible pipe per Generic letter 88-10 is non-resistant austenitic stainless steel pipe 4"NPS and greater operating at a temperature greater than 200 F.

During RF0 #8 inspections were made of the safety and 10% of the non-safety (non-code) pipe. IGSCC was found. There was a discussion with the NRC at that time and the commitment quoted above was altered. Rather than inspect an additional 10% of the non-safety pipe, the areas of the safety and non-safety pipe that had IGSCC would be replaced and all IGSCC susceptible pipe would be: replaced in future outages. This increased the original scope by adding the safety-related RWCU pipe into the replacement commitment. Piping was replaced in the areas where IGSCC was found during RF0 #8 by Plant Design Change 91-39.

References

1) NRC Generic letter 88-01

2) NRC Letter 90-104, dated April 26, 1990

3) BEco Letter 90-140, dated November 15, 1990 Commitment History /Proaress Progress and Summary of Changes - March 1992 to Angust 15, 1992 A Plant Design Change has been developed to replace remaining safety-related and non-safety related IGSCC susceptible pipe in the RWCU system.

Plans are being made to replace the balance of susceptible piping in RF0

1. 9 and MCD #10.

Page 52 of 54

l ATTACHMENT 2 (Continued)

SCHEDULE B l

EDSFI HVAC (LTP# 583)

Commitment DescriDtion The Switchgear and Battery Rooms contain safety-related electrical equipment. Area cooling is provided by the non-safety related Turbine Building Ventilation System. An analysis of the electrical equipment operability was conducted in response to a concern raised by the NRC during the Electrical Distribution System Functional Inspection.

. Compensatory measures were established to ensure the electrical equipment

-would perform its intended function. An analysis of the temperature response of the Switchgear and Battery Room to a loss of HVAC will be conducted. Compensatory measures will remain in place until.this is resolved.

Beforences

1) BECo Letter 91-101, dated August 8.1991, "Resnonse to NRC Electrical Distribution System Fainctional Inspection-(EDSFI), Switchgaar/ Battery Room HVAC Concern

2) BECo letter 91-117, dated October 11, 1991, " Revised Response to NRC Electrical Distribution System functional Inspection (EDSFI)

Switchgear/ Battery Room HVAC concern 3)- NRC Letter 91-287, dated October 18,1991, " Electrical Distribution System functional Inspection (EDSFI), Inspection Report No. 50- >

293/91-80

4) BECo Letter 91-145, dated October 24,1991, " Update to Electrical Distribution System Functional Inspection'(EDSF1).Switchgear/ Battery Room HVAC issue"

5) BEco Letter 91-999, dated November 25, 1991, " Reply to Notice of Violation, Unresolved Items and Observations-Identified During the Electrical Distribution System Functional Inspection.(EDSfl)

(Reference IR 91-80)"

6)' BECo Letter 92-004, dated January 17,1992, "EDSFI - m AC Review"

'7). -BECo Letter 92-068, dated June 30, 1992 "Upd_ ate to Unresolved Item 50-293/91-80-02 Identified During the Electrical Distribution System Functional Inspection"

( Eommitment History /Proaren l' Progress and Summary of Changes.K March 1992 to August 15, 1992 An analysis of the temperature response of the Switchgear'& Battery Room L was conducted. In ~'dition, a test of the Turbine Building HVAC system l was conducted to st ,rt the operability evaluation. The test results

. reinforced.the cont. . ions previously derived in the operability.

assessment. The. tests'results were factored into the temperature u prediction model. -These predictions correlated well with the actual field data. /A plant design change to' provide-SR ventilation-utilizing the. temperature model results is being evaluated to restore full design margin. An implementation schedule will be provided in the next LTP submittal.

1 Page 53 of 34

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ATTACHMENT 2 (Continued)

EhfEVLLB 125V Battery Charcer ReDiacement (LTP #597)

Comitment Q. e scription BECo has encountered difficulty in A: supply voltage transients causing '

battery charger output fluctuations, potentially challenging functionality of certain critical 125 VDC loads such as the HPCI and RCIC instrument-inverters.

We will replace the three 125 VDC battery chargers with new chargers

. designed to respond to expected AC voltage transients. We tentatively plan to have.all three 125 VDC battery chargers installed prior- to startup from RF0 9.

References

1. BEco Letter 92-058 dated May-7, 1992 Cgamitment History /Proaress Progress and Summary of Charges - March 1992 to' August 15, 1992 Design change packages have been prepared. The replacement chargers have been ordered and qualificatior testing is imminent. The replacement of the three 125 VDC battery chargers is on' schedule for installation-prior to restart from RF0 9.

P Page 54 of 54

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ATTACHMEliT 3 .

ADDITIONAL ITEMS LIST (SCHEDULE C)*

~

FEBRUARY 1992 ITEM TARGET SCHEDULE CURRENT STATUS Cooling' Water Betterment (LTP #322) " Ongoing through RF0 #9 No change Intake Canal Dredging (LTP.#486) Cycle ~9 & Ongoing Ongoing and Cycle 10 Logic System Functional Test Mods (LTP #224)'- RF0 #9 MCO #10 (on line

. installation in progress)

Turbine.Bearir.g Fire-Protection (LTP'#234) 1992 Mid-Cycle Outage No change i

. Analog Trip Drawing Update-(LTP'#319) December.1992- No change Siren Feedback-System'(LTP #311) Completed, Complete

! '- Siarch 31, 1992 h PriorityBDrawingUhdate.(LTP#051) Cycle 9 No change Design Basis Information System (LTP #264) Cycle 8 & Ongoing Ongoing Design Configuration Control u.TD #367) Fall 1993- No change

Hanger Drawing Update l(LTP #112) Ongoing through 1992 No change

! Radwaste Betterment (LTP #022) Revised Radwaste No change

. Improvement Program

developed to run 3

through 1996 i.

i I .-

• Represents a portion'of major plant betterments. Total LTP data base contains additional plant betterments, programs / projects and issues.

t

?

Page 1 of 4

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r

~kTTACHMENT3 .

. ' ADDITIONAL'ITEf45 LIST (SCHECULE C)*'

FEBRUARY 1992

. ITEM. TARGET SCHEDULE CURRENT STATUS

. Spent Resin Storage Tank Replacement.'(LTP.#023)' Removal and' Replacement Schedule being in Cycle 10

~

' re-e, aluated E ' Valve Betterment,III;(LTP #126). -Ongoing through Cycle 9 Ongoing Radiation Source Reduction (LTP #266) ' Ongoing through 1995 No change i

- Replace GE Time: Delay Relays w/Agastat (LTP #414) 1992 mid-cycle outage No' change l Ventilation Exhaust Fans 104 A/B Replacement ' Cycle 9, project scope Cancelled'

j. (LTP #331) being re-evaluated Instrument Recirc. Pump Shaft (LTP #546) Instrumentation partially No change l completed - on hold Shaft . testing completc L

. No cracks per REM testing (LTP #396)

Degraded Voltage Study (LTP #015) Cycle 8 & Ongoing. No change i i Specific identified modifications were

, transferred to Schedule B Setpoint Control Program Study (LTP #108) . Cycle 10 No change i-

l.  ;

. i

• Represents a portion.of major plant betterments. Total LTP data base contains i

additional plant betterments, programs / projects and issues.

, t I I l-3 i

[" Page 2 of 4 a

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, P.

l ATTACHMENT-.3 .

L . ADDITIONAL.ITCAS LIST (SCHEDULE C)*

i:

FEf3RUARY'1992

ITEM' TARGET SCHEDULE CURRENT STATUS Inspect LP Turbine Rotor ** RF0 #9 No change i ' Abandnn .In-Place Program (LTP.#278). On hold during 1992 No change

TIP System Replacement (LTP #380) .

RF0 #9- No change b- Damper. Inspection' Platforms (LTP #737) RF0 #9 No change

l. ,

. R.V. Beltline Weld Inspection.(LTP #399).

RF0 #10 No change Turbine Trucklock Sprinkler -(LTP 4236) RF0 #9 MCO #11 Inspect / Replace' Lower Core Support Plate Flow RF0 #9 RF0 #10

. Plugs WE SIL 359) (LTP #448)

Generator Retaining Ring Rep h ement (LTP #531) RF0 #9 No change t

Low Level Radwaste Interim Storage-(LTP #496) ' Ongoing through 1996 No change Replace Simplex Panels (LTP #524) December 1993 On hold due to funding I' restrictions i-Additional Sper.t Fuel Storage (LTP #085) RF0 #10 No change

j. Replace M0-1001-28 A&B Yokes (LTP #586); RF0 #9 A RF0 #9, B MCO #9 Represents a portion of major plant betterments. Total LTP data base contains additional. plant betterments, programs / projects and issues.

• • Performed as: routine work under outage budget.

i Page 3 of 4

Al

.r,

[

ATTACHMENT 3 ADDITIONAL ITEMS LIST-(SCHEDULE C)*:

g 4

FEBRUARY 1992

-ITEM- TARGET SCHEDULE- CURRENT STATUS

, REM Test Recirc Pumps (LTP #396)

- Initial test No change L completed in L RF0 #8.

Additional test planned .for RF0 #9 Replace Effluent Monitors -(LTP. #590)- MCO #10' No change Relocate Alarm Check Valve (LTP #238) RF0 #9- Cancelled Steam Tunnel HVAC Evaluation (LTP #576)- RF0 #9 MCO #10 Change HPCI Booster Pump' Impeller'(LTP #577) RF0 #9 RF0 #10 to Five Vane Impeller Replace ISI Shield. Blocks with' Shield Doors Through RF0 #10 Scope is being (LTP #572)- re-evaluated Exciter Cubicle.002. Modification'(LTP #235) RF0 #9 MCO #10 t

' TBCCW Pipe Insulation (LTPi#027)

RF0 #9 RF0 #10 Replace RPV_ Studs..(LTP #520). RF0 #9 No change t

l T.

• Represents a partion.' of maf plant:betterments. Total LTP data base contains additional. plant betterment,, programs / projects and issues. [

l i

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