ML19332A943
| ML19332A943 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 07/15/1980 |
| From: | Andognini G BOSTON EDISON CO. |
| To: | Brunner E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML19332A942 | List: |
| References | |
| 80-144, NUDOCS 8009190076 | |
| Download: ML19332A943 (2) | |
Text
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tuooTON EDISDN COMPANY
...ron. w..acuu.arr osa,
July 15,1980
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Mr. Eldon J. Brunner, Chief Reactor Operations sud Nuclear Support Branch Office of Inspection and Enforcement Region I U.S. Nuclear Regulatory Commission 631 Park Avenue King of Prussia, PA.
19406 License No. DPR-35 Docket No. 50-293 Response to IE Inspection #80-20
Dear Mr. Brunner:
Inspection Report #80-20 dated June 4, 1980 contained two items of non-compliance. Boston Edison Company's response to those itens and our position relative to an NRC finding in Section 3.1, (Future Test Schedule) is presented below.
Infractions A.
10 CFR 50, Appendix J, Section III.A.1. (a), states that, "During the period between the initiation of the containment inspection and the performance of the type A test, no repairs or adjustments shall be made so that the con-tainment can be tested in as close to the 'as is' condition as practical."
Contrary to the above, during the type A test, one repair and one adjust-ment to t!he containment isolation boundary were made without measuring (quantifying) the "as found" leakage.
They are:
1.
Attempted repair (tightening) of a leaking 8 inch pipe flange on the RCIC Turbine exhaust line on May 5, 1980.
2.
Made adjustment by closure of valve A0 5033A in the Containment Atmospheric Control System on May 6, 1980.
B.
10 CFR 50, Appendix J, Secticn IV.A, requires that any modification or replacement of'a component which is part of the primary reactor contain-ment be.indary be followed by the applicable type leakage-rate test.
Paragraph VII.E of PNPS Procedure No. 8.7.1.3, Local Leak Rate Test,
- states that, "Whenever maintenance is performed on any of the tested valves, seals, or penetrations which affect their leak tight integrity.
such valve, seal, or-penetration must be retested..."
Contrary to the above, an 8 inch pipa flange on the RCIC Turbine exhaust line, which is part. of the' primary reactor containment boundary, was disassembled for maintenance on May 2, 1980 and not retested. Leakage from this flange subsequently contributed to the failure of the type A. test to meet its acceptance criteria on May 5, 1980.
80'09190 D
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.J BOSTON EDCN. COMPANY Hr. Eld:n J. Brunnsr July 15,1980 Page 2
Response
Although procedural controls (Procedure 8.7.1.3 " Local Leak Rate Test" and Procedure 8.7.1.4 " Primary Containment Integrated Leak Rate Test") in effect at the time do address these occurrences, it was concluded that these controls should be revised to provide more specific direction for cases where work has been' performed on the containment isolation boundary. There-fore to prevent recurrences, corrective actions will be implemented as follows:
A.
1.
Procedure 8.7.1.4 will be revised to clearly specify what actions are to be treen by the test director upon discovery.of unidentified leakages a ' deviations from valve lineups and positions.
These actions v.
be implemented prior to the next PCILRT.
2.
The maintat.-nce staff will be provided with guidance on which valves and seals require post work testing under Procedure 8.7.1.3 by August 30, 1980. Additionally, administrative controls will be initiated regarding the LLRT program which will require that during outages,_all work performed on containment penetrations be checked for applicability to the LLRT program.
These controls will be in effect prior to initiation of our_next LLRT.
B.
The corrective actions stated above assure future compliance with Appen-dix J and Station Procedure 8.7.1.3 However, relative to the NRC finding in Section 3.1, Future Test Schedule which stated in part; "The inspector noted that the initial attempt of the 1976 and 1980 periodic Type A test at Pilgrim failed to meet the acceptance criteria and that the licensee was therefore subject to the increased frequency of tests as described above," we offer-the following:
The intent of the acceptance criteria established for Appendix J Type "A" testing is to assess overall degradation of the primary containment by obtaining an overall leakage rate from tha summation of leakage through all potential leakage paths.
This in turn assures that proper maintenance and repairs are made to maintain the integrity of the containment during its service life.
The initial pressurization of 5/5/80 identified a failure of the Type "B" test program but not a degradation of the primary containment boundary.
Our evalua-tion of the test results will be contained within the PCILRT 90 day report.
We trust this letter is responsive to,your concerns, however, should you desire additional information, please contact us.
Very truly yours, t
a L
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