ML20009A194
| ML20009A194 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 06/26/1981 |
| From: | Novak T Office of Nuclear Reactor Regulation |
| To: | Morisi A BOSTON EDISON CO. |
| References | |
| NUDOCS 8107090176 | |
| Download: ML20009A194 (3) | |
Text
a cc Docket No. 50-293
'JUN 26 1981 f?
$/g' g,n"rp T Mr. A. Victor Morisi, Mgr.
i Nuclear Operations Support Dept.
ge Boston Edison Conpany l9f r-JUN 2 9 G31.a :~
N/C Nuclear 800 Boylston Street
_] v 5, mun.ym 12 y
Boston, Massachusetts 02199 h
amum
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Dear Mr. Morisi:
ykr{ es RE: Pilgrim I - Containtrent Atnesphere Control System In Boston Edison Cowany's letter of October 19, 1979 (BECo.79-207),
BECo. referred to their analysis which demonstrated cogliance with 10 CFR 50.44. Our letter of October 30, 1979 requested that this analysis be forwarded to us, and that it contain sufficient detail for us to evaluate conpliance with 10 CFR 50, GDC 41, 42, and 43.
On May 29,1981, your staff informed us of a potential non-compliance with 10 CFR 50.44. By June 2,1981, actions were conpleted at Pilgrim to guarantee conpliance, and ir.nediate safety concerns were resolved. The NRC project manager requested a submittal by BECo.
regarding cocpliance with the regulation, from its inplementation to June 2,1981. Your staff supplied that response on June 15, 1981 (BECo.81-127). This response was followed by a meeting with us on June 18, 1981. During the meating it was determined, as documented in BECo.81-127, that Pilgrim I had not been in compliance with the
~ regulation from the effective date of the nile (11/27/78) to June 2, 1981. This matter of past non-coup 11ance, will be addressed by our Office of Inspection and Enforcement. The Office of Nuclear Reactor Regulation will assure the current cor.pliance of Pilgrim I with 10 CFR 50.44 by performing a review of your present system.
This letter formalizes the conclusions of that meeting.
Further information is necessary for us to evaluate the compliance of your systera with 10 CFR 50, App. A, GDC 41, 42, and 43. Therefore, in order to determine whether your license should be modified or suspended, you are required pursuant to 10 CFR 50.54(f), to provide to us within seven (7) days of your receipt of this letter, a written stater.ent, signed under oath or affirmation, which confirms the system's current cocpliance with 10 CFR 50.44 and includes the following:
1.
A detailed system description which addresses, in detail, redundance in conponents and features, interconnection capabilities, leak detection capability, automatic isolation and containnent capability, such that with either a loss of offsite or onsite pouer, accoapanied by ti mt li -it is, st uk f;ilm, :. g ;to a... r....m
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The pre-operational test data and test proceoure(s) used to demonstrate coapliance with App. A, CDC 43, and App. B XI, of 10 CFR 50.
4.
A discussion of how the explicit requirements for Design Control (10 CFR 50 App. S, XI) were met. Specifically, a) An independent design review to verify the adequacy of the system design, and b) suitability of parts regarding GDC 4.
5.
A discussion of the design control measures which guaranteed an independent design review for field chances to the system, from initial installation to present, per 10 CFR 50, App. B. III, and a similar discussion for future field changes.
- 6. -In order to assure future cocpliance, your statement should include a connitment to provide Technical Specifications for the system regarding a) surveillance of ducts, piping, filter francs, pressure source 4
levels (ie. required capacity for system operation )2 or other important cor:ponents or aspects with the apprcpriate Limiting Conditions of Operation, and b) periodic pressure and functional testing to demonstrate full compliance
.with GDC 43. Such testing aust reflect the Test Controls of 10 CFR 50, App. D, XI. Records retention sust coriply with 10 CFR 50, App. 8, XVII.
The subittal of such proposed Technical Specifications will be acceptable in lieu of the co;.altant. Our review of your submittal should not preclude your co:pliance with your proposed specifications unless a conflict exists between them and exi' sting specifications.
Sincerely.
ORIGINAL SIGNED BY i
Thomas M. Novak, Assistant Director for Operating Reactors Division of Licensing I
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UNITED STATES e
o NUCLEAR REGULATORY COMMISJlON g
- j WASHINGTON, D. C. 20555 k..... j/
June 26, 1981 Docket No. 50-293 l
Mr. A. Victor Morisi, Mgr.
- Nuclear Operations Support Dept.
Boston Edison Cogany M/C Nuclear 800 Boylston Street Boston, Massachusetts 02199
Dear Mr. Morisi:
RE: Pilgrim I - Containnent Atmosphere' Control System
. In Boston Edison Cogany's letter of October 19, 1979 (BECo.79-207),
BECo. referred to their analysis which demonstrated compliance with 10 CFR 50.44. Our letter of October 30, 1979 requested that this analysis be forwarded to us, and that it contain sufficient detail for us to evaluate cogliance with 10 CFR 50, GDC 41, 42, and 43.
On May 29,1981, your staff informed us of a potential non-compliance with 10 CFR 50.44.
By June 2' 1981, actions were completed at Pilgrim to guarantee compliance, and imediate safety concerns were resolved.
The NRC project manager requested a submittal by BECo.
regarding cogliance with the regulation, from its implementation
~
to June 2,1981. Your staff supplied that response on June 15, 1981 I
(BECo.81-127).
This response was followed by a meeting with us on June 18, 1981. During the meeting it was determined, as documented in BECo.81-127, that Pilgrim I had not been in compliance with the regulation from the effective date of the rule (11/27/78) to June 2, 1981. This matter of past non-compliance, will be addressed by our Office of Inspection and Enforcement. The Office of duclear Reactor Regulation will assure the current compliance of Pilgrim I with 10 CFR 50.44 by performing a review of your present system.
[
This letter formalizes the conclusions of that meeting.
Further information is necessary for us to evaluate the compliance of your system with 10 CFR 50, ' App. A, GDC 41, 42, and 43. Therefore, in order to determine whetner your license should be modified or suspended, l
you-are required pursuant to 10 CFR 50.54(f), to provide to us within l
sever-(7) days of your receipt of this letter, a written statement, signed under oath or affirmation, which confirms the system's current l
cogliance with 10 CFR 50.44 and includes the following:
I 1.
A detailed system description which addresses, in detail, redundance in cogonents and features, interconnection capabilities, leak detection capability,' automatic isolation and containment capability, l
such that with either a loss of offsite or onsite power, accompanied by the most limiting single failure, the system will perform its safety function.
l
- 2. Current (as built) piping and instrumentation drawings (F&ID's) and electrical schematics for the system.
I
\\
4
_2_
3.
The pre-operational test data and test procedure (s) used to demonstrate compliance with App. A, GDC 43, and App. B, XI, of 10 CFR 50.
4.
A discussion of how the explicit requirements for Design Control (10 CFR 50 App. B, XI) were met.
Specifically, a) An independent design review to verify the adequacy of the system design, and b) suitability of parts regarding GDC 4.
5.
A discussion of the design control measures which guaranteed an independent design review for field changes to the system, from initial installation to present, per 10 CFR 50, App. B. III, and a similar discussion for future field changes.
6.
In order to assure future compliance, your statement should include a comitment to provide Technical Specifications for the system regarding a) surveillance of ducts, piping, filter frames, pressure source levels (ie. required capacity for system operation ), or other important conponents or aspects with the appropriate Limiting Conditions of Operation, and b) periodic pressure and functional testing to demonstrate full compliance with GDC 43. Such testing nust reflect the Test Controls of 10 CFR 50, App. B, XI. Records retention must comply with 10 CFR 50, App. B, XVII.
The submittal of such proposed Technical Specifications will be acceptable in lieu of the comitment.
Our review of your submittal should not preclude your conpliance with your proposed specifications unless a conflict -exists between them and existing specifications.
Sincerely, m:#
omas M. Novak, Assistant Director for Operating Reactors Division of Licensing cc: See next page 1
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d Mr. A. Victor Morisi Boston Edison Company cc:
Mr. Richard D. Machon Pilgrim Station Manager Boston Edison Company RFD #1, Rocky Hill Road Plymouth, Massachusetts 02360 Henry.~Herrmann, Esquire Massachusetts Wildlife Federation 151 Tremont Street Boston, Massachusetts 02111 Plymouth Public Library North Street Plymouth, Massachusetts 02360 Resident Inspector c/o U. S. HRC P. O. Box 867 Plymouth, Massachusetts 02360 O
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