ML20010A264

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Forwards Addl Info Needed to Assume Compliance w/10CFR50.44, in Response to NRC .Tech Specs for Standby Gas Treatment Sys Commensurate W/Suggested Criteria Will Be Developed.W/O Encls
ML20010A264
Person / Time
Site: Pilgrim
Issue date: 07/07/1981
From: Morisi A
BOSTON EDISON CO.
To: Ippolito T
Office of Nuclear Reactor Regulation
References
81-154, IEB-79-01B, IEB-79-1B, NUDOCS 8108110248
Download: ML20010A264 (3)


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BasTON EpisON COMPANY DENERAL Orricts 800 BovLaTON STREET BonTON, M AESACNUS ETTs 0219 9 A. V. M O Rf S 8 MANAGER NUCLEAR OPERATIONS SUPPORT DEPARTMENT July 7, 1981 BECo Ltr. #81-154 Mr. Thomas A. Ippolito, Chief Operating Reactors Branch #2 Division of Licensing Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, DC 20555 License No. DPR-35 Docket No. 50-293

Dear Sir:

In your letter dated June 26, 1981, you requested Boston Edison Company (BECo) to provide additional information necessary for the Office of Nuclear Reactor Regulation (NRR) to assure the current compliance of Pilgrim Nuclear Power Station (PNPS) with 10 CFR 50.44. This system information was requested in sufficient detail to enable NRR to evaluate the cystem's specific compliance with 10 CFR 50 Appendix A, GDC 41, 42 and 43.

In response to your requests and pursuant to 10 CFR 50.44(f), Boston Edison Company herein provides as Attachments to this letter, documentation which (except for the Stand-by Gas Treatment (SBGT) system component qualification issue discussed below) confirms PNPS's compliance with 10 CFR50.44.

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addition, Bosto: Edison Company shall develop Technical Specifications for the system commensurate with the suggested criteria delineated in your letter.

These proposed Technical Specifications shall be provided for your review by September 1, 1981.

The following is a list of the documentation enclosed as Attachments to this letter.

A detailed system description which addresses, in detail, Attachment A. / components and features, interconnection capabilities, leak redundance in detection capability, automatic isolation and containment capability, such that with either a loss of off-site or ca-site power, accompanied by the most limiting single failure, +he sve'.em will perform its safety function.

Attachment B.

Current (as-built) piping and instrumentation drawings (PalD's) and electrical schematics for the system.

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1 ED} TON EDCON COMPANY Mr. Thomas A. Ippolito, Chief July 7, 1981 Page.Two Attachment C.

The pre-operational test data and test procedure (s) used to demonstrate compliance with Appendix A, GDC 43, and Appendix B, XI, of 10 CFR 50.

Attachment D.

A discussion of how the explicit requirements for Design Control (10 CFR 50 App. 9 III) were met.

Specifically, an independent design review to verify ti,e adequacy of the system and design.

A dis-cussion of the design control measures which guaranteed an independent

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design review for field changes to the system from initial inst.allation to present per 10 CFR 50 Appendix B III and a similar discussion for future field changes.

Attachment E.

A discussion of the suitability of system parts regarding GDC 4.

The utilization of the SPGT system as the purge filtration system in con-formance with the rcq"i;ements of 10 CFR 50.44(g) necessitated a reevalua-tion of the-qualification of the components of the SBGT system to assure compliance with GDC 4 under the specified criteria of IEB 79-01B. This reevaluation revealed an unavailability of documentation to substantiate the qualification of certain components in the S8GT system. This was verbally reported to I&E on July 6,1981, and is the subject of a follow-up LER issued on July 7,1981.

Pilgrim Nuclear Power Station was shut down on June 30, 1981, due to an unrelated issue.

Its retcen to operation, however, is contingent upon our resolution of the SBGT system concerns by either documenting the qualification of required equipment or replacement with qualified components.

We will notify you as soon as such documentation is available or such replacement is effected.

Boston Edison Compar. is confident that your review of the enclosed docu-mentation will confirm our position that with the exception of the SBGT system component qualification issue, Pilgrim Nuclear Power Station currently complies with 10 CFR 50.44 l

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  • STON EDCON COMPANY

,o Mr. Thomas A. Ippolito, Chief July 7, 1981 Page Three We are cognizant of the fact that the issue of compliance with 10 CFR 50.44 identified to your staff on May 29, 1981, subsequently documented in BECo Letter #81-127 and discussed in a meeting with you on June 18, 1981, will be addressed by the Office of Inspection and Enforcement. Please be advised that this issue is the subject of a detailed in-house investigation end that this investigation is being given priority attention.

Should you have any additional comments or questions, please do not hesitate to contact us.

Very truly yours, A

Commcnwealth of Massachusetts)

County of Suffolk

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The.n personally appeared before me A. Victor Morisi, who, being duly sworn, did state that he is Manager - Nuclear Operations Support of Boston Edison Company, the applicant herein, and that he is duly authorized to execute and file the submittal contained herein in the name and on behalf of Boston Edison Company and that the statements in said submittal are true to the best of his knowledge and belief.

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