ML20010D135
| ML20010D135 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 08/14/1981 |
| From: | Morisi A BOSTON EDISON CO. |
| To: | Eisenhut D Office of Nuclear Reactor Regulation |
| References | |
| TASK-***, TASK-TM 81-190, NUDOCS 8108240053 | |
| Download: ML20010D135 (28) | |
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.l BOSTON EDISON COMPANY acNemat arrices eco eOvtsv0N sincer BOSTO N, M E54c c a 02199 h
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MANAGER
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NUCLEAR OPERATIONS SUPPORT DEPARTMENT v1 \\
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August 14, 1981
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- gg" BECo. Ltr. #81-190 Mr. Darrell G. Eisenhut, Director y
Division of Licensing
,x_f Office of Nuclear Regulatory Co' amiss [idn Washington, D.C.
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License No. DPR-35 Docket No. 50-293 ORDER CONFIRMING LICENSEE COMMITMENTS ON POST TMI RELATED ISSUES 4
Dear Sir :
i Boston Edison has reviewed your letter dated July 10, 1981 confirming i
our commitments for TMI related activities for Pilgrim Nuclear Power i
Station, Unit 1.
The order does not address our apecific commitments as referenced in the attachment to the order. It is Boston Edison's understanding, based on telphone conversations with your staf f on August 7,1981, that the Commission's intent is to confirm our specific commitments as stated in reference A, B, C, D, E, F, G and H.
Bas ed on that conclusion Boston Edison will not request a hearing for stay-of the order dated July 10, 1981.
j In an effort to address specific requirements and to provide clarifi-l cation of our commitments, we are providing the following information regarding Post TMI related commitments in Attachment (1).
4 Additionally, we are reviewing the implementation of our commitments and will notify you of any deviations.
Very truly yours, l
Attachments AVM/mce O
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References (A) BEco Ltr 81-92 dated May 8, 1981 (B) BECo Ltr 81-44 dated Feb 27, 1981 (C) BECo Ltr 81-37 dated Feb 11, 1981 (D) BECo Ltr 81-10 dated Jan 22, 1981 (E) BECo Ltr 81-01 dated Jan 5, 1981 (F) BECo Ltr 80-310 dated Dec 15. 1980 (G) BECo Ltr 80-246 dated Oct 1, 1980 (H) BECo Ltr 80-54 dated April 4, 1980
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v-9 ATTACHMENT 1
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I.A.1.1 Shift Technical Advisor As s tated in reference (F) and (H) we created the position of STA.
In referei.cc (E) we described our training program for STA, in that response we stated cur initial candidates will have completed training in section A and B by January 1, 1981 and section C and D of the program is scheduled to be complete by June 1, 1981 with requalification training in place by Jan 1, 1982. Our long term program was also described in that letter which is consistent with those in the INPO document entitled " Nuclear Power Plant Shift Technical Advisor".
t 1.A.2.1 Reactor Operator Qualification As stated in reference (F) we had completed the following:
1.
Revise training manual to required SRO applicants to have been an RO for 1 year by 12/1/80 2.
SRO applicants to have experience commensurate with recommendations of I.A.2.1 and incorporate that criteria in our training manual by 5/1/80 3.
SRO and R0 applicants to have 3 months On the Job Training as an extra person on shift and incorporation of this requirement in our training manual by 8/1/80 4.
Modify training and submit a revised program to OLB by 8/1/80 and to address mitigating core damage training in response to the requirements in TAP II.B.4 5.
Certification of competence and fitness of applicants for SRO and R0 license incorporated into training manual by 5/1/80.
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i II.B.2 Plant Shielding i
As stated in references (E) and (F) we committed to the following:
1.
A review of our initial shielding study based on the clarification of NUREG 0737 item II.'.2.
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A scheduled completion by 1/1/82 of the followine modifications to provide vital area accessability:
l Remote closure capability of the Reactor Building a.
Truck Lock Door; b.
Post Accident Sample Sink installation; c.
Remote operation of Post Accident Combustible Gas Control Valves.
3.
Not to consider a LOCA event in which the primary eystem does not depressurize in considering dose rates. This is based on the conclusion that emergency procedures in effect require the RCS be promptly depressurized and cooled down with low pressure systems following an accident of large 4cale fuel damage, l
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O II.B.3 Post Accident Sampling As stated in reference (B, (E) and (H) we committed to the followinn:
1.
Provide interim procedures for taking and handling a car *2inment atmospheric sample by Nov 28, 1980.
2.
Provide a new sample station outside the reactor building with new sample points for re actor coolant. Provision to maintain exposure to 3 rem whole body and 18 3/4 rem for extremities to the operator.
Vrotection to the general public against the possibility of gas samples escaping from the new sample location.
Liquid Samples will be analyzed for dissolved hydrogen and isotopic content. Cas samples will be analyzed for hydrogen, oxygen and isotopic content.
3.
Provide safety grade components up to and including the second automatically operated isolation valve in each sample line. Redundant sample lines up to the second isolation valve in each sampic line. Non safety grade components and materials for the balance of the system.
The su',eduled completion as stated in reference (B) is Jan. 14, 1982
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4 II.B.4 Training for Mitigating Core Damane As stated in references (E) and (F) we commi:ted to the following:
Training for use of installed equipment and systems to control or miticate accidents in which the core is severely damaged has been developed.
The program is intended for traininn STA's and operating personnel from the plant manager through the operating chain to the licensed operators and includes all training indicated in enclosure 3 to H. R. Denton's March 38, 1980 letterProperty "Letter" (as page type) with input value "05000000/LER-1975-004, :on 750112 & 13,analysis of Reactor Bldg Vent Process Radiation Monitoring Sys Revealed Release of Radioactive Effluents Exceeding Tech Spec Limit by 55%. Caused by High Iodine Activity in Reactor Coolant"March 38, 1980" contains a sequence that could not be interpreted against an available match matrix for date components." contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process..
The training is scheduled tentatively for February through April 1981.
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I.C.1 Accident Procedures i
i As sta,ted in reference (F) we committed to the following:
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Revised and train operators in procedures applicable l
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Subsequent I&E site inspection based on our response in reference 1
(H) and review of our procedures and training have concluded that this item is complete.
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2.
Reanalyze and propose guidelines regarding Emergency procedures i
for Inadequate Core Cooling by 1/1/81. Revise operators training j
and procedures after NRC guidance is issued.
3.
Reanalyze and propose guidelines regarding Emergency procedures for Accidents and Transients by 1/1/81. Revise operators training and procedures after NRC guidance is issued.
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1.0.5 Feedback of Operating Experience As stated in references (E) and (F) we committed to the followir. ;:
1.
Procedures governing feedback of operating experience will be in effect by January 31, 1981.
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o I.C.6 Correct Performance of Operating Activities As stated in references (B) and (F) we committed to the following:
A station policy regarding the subject matter will be in place by March 31, 1981 and procedures affected by that policy will be evised by June 1, 1981.
II.D.1 SRV Testing As stated in reference (F) we committed to the following:
1.
A testing program for RV/SV's as outlined by the BWR Owner's Group committee on RV/SV testing and a schedule consistent with NRC requirements.
2.
Completion of test program and a review that valves meet operability concerns by 7/1/81.
3.
Plant specific report by 10/1/81.
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II.E.4.2 Containment Isolation As we stated in references (D), (E) and (F) we committed to the following:
1.
Provide documentation to position: 1-4 for II.E.4.2 2.
Provide a response demonstrating the adequacy of our containment isolation setpoint.
(Position 5) 3.
Implement Administrative controls to satisfy pottition (6).
II.F.1 Post Accident Monitoring As we stated in our reference (B) and (F) we committed to the following:
1.
Noble Gas Monitors have been installed per catagory A modifications. Procedures have been changed to convert mr/hr to uCi/sec. Detailed justification to show con-formance with NUREG 0737 has been provided.
2.
Particulate / Iodine monitoring capability is installed at PNPS-1.
In the event the sample device is unavailable cal-culations have been performed and procedures are inplace to determine conservative release rate estimates.
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II.F.2 Instrumentation for Inadequate Core Cooling As we stated in our references (E) and (F) are committed to the following:
We participated in and endorsed the BWR Owner's Group position that current instrumentation is capable of detecting inadequate core cooling and no modifications are necessary at this time, but are evaluating our position and if any change is made we will notify NRC at that time.
II.K.3.3 SV/RV Challennes As we stated in our references (B) and (F) we committed to the following:
Provide a report detailing SV/RV challenges since April of 1980.
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II.K.3.13 Separation of HPCI/RCIC Initiation Levels and Auto Restart of RCIC As we stated in our references (C), (E) and (F) we committed to the following:
1.
Provide results of study to determine the feasibility and enhancement of separation of HPCI/RCIC initiation levels.
Based on that report it was concluded that no modification is necessary.
2.
Provide results of a study to determine the feasibility and enhancement of Auto Restart capability to the RCIC system.
Based on that report, we committed to implement option 1 by January 1, 1982 and option 2 by July 1, 1982.
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4 II.K.3.16 Reduction of Challenges and j
Failures to Relief Valves As we stated in our reference (A) and (F) we committed to the following:
We participated 1-and endorsed the BWR Owner's Group position that would reduce the incidence of SORV. Additionally,we stated we have modified our RV and have procedures in effect that meet the requirements to reduce the incidence c.f SORV and challenges to relief valves.
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II.K.3.17 ECCS Outage Reporting As we stated in our referei.cc (D) and (F) we committed to the following:
Provide a report detailing ECC system outages from January 1975 to December 1979. This item was completed and sent on January 22, 1981.
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O II.K.3 d ADS Logic Modification As we,tated in our references (A) and (F) we committec. to the following:
We particpated in and endorsed the BWR Owners Group position that identified three options to ADS modifications including retention of existing logic coupled with implementation of the symptom oriented emergency procedures.
II.K.3.21 CSS /LPCI Restart As we stated in our references (E) and (F) we committed to the following:
We participated in and endorsed the BWR Owners Group position that no enhancement to safety would be achieved and thus, no modifications are necessary.
II.K.3.22 RCIC Suction As we stated in our references (B), (D) and (F) we commit 6ed to the following:
We have reviewed and revised our procedures and have concluded that existing procedures are adequate.
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s II.K.3.27 Common Water Level Reference As we stated in our referencs (B), (D) and (F) we committed to the following:
Marker plates will be installed on all necessary level instruments referencing the top of active fuel.
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e II.K.3.30 SB LOCA Methods As we stated in our references (F) and (G) we committed to the following:
General Electric will provide the NRC with a generic position and BECo will determine it's applicability to PNPS-1.
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9 II.K.3.44 Evaluation of Transients with Single Failure to Verify No Fuel Failure As we stated in our references (E) and (F) we committed to the following:
We participated in and endorsed the BWR Owners Group position and reviewed its applicability to PNt>S-1.
No further action is planned.
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o II.K.3.45 Evaluation of Depressurization other Than ADS As we stated in our references (E) and (F) we committed to the following:
We participated in and endorsed the BWR Owners Group position and reviewed its applicability to PNPS-1.
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III.D.3.3 Improved Inplant Iodine Monitoring As we stated in our reference (H) we committed to the following:
The intent of this position has been met by successfully completing the following:
1.
'ilver Zeolite cartridges have been purchased & stored onsite.
2.
Cartridge equipment is procured and installed.
3.
Standards for calibration have been prepared.
4.
Procedures have been modified and training complete.
r III.D.3.4 Control Room Habitability As we stated in our reference (C) and (E) we committed to the following:
Provide details of the Control Room Habitability Study by Jan. 21, 1981.
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