ML20010G013
| ML20010G013 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 09/08/1981 |
| From: | Morisi A BOSTON EDISON CO. |
| To: | Ippolito T Office of Nuclear Reactor Regulation |
| References | |
| 81-212, NUDOCS 8109150231 | |
| Download: ML20010G013 (4) | |
Text
.
BOSTON EOlsON COMPANY GENER AL OFFICES 800 BOYLSTON STREET BO STON, MAm e ACHL8B ETTm 0219 9 A. V. M O RISI MANADER HuCLEAR OPERATIONE SUPPORT DEPARTMEMT September 8, 1981 BECo Ltr
- ~ g 7/\\
@4 :L e
Mr. Thomas A. Ippolito, Chief N[ *p Operating Reactors Branch #2 q
Division of Licensing g1 h/
Office of Nuclear Reactor Regulation gd cp r
U.S. Nuclear Regulatory Commission O
]y wf Washington, D. C.
20555
/
\\
License Docket No. 50-293 Response to IE Inspection #81-12 Daar Sir:
The following contains Boston Edison's response to items identified by IE Inspection 81-12, NRC letter of July 29, 1981:
Notice of Violation, Appendix A, Item (1)
ANSI N18.7-1972, Section 5.3.2.4, states that " procedures should identify those independent actions or procedures that should be completed and plant conditions that should exist prior to its use." Station Procedure No. 2.2.87, " Control Rod Drive System", Revision 8, does not require a Shutdown Margin calculation /verifi-cation (to ensure that Technical Specification Sections 3.3.A.2.b, 3.3.A.1, and 4.3.A.1 are met) prior to making a control rod inoperable. On May 21, 1981, control rod no. 22-35 was valved out of service in the full out position with the reactor at power.
It was not until May 29, 1981 that the licensee received c.ticulations from General Electric Co. which verified that the required Shutdown Margin had been met.
Response
Reactor Engineering personnel are cognizant of their responsibility for supplying the Watch Engineer with confinnation that the shutdown margin is being maintained prior to valving a control rod out of service.
Procedure 2.2.87 has been revised to state that Reactor Engineering must be con-sulted regarding the shutdown margin, and must confirm that it is being maintained when a control rod is valved out of servicp bT/o0/
Full compliance has been achieved.
1
/!O 0109150231 010908 PDR ADOCK 05000293 G
COhTON EDICON COMPANY Mr. Thomas A. Ippolito, Chief September 8, 1981 Page 2 Notice of Violation, Appendix A, I+em (2)
ANSI N18.7-1072, Section 5.3.4.4, states that "The limits (maximum and minimum) for significant process parameters should be identified. The nature and frequency of this monitoring shall be covered by eperating procedures, as appropriate."
Station Procedure No. 2.2.70 " Primary Coatainment Atmospheric System", Revision l
16, requires operation of the Standby Gas Treatment System, per Procedure No.
2.2.50, when inerting and venting the drywell or torus. Technical Specification 4.7.B.1.a(6) requires a laboratory analysis of the charcoal filters of the Standby Gas Treatment System (SGTS) after every 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of operation. Neither procedure (2.2.70, nor 2.2.50) specifies requirements to keep accurate times for each filter train of the SGTS. On May 6,1981, the licensee was logging times that either the ' A' or
'B' SGTS fan was in operation; however, since April,1981, the licensees had placed the SGTS dampers in the open position and therefore whenever either fan was run, both filters would be in operation.
Response
Interim management controls have been implemented to monitor and log the opera-tional run times for each filter train of SBSTS.
Procedure 1.3.34, Conduct of Operations, and OPER-38 are beira revised to address the operational run time on the SGTS. The run time shall be logged for each SGTS on a watch-to-watch basis.
Full compliance shall be achieved by September 30, 1981.
Notice of Violation, Appendix A, Item (3)
ANSI N18.7-1972, Section 5.1, states that "In particular, written administrative policies shall be provided to control the issuance of documents, including changes..." Station Procedure No.1.3.8, Document Control, Revision 25, was inadequate in that it does not address control of procedures which are posted
(
at various locations throughout the station. At various times during May,1981, copies of an out of date (retired) procedure No. 5.3.1, " Shutdown From Outside the Control Roca", were posted in the Emergency Diesel Room, at ECCS equipment, j
and at 4160v and 480v switchgear.
l
Response
l The innediate concern of retired procedures, such as 5.3.1, was corrected by removing and replacing them in their respective locations. To preclude recurrence, Procedure 1.3.8 and associated work instructions shall be revised by October 30, 1981.
Notice of Violation, Appendix A, Item (4)
ANSI N18.7-1972, Section 5.3.3, states that " Instructions for energizing, filling, venting, draining, startup, shutting down, changing modes of operation, and other instructions appropriate for operations of systems related to safety of the plant shall be deliniated in system procedures..." Station Procedures for operations of the Residual Heat Removal (RHR) System (2.2.86, Revision 13) and the Fuel Pool
. CONTON E0120N COMPANY Mr. Thomas A. Ippolito. Chief Septenber 8,1981 Page 3 Cooling and Cleanup System (FPCCS) (2.2.85, Revision 8) were inadequate in that they did not specify the normal position of the RHR-to-Fuel Pool spectacl e flanges; nor mention repositioning these flanges when using the FPCCS to clean up water from the torus via the RHR System.
Response
Currently, the system is red-tagged in order not to permit use of the spectacle flanges during normal power operations.
Procedures 2.2.85 and 2.2.86 are being updated to include coverace of the normal position of the spectacle flanges during t
normal operation.
Full compliance shall be achieved by September 30, 1981.
Notice of Violatior,, Appendix A, Item (5)
ANSI N18.7-1972, Section 5.3.6, states that "...the procedures shall have provisions for meeting surveillance schedules and for assuring measurement accuracies adequate to keep safety parameters within operational and safety limits." Technical Spec-ification Table 3.7.1 specifies that the two RHR discharge isolation valves to radwaste must close in less than or equal to 20 seconds. Two of the licensee's procedures "8.7.4.3 " Test Isolation Valves Except MSIV's", Revision 5, and 8.5.2.1 "LPCI Subsystem Operability Surveillance Test", Revision 7, were inadequate in that they specified that the maximum acceptable closing time for the RHR to Radwaste Isolation Valves (1001-21,1001-32) was 25 seconds.
Revision SR0s 81-12 and -13 were issued June 2,1981 to correct the maximal allowable closing time of the two RHR discharge isolation valves to 20 seconds. This change also has been incorporated into Revision 4, Procedure 8.7.4.3, on June 3,1981 and into Revision 8, Procedure 8.5.2.1, on June 24, 1981.
Full compliance has been achieved.
Notice of Violation, Appendix A, Item (6)
ANSI N18.7-1972, Section 5.3.6 states that "...The pri:edures shall have provisions...
for assuring measurem nt accuracies adequate to keep safety parameters within operational and safety limits." Procedure No. 8.8.1.8, local Leak Rate Testing of Feedwater Check Valves, Revis*on 7, was inadequate in that the acceptance criteria in Section IX was not consistent with Technical Specification Section 4.7.A.2.f.
Response
Procedure 8.7.1.8," Local Leak Rate Testing of Feedwater Check Valves," has been revised.
Full compliance has been achieved.
ObTON Eol DN COMPANY Mr. Thomos A. Ippolito, Chief September 8. 1981 Page 4 Notice __of Violation, Appendix A, Item (7)
ANSI N18.7-1972, Section 5.3.3, states that " Instructions for... filling, venting, draining,... shall be deliniated in system procedures. Procedure No. 8.7.1.5, " Local Leak Rate Testing of Primary Containment Penetrations and. Isolation Valves", Revision 8, was inadequate in that many system figures (providing the lineup for individual valves) incl. Jed incorrect locations for venting and draining during leak rate testing.
Responses The corrective action will be to revise procedure 8.7.1.5 to clarify the
" venting, draining, filling...". The revision to 8.7.1.5 shall delineate the procedure for performing each test including the ' venting, draining, filling...'
This action involves new more complete sketches of the piping and valving to be tested, and instructions for performing each test. This action is extremely labor intensive. An estimated 300 man-hours will be required to review and revise the system sketches; additional man-hours will be required to validate the work.
Changes to Procedure 8.7.1.5 sketches will be drafted and validated concomitantly with the testing during the 1981 outage.
Full compliance will be achieved by 1/1/82.
We believe the above response satisfactorily addresses the identified items.
Should you have further questions concerning this response after reviewing it, plean contact us.
Very truly yours, Conmonwealth of Massachusettd County of Suffolk i
Then 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 j
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.
My Conmission expires:
<Uva h
. b1 A Notary Pulilic j7
-