ML20040E370
| ML20040E370 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 01/15/1982 |
| From: | Morisi A BOSTON EDISON CO. |
| To: | Brunner E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML20040E366 | List: |
| References | |
| NUDOCS 8202040237 | |
| Download: ML20040E370 (3) | |
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4 BOSTON EDISON COMPANY DENERAL OFFicts 800 BovtstoN simEET SOSTO N, M ASS ACHUB ETim 0 219 9 A. V. M O Rigi MANADER NUCLEAR OPERATION 5 BUPPORT DEPARTMENT BECo. Ltr. #82-13 Mr. Eldon J. Brunner, Chief Reactor Projects Branch No. 1 Division of Resident and Project Inspection 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 Inspection 81-19 Reference (A): NRC Letter dated November 25, 1981, IE Inspection 81-19 (BECo. Ltr. #1.81.342)
Dear Sir:
This submittal is in response to the items of violation identified in Reference (A). We regret that, due to the holidays, this response was delayed.
Violation, Item A (1)
USNRC Regulatory Guide 1.33, Appendix A, Section 7, specifies procedures for the operation of the liquid radioactive waste system. Procedure No. 7.9.2, " Liquid Radioactive Waste Discharge", Revision 11,Section V.A., Precautions, requires that if a dilution pump in operation at the start of a release fails, the Watch Engineer should terminate the release and have a new discharge permit issued which reflects the new dilution flow.
During a radioactive discharge of the 'B' miscellaneous tank between the period of 2:05 pm and 4:30 pm on August 20, 1981, the Watch Engineer did not terminate the release when a dilution pump (circulating water cump) was secured.
Response
The immediate response to this item was an entry in the Watch Engineer's instruc-tion log book pertaining to taking the pumps out of service when discharging.
To preclude a shutdown of the pumps during a discharge, a sign has been made to install on the ampere meters for the circulating water pumps.
Also, station procedures numbers 7.9.2 and 2.1.17, which relate to liquid radioactive waste discharges, will be reviewed and, where necessary, be revised to contain similar language pertaining to discharges. The revisions will also address the proper use of the sign mentioned above. These revisions will be implemented prior to start-up.
8202040237 820129 PDR ADOCK 05000293 a
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e C 0".T O N EDICON COMPANY ltr. Eldon J. Brunner, Chief January 15, 1982 Page 2 Violation, Item A (2)
USNRC Regulatory Guide 1.33, Appendix A, Section B, specific procedures for surveillance tests of the Service Water System.
Procedure No. PT 80-76, "SSW Performance Test", Revision 1,Section III, Prerequisites, specifies that the screenwash pumps must be off during the test.
TP 80-76 was performed on August 19, 1981 with the screenwash pumps in operation 3
with the completed test data having been reviewed and found acceptable by the Performance Engineer and Watch Engineer on August 19, 1981.
Response
As noted in the inspection report, our immediate act;9p upon discovery that the calculation had not accounted for the screenwash pumps ceing on was to revise the calculations. The corrections were documented and the Watch Engineer was notified that the test still met the acceptance criteria.
TP 80-76 is a temporary procedure which was used for conducting a performance test of the SSW System to ronitor for and improve our understanding of fouling due to mussel intrusion during Cycle #5. Should TP 80-76 be used next cycle, a revision will be prepared to allow for retaining the screenwash pumps in service if plant conditions require. The revision also will state that the test results must be adjusted for flow diverted to the screen wash system.
Violation, Item B 10 CFR 50.59 (b) states in part "the licensee shall maintain records of chanaes in the facility... to the extent that such changes constitute changes in the facility as described in the safety analysis report... These records shall include a written safety evaluation which provides the basis for the determination that the change... does not involve an unreviewed safety question.
Contrary to the above, on September 17, 1981, modifications were made to the Residual Heat Removal System pump minimum recirculation protective features as described in the FSAR Section 7.4.3.5.4 without a safety evaluation having been performed.
Response
We do not interpret 10 CFR 50.59 as requiring a review of maintenance activities per-formed within the system operability requirements of Technical Specifications.
How-ever, we concur that a 10 CFR 50.59 review should have been performed to determine whether the "A" Containment Cooling Loop was operable in accordance with Technical Specification requirements after making the minimum flow valve inoperable.
The plant conditions and evolutions in progress were reviewed and discussed by shift personnel and-senior station management during this event to ensure that the requirements of the Technical Specifications were met. Since the Limiting Conditions for Operation, as specified in the Technical Specifications, are sup-ported by Safety Evaluations, it has been our belief that they form the basis for what is permissible provided that the specified actions are taken. lhe Maintenance Request Process is our mechanism for ensuring that proper review is conducted prior to allowing an activity to commence, documenting that review, and ensuring that the component / system is returned to normal following the activity.
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- CO3 TON EDB20N COMPANY Mr. Eldon J. Brunner, Chief January 15, 1982 Page 3 In response to discussions with NRC, senior station management issued a policy on September 22, 1981 to all operating shifts requiring that any safety related pump / system be considered inoperable whenever the minimum flow recirculation valve on the pump / system is made inoperable. A written safety evaluation is being prepared to detennine whether this policy should be adopted as a pemanent station policy or modified following a 10 CFR 50.59 review.
A corporate directive has been issued to require that whenever any portion of a safety system or its related auxiliary systems is made inoperable for main-l tenance or testing, the affected safety system shall be considered inoperable and requirements of the Technical Specifications appropriately implemented unless a written safety evaluation has been prepared which demonstrates that the system as i
configured for maintenance or testing is able to perform its required safety function and a 10 CFR 50.59 review has been perfomed.
Boston Edison believes that implementing this directive provides increased assurance that the requirement of 10 CFR 50.59 will be met.
Very _truly yours,
f A
Commonwealth of Massachusetts) b
&AN County of Suffolk
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Then personally appeared before me John M. Fulton, who, being duly sworn, did state that he is Project Manager - Nuclear Licensing of Boston Edison Company, the applicant herein, and that he is duly authorized to sign for A. Victor Morisi, Manager - Nuclear Operations Support 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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