ML20054G509
| ML20054G509 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 06/09/1982 |
| From: | Moris A, Morisi A BOSTON EDISON CO. |
| To: | Eisenhut D Office of Nuclear Reactor Regulation |
| References | |
| RTR-NUREG-0737, RTR-NUREG-737, TASK-2.B.2, TASK-2.B.3, TASK-2.F.1, TASK-2.K.3.27, TASK-TM 82-172, GL-82-05, GL-82-10, GL-82-5, NUDOCS 8206210620 | |
| Download: ML20054G509 (6) | |
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BOSTON EDISDN COMPANY orwenAL Drescre soo sortston sTazer WDaTON, MassACMUserfs 021')9 A. V. M D R15 8 MANAoER NUCLEAR OPERATIONS SUPPORT DEPARTMENT June 9, 1982 Mr. Darrell G. Eisenhut, Director Division of Licensing Office of Nuclear Reactor PLgulation U.S. Nuclear Regulatory Comnission Washington, D.C.
20555 License No. DPR-35 Docket No. 50-293 Additional Information on NUREG 0737 Items In Response to NBC Generic Ltr 82-05 and 82-10 Dear Sir; The subject letters requested dates for empletion of specific NUREG 0737 modifications. Boston Edison responded to that request and stated we would provide dates for cmpletion consistent with our integrated work plan cur-rently under development with manbers of your staff. Additionally, we are now providing further clarification of our position as you have requested during a site visit by Ken Eccleston. Attachnent A provides that response.
Should you have any questions or concerns on these NUREG items, please do not hesitate to contact us.
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D Very truly yours, I
l A. V. bbrisi l
8206210620 820609 PDR ADOCK 05000293 P
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i<tEt.utBCES A.81-200 Dated June 1, 1981 B.
82-24 Dated Jan. 25, 1982 C.
82-46 Dated Feb. 5, 1982 D.
82-62 Dated Feb. 24, 1982 E.82-148 Dated May 24, 1982 F.82-105 Dated April 16, 1982
5 II.B.2 Plant Shielding Boston Edison canpleted the Vital Area Accessibility Study for PNPS by January 1, 1982.
The study identified the need for the following nodifications:
i (1) Remote Operation Capability for Post Accident Canbustible Gas Control (Item 2.1.5a)
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(2) Post Accident Sampling System (Itan II.B.3)
(3) Containment H /0 bbnitoring System (Itan II.F.1.6) 2 (4) Upgrade of existing TSC Renote Operation Capability for Combustible Gas Control item 2.1.5a was canpleted prior to start-up fran Refueling Outage #4.
The Post Accident Sampling and Containnent H /0 bnitoring will be completed 2 2 by Decanber 30, 1983. Wese items are discussed in more detail under their re-spective NUREG 0737 task action plan task number, i.e, II.B.3 and II.F.1.6.
Upgrade of existing TSC has been delayed and a date cannot be provided at this time. Justification and compensatory measures have been outlined in Ref (A). Additionally all correspondence on this item will be addressed under NUREG 0737 item III.A.1.2 and will no longer be discissed in correspondence for item II.B.2.
Radiation Analyses to denonstrate Environmental Qualification of Electrical Equipnent (IE-79-01B) will be complete by June 30, 1982. We results of this study on that issue will no longer be incorporated in correspndance in NUREG 0737 item II.B.2.
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II.B.3 Post Accident Sampling i
II.F.1.6 Containmnt 11/0 2nitoring System 2 7
'Ihe subject NUREG Items have previously been scheduled for empletion by February 1, 1983. At a meeting with members of your staff on February 19, 1982, Boston Edison described its concerns regarding the potential safety hazard of-j intense construction activity on nodification work at PNPS #1. Subsegne.ntly, nodification work was denobilized in mid March of 1982 in order to mplan and r
integrate all activities with the intent to-control the overall magnitude of construction work and provide adequate assurance for reducing potential safety 1
hazards.
j Currently, we plan to cmplete the subject items by December 30, 1983.
i We have provided. justification and cmpensatory measures in Ref. B which are i
i reiterated for your benefit.
Boston Edison Company's resources have been severely taxed in response to additional NRC concerns such as NRC I&E Bulletins79-01B, 80-11, Fire Protection and M rk I containment integrity.
a Our engineering effort was initially prioritized and sequenced i
to meet the const.ruction schedule and preclude conflict with these concerns. During the Spring and Sunner of 1981, as the engineering scope associated with these issues continued to evolve, a myriad of engineering resource constraints becane apparent. Priorities were reassessed and adjusted, construction schedules were compres-1 i
se1, but the nnjor scope of activities were forced into the 1981 i
rel'ueling outage and occurred simultaneously with other refueling
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outage-related and modification projects. Construction progress against schedule was adversely affected by lost productivity due 1
j to labor disputes and subsequent lower efficiency during extended j
hours worked in attempting to compensate for the schedule delays, j
and because the work was performed during a major outage when plant support services were strained to capacity. Installation of these systems is a major construction effort involving hundreds of crafts-l nun and hundreds of thousands of manhours. Despite these cmplica-tions, the design for these systems is emplete and the installation i
is currently 60% cmplete.
Continued safe operation of Pilgrim Station without the new l
post-accident sampling system and H /0 nonitoring systems is 2 2 assured because the existing systems and interim procedures will i
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be adequate for events which would reasonably be expected to occur during the short period during which they are to be required for service.
Pilgrim Station has inplemented interim procedures for obtain-ing primary containment gas samples and reactor water sanples after an accident. 'Ihere are presently one oxygen analyzer. for measuring primary containnent atnosphere oxygen content and tw redundant hydrogen analyzers for measuring the drywell atmosphere hydrogen content. 'Ihese analyzers have remote readout in the Main Control Roan.
Prinury containment integrity is assured following a IOCA because the operators are provided with numerous indications which would enable the primary containment conditions to be assescal.
'Ihe Containment Atnosphere Dilution system would be implenented within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> of a IOCA; thus,4% hydrogen volume in the contain-nent wculd not be reachel.
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II.K.3.27 Camon Reference IcVel Boston Edison provided justification and conpensatory measures for relief frm implementation iri Ref. (C). The date for cmpletion will be based on our integrated approach for satisfying NUREG Itms I.C.1, I.D.1, I.D.2, and there-fore cannot be provided at this time.
The primary reason for this approach is to change the control room indications only once. Each NUREG item can potentially result in changes to the water level indications for different reasons. If each position is addressed'in-dependently it could result in several changes to the control rom indications and this may lead to confusion of: the operators. A single revision factoring all aspects of NUREG-0737 pertaining to reactor water level would avoid this confusion.
We have incorporated an interim modification adding marker plates referencing instrununts to the top of active fuel. Operator training is provided to assure an understanding of all water level instrument indications.
An operator's response will be no different whether marker plates or cormon scales are provided. He reacts to qualitative changes in instrument indication and therefore does not interpolate the data provided by marker plates or camon scales.
It is our belief that the interim modification of providing marker plates is adequate and sufficient justification exists for our delaying implmentation of this item.
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