ML20079P068

Updates 821022 Supplemental Response to IE Insp Repts 50-293/82-04 & 50-293/82-19.Corrective Actions:Sketches Associated W/Procedure 8.7.1.5 Verified & Valve Checklists of Affected Sys Will Be Updated.Status Rept Due by 830630

ML20079P068
Person / Time
Site:	Pilgrim
Issue date:	02/17/1983
From:	Harrington W BOSTON EDISON CO.
To:	Starostecki R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
References
83-49, NUDOCS 8303040513
Download: ML20079P068 (3)

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> EOSTON EDISON CO W %NY 800 BOYLSTON STREET BOSTON. MASSADHUBETTs 02199 WILLIAM O. HARRf NGTON u .... .. ........,

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February 17, 1983 BECo. Ltr. # 83-49 Mr. Richard W. Starostecki, Director Division of Project and Resident Programs l Region 1 l U.S. Nuclear Regulatory Commission 631 Park Avenue l

King of Prussia, PA 19406 License No. DPR-35 l Docket No. 50-293 l Update to Supplemental Response to IE Report 82-04 and IE Report 82-19

Dear Sir:

BECo. Letter #82-275, dated 10/22/82, outlined a plan to correct the deviations identified in IE Report 82-04 and IE Report 82-19, related to the following documents:

1. Sketches associated with Procedure 8.7.1.5, " Local Leak Rate Testing of Primary Containment Penetrations & Isolation Valves."

2. System P&ID's which were subjected to a walkdown just prior to restart from the 1981 Refueling Outage.

3. Valve lineup checklists associated with the system procedures.

The plan was divided into two phases, with a Phase One completion date of 2/15/83.

Phase One - Identification of Deviations, consisted of the following work items:

1. Procedure 8.7.1.5, Local Leak Rate Testing of Primary Containment Penetrations and 1 solation Valves, would be verified by station test personnel. Responsible BEco, management personnel completed this initial verification on 12/31/82.

2. Procedure 8.7.1.5, would be compared to Procedure 8.C.13, Locked ,

Open, Locked Closed Valve Lineup Surveillance, and updated as C' necessary. Final verification of Procedure 8.7.1.5 sketches was N completed on 1/12/83.

8303040513 830217

[DRADOCK 05000293 PDR gg.ol

S MOlTON EJ5ON COMPANY Mr. Richard W. Starostecki, Director Page 2

3. The P&lD's would be marked up to duplicate the verified sketches in Procedure 8.7.1.5. This work item was completed on 1/28/83.

4. The deviations between the verified sketches in Procedure 8.7.1.5 and the affected system procedure valve checklists would be identified. This work item was completed on 1/28/83.

We stated that the schedule for the completion of Phase Two - Corrective Action, would be contingent upon the number of deviations identified in Phase One.

There -are 14 P&ID's affected by the updated 8.7.1.5 sketches.

The following plan outlines the schedule for completing the work items associated with the Item of Noncompliance, 82-04-03.

1. Procedure 8.2.3, Visual & tbnual Inspection of Primary Containment Isolation Valves 1" and Smaller, will have all of the valves identi-fled in the procedure transcribed into the Appendix A valve checklists of the affected system procedures by 6/1/83. At the conclusion of this work item, Procedure 8.2.3, Visual & Manual Inspection of Primary Containment Isolation Valves 1" and Smaller, will be retired.

2. All of the verified sketches associated with Procedure 8.7.1.5, Local Leak Rate Testing of Primary Containment Penetrations and Isolation Valve s , will be redrawn and retyped to incorporate new data identified as a result of this effort by 6/15/83.

3. The affected systems with valves located outside of the primary containment will have their Appendix A valve checklists updated to incorporate the deviations identified between them and the Procedure 8.7.1.5 sketches by 7/15/83.

The affected systems with valves located inside the primary containment will have their Appendix A valve checklists updated to incorporate the deviations identified between them and the Procedure 8.7.1.5 sketches after the next refueling outage.

This delay is necessary because, in some cases, the actual location of the valves (a requirement of the valve checklist) must be identified by a plant walkdown; therefore, this item will be scheduled as a task for the next refueling outage.

4. P&ID's will be marked up, verified and made available to the licensed operators in the Control Room by 4/1/83.

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• - SOSTON EOlIN COMPANY e

Mr. Richard W. Starostecki, Director Page 3

5. Thirty-seven-(37) deviations are valves known to be inside the

~ primary containment; therefore, the final drawing revision will not take place until after the next refueling outage. There is additional information required to allow proper identification on the P&ID's that has to be obtained during an outage; therefore, the completion of this project is being scheduled as a task for the next refueling outage.

Because a final closecut date cannot be identified at this time, we will provide the NRC Resident Inspectors with a status report prior to 6/30/83, which will address the progress made to date.

In closing, I wish to stress that all deviations identified by station personnel relative to valves not on-P&ID's or in Appendix A valve checklists will be corrected'in a timely manner.

Should you require any further information concerning this response, please contact us.

Very truly yours, Commonwealth of Massachusetts)

County of Suffolk Then personally appeared before me William D. liarrington, who, being duly sworn, did state that he is Senior Vice President - Nuc1 car 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.

My Commission expires: h2_9 p b Notary'PW11c i b _ _ . _ _ _ . _ _ _ _ _ . . _ _ _ _ _ _ . _ _ . _