ML20085A298

Advises of Proposed Alternate Testing Schedule Re Inservice Insp Based on Testing Conducted Through Integration W/Valve Betterment Program & Local Rate Testing.Completion Expected Prior to Startup from Refuel Outage 7

ML20085A298
Person / Time
Site:	Pilgrim
Issue date:	06/27/1983
From:	Harrington W BOSTON EDISON CO.
To:	Vassallo D Office of Nuclear Reactor Regulation
References
83-163, NUDOCS 8307050252
Download: ML20085A298 (2)

Text

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BOSTON EDISON COMPANY B00 BovLsTON STREET RonTON. MASSACHUSETTS 02199 WILLIAM O. HARRINGTON esween vses passiosuv N R LsAR June 27, 1983 .

BECo Letter No.83-163 Mr. Domenic B. Vassallo, Chief Operating Reactors Branch #2 Division of Licensing Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D.C. 20555 License No. DPR-35 Docket No. 50-293

Subject:

Request for Schedular Extension: Completion of Class II & III Hydro-static Tests.

References:

(A) Boston Edison Company (BECo) Letter No. 82-25 (A.V. Morisi to D.B. Vassallo), dated July 2,1982.

(B) BECo Letter No. 83-91 (W.D. Harringto* to D.'3. Yassallo), dated April 14, 1983

Dear Sir:

In Reference (A) Boston Edison Company transmitted the Final Report of all Inser-vice Inspection Activities conducted during Refueling Outage No. 5. It was l nated in the letter that some portions of tk Inservice inspection Drogchm Mr i the first inspection interval were not implemented, specifically the hydrost& tic pressure test for the Class II and Class III piping systems. We proposed to do these tests as part of the first period of the second inspection interval, in effect an extension of the first inspection interval. We justified this exten-sion through para IWA - 2400 (a) of ASME Section XI,1974 edition.

l On April 14, 1983, BECo met with members of your staff to present its Long Term Program and Schedule, which was subsequently transmitted to you in Reference (B).

As discussed during that meeting, the primary objective of BECo's Long Term Program is to enhance the safe operation of the plant by balancing the improve-ments required by the Regulators and our Management, while allowing the appro-priate levels of controls to be exercised. The key decisions to allow the above to occur include; maintaining area manloading densities at a controllable level; l focusing and directing the organization's efforts toward a specific set of goals and schedules; and committing to a midcycle modifications outage.

The hydrostatic testing schedule iias been identified as one which requires resched-uling to accorrplish the goals of our Long Term Program.

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COETON EDISON COMPANY Mr. Domenic B. Vassallo, Chief Page 2 Boston Edison is now proposing an alternate testing schedule in accordance with the following criteria. Testing will be conducted through integration with the Valve Betterment Program and local leak rate testing. We propose to accomplish one-third of the required testing in each of the following outages: Refuel Outage No. 6, Modification Outage No.1, and Refuel Outage No. 7. All testing will be completed prior to startup from Refuel Outage No. 7 (presently scheduled for 11/29/85).

Our justification for the proposed new schedule is two-fold. First, the systems for which Class II and Class III tests are required are operated repeatedly. As such these systems are also subject to frequent observation for leakage. Second, the ASME Section XI requirements are vague with respect to the specific require-ment for 100% completion of hydrostatic testing during Refuel Outage No. 6. We feel that extending the schedule for completion of testing meets the intent of ASME Section XI. In summary, we feel that system integrity will be assured due to frequent system use and observation, and because our new schedule is in com-pliance with the intent of ASME Section XI.

Your attention to this item is greatly appreciated. We believe that the infor-mation provided is adequate to enable you to grant the requested schedular relief.

Should you require any additional information or have any questions, please do not hesitate to contact us.

Very truly yours, g i lI h6%

JMF/ mat (

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