ML20151L650

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-293/88-11

ML20151L650
Person / Time
Site:	Pilgrim
Issue date:	07/22/1988
From:	Gallo R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	Bird R BOSTON EDISON CO.
Shared Package
ML20151L657	List: ML20151L650
References
NUDOCS 8808040101
Download: ML20151L650 (2)

See also: IR 05000293/1988011

Text

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JUL 221988

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Docket No. 50-293

Boston Edison Company

ATTN: Mr. Ralph G. Bird

Senior Vice President - Nuclear

Pilgrim Nuclear Power Station

RF0 #1 Rocky Hill Road

flymouth, Massachusetts 02360

Gentlemen:

Subject: Inspection No. 50-293/88-11

This refers to your letter dated June 21, 1988, in response to our letter dated

May 17, 1988.

Thank you for informing us of the actions taken to resolve the issues

identified from the E0P inspection. Your actions taken to resolve several of

the items were reviewed in inspection 50-293/88-19. Those not yet examined

will be re" %d in a future inspection of your licensed program.

Your cooperation with us is appreciated.

Sincerely,

h #

Robert M. Gal o, Chief

Operations Branch

Division of Reactor Safety

cc:

K. Highfill, Station Director

R. Anderson, Plant Manager

J. Keyes, licensing Division Manager

E. Robinson, Nuclear Information Manager

R. Swanson, Nuclear Engineering Department Manager i

The Honorable Edward J. Markey

The Honorable Edward P. Kirby l

The Honorable Peter V. Forman

B. McIntyre, Chairman, Department of Public Utilities ,

Chairman, Plymouth Board of Selectmen  !

Chairman, Duxbury Board of Selectmen f

Plymouth Civil Defense Director i

P. Agnes, Assistant Secretary of public Safety, Commonwealth of Massachusetts  !

S. Pollard, Massachusetts Secretary of Energy Resources i i

R. Shimshak, MASSPIRG \  ;

Public Document Room (POR) /

b  !

Local Public Document Room (LPOR)

Nuclear Safety Information Center (NSIC) \ \\

f

NRC Resident Inspector

Commonwealth of Massachusetts (2) ,

6800040101 800722

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IAL ORD COM E M IM 88-11 - 0001.0.0 '

$DR ADOCK 05000293 PNV __

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Boston Edison Company 2

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bec:

Region 1 Occket Room (with concurrences)

M. Perkins, Management Assistant, DRMA

S. Collins, DRP

R. Blough, ORP

L. Doerflein, DRP

R. Sores, DRSS

0. Mcdonald, PM, NRR

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R I,- f R ORS RI:0RS' , RI:0RP RI:0RS

F rq). Evans Lange Blough Gallo

0784/88 OT/}D/88 07/20/88 07/'?R/88 07/ Af88

0FFICIAL RECORD COPY RL PILGRIM 88-11 - 0002.0.0

07/19/88

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Pilgrim Nuclear Power Station

Rocky Hill Road

Plymouth Massachusetts 02360

Ralph G. Bird June 21. I988

Senior Vge President - Nuclear

BECo Ltr #88-097

U.S. Nuclear Regulatory Commission

Attn: Document Control Desk

Hashington, D.C. 20555

Docket No. 50-293

License No. DPR-35

Subject: NRC Inspection Report 50-293/88-11

Dear Sir:

Attached is Boston Edison Company's response to the unresolved items described

in the subject inspection report.

An excerpt from the appropriate section(s) of the inspection report is first

stated, followed by the Boston Edison Company response. The corrective action

for each of the items has been satisfactorily completed to support plant

operation.

Please do not hesitate to contact me directly if there are any questions.

hd

R.G. Bird

CS/b1

Attachment 1: Respcose to Unresolved Items

, Attachment 2: i. valuation of Combustible Gas Control Discrepancy

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cc: Mr. H1111am Russell

Regional Administrator, Region I

U.S. Nuclear Regulatory Commission

475 Allendale Rd.

King of Prussia, PA 19406

Sr. Resident Inspector - Pilgrim Station

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, ATTACHMENT 1

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Resoonse to Unresolved Items

. (Inspection Report 88-11)

NRC Unresolved Item 88-11-01

Exterot from Insor: tion Reoort. Section 4

Comparison of Plant Specific Technical Guidelines, BHR Owners Group Emergency .

Guidelines _and Emergency Ooerating Procedures (EOP's) -

Plant Specific Technical Guidelines (P-STG)/EOP Review

"All EOPs and those portions of satellite procedures which contained steps

based on the P-STGs were compared to the P-STG. The following differences

were noted.

"EOP-3: Primary Containment Control"

"PSTG steps PC/H-2,1 (suppression chamber spray), 2.2 (torus or drywell

vent), 2.3 (purge), and 2.4 (drywell spray) were reordered in the E0P in the

order of: 2.2, 2.3, 2.1, 2.4. The licensee had not previously identified

this potential safety-significant deviation. Either analysis of the

acceptability of E0P sequence or procedure revision to match the PSTGs is

required. This is an unresolved item (50-293/88-11-01)."

BECo Resconse to Unresolved Item 88-11-01

This condition has been evaluated and determined to not be a safety

significant deviation. The detailed evaluation is provided as Attachment 2.

This item is a technical inaccuracy and will be corrected as part of the next

major revision to the E0Ps. This discrepancy is formally captured as

verification discrepancy number D-7-2 for E0P-3.

NRC Unresolved Item 88-11-02

Exteret from Insoection Reoort. Section 8

"Walkthrough of Emeraency Ooeratina Procedures

and Satellite Procedures"

"A number of the E0P-related items identified by the inspectors h.ad also been

identified by the facility review process and actions were being taken to

address the observed problems. However, the facility review of the satellite

procedures was still in progress even though the procedures were approved and

issued, i.e., they had not yet finished their own walkthrough of the

satellite procedures. Furthermore, the operation management agreed to assure

that the plant labeling was consistent with the E0Ps and satellite

procedures. Therefore, pending further NRC review following completion of

the facility walkthrough of the satellite procedures and the licensee actions

to correct the identified deficiencies, this item will remain unresolved

(50-293/88-11-02)."

Page 1 of 3

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ATTACHHENT 1 (cont'd)

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BECo Resco'nse to Unresolved Item 88-11-02

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Review of E0P satellite procedures has been completed. The discrepancies

identified by the NRC, including those identified in Attachment C of the

Inspection Report, and by walkdowns performed by PNPS licensed operators have

been corrected.

NRC Unresolved Item 88-11-03

Excerot from Insoection Reoort. Section 4

"P-STG/EOP Review"

"EOP-3: Primary Containment Control"

"Primary contair. ment venting was allowed by procedure after torus pressure

exceeds 11 psig but before reaching the Primary Containment Pressure Limit

(PCPL; 48 psig) irrespective of resultant reactivity release rate. Procedure

5.4.6 stated that venting, irrespective of resultant reactivity release rate,

was appropriate only when the primary containment pressure is above the PCPL

(or when drywell or torus hydrogen concentration was above 61.). The licensee

stated that they will revise the procedures to remove the inconsistency and

instruct operators to vent before reaching the PCPL."

"Saf ellite Procedures Review"

"5 4.6: Post Accident Containment Control (Ventina)"

"The procedure directed using both a small vent path (1 or 2 inch valves) and

a large path (through 8 inch valves) for containment venting. In some

scenarios it inay not be necessary to open both sets of valves if after

opening only the 2 inch or the 1 inch valves the containment pressure is

cori trolled appropriately. The licensee agreed to revise the procedure or

justify not revising it."

"A caution contained the words "If at all possible . ... shall ...". This

statement did not provide clear direction to the SRO. The licensee agreed to

revise the procedure or justify not revising it."

"Step 2 of Attachment A of this procedure stated that the E0P is applicable

when primary containment pressure ntarAe12.5 psig, as opposed to above 2.5

psig. The licensee agreed to revise this statement."

"The caution statement about rupture of the ductwork with venting did not

include notification of Health Physics. The licensee agreed to revise the

procedure or justify not revising it."

"Step 2 of Attachment A of this procedure was missing a statement regarding

opening the appropriate valves as necessary to perform the step. The

licensee agreed to consider revising this statement."

"Step 3 of Attachment A of this procedure did not provide clear direction to

the operator on the value of primary containment pressure to terminate torus

venting. The licensee agreed to revise the procedure or justify not revising

it."

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ATTACHMENT 1 (cont'd)

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"The ltems concerning containment venting will be collectively included as

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• part of unresolved items 50-293/88-11-03. See Section 8 for additional

containment venting items."

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Excerot from Insoection Reoort. Section 8"

"One item identified during the walkthrough of the E0Ps was an apparent need

for additional training on when to initiate and when to terminate venting of  ;

the containment in accordance with the intent of the EPGs and the

procedures. Items concerning containment venting will be considered an

unresolved item (50-293/88-11-03.)"

BEco Resoonse to Unresolved Item 88-11-03

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PNPS Procedure 5.4.6, "Primary Containment Venting and Purging Under i

Emergency Conditions" - Attachment A, has been revised (Revision 18) to j

correct all the identified discrepan:les.

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Operator training on when to initiate and when to terminate venting, in  ;

accordance with the intent of the PSTGs, is given as part of training module

87-0-RQ-05A-01-07. The intent of venting is stressed to each operating crew.

NRC Unresolved Item 88-11-04

Excerot for Insoection Reoort. Section 11

"EOP Ouality Assurance Measures"

"A review was conducted to determine if Quality Assurance Measures are

adequate to ensure that high quality E0Ps are developed, implemented and

maintained."

"The QA measures associated with the development of the E0Ps were found to be

acceptable, based on discussions with the Quality Engineering Division

Manager and Senior Quality Engineer. However, it was concluded that a

programmatic approach to ensure the continued quality of the E0Ps through

audits of the maintenance of the E0Ps did not exist in the area of auditing

of the E0P program."

"In subsequent discussions with the Vice President, Nuclear Engineering

Division and Quality Assurance management, 8ECo committed to revise the 1988

Internal Audit Schedule to include an annual audit of the E0P program. This

audit will be performed as a Safety System Audit in the fourth quarter of

1988. The proceduralization of continued quality assurance measures is an

Unresolved Item (50-293/88-11-04)."

BECo Resoonse to Unresolved Item 88-11-04

As indicated in the inspection report excerpt, the 1988 Quality Assurance

Audit Schedule was revised to include an annual audit of the E0P program

beginning in the fourth quarter of 1988. The Audit Schedule revision was

formally approved March 17, 1988.

In addition Quality Assurance Department Procedure No. 18.01, "Preparation,

Performance, Reporting and Follow-up of Quality Assurance Department Internal

Audits" was revised on April 25, 1988 to reflect, an annual audit frequency

for the EOP program.

Page 3 of 3

. ATTACHMENT 2

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EVALUATION OF THE E0P-PSTG DISCREPANCY

. RELATIVE TO

COMBUSTIBLE GAS CONTROL

Nhen primary containment hydrogen and oxygen concentrations reach the

deflagration limits (6% and 5%, respectively), the PSTGs require wetwell

spraying, venting, and purging in that order (PSTG Steps PC/H-2.1, 2.2, and 2.3).

Procedure 5.4.6 (Rev. 17) specifies that venting precede purging. However E0P-3 .

(Rev. 0) does not specify that wetwell spraying should precede the vent and purge

evolution.

The effect of this dis:repancy between the PSTGs and the E0Ps may be evaluated by

examining all events to which E0P-3 may apply. All such events may be segregated

into two classes: those for which the containment remains inerted (i.e., oxygen

concentration remains below 5%) throughout the event and those for which it does

not. Events within the former class are not affected by the E0P discrepancy

because the conditions required for execution of the discrepant step, hydrogen

and oxygen concentrations reaching their deflagration limits, are not met. Thus

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the discrepancy can affect only those events within the latter class.

This smaller set of potentially affected events, those for which the containment

does not remain inerted, may be further segregated into two additional classes:

those for which the containment is deinerted when the event initiates (e.g.,

events initiated within one of the 24-hour periods when power operation is

permitted without containment inertion) and those for which the containment

becomes deinerted during the event. The Boston Edison Company has removed all

air sources from within the Pilgrim primary containment. Therefore, with the

exception of deliberate deinertion, which is not called for in the EOPs, the

primary containment will become deinerted during an event only if its pressure is

reduced to the point at which the reactor-building-to-torus vacuum breakers open,

drawing air from the reactor building into the wetwell airspace. This will

happen only if containment temperatures are reduced to well below those which

existed when the event initiated, and the only viable mechanism for effecting *

such temperature reductions is the prolonged operation of containment sprays.

However, the E0Ps preclude the use of containment sprays when containment

pressure is below 2.5 psig. Thus the Pilgrim systems configuration together with

the EOPs preclude the containment from becoming deinerted during an event, so

that there are no events within the latter class and the EOP discrepancy can

affect only those events within the former.

This smaller set of potentially affected events, those which initiate during a

period when the containment hns been deinerted, may be further segregated into

two classes: those which initiate before the reactor has developed a significant

power history (i.e., startup events) and those which initiate afterwards. With

no significant power history, the reactor core cannot develop decay heat

sufficient to generate enough hydrogen to approach the hydrogen deflagration

limit. Events within the former class are therefore not affected by the EOP

discrepancy because the conditions required for execution of the discrepant step,

hydrogen and oxygen concentrations reaching their deflagration limits, are not

met. Thus the discrepancy can affect only the events within the latter class.

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. ATTACHMENT 2 (cent'd)

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This smaller set of potentially affected events, those which initiate during a

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period when the containment has been deinerted but only after the reactor has

developed a significant power history, may be further segregated into two

additional classes: loss of coolant accidents (LOCAs) and non-LOCAs. During a

LOCA the steam released into the drywell will quickly increase containment

pressure to the Suppression Chamber Spray Initiltion Pressura (refer to the

definition of the SCSIP in Appendix A of the BHORG EPGs), and this will occur ,

before any appreciable hydrogen can be generated. E0P-3 requires initiation of

wetwell sprays before containment pressure reaches SCSIP, so that the operator

will have been directed to operate wetwell sprays before the conditions required

for execution of the discrepant step, hydrogen and oxygen concentrations reaching

their deflagration limits, are met. Thus the E0Ps will require wetwell spraying

before the vent and purge evolution for any event within the former class, so

that the EOP discrepancy can affect only those events within the latter.

This smaller set of potentially affected events, non-LOCAs which initiate during

a period when the containment has been deinerted but only after the reactor has

developed a significant power history, may be further segregated into two

additional classes: those for which adequate core cooling is maintained and those

for which it is not. If adequate core cooling is maintained then no significant

hydrogen generation occurs and the conditions required for execution of the

discrepant step, hydrogen and oxygen concentrations reaching their deflagration

limits, are not met. Thus the discrepancy can affect only those events within

the latter class.

This smaller set of potentially affected events, non-LOCAs, with loss of adequate

core cooling which initiate during a period when the containment has been

deinerted but only af ter the reactor has developed a significant power history,

may be further segregated into two additional classes: those which generate

sufficient hydrogen to reach the deflagration limit and those which do not.

Clearly events within the latter class are not affected by the E0P discrepancy

because the conditions required for execution of the discrepant step, hydrogen,

and oxygen concentrations reaching their deflagration limits, are not met. Thus

the discrepancy can affect only those events within the former class.

This smaller set of potentially affected events, non-LOCAs with loss of adequate

core cooling, which generate sufficient hydrogen to reach the deflagration limit,

and which initiate during a period when the containment has been deinerted but

only after the reactor has developed a significant power history, must be further

reduced to actually define the set of events which can be affected by the E0P

discrepancy. As a minimum, the following subsets of events must be excised:

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1. Events in which the RPV is blown down to the suppression pool after the pool

has been substantially heated. The E0Ps require that the RPV be rapidly

depressurized prior to loss of adequate core cooling and, therefore, prior to

any significant hydrogen generation. If the RPV is depressurized by blowing

down to the suppression pool, then the thermal energy transferred to the pool

will raise the wetwell water temperature, which in turn raises the partial

pressure of the water vapor in the wetwell airspace and the temperature and

partial pressure of the dry gas in the airspace. If the wetwell water

temperature is relatively high when the blowdown is initiated, this will be

sufficient to raise containment pressure to the Suppression Chamber Spray t

"

Initiation Pressure. E0P-3 requires initiation of wetwell sprays before

containment pressure reaches the SCSIP, so that the operator will have been

directed to operate wetwell sorays before the Londitions required for

execution of the discrepant step, hydrogen and oxygen concentrations reaching

their deflagration limits, are met. Thus the E0Ps will require wetwell

spraying before the vent and purge evolution for these events. ,

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ATTACHMENT 2 (cont'd)

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significant hydrogen generation occurs. Events in which safety

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Because the Pilgrim safety valves

are unpiped, any continued steam discharge through these valves will raise

containment pressure to the Suppression Chamber Spray Initiation Pressur

E0P-3 requires initiation of wetwell sprays before containment pressure

reaches the SCSIP, to that the operator will have been directed to operate

wetwell sprays before the conditions required for execution of the discr

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step,

are hydrogen

met. and oxygen concentrations reaching their deflagration

Thus the

purge evolution EGPs events.

for these will require wetwell spraying before the vent and

3.

the SRVs are inoperable). Events in which the main condenser is utiliz

For these events, any hydrogen generated will be

discharged

primary through the offgas system and will therefore not accumulate in

containment.

discrepant step, hydrogen and oxygen concentrations reachin

deflag ation limits, are not met for these events.

4.

Events in which reactor core decay heat cannot be effectively removed from

the primary

generation containment for a prolonged period before significant hydrogen

occurs.

the pool will raise the wetwell water temperature, which in

partial pressure of the water vapor in the vetwell airspace and the

temperature and partial pressure of the dry gas in the airspace. If this

Suppression Chamber Spray Initiation Pressure. occurs over a prolo

E0P-3 requires initiation of

wetwell sprays before containment pressure reaches the SCSIP, so that the

operator will have been directed to operate wetwell sprays b(fore the

conditions required for execution of the discrepant step, hydrogen and oxyge

concentrations reaching their deflagration limits, are met. Thus the E0Ps

will require wetwell spraying before the vent and purg0 evolution for these

events.

the preceding logic.Thus the set of avents which may be affected by the E0P

set is vanishingly small and clearly does not warrant correction of t

discrepancy in ';he near term (i.e., before the E0Ps undergo their next revision).

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