ML20153D545
| ML20153D545 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 02/13/1986 |
| From: | Harrington W BOSTON EDISON CO. |
| To: | Martin T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| 86-012, 86-12, NUDOCS 8602240182 | |
| Download: ML20153D545 (15) | |
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' EOSTON EDISON COMPANY -
300 BOVLaTCH STREET BOSTON. MASSACHUSETTS 02199 WILLIAM O. HARRINGTON esenen vise PASetesNT
. February la 1986 swese.
BEco Ltr. #86- 012 Thomas T. Martin, Director Division of Radiation Safety and Safeguards U.S. Nuclear Regulatory Commission 631 Park Avenue King of Prussia, PA 19406 License No. DPR-35 Docket No. 50-293
Subject:
Response to " Areas Requiring Improvement" as Contained in NRC Inspection Report 85-27
Dear Mr. Martin:
This letter is in response to the subject " Areas Requiring Improvement" contained in NRC Inspection Report 85-27, conducted by Mr. R. Nimitz of your office on September 16-20, 1985 at Pilgrim Nuclear Power Station.
The subject issues and Boston Edison's responses are enclosed as an attachment to this letter.
Please note that this response is being submitted in accordance with our telecon to the NRC on 1/9/86, during which we were approved for a response due date extension to 2/13/86.
If you should have any further questions regarding this matter, please do not hesitate to contact me.
Very truly yours, I
W. D. Harrington Attachment'
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- ISSUE -
Demonstrate the adequacy of system purge times.
Data were not presented to demonstrate the adequacy of the purge times specified in procedures.
Adequate purge time is needed to ensure representative sampling.
(50-392/85-27-01)
RESPONSE
The Nuclear Engineering Department is currently evaluating adequacy of the PASS system purge times. Their evaluation is expected to be completed by 3/1/86.
ISSUE Demonstrate the adequacy of the sample dilution method and related equipment.
Data were not available to demonstrate the adequacy of the sample dilution method and related equipment. Sampling dilution is a key element in the quantification of sample results.
(50-293/05-85-27-02)
RESPONSE
The Chemistry Group is currently evaluating the adequacy of the sample dilution method and related equipment in view of General Electric's recommendation. We estimate completion of this review by 8/31/86.
ISSUE Determine the volume of the coolant collection ball valve.
During the preoperational testing, the ball valve, which collects a mer.sured volume of coolant, was determined to be 0.14 ml, instead of-the value of 0.10 ml.
The value of 0.10 ml. was prosented in procedures. The valve, which was actually tested during preops, has since been replaced, but the new valve's volume has not been determined.
(50-293/85-27-03)
RESPONSE
The volume of the valvn will be de'termined through the Chemistry Group's evaluation mentioned in our response to Issue #85-27-02.
The appropriate procedure will be revised by the Chemistry Group to reflect the new volume.
These actions are expected to be completed by 8/31/86.
ISSUE Repair and/or replace the flow control check valve.
After the primary ~ system tests had been successfully conducted, the flow control valve stuck open in a fixed position (0.6 GPM). The design flow rate of 1 GPM could not be attained.
(50-293/85-27-04)
RESPONSE
A Maintenance Request has been generated in order to facilitate repairs to the flow control valve. These repairs are expected to be completed (by the Maintenance Group) by 3/1/86.
31 JISSUE:'
~
1 IDemonstratie' the adequacy lof system purge times. Data were not presented to rdemonstrate the: adequacy of the purge times specified in' procedures.
Adequate.
system purge' time is needed.to-ensure representative' sampling.
(50-293/85-27-05)
' RESPONSE-See response to. Issue #85-27-01.
ISSUE' The capability to obtain!a repres'entative sample of containment atmosphere should be demonstrated.:-(50-293/85-27-06):
1.
There has been no line' loss or plate-out study conducted.
- 2. 'TheJsampling-assembly-is not heat. traced. -This could lead to excessive condensation ~ collecting on the iodine ' cartridges. This problem would be
.particularly troublesome with high humidity in containment.
RESPONSE
The Nuclear Engineering Department is evaluating the subject issues and we anticipate completion of this review by 3/1/86.
ISSUE Correct the air sampler rotometer reading for differences in air density created by pump suction. The sampling procedure (5.7.11) uses._ the rotometer reading in the calculation of the radioiodine concentration.
(50-293/85-27-07)-
RESPONSE
The Nuclear Engineering Department is evaluating the-air sampler rotometer readings for differences in air density created by air suction..64 anticipate-
~
completion of this review by 3/1/86.
q ISSUE The detection limit and sensitivity of the chloride analysis method should be clearly defined.
Procedures should be revised to include provisions for-the retention of an undiluted sample 'for up to 30 ' days for more detailed ' chloride'
)
analysis. ~(50-293/85-27-08)
RESPONSE
'j The Chemistry Group is currently assessing the system's capabilities in regard to chloride. analysis. Their subsequent conclusions' (scheduled to be finished 6/30/86) and corrective actions taag include'a new time and motion ~ study and
- procedural' changes.
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. ISSUE *
- Obtain and. maintain supplies necessary to conduct boron-analysis with carminic acid method. (50-293/85-27-09) p.-
- RESPONSE iz
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The above-mentioned supplies have-been obtained and a new calibration curve-has been drafted to be-used in this analysis. The current procedure will,be l
revised-to reflect this 'new curve.by 5/30/86.
ISSUE Clarify. commitments and capabilities relative ~to pH. analyses. (50-293/85-27-10)
RESPONSE
l Boston Edison is not committed to performing pH. measurements on post-accident-samples.
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-ISSUE I
Review and evaluate the need to perform isotopic analyses of dissolved
~
gasses.
If a need is identified, provision should '.w made to conduct isotopic analyses on dissolved gasses.
(50-293/85-27-11)
RESPONSE-The Chemistry Group has assessed the need to. perform isotopic analysis 'of, dissolved gasses 'and has concluded that they are not necessary for the initial core damage assessment process. Therefore, Procedure 5.7.5 will be-revised-(by the. Chemistry Group) by 12/31/86.
ISSUE The following matters requiring licensee attention were identified:
(50/293/85-27-12) a) The use of dissolved gas or hydrogen analysis data in the assessment of core damage should be clearly specified. 'Also, it:should be demonstrated that the committed range and accuracy can be achieved. ' Procedures should be established and implemented where needed.
i.
b), The amount of gas transported to the 1.boratory for analysis should.be l
minimized.
l c) Personnel should be instructed either to follow procedures er the procedures should be revised to reflect actual practices. Incorrect gas volumes were injected into the gas chromatograph.
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, RESPONSE
- a) 1See response to Issue #85-27-11.
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.b) & c) The appropriate procedures are' currently.being revised by the Chemistry Group to address incorrect gas volumes; minimization ~of gas volumes, and range and. accuracy issues.
These_ procedure changes are expected to be completed by:12/31/86.
ISSUE
' Establish a routine maintenance program for'the PASS. Not all components of
. the PASS have been 4 included in a regular surveillance / calibration program.
Also, there does'not appear to be a formal administrative procedure for
~
assuring that'non-safety related. equipment, such as~the PASS,Iis incorporated-in the' routine maintenance (50-293/85-27-13)
RESPONSE
f A procedure which will implement a once-per-cycle. calibration-of PASS instrumentation will be. written and implemented (by the Maintenance Group) by 9/1/86.
ISSUE Establish a spare parts program for the PASS.
A PASS spare parts program is under development.. The licensee is coordinating this program development with the BWR Owner's Group.
(50-293/85-27-14).
RESPONSE
Efforts are ongoing in BECo to develop a PASS spare parts program. The Nuclear Engineering Department has'been requested to assist in this development.
ISSUE Establish PASS sample shipping procedures.
The procedures for the handling, loading and off-site shipment of samples are in 'a draf t form and arrangements are being made through the PIMS to supply the needed shipping cask. (50-293/85-27-15)
RESPONSE
4 Procedures'are currently being drafted by the Radiological Section.
It is estimated that the procedures will'be incorporated by 8/31/86.
L ISSUE
'_ Arrangements;for-backup off-site' analysis are incomplete. A verbal agreement existe.with Millstone to provide batkup support.
This agreement :is being-
- formalized by' the licensee's legal staff.
(50-293/85-27-16) 5-?
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RESPONSE
LThe Radiological Section is currently providing answers t'o several technical 2
- questions posed by Millstone. Subsequent to resolution of the technical issues BECo's legal department will.be requested to review the legalities of the contract.
prior to BECo's signing the document.
ISSUE
-Establish provisions for detection of leakage across chiller.- Provisions have not been made for the detection of leakage of reactor coolant into the chiller cooling water. The pressure differential between the sampling and the cooling lines could result in the buildup of significant activity in the chiller in the event of such a leak.
(50-293/85-27-17)
RESPONSE
The Nuclear Engineering Department has been requested to analyze the above issue and supply recommendations to the Radiological Section. NED's analysis is expected to be completed by 4/30/86.
ISSUE Provide provisions to preclude PASS from exceeding its design temperature specification.
The chiller will automatically shutdown on low or high pressure signals.
- However, mechanisms have not been provided for the interruption of the flow of the uncooled water into the PASS or of operator actions procedures to prevent the PASS from exceeding its temperature design specifications.
(50-193/85-27-18)
RESPONSE
An Engineering Support Request has been initiated to request 'the Nuclear Engineering Cepartment's evaluation of the system's design capabilities in this area. The evaluation is expected to be completed by 4/30/86.
ISSUE Improve the safety of the access to the PASS.
Under accident conditions personnel may be required to climb a 20' ladder to the location of the PASS controls while wearing protective clothing and SCBA gear. The ladder does not have a cage to prevent a person from falling backward.
(50-293/85-27-19)
RESPONSE
1 A safety cage on the subject ladder was installed on 1/31/86.
H ISSUE i
Establish Alarm Set Points for the Pr.3S Area Radiation Monitor.
Consider using ar alarm set point based on maximum dose rates that could be
~ encountered such that 10 CFR 50 GDC 19 dose limits will not be exceeded.
(50-293/05-27-20)
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J RESPOWSE The Radiological Section is currently considering revising Procedere 5.7.2.16 to require the issuance of self-alarming dosimetry. By 6/1/86, the procedure will be revised and the associated equipment will'have been obtained.
ISSOE Evaluate the need to install charcoal filters in the exhaust hood of the chemistry laboratory.
A charcoal. filter has ' not been provided for the laboratory ventilation exhaust system. During an accident radioiodine releases may result from the operation of.the gas chromatograph, plasma spectrometer and laboratory hood.
(50-293/85-27-21)
RESPONSE
The Nuclear Engineering Department has evaluated the sample hood system in the chemistry laboratory-to assess the adequacy of filtration. The Radiological Section is reviewing NED's evaluation and will take appropriate actions.
ISSUE Calibrate the PASS radiation detector in accordance with neanufacturer's specifications.
The three radiation detectors associated with the PASS are not calibrated in accordance with manufacturer's specifications and recommendations.
For example, the manufacturer requires the one electronic channel to be set at 2200 volts and the other two channels at 2500 volts. Based on the calibration procedure, all electronic channels were set at 2500 volts. Also,.there was no in-situ check of the instruments response following reinstallation.
(50-293/85-27-22)
RESPONGE Procedure 6.5-305 has been revised to coincide with the manufacturer's
' i recommendations regarding voltage settings.
)
i In-situ checks are next to impossible to conduct due to the amount of lead 1
j bricks surrounding thq sampling station.
Additionally, our current methods of calibration give us an adequate level of assurance that the units are operable and calibrated properly.
ISSUE Reevaluate the adequacy of the " time and motion" study performed for collection of PASS samples.
Ensure the requirements of 10 CFR 50 GDC 19 can be met.
The " Time and Motion Study" was conducted using' generic methods before the actual procedures were developed.
It is not clear that the samples can be collected and analyzed within GDC limits using the existing procedures.
(50-293/85-27-23).
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- The adequacy.of.the existing-time land motion. studies will-beLreevaluated~and,
.if necessaryi another time ;and motion study will be' conducted by the Radiological Section'by 12/31/86.
e ISSUEi 3
[Clarifyuseofpressure[inprocedures.
L Prodedure 5.7 '4.~1.9 does not inclthie provisions forl the ' spec'ification of : the' press'ure lin, units,of -inches of Hg. LProcedures use~ units offpsig. ~
Subatmospheric'readoutsLin " inches'of;Hg" are the most. appropriate readouts.
(50-293/85-27-24)3
RESPONSE
- The appropriate procedural changes are currently'being prepared by the 1 Chemistry Group and are expected ~to be completed by 6/30/86.
ISSUE Establish reliable backup power for'the chiller.
A reliable source of backup power has not been provided for the chiller;used for. cooling the -incoming reactor coolant in the event of. a loss 'of off-site power. While a backup method ~of cooling has been devised, it has not-boon-tested for. proper hose fitting. Also, the heat removal capability of this method has not been established.
(50-293/85-27-25)
RESPONSE
The Nuclear Engineering Department has been asked to evaluate'.this issue.
Their recommer.dations are expected by 4/30/86.
ISSUE Identify and provide " carrying devices".
Procedure 5.7.3.1.2 states that a " carrying device" would be used to transport ~
the syringe containing radioactive gasses.
It is not clear what type of
" carrying device" is to be used (50-293/85-17-26)
~
MGMSE A procedural change will be initiated by the Chemistry Group to identify the i
" carrying device."' The procedural change 'is expected =to be completed by.
6/30/86.
-ISSUE Clearly.specify the range of'all High Range Noble Gas Monitors. The reasons for the inconsistencies between the range of capability;of.the high-range
. monitors as'can bo derived from the' reports by ENTECH.and from information
, zsupplied by:the. licensee to NRC.should be.investigatedi ^Also: range overlap should be clearly.specified; ' (50-293/85-27-27).
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tRESPONSE-r
'The above issues are being evaluated by~ the RadiologicalLSection. Their' evaluation
.is expected to be completed byl7/31/86.
ISSUE l
The ability of the low range monitors to function.for sustained periods of time at concentrations close to and beyond their upperf range for and to recover therefrom
[_
during a post-accident ' sequence :should be established. If this cannot be
~
l satisfactorily accomplished, ~ provisions. for turning off the.pmeer to them and/or bypassing them during these periods ~ of -time should be considered.
(50-293/85-27-28)
RESPONSE ~
l' The Nuclear Engineering Department has been requested to assess the above -issue and j
provide recommendations regarding the recovery ability of the low-range monitors.
l Their assessment. is expected to be completed by 4/30/86.
ISSUE The possible effect of radioiodines deposited within ducts on the response of the high range monitors should be considered.
If it is appreciable, considerations should be given to relocating the detectors to a shield cave within which they view a suitable volume of an off-line aliquot of the stack / vent flow.
(50-293/85-27-29).
RESPONSE
The above possibility is currently being considered by the Radiological Section.
Their evaluation will be completed by 12/31/86.
ISSUE I
Establish provisions in procedures for the sampling of the main stack and the reactor building vent (similar to those now contained in these for sampling in the turbine building) for the measurement of samples of radiation levels up to and including design basis, so as to accomplish continuous sampling throughout a post-accident sequence.
(50-293/85-27-30)
RESPONSE
Health Physics and Chemistry personnel will perform a new time and cotion study to formulate a basis for revising the M.S. and R.B.V. ' sampling procedures.
Following l
an evaluation of the study by the Radiological Section (expected to be completed by 7/31/86). Chemistry.will then revise the affected procedures, cs appropriate. The revisions are expected to be incorporated by 12/31/86.
ISSUE Perform a time and motion study to ascertain that the system design will make it possible to remove and transport-design basis samples' within GDC-19 criteria.
All appropriate source terms should be used for thia stud /.
(50-293/85-27-31)
RESPONSE
-See response to Issue #85-27-30.' -
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ISSUE.
frovide the'necessary nomograms and calculator / computer procedures, whereby..
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measurement of the collected radioiodine activities can readily be-translated-c into release concentrations and rates.
(50-293/85-27-32)
RESPONSE
We believe that this capability currently exists through the following procedures:
.5.7.3.4
-(" Sampling,-Transport, and Analysis of Effluent Iodines and Particulates from the Reactor Building Vent Under Emergency
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Procedures")
5.7.3.3
(" Sampling Transport and Analysis of Effluent. Iodines and
'Particulates from the Main Stack Under Emergency Conditions")
5.7.2.18. ("Off-Site Dose Projections and Protective Action Guides for the
' General-Public")
l However, an evaluation will be performed by the Radiological Section and, if i
appropriate, additional nomograms or other aids will be added to existing l-procedures. This evaluation is expected to be completed by 12/31/86.
ISSUE
[
Develop correction factors for the non-isokinetic sampling rates for the range -
of stack flow rates of the unit vent especially for those. anticipated under
~
accident conditions.
(50-293/85-27-33) t-
RESPONSE
l The Nuclear Engineering Department is currently studying this issue.
By 3/31/86, they will submit their findings to the Radiological'Section who'will, j.
in turn, determine the acceptability of applylreg correction factors'in accordance. with ANSI' Guidelines.
The Chemistry Group will subsequently revise the appropriate procedures. The procedural revisions are expected - to be completed by 12/31/86.
ISSUE y
Evaluate the capabilities of the sampling system to collect representative L
. samples under accident condition.
(50-293/85-27-34)
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RESPONSE
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The Nuclear Engineering Dep6rtment is currently evaluating BECo's capabilities l
to collect non-isokinetic samples under accident conditions, and, jms mentioned in the-response to Issue 85-27-33,.their findings ;will be forwarded to the l~
Radiological Section by 3/31/86 for further dispositioning.
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ISSUE *'
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. In order to reduce-the anticipated dose rate of the collected sample, and/or to facilitate 'its analysis, the licensee should review and/or_ resolve -(as
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appropriate) the following matters:
(50-293/85-27-35)
. a.
Provide shielding for the effluent sample holders b.
The provision of labels and a' flow diagram for the valves and indicators on the sample racks.
c.
- The heat tracing of the sampling'line for reactor building vent, in view of the' possibility that it may contain steam leakage or moisture therefrom under accident conditions.
d.
The provision of features which will enable the purging of in-place sample canister and nearby sample lines with a clean air supply, prior.to their removal for transport and analysis, e.
The addition to manual dose assessment procedures of nomograms which would make it possible to estimate field iodine dose rates on the basis of measured radioiodine activity (or release rates derived therefrom).
l
RESPONSE
Shielding for effluent sample holders will be addressed on completion of a.
time-motion studies (for details see BECo's response to Issue 85-27-31).
b.
The Chemistry Group will place the appropriate labels and diagrams on the Main Stack and Reactor building vent panels, nctions are expected to be completed by 6/30/86.
The Nuclear Engineering Department is evaluating the need to heat trace c.
the sampling line for the Reactor Building vent. Their analysis is expected to be completed by 5/1/86.
d.
The Nuclear Engineering Department is evaluating the need to install an air or nitrogen system to purge in-place cannisters at the Main Stack and Reactor Building Vent areas. Their evaluation will be completed by 5/1/06, The Chemistry Group will revise procedures where actual readings in "MR" e.
or "R" will be recorded on a data sheet and the information relayed back to the TSC for estimation of field iodine dose rates. The-subject
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procedures will be revised by 12/31/86, in conjunction with other actions described in the response to Issue #85-27-30.
ISSUE _
Fully establish and implement the operator Training Modules for operation /use of the PAM panel (Module CT-SH/IG-S-120).
(50-293/85-27-36).
1
RESPONSE
A new reference text has been developed and is being used as a reference for the operator training module. The above training will be included in the 1986 Operator requalification training. 4
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ISSUE Train and qualify appropriate personnel on Procedure 5.7.5,:"Estinating Core
' Damage".
Personne1'have not been trained in the new procedure.
'(50-293/85-27-37)'
RESPONSE
S.T.A. personnel are considered the primary audience for training on Procedure 5.7.5.
All S.T. A. personnel were sent a copj of the subject procedure to review in Sept 9mber,1985. An S.T. A. Initial Training Program is currently being designed by the Training Group and will be conducted by 5/31/86.
ISSUE Include North / East Torus Monitor Response Curve in Procedure 5.7.5.
The procedure contains only the Drywell monitor response curve.
However, the Drywell response curve is being incorrectly used with the Torus monitors (50-293/85-27-38).
RESPONSE
The above issue (s) will be evaluated and, if necessary, corrected by the Radiological Section by 8/31/86.
ISSUE Review dose / damage response curves for the Drywell Monitors.
At less tSan 100% core damage, no other radiation sources (e.g. primary lines. in area of detectors) are used as contributors to the detector readings. A review should be performed to ensure that sources in the area of the detectors (other than the gaseous activity in primary containment) do not adversely effect the core daraage estimates.
(50-293/85-27-39)
RESPONSE
The above issue will be evaluated by the Radiological Section and, if necessary, corrective actions will be implemented.
ISSUE The licensee should obtain additional SAM-2s.
Currently all SAM-2s (4) have been assigned to specific locations. The licensee does not have any spare units. Spare units should be obtained in the event an assigned SAM-2 becomes defective or needs calibration.
(50-293/85-27-40)
RESPONSE
Two (2) additional SAM-2's have benn received and will be used as spare units. t
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' CeYt'ain aspects ~ of,the procedures.for calibration and' use.of. the StYt-2 are.
written-in such a manner that literal reading of the-procedures would cause.
. errors'in quantification~of airborne! imine: -(50-293/85-27-41)
- --- the method for determination and use ofTiodine measurement. efficiency-is-not clear / consistent;between SArt-2 calibration /use_ procedures,-
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CPM l's not defiSed' (i.e, net or gross).
-RESPONSE i
New' equipment which will modify the counting 9. ceoure has arrived as -of E
l1 1/2/86. ' Procedure 6.5-287, (" Calibration of h mline SArt-2") has ~been revised to reflect the new counting methods and to'e druss the two above items.
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~. ISSUE Some of the procedures for use of the SArt-2 do not include the correction fr-tors for determination of total iodine dose...The procedures only inclu'de-correction factors for dose due to I-131.
(50-293/85-27-42)
.RESPONGE-All environmental monitoring teams' I-131' readings are corrected for total L
iodine dose by the Emergency Dose Assessment Engineers via Procedure 5.7.2.18 t
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("Off-Site Dose Projections.and Protective Action Guides for the General
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Additionally, Procedure 5.7.2.19 ("In-Plant I-131 Air Sampling and-Analysis") is currently being revised to add this capability. We'estimateithe Radiological Section will have the procedure in place by 3/31/86.-
ISSUE No verification of acceptability of air flow calibration devices used to.
calibrate iodine air samplers has been performed.
(50-293/85-27-43)
RESPONSE
The Radiological Section currently has the iodine air samplers calibrated by a l.
vendor who uses an NBS traceable calibrator. The Station procedure will be revised by 3/31/86 to require recording of.the calibrator serial number on the calibration form.
ISSUE l~
Procedures for use of the SArt-2s for arealysis of iodine activity collected on sample media allow the' analyses to be made in up to a radiation ~ field of 4-mR/hr. -The licensee should perform and document an evaluation that:
demonstrates that m'SArt-2 can detect 1 x 10-7 uCi/ml in a'4 mR/hr' field.
(50-293/85-27-44)
RESPONSE-i The above evaluation is' currently being conducted by'the Radiological Section and will:be completed by'8/31/86.
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' ISSUE' The model of.the installed solenoid valves differed from the test model. The licenseo tried to qualify the installed model by similarity. However, evaluation af similarities and differences between the installed model and the test model
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organic materials used and their thermal aging effect,- coil temperature e ding, physical size and construction etc.) were not performed.
(50-293/85-27-45)
RESPONSE
The Nuclear Engineering Department has completed a similarity analytis (on 11/1/85) and has filed that information in the E.Q. reference files.
ISSUE The valve manufacturer recommended the O-rings be,eplaced once every five
-years.
This was not addressed in the EQ file.
Justification should be provided if this recommendation is not to be implemented.
(50-293/85-27-46) l
RESPONSE
l The Nuclear Engineering Department has added justification documentation to the E.Q. files to address the above issue.
ISSUE Information Notice 84-68 identified field cable degradation when connected to high power solenoid valves. The cable degradation was caused by substantial temperature increase in the solenoid housing. The effect of this should be addressed in the EQ file.
(50-293/85-27-47)
RESPONSE
As a result of NED's review f Info Notice 84-68, tA e above mentioned effects have been added to the E.Q. files as of 12/1/85.
ISSUE Review and evaluate the need to incorporate the perodic calibration of PASS instrumentation into the routine maintenance / calibration program. Critical instruments should be included in such a program.
(50-293/85-27-48)
RESPONSE
See response to Issue #85-27-13.
ISSUE l
i The radiation exposure qualification data was not contained in the EQ files..
This data should be made available for NRC review (50-293/85-27-49).
RESPONSE
Revision 1 and 2 to the EQES have been added (by the Nuclear Engineering Department) to the reference files pertaining to the Raychem Shrink Tobing material used in the PASS system. The tubing is the only radiation sensitive material used in the construction of the radiation detectors. The data in the flies is now considered complete and will be made available to the inspector upon request.
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-The coaxial cables for thd' radiation' detectors. at'the Drywell were found 3
layingon the floor and ;were subject' to 'being stepped on.
The licensee's May-:
"18,il982 letteriindicated.the cables'were~in conduit. There appears to-be a'
- Deviation from the information provided ~ to the NRC.
(50-293/85-27-50).
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. RESPONSE' The 'above issue'was separately responded' to via Boston Edison Letter #85-222,.
~
dated ^12/13/85.
~
ISSUE Page 18 of the Test Report 1035-1 described the yearly,-. 5-year and 10-year.
maintenance requirements.for the H 02 2 analyzar, The yearly maintenance requirement ' states " carefully (inspect for degradation,:
replace as necessary"..This description appears to provide less than:
acceptable guidance relative to performing an inspection of this safety.
related system. The qualification maintenance for this system was not available for review. The. licensee should clearly. identify the inspection-acceptance criteria.
(50-293/85-27-51)
RESPONSE
The Maintenance -Section has requested the Nuclear. Engineering Department to evaluate the above issue and provide recommendations. NED's evaluation is expected to be completed by 4/30/86.
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