ML20202J699

Suppls Response to Violations Noted in Insp Rept 50-293/86-06.Corrective Actions:Sys Walkdown in Progress to Ensure That All Valves Properly Labeled & Identified on Piping & Instrumentation Drawings

ML20202J699
Person / Time
Site:	Pilgrim
Issue date:	07/03/1986
From:	Lydon J BOSTON EDISON CO.
To:	Kister H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
References
86-091, 86-91, NUDOCS 8607170130
Download: ML20202J699 (4)

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b BOSTON EDISON COMPANY Roo BoYLSTON STREET BOSTON. MASSACHUSETTS O2199 JAMES M. LYOON tarcutive vice pass oteev July 3 ' , 1986 BECo Ltr. #86- 091 Mr. Harry B. Kister, Chief Projects Branch No. 1 U. S. Nuclear Regulatory Commission 631 Park Avenue - Region 1 King of Prussia, PA 19406 Docket No. 50-293 Licenso No. DPR-35

Reference:

BECo (First Response) Letter to NRC dated May 2, 1986

Subject:

Second Retronse to Notice of Violation 2nd Order Items as Contained in NRC Inspection Report #86-06

Dear Mr. Mister:

This letter is to provide additional details regarding our action plans in certain areas, as committed to in the reference. Details of those plans are  !

enclosed as an attachment to this letter.

l Please note that, per arrangement with Mr. Strosnider of your staff, this response is being sent nine days beyond the original due date. -

Should you have further questions regarding these matters, please do not hesitate to contact me.

Sincerely, w, M ames M. Lydon JC/vep Attachment 8607170130 860703 h

4; PDR ADOCK 05000293 C G PDR .

LE D \ \\L

ATTACHMENT Licensee Response Item #86-06-01

" Evaluate the need to include instrument root valvo positions in station procedures and drawings."

Boston Edison agrees with the need to identify and control certain isolation and root valves and is currently developing a plan which will:

identify what instrument root and isolation valves need to be controlled; a

establish how these valves will be controlled (i.e., revise drawings and procedures to allow for control).

T -acti lan will be submitted to Region 1 in an update letter within sixty days.

Updated Response Boston Edison is currently performing a walkdown of all plant systems to ensure that all valves are properly labeled and identified on piping and instrumentation drawings (P&ID's) and in the system operating procedures.

This review will include all valves in the system's flow path, all vent and drain valves on the orocess piping and the instrumentation root valves. (An instrumentation root valve is defined as the first isolation valve from the process piping to an instrument.)

The current schedule calls for valves inside the drywell to be labeled and valves to be identified which need to be added to the P&ID's and/or operating procedures during the current shutdown. The affected procedures will be revised within ninety days after start-up.

The remainder p of-the labeling and identification of plant valves will be completed (by June, 1987.,) Safety re ted-systems will be reviewed first. The affected P&IMs wi1The updated by December, 1987x J

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ATTACHMENT (centinued)

Licensee Response Item #86-06-03

" Complete labeling of station valves and components."

Labeling of station valves and components has previously been identified as an issue by INPO and is currently being addressed by Boston Edison. Efforts are ongoing to inspect and identify non-labeled valves and components. The inspection is proceeding by plant area and level and is approximately 20% complete.

Areas of need are being recorded and will be corrected once the total plant inspection is completed. Our final completion dates of the above actions will be submitted to Region 1 in an update _leitut_within_ sixty days.

Updated Response See response for Item 86-06-01.

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ATTACHMENT (continued)

Licensee Response Item #86-06-06

" Investigate the cause and required corrective actions for the residual RCIC flow indication occasionally noted after RCIC Surveillance tests by June 1, 1986."

The RCIC residual flow indication issue is currently under evaluation by Boston Edison Company. Once a root cause analysis is completed, an action plan will be developed. The results of the root cause analysis and our corrective action plans (including a final completi9n_date) ~

will be submitted in an update letter to Region 1 within(}Iixty dayi{)

Updated Response Venting on the subject system was performed in April and indicated full water flow with no observed restrictions. However, it is our belief that further analysis of this problem can only be continued when we have steam capability.

We will then continue root cause analysis during the next controlled power ascent. Prior to start-up we will re-confirm the lines are clear by disconnecting and blowing down the lines between the sensor and the flow instrument. The results of our root cause analysis and subsequent resolution are expected to be completed within thirty days after start-up.

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