ML20203L257
| ML20203L257 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 03/02/1998 |
| From: | Olivier L BOSTON EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| BECO-2.98.018, GL-96-06, GL-96-6, NUDOCS 9803050418 | |
| Download: ML20203L257 (40) | |
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Boston Edison Pilgrim Nuclear Power Staten Rocky Hill Road Plymouth, Massachusetts 02360 March 2,1998 L.J. olivier Vice President Nuclear and Station Director BECo 2.98.018 U.S. Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 License DPP-35 Docket 50-293
- LONG TERM PROGRAM: SEMI-ANNUAL REPORT This letter provides the semi-annual Long Term Prograra (LTP) update. The update includes a schedule, commitment descriptions, progress since the last update, and a summary of changes. Changes in status since our last submittal are marked by revision bars in the right margins.
Since the last update, we have completed the fol lowing:
Assurance of Equipment Operability and integrity During Design Basis Accident Conditions (GL 96-06)
This will be removed from future LTP reports.
Scheaule Revisions include:
. Salt Service Water System
. Motor Operated Valves
. Standard Technical Specification Conversion if you have any questions on the contents of this report, please direct them to Marie T. .
Lenhart of our Regulatory Affairs Department at (508) 830-7937.
.J. Olivier HVO/MTL/dcg/LTP/feb/98CVR 7
Attachment 1: Long-Term Program (LTP) Schedule ' -
Attachment 2: LTP Schedule B ltems 'f Attachment 3: LTP Schedule C ltems J
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U.S. Nucl3Ir Rsgulttory Commission
. Paga 2 cc: Mr, Alan B.~ Wang, Project Manager Project Directorate 13 Office of Nuclear Reactor Regulation Mail Stop: OWFN 14B2 U. S. Nuclear Regulatory Commission 1 White Flint North 11555 Rockville Pike Rockville, MD 20852 U. S. Nuclear Regulatory Commission Region 1 475 Allendete Road King of Prussia, PA 19406 Senior NRC Resident inspectcr Pilgrim Nuclear Power Station l
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ATTACHMENT 1
. Long-Term Progre. {! TP) Schedule 1997 1900 1999 2000 2001 I Schedule B Commitments JlFlM i AlMlJlJlAlSIOlNlD JlFlMlAlM!JlJjAlS!OlNlD JjFlMlAlMiJlJlA{SlOlNlD JlFjMlAlMlJlJlAlS}O!NjD J[FjMlAlMjJjJlA RFO r12 Apnl1999 s- veracemen Program -
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WOW Yesang and Surwomance Sem Accasert Management *
- 120 days after receipt of NRC letter ECCS Purnp Stramas Tech Spec Cor=ormon Protect b les Degradabon si Space ruel Pools conia.n=eni m enne oe s = accani c" complete oe gn e -
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Page 1 of I
, ATTACHMENT 2 TABLE OF CONTENTS LTP Schcdule B ltems 4 LTP LTP Page
_ Schedule - Number Title Number B 410 Seismic Verification Program (GL 87-02) 1
)
B 255, Salt Service Water System (GL 89-13) 6 473 B 487 Safety Related MOV Testing and Surveillance (GL 89-10) 10 Pressure Locking and Thermal Binding of Safety Related, Power-Operated Gate Valves (GL 95-07)
Periodic Verification of Design - Basis Capability of Safety.
Related, Motor-Operated Valves (GL 96-05)
B 489 Severe Accident Management Program 18 B 504 BWR Thermal-Hydraulic Instabilities (GL 94-02) 21 B 723 ECCS Pump Strainers (Bulletins 95-02,56-03) 24 B 706 Technical Specification Conversion Project 27 B 707 Boraflex Degradation in Spent Fuel Pools (GL 96-04) 29 B --
Assurance of Equipment Operability and Containment 31 Integrity During Design-Basis Accident Condition (GL 96-06)
B 10CFR50,54(f) RAI Reguding Adequacy and Availability of 33 Design Basis Information Itp97 toc. doc /Itp/feb98
, - -_- .~
ATTACHMENT 2 l
SCHEDULE B SEIS&41C VERIFICATION PROGRAM (GL 87-02) (LTP #410)
Commitment Description The NRC's final Supplemental Safety Evaluation Report (SER) on Revision 2 of the Generic Implementation Procedures (GIP-2) for A-46 was issued via Generic Letter 87-02, Supplement 1, ca May 22,1992 (Reference 4). By September 21,1992, each licensee was required to respond to the SER stating whether they intend to follow the GIP-2 guidance, provide a schedule for implementation of the GlP including submission of a report summarizing the results of the A-46 review, and provide information on the procedures and criteria used to generate the in structure response spectra used for A-46 implementation.
Evaluation of equipment is to include (a) adequacy of equipment anchorage; (b) functional capability of essential relays; (c) identification of potential outliers and deficiencies; and (d) seismic systems interactions.
In our response (Reference S), we committed to implement GIP-2 in its entirety and provided a description of the procedures and enteria used to generate the in-structure response spectra A schedule of GIP-2 implementation and submission of a summary report was deferred to the February 1993 LTP semi-annual update (provided below).
In Reference 6, the NRC issued a Safety Evaluation Report (SER) approving our responsa.
The SER assumed a commitment on BECo's part to implement the GIP-2 in its entirety and noted our in-structure response spectra should be treated as median-centered. We affira.ed the NRC assumption to be correct in Reference 7 and clarified our continued commitment to implement the seismic verification program at Pilgrim Station through the GIP-2 and its subsequent revisions.
Our schedule for completion of the GlP and submission of a summary report is scheduled for 9/30/96.
(BECo lADB RL 95.0003)
References
- 1) NRC Letter dated February 19,1987, GL 87-02
- 2) BECo Letter 88-145, dated October 11,1988, Response to GL 87-02
- 3) NRC LetterJated June 7,1989, Acknowledgment of BECo Response
- 4) NRC Letter dated May 22,1992, GL 87-02, Supplement 1,
- 5) BECo Letter 92-109, dated September 21,1992, Response to GL 87-02, Supplement 1
- 7) BECo Letter 93-019, dated February 11,1993, Additional Information Regarding NRC SER of PNPS Response to GL 87-C2, Supplement 1
- 8) BECo Letter 94-16 dated February 9,1994, Additional Response to GL 87-02, Supplement 1
- 9) NRC Letter dated June 17,1994, Re-evaluation of Approval for Developing Floor Response Spectra for t,,e Resciution of USI A-46.
- 10) BECo Letter 96-068 dated July 12,1996, Revision of A-46 submittal date.
- 12) NRC Letter dated December 16,1997, Request for Additional Information. l Page 1 of 34
ATTACHMENT 2 s
SCHEDULER Commitment Historv!Pronness Progress and Summary of Changes March 1989 to February 1990 A. Develop safe shutdown equipment list - Schedule Revised B. Recreate original seismic design basis documentation - Schedule Revised C. Training and commence walkdown of accessible areas - Schedule Revised The schedule for performing these three items was revised from Cycle 8 to Cycle 9 as a result of our re-assessment of the work to be performed for this seismic issus, with respect to the generic work scope for other similar existing and emerging seismic issues. By incorporating the similarities of work scope for each of the below listed issues into one set of physical activities, we can best optimize our resources. Other seismic issues include:
. Seismic Design Basis (USI A-40)
. Eastem Seismicity and Seismic Design Margins -
Extemal Events (seismic) for Individual Plant Examinations Progress and Summary of Changes - February 1990 to November 1990
. A revised schedule for implementation of the seismic verification program will be developed after issuance of the NRC SER resolving the GlP open issues Progress and Summary of Changes - December 1990 to February 1991
. t'o chances from the previous report period.
Progress and Summary of Changes - March 1991 to August 1991
. A schedule for implementation of the seismic verification program will be -
developed afterissuance of the NRC SER resolving the GIP open issues.
Progress and Summary of Changes - August 1991 to February 1992 A schedule for impit. mentation of the seismic verification program will be developed after issuance of the NRC SER resolving the GIP open issues.
Progress and Summary of Changes - March 1992 to August 15,1992 Reference 4, issued the final NRC SER (SSER No. 2) resolving the GIP open issues and superseded all previous NRC SER documents. A response contcinirig the following information will be made by September 21,1992:
A statement whether we commit to use both the SQUG commitments and the implementation guidance provided in GIP-2 as supplemented by the SSER No. 2 for the resolution of USl A-46.
. A plant specific schedule for the implementation of the GlP and submission of a report summarizing the results of the USl A-46 raview.
Detailed description of the procedures and criteria used to generate the in-structure response spectra.
Page 2 of 34
ATTACHMENT 2 l'
)
I SCHEDULEB Progress and Summary of Changes - August 16,1992 February 15,1993 Three BECo personnel and a co,1 tractor have completed the GIP Seismic Walkdowr' and Evaluation SOUG Training Prograrn.
A safe shutdown equipmenilist has bee 1 developed and is undergoing final review and approval.
A portinn of the seismic walkdown; began in MCO #9. On-line walkdowns continue during operating cycle 9. Outage walkdowns are planned for RFO #9 with any further on-line portions in opersting cycle 10. Remaining off-line portions will be done in MCO 10 and RFO #10.
e At BECo's request, a meeting was held in our Braintree offices on September 3, 1992, in which we presented our intended approach to A 46 resolution and solicited NRC feedback prior to preparing our Generic Letter 87 02 response letter, Progress and Summary of Changes - February 16,1993 July 31,1993
- Welkdowns scheduled for RFO #9 were completed anu other walkdowns are continuing while on-line. The goalis to minimize the impact of performing walkdowns during an outage where safe and practicable.
Relays associated with the safe shutdown equipment list aro being assessed via a full circuit analysis. This is a ta:,k being worked by Engineering and Operations.
The majority of the SSEL equipment and relay evaluations are expected to completed by RFO #10.
Cable tray walkdowns have been completed and the evaluations are expected to completed by RFO #10.
Four more engineers have completed the SQUG Walkdown Screening and Seismic Evaluation Training Course (Total of 7 engineers now certified),
Progress and Summary of Changes August 1,1993 - January 31,1994
. Remaining SSEL walkdowns N. been planned and schedded for MCO #10.
Relay evaluations are nearing completion. Discussions between engineering and operations concerning es sential relay designation is progressing.
A letter requesting a review of our A-46 plan has been sent (Ref. 8). We have completed an initiative that demonstrates the conservatism of the PNPS design basis spectra. This would justify it to be classified as a "consvrvative design" spect a for A 48 implementation.
te.umentation packages are being assembled to support close-out.
s Page 3 of 34 m ,
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ATTACHMENT 2 SCHEDULE B Progress and Summary of Changes February 1,1994 - July 31,1994
- Final SSEL walkdowns are scheduled for MCO #10.
Seismic Evaluation Work Sheets for SSEL components are progressing.
- NRC approved PNPS classification ai, a " conservative design" spectra for A 46 o implementation above 4 Hz.
e' Relay qualification has been initiated.
Progress and Summary of Changes August 1,1994 January 31,1995 e Final SSE walkdowns are scheduled for RFO # 10 e Relay qualification is progressing.
. We have rescheduled the report submittal date to 6/96. Greater than 90% of the walkcowns are complete. However ompletion has been slowed by the .
l temporary reassignment of uniquely qualified personnel to support significant l emergent issues, e.g., the extended main generator forced catage, and the core shroud repair preparation.
1 Progress and Summary of Changes January 31,1995 - August 1,1995 e SSEL walkdowns are now completed.
. Relay qualification is approaching completion; e
Seismic Joluation Work Sheets (SEWS) development is nearing completion.
. Final report will be started in the 4th quarter. Submittal in June 1996 remains unchanged.
Progress and Summary of Changes - August 1,1995 January 31,1996
. Seismic Evaluation Work Sheets (SEWS) are complete.
- Relay qualification assessment essentially complete.
. Assessment of " potential outliers" initiated.
- ' Development of documentation and fina! report is progressing and the submittal is planned for June 1996. - -
i Page 4 of 34
( u
ATTACHMENT 2 SCHEDULEB Progress and Summary of Changes February 1,1996 July 31,1996 e Requested and received an extension of the final report submittal date from June 1996 to Septembat 1996.
. Outlier assessments are continuing.
Validations and verification of safe shutdown equipment list (SSEL) pathways on simulator completed. Feedback is being incorporated into the program.
. Operations review of the prc; ram is in progress.
. Final report devek.pment continues.
Progress of Summary and Changes - August 1,1996 January 31,1997 e Final report submitted for NRC review in September 1996.
. Outlier disposition work plan developed based upon program findings.
. Walkdowns supporting outlier disposition scheduled for RFO #11.
. Outlier disposition has been prioritizad and is proceeding.
- Current planning, which is linked to receipt of an SER in 1997, calls for disposition of known outliers by RFO #12.
Progress of Summary of Changes - February 1,1997 July 31,1997 l e Outlier disposition work plan updated to reflect progress and RFO #11 walkdown findings.
. Resolution of spatialinteractions and completion of SEWS for items walked down during RFO #11.
. PDCs (FRNs) and MRs have been issued to address a family of spatial l interaction outliers that can be worked during plant operation (on-line).
, e Participating in the ongoing dialog between the NRC cnd SQUG concerning l lssues associated with the use of Generic Implementatirn Procedure (CC )
l Method A (a method used to verify the seismic adequacy of equipment installed in operating nucluar plants).
l e identifying outliers for potential field modifications during RFO #12.
Progress and Summary of Changes - August 1,1997 - January 31,1998 Based on the NRC review of Pilgrim's September 30,1996 summary report submittal, a Request for Additional Information (RAl) was issued on December 16,1997. A 90 day response was requested. We are addressing the RAI quer,tions and expect to respond within the requested time.
The resolution o,' equipment outliers is proceeding with specific emphasis on activities t' ,
will requirrs implementation during RFO #12. 1 Page 5 of 34
ATTACHMEtP 2 1 .,
SCHEDULE B SALT SERVICE WATER SYSTEM (GL E9131(LTP #255,473)
Commitment Description Generic Letter (GL) 8913 required licenstes to review and evaluate the adequacy of the service water system and all safety related heat exchangers. The review identified a number of enhancements to the PNPS programs and procedures. As a result, DECO comhiltted via Reference 2 to th2 following.
Prior to end of RFO #8, modify the RBCCW heat exchanger test procedures to include an analytical model to calculate RBCCW heat exchanger performance at test and design conditions. (Complete)
Conduct tests with modified procedures during Cycle 9. (Complete)
Prior to end of RFO #9, modify tha '1HR heat exchanger test procedures to include an analytical model to cr' alate RHR heat exchanger performance at test and design conditions. Complete)
Conduct tests with modified procedures during Cycle 10. (Complete)
Develop a regular maintenance / test program on heat transfer capability of the remaining heat exchangers by RFO #9. (Complete)
Conduct a single failure analysis for the RBCCW subsystem by end of RFO
- 8. (Complete)
Prior to end of RFO #8, upgrade the licensed operator training module to include a loss of all service water. (Complete)
Complete SWCPI Items by the end of RFO #11. (BECo IADB RC 05.0053, SW95.XXXX)
Credit was also taken in Reference 2 for the SSW piping inspection and replacement program already underway at Pilgrim which, henceforth, will be integrated as part of our Generic Letter 8913 implementation efforts.
References
- 1) NRC Letter; GL 89-13:" Service Water System Problems Affecting Safety-Ratated Equipment
- 2) BECo Letter 2.90.047, dated April 2,1990, " Response to GL 8913" Commitment History /Proare.ss Progress and Summary of Changes - March 1990 to November 1990 The licensed operator training module upgrade is complete. There are no changes to the other above-described commitments and schedules.
Page 6 of 34
ATTACHMENT 2 SCHEDULE B Progress and Summary of Changes December 1990 to February 1991 A single failure analysis of the RBCCW subsystem has been performed. Theie are no changes to the other above described commitments and schedules.
Progress and Summary of Changes March 1991 to August 1991 l RBCCW heat exchanger test procedures have been modified to include an analytical model to calculate RBCCW heat exchanger performance at test and design conditions.
In addition, activities associated with SSW piping inspection ar.d replacement are being integrated under our GL 89-13 effort. Further inspectie.1s of the SSW piping will be scheduled during each planned mid-cycle or refueling outage of sufficient duration. It remains our intention to replace SSW pipuig when the inspection of piping shows that to be necessary.
Progrcss and Summary of Changes August 1991 to February 1992 Efforts to enhance the Salt Service Water System are proceeding as indicated in our response to Generic Letter 89-13. There are no changes to the above described commitments.
Progress and Summary of Changes March 1992 to August 15,1992 A decision was made to replace the buried SSW piping with corrosion resistant titanium. Five Plant Design Change Packages were prepared to facilitate replacement of the pipe. Construction of a pipe vault at the intake structure is in progress. Replacement activities will continue through MCO9 and RFO #9. Above ground piping will be routinely examined by non-destructive technology (typically UT) and will be replaced as required Efford to enhance the SSW system are proceeding as indicated above.
Progress and Summary of Changes August 15,1992 February 15,1993 There are no changes to the GL 89-13 (LTP 473) commitments described above.
We are currently installing replacement SSW underground piping (LTP 255) in preparation for system tie in RFO #9 (4/93). To support this affort, during MCO 9 (10/92) we replaced spool pieces in the Auxiliary Bay and Screen House. We also plan to replace the remainder of the intake Structure and Auxiliary Bay above ground inlet piping and tie in the new inlet loop buried piping in RFO #9.
Page 7 of 34
) . . . . .. _ . . . .
ATTACHMENT 2 SCHEDULEB Progress and Summary of Changes - February 15,1993 - July 30,1993 RBCCW Heat Exchanger testing was completed on schedule in cycle 9. The RHR Heat Exchanger Test Procedure and Analytical Model was completed on schedule in RFO #9 The Heat Exchanger Maintenance and Test Program for Heat Transfer Capability was also completed on schedule in RFO #9. There are no changes to the remaining GL 8913 (LTP 473) commitments described above.
Replacement of the SSW piping (LTP 255) was completed on schedule in RFO #9.
Through RFO #9,250 feet of above ground rubber lined carbon steel pipe has been replaced. In addition,430 feet of buried rubber lined carbon steel pipe has been replaced with Titanium pipe. Augmented ISI of above ground rubber lined carbon steel pipe was also completed on schedule in RFO #9. Future ISI will be captured under LTP 473. LTP 255 is completed.
Progress and Summary of Changes August 1,1993 - January 31,1994 There are no changes to the remaining GL 89-13 commitments described above. ln summary, RHR heat exchanger tests will be conducted with modified procedures during Cycle 10. Ongoing inspections of the Salt Service Water System have been incorporated into our ISI program.
Progress and Summary of Changes February 1,1994 - July 31,1994 There are no changes to the remaining GL 89-13 (LTP 473) commitments described above.
Progress and Summary of Changes- August 1,1994 - January 31,1995 We performed an extensivu self assessment of the Salt Service Water System and our response to GL 89-13 (Reference 2). We are in the process of developing a plan to address issues and enhancements identified in the self assessment.
RHR heat exchanger tects were conducted with modified procedures during Cycle
- 10. Ongoing inspections of the Salt Service Water System have been incorporated into our ISI program.
Progress and Summary of Changes - February 1,1995 - July 31,1995 We are implementing a comprehensive set of enhancemer,ts identified in the Salt Service Water System Self Assessment (SWSOPI). We plan to implement most of the erihancements prior to the end of 1995, and all of these enhancements are currently scheduled for completion by the end of RFO-15 Progress and Summarv of Changes - August 1,1995 - January 31,1996 We are currently on schedule to complete the SWSOPl items by the end of RFO
- 11.
Page 8 of 34
ATTACHMENT 2 SCHEDULEB Progress and Summary of Changes - February 1,1996 July 31,1996 Of the original 149 SWSOPl action items,21 remain open. All SWSOPl related action items are scheduled to be completed by the end of RFO #11.
Progress and Summary of Changes August 1,1996 January 31,1997 Ten SWSOPl action items remain open. These items are now scheduled for completion aftti RFO #11. A final close-out report will be issued before July 31, 1997.-
Progress and Summary of Changes - February 1,1997 - July 31,1997 Three SWSOPl action items remain open. A NRC SpecialInspection began May 14,1997, to review the disposition of all SWSOPl action items and related GL 8913 issues. Supporting this inspection, along with adions taken to respond to sovvcal issues raised, has affected the completion of the close out report. A new schedule will be determined after the conclusion of the specialinspectica.
Progress and Summary of Changes - August 1,1997 January 31,1998 The remaining SWSOPl action items are scheduled for completion by July 31,1998, The effert to produce a close-out report was affected by NRC Special Inspection 97-05 and is now scheduled to be done by the end of 1998.-
A .
ATTACHMENT 2 SCHEDULE B SAFETY REL ATED MOV TESTING AND SURVElLLANCE fGL 8910)(LTP #487)
PRESSURE LOCKING AND THERMAL BINDING OF SAFETY-RELATED. POWER.
OPERATED GATE VALVES (GL 95 07)
PERIODIC VERIFICATION OF DESIGN BASIS CAPAB!LITY OF SAFETY-RELATED MOTOR OPERATED VALVES (GL 96-05)
Commitment Description Generic Letter (GL) 89-10 (Ref.1) expands the scope of the motor operated valve program required by NRC Sul'etin 85-03 and its Supplement, to include additional testing, inspecting, and maintenance for all safety related motor operated vanes.
In our Reference 2 response to the GL, we committed to develop a program to enhance the maintenance, analysis, and testing already being conducted on MOVs at Pilgrim. The GL calls for the development of this program within 1 year or one refueling outage from the date of the letter, whichever is later. For BECo, tnis schedule translates to RFO #8. Our plan was to begin a design basis rsview of MOVs in the first quarter of 1991 and to begin testing in RFO #9. Based on resource constraints in 1990, we revised the design basis resiew schedule to commence in the last quarter of 1991. This revision continues to support our commitment to begin testing in RFO #9 and supports our program development schedule. We anticipate the testing will require three refueling outages, based on the extent of known scope.
Additional scopo determine ans as a result of NUMARC and BWROG involvement will be factored into our final scope and schedule as appropriate.
Reference 6 requested Licensees to perform a plant specific safety as,=essment to determine if generic safat.y assessments performed by the NRC staff and the BWR Owners' Group are applicable. If MOVs are discovered with potential deficiencies of greater significance than the HPCI, RCIC, and RWCU MOVs, planned activities to address the generic letter were to be re-prioritized accordingly. Notificawn within 30 days of receipt of Supplement 3 was required verifying a plant specific safety assessment was perfermed and identifying whether there were MOVs with deficiencies of greater safety significance than in the HPCI, RCIC, and RWCU systems. An additional notification within 120 days of receipt was also requasted to provide the criteria reflecting operating experience and the latest test data applied in determining whether deficiencies exist in the HPCI, RCIC, and RWCU MOVs.
In our Reference 7 letter, we concluded the subject valves in the HPC!, RCIC, and RWCU systems were capable of performing their safety functon to provide containment iso',ation in the event of a line break outside containment. This submittal provided our 30 and 120 day response to the generic letter and precluded having to perform a plar.t specific safety assessment. We also committed in Reference 7 to conduct diagnostic testing tn the Reactor Water Cleanup (RWCU) MO-12012 valve during RFO #8 We expanded our planned RFO #8 testing to include 2 additional valves: RWCU MO-12015 and Closed Cooling Water MO-4010A.
The NRC issued a Request for Additional Information (RAl) (Rei.10) after reviewing our Reference 7 and 8 responses to GL 89-10 Supplement 3. BECo responded to the RAI on August 29,1991 (Ref.11).
Page 10 of 34
ATTACHMENT 2 SCHEDULE B During the week of March 913,1992, the NRC conducted an inspection of the PNPS GL 8910 MOV program. As a result of this inspection Boston Edison committed to resubmit the GL 8910, Supplement 3, response and accelerate the schedule for priority i valves to have the GL 8910 actions completed by the end of RFO #10.
RFO #10 is scheduled for 1995. The remaining safety related valves will be completed by the end of RFO #11.
(BECo IADB RL95.000)
References
- 1) NRC Letter dated June 28,1989, GL 8910
- Safety Related MOV Testing and Surveillance"
- 2) BECo Letter, dated Jai,uary 15,1990,2.90.013
- 3) NRC Letter dated June 7,1990, Response to GL 8910
- 4) NRC Letter dated June 13,1990, Supplement 1 to GL 8910
- 5) NRC Letter dated August 3,1990, Supplement 2 to GL 8910
- 6) NRC Letter dated October 25,1990 Supplement 3 to GL 89-10
- 7) BECo Letter dated December 17,1990,2.90.158
- 8) BECo Letter dated February 26,1991,2.91.022
- 9) NRC Letter dated April 1,1991 Meeting Summary BECo/NRC
- 10) NRC Letter dated June 24,1991, RAI regarding GL 8910 Supplement 3
- 11) BECo Letter dated August 29,1991,2.91.111
- 12) NRC Letter dated February 18,1992, Closure of GL 8910, Supplement 3
- 13) NRC Letter dated February 12,1992, GL 89-10 Supplement 4
- 14) NRC Letter dated June 3,1992, inspection 50-293/92 80 Motor Operated Valve Inspection
- 15) NRC Letter dated May 5,1992, Motor Operated Valve Inspection at PNPS (NRC Inspection Report 50-293/92 80)
- 16) BECo Letter dated April 14,1992, Revision to GL 8910 Supplement 3 Response,-
2.92.044
- 17) NRC Letter dated June 28,1993, GL 89-10 Supplement 5
- 18) BECo Letter dated OMober 21,1993, Response to GL89-10 Supplement 5,2.93.135
- 19) BECo Letter dated cmaary 7,1994, Update to GL8910, Supplement 3 Response, 2.94.005
- 20) NRC Letter dated April 19,1994, GL 89-10, Supplement 5
- 21) GL 9*.,07," Pressure Locking and Thermal Binding of Safety Related Power Operated Gate Valves (BECo #1.95.131)
- 22) BECo Letter dated October 16,1995,60-Day Response to GL 95-07,2.95.108.
- 23) BECo Letter dated February 23,1996,180-Day Response to GL 95-07,2.96.013
- 24) NRC GL 96-05, Periodic Verification of Design Basis Capability of Safety Related Motor Operated Valves, September 18,1996
- 25) BECo Letter dated November 15,1996, Response to GL 96-05,2.90.099
- 27) BECo Letter dated June 18,1997,180-Day Response to GL 96-05,2.97.064
- 28) BECo Letter dated December 23,1997, Supplementary Information Related to GL 96-05, 2.97.133
- 29) BECo Letter dated December 11,1997, Information Related to Closure of GL 96-10, 2.97.129
- 30) NRC Inspection 97-13, dated February 6,1998, includes close-out of G' 99-10 Page 11 of 34
ATTACHMENT 2 SCHEDULE B Commitment Historv/Proaress Progret . ., t Summary of Changes - February 1990 to November 1930 e
Begin a design basis review of MOVs is on schedule for first quarter of 1991, e
Begin testing is on schedule for RFO #9 (completion within 3 refueling outages),
e 30 day notification in accordance with Generic Letter 8910, Supplement 3 is planned for submittal by December 13,1990.
. 120 day notification efforta are planned for submittal by March 13,1991.
Progress and Summary of Changes - December 1990 to February 1991 e
The schedule for commencement of design basis reviews of MOVs is being changed from the first quarter of 1991 to the last quarter of 1991. This schedule revision continues to support our commitment to beg,n testing in RFO #9.
Begin testing is on schedule for RFO #9 (completion within 3 refueling outages).
. 30 day and 120 day notifications are complete.
3 safety related valves are on schedule for diagnostic testing during RFO #8 (MO-12012,12015, and 4010A).
- Development of a Program Plan is on schedule for completion by May 1,1991.
Progress arid Summary of Changes - March 1991 to Au]ust 1991 e Commencement of design basis reviews of MOVs is on schedule for the last quarter of 1991.
- Begin testing is on schedule for RFO #9 (completion within 3 refueling outages).
Diagnostic testing of MO-12012,12015, and 4010A was conducted during RFO
- 8. In addition to this testing, we completed diagnostic testing on the remaining I
GL 8910 Supplement 3 MOVs (4 valves) and on another 10 safety related MOVs.
e Development of a Program Plan is complete.
Progress and Summary of Changes - August 1991 to February 1992 Design basis reviews of MOVs continue to support our commitment to begin testing in RFO #9.
- Testing is on schedule to begin in RFO #9 (completion within 3 refueling outages).
Piocedures are in preparation describing design basis review methodology, control of switch settings, and degradod voltage analysis. Additionally, a Nuclear Organization Procedure establishing our MOV program is in final review.
e The schedule for static testing of MOVs has been accelerated and some testing t
-will be done during our mid cycle outage prior to RFO #9.
. MOVs tested using MOVATS test equipment were reviewed and have been retested using more accurate diagnostic test equipment or been reviewed to ensure there is sufficient margin.
Page 12 of 34
o ATTACHMENT 2 SCHEDULEB Progress and Summary of Changes - March 1992 to August 15,1992 l
e Design basis reviews of MOVs continue to support our commitment to begin testing in RFO #9.
e Testing is on schedule to begin RFO #9.
. GL 89-10 activities will be completed for priority i valves by the end of RFO #10.
- Reference 16 submitted a revision to GL 8910, Supplement 3, response (Reference 8).
Nuclear Organization Procedure 92M1
- Motor Operated Valve Program" has been approved.
Procedures describing design basis review methodology and control of switch settings are appFved. Draft procedures for degradad voltage of motors are being revised to include temperature effects on available torque. Additional procedures are being developed as necessary.
Progress and Summary of Changes - August 15,1992 February 15,1993 Design bas!s mvlew is on schedule to support commitment to complete Priority i valves by RFO #10.
. Static testing was performed during MCO #9.
. New state of the art test equipment was purchased that provlJes direct stem torque and thrust measurements.
Progress and Summary of Changes February 15,1953 July 31,1993 Design Basis Reviews (DBR) and Diagnostic Testing are on schedule to complete Priority 1 MOVs (55 valves) by RFO #10. DBR and Testing related to the remaining Safety Related (SR) MOVs (35 valves) is also on schedule and is expected to be completed by RFO #11, Significant MOV testing, maintenance and inspections were completed in RFO #9.
Maintenance and inspections were conducted on 56 SR MOVs. Diagnostic Testing was completed on 21 SR MOVs.
Through RFO #9,46 out of a total population of 90 SR MOW 1 ave been set up via diagnostic testing techniques. Through RFO #9,29 of 55 ; nority i MOVs have been sa's up via diagnostic testing techniques.
MOV testing, maintenance, and inspections are schedt. led to continue in MCO 10, including the first phase of Dynamic Testing.
Page 13 of 34
O ATTACHMENT 2 SCHEDULE B Progress and Summary of Changes August 1,1993 January 31,1994 Design Basis Reviews (DBR), Diagnostic Testing, Inspections, Maintenance and Modifications are on schedule to support the commitment to complete Priority 1 MOVa (55 val s) by RFO #10. Similar efforts related to the remaining Safety Related (SR)
MOVs 95 valves) are also c,n schedule and are expected to be completed per the current commitment, RFO #11.
The first phase of Dynamic Testing is on schedule to commence in MCO 10.)The use of an alternative valve end actuator design is under consideration for implementation on a certain population of MOVs. Candidate MOVs are those which would require significant modifications utilidng typical manufacturer product design and applications.
The attemative design has several advantages ncluding a solid state control system, enhanced repeatability, reduced electrical po"nr demand and a reduced preventative malntenance frequency. The alternate de' ;.would also decrease the probability of potential common mode failure issues and diversify plant design.
Our response to GL 8910, Supplement 5. (Ref.18), indicated actions to be taken to resolve the accuracy issues associated with the use of Liberty Technologies VOTES equipment. The following actions were required:
. Update the VOTES test results using the revised property constants and torque correction factors. This action is complete. Subsequent to this action, Liberty issued Customer Service Bulletin (CSB) 031 that requires review of test results due to a software problem in the VOTES equipment. This new action will be completed and updated by our next LTP submittal.
. Revise Liberty Technologies test results to use a curve fit algorithm and determine extrapolation error. This action is complete. Subsequent to completion, Liberty issued CSB-031 causing a need to review post test tesults.
This new action will be completed and updated by our next LTP su~omittal.
Progress and Summary of Charges February 1,1994 - July 31,1994 Design Basis Reviews (DBR), Diagnostic Testing, inspections, Maintenance and Modifications are on schedule to support the commitment to completa Priority 1 MO\/s (55 valves) by the end of RFO #10. Similar efforts related to the remaining Safety Related (SR) MOVs (35 valves) are also on schedule and are expected to be completed per the current commitment, RFO #11. The work scope app;icable to the Priority i MOVs includes approximately (90) Inspections, (17) Overhauls, (48) Static Diagnostic Tests, (36) Dynamic Diagnostic Tests and (52) Modifications.
The first phase of Dynamic Testing is on schedule to commence in MCO #10.
The use of an attemative valve design, as previously discussed, is being aggressively pursued for implementation on (4) MOVs in RFO #10. The use of an attornat!ve actuator dsign is alsa being aggressively pursued for imolementation on (1) MOV in RFO #10. The alterr ate design incorporates GL 8910 ' lessons learned' as well as the most recent EPRI and INEL technicalinformation. Back up plans are also being developed should new product qualification issues not support our RFO #10 schedule commitment.
Page 14 of 34
ATTACHMENT 2 SCHEDULE B i
Progress and Summary of Changes July 31,1994 January 31,1995
'GL 8910, Safaty Related MOV Testing and Surveillance' activities continue on schedule to support the commhment to complete Priority i MOVs (55 valves) by RFO
- 10, with the remaining Safety Related (SR) MOVs (35 valves) following per the current schedule commitment, RFO #11.
Significant progress was made during the generator forced outage in the Fall of 1994.
The forced outage enveloped the original scheduled MCO #10. A total of forty nine (49) MOVs were worked during the Fall outage. Industry corrective actions and GL 89-10 design changes accounted f or thirty six (36) of the forty nine (49) activities performed. Activities ranged in complexity from complete actuator replacement / valve i disassembly to simple changes in gear ratio and EQ inspections.
Valve modifications were completed on three (3) MOVs for the purpose of instal!ing pressu.e locking relief paths. Potential over thrust /over torque conditions were also dispositioned on two MOVs in the RWCU and RCIC systems.
The first phase of Dynamic Testing was completed during the Fall utage. Differential pressure diagnostic testing was completed on thirteen (13) MOVs. Static diagnostic
^
testing also continued during this outage with twenty-five (25) MOVs being set using state-of the art equipment and industry data.
, The use of an alternative valve design, as previously discussed, is scheduled for
- implementation on (4) MOVs in RFO #10. The use of an alternative actuator design is aisc being aggressively pursued for implementation on (1) MOV in RFO #10. The attemate designs incorporate GL 89-101essons teamed' as well as the most recent EPRI and INEL technical information. Back up plans are in place to install a conventional design actuator should delivery of the new actuator not support our RFO
- 10 schedule commitment. Whichever actuator is installed, committed actions will be completed in RFO #10.
Progress and Summary of Changes - February 1,1995 - July 31,1995 The first phase of GL 89-10, Safety Related (SR) MOV Testing and Surveillance activities (55 Priority 1 MOVs) was complated on schedule in Rc0 #10. The remaining Safety Related MOVs (35 valves) will follow per the current schedule commitment, RFO #11.
Significant progress was made during RFO #10 (Spring 95). A to' 4 of sixty eight (68)
SR MOVs were worked during the refueling outage. Industry corrective actions and
, GL8910 design changes accounted for forty (40) of the sixty eight (68) activities performed. Activities ranged in complexity from complete valve / actuator replacement to simple changes in gear ratio anc EQ inspections.
- - Valve modifications were completed on five (5) MOVs in RFO #10 for the purpose of installing pressure locking relief patt s. This brings the total number of MOV related modifications to eight. No additional MOV modifications related to this issue are expected.
During RFO #10, differential pressure diagnostic tehg was completed on thirty five (35) MOVs. Static diagnostic testing also continuea during the RFO with forty (40)
MOVs being set using state-of the wt equipment and industry data.
Page 15 of 34
i q
, ATTACHMENT 2 l' SCHEDULE B Design basis operation for eight three pe Mt (83%) of Priority 1 gate and globe motor operated valves has been confirr' < a via differential pressure diagnostic testing.
Static diagnostic testing has been perfc.ned on all Priority 1 gate and globe motor operated valves (47).
The installation of an altemative valve design (" Sentinel"), as discussed in the prevbus l update, was completed on (4) MOVs in RFO #10. Three of the six GL 8910 Supplement 3 MOVs were replaced with the new design. RFO W10 test results indicate l
excellent performance characteristics. The use of an alternative actuator design is also continuing to be aggressively pursued for future implementation. The altemate designs incorporate GL 8910 " lessons learned" as well as the most recent EPRI ano INEL technical information and thus represent a truly enginaered solution to many outstanding design issues.
Progress and Summary of Changes August 1,1995 - January 31,1996
! The scope of work associated with RFO #11 will be cimilar in nature and in quanaty to that accomplished in RFO #10 (summarized in the p'evious updato). Certain Priority 1 MOV's will again be worked for the purpose of accamplishing standard preventative maintenance, disposition of emergent generic iridustry issues, or to inspect for ,
potential degradation for trending or corrective maintenance. The atrategy is to complete as much of the scope on line within the scheduled system windows as possible. This strategy optimizes resources and considers ALARA.
The issue of " Pressure Locking and Thermal Binding..." with respect to MOVs is essent: ally complete. Twelvo (12) MOVs have been determ'.ned to be susceptible to pressure locking and three (3) MOVs have been determined to be susceptible to thermal binding. Physicci modifications are complete on eleven (11), procedure changes are planned on four (4), with the remainder being dispositioned via engineering evaluation as not susceptible. Specific details are available in our 180-day response to GL 35 07. (Ref. 23)
Progress and Summary of Changes February 1,1995 - July 31,199S The remaining Safety Related MOVs (35 valves) are on schedule to cor. plete per the current commitment, RFO #11.
BECo is also pursuing a permanently installed MOV monitoring system. It is designed to be a non intrusive device capable of automatically acquiring critical vi. . I performance parameters It will record and store the valve data onto a removable cartridge for future analysis. The system provides a method of trending valve performance to address periodic test verification requirements.
The installation of an altemative valve design (" Sentinel"), was completed on (4)
MOVs in RFO #10. Three of six GL 89-10 Supplement 3 MOVs were repiaced with the new design, RFO #10 test results indicate excellent performance characteristics.
Confirmato;y flow and thermal effects testing was conducted by OEM (General Electric) in May 1996. The testing identified condition: which are not specifically or conservatively addressed in GL 95-07 (Pressure locking and Thermal Binding of Safety Related Power Operated Gate Valves"). This issue was identified in our response to RAI TAC No. M93504 and will be followed/dispositioned under GL 95-07.
Page 16 of 34
ATTACHMENT 2 SCHEDULE B Progress and Summary of Changes - August 1,1990 January 31,1997 There are no significant changes to the commitments identified or referenced above.
The first phase of GL 8910, Safety Related (SR) MOV Testing and Surveillarice activities (55 Priority 1 MOVs) was completed on schedule in RFO #10. The remaining 1 safety related MOVs (35 valves) are on schedule to complete per the current commitment, RFO #11 (February 1997).
C The scope of work associated with RFO #11 v.ill be simf.e in nature and in que*ity to that accomplished in RFO #10. Approximately fifty (50) safety related MOVs t 4 3 up the RFO #11 scope. Certain Priority i MOVs will again be worked for the purps ,e of accomplishing standard preventive maintenance, trending, disposition of emergent generic industry issues, or to inspect for potential degradation and perform the associated corrective maintenance.
Approximately thirty safety related MOVs were completed on-line within the scheduled system windows. This strategy increases design mar 0in at the earliest possible time and optimizes resource; / ALARA considerations.
Pilgrim also intends to install and test the ' Sentry' on-line monitoring system on approximately ei0ht (8) MOVs in RFO #11. This system has the capability to record and store diagnostic data which can be used to analyze the MOVs performance over time. Pilgrim intends to utilize this system es one of the elements of the Periodic Verification Program (GL 96-05). BECo Letter 96-099, dated November 15,1996, provides our current commitment relative to periodic verification to be established by September 30,1997.
Progress and Summary of Changes February 1,1997 July 31,1997 All activities and commitments associated with GL 89-10 have been completed (Ref.
26).
The MOV verification program will be established by S3ptember 30,1997.
Boston Edison Company expects to begin implementation of the MOV verification program by December 31,1997. (Ref. 27).
Progress and Summary of Changes - August 1,1997 January 31,1998 The MOV periodic verification program was established by September 30,199, . We are currently developing the implementing procedures and expect to begin implementation of the periortic verification program by February 28,1998 (Ref. 28).
All activities and commitments associated with GL 89-10 were inspected and GL 89 10 was closed by NRC Inspection Report 97-13, based on a commitment to implement the EPRI Performance Prediction Methodology (PPM) for non testable MOVs by June 30,1998 (Ref. 29).
el Page 17 of 34
ATTACHMENT 2 19,tig,DULE B EEVERE ACCIDENT MANAGEMENT PROGRAM (LTP #489)
Commitment Description By letter dated March 24,1995, we informed the NRC that Pilgrim Station intends to implement the formal industry position on severe accident management approved by the Nuclear Energy Institute's Nuclear Strategic issues Advisory Committee on November 21,1994, from NEl to the Director, Office of Nuclear Regulation states that:
Each licensee will:
Assess current capabilities to respond to severe accident conditions using Section 5 of NEl 9104, Revision 1,
- Severe Accident issue Closure Guidelines."
e implement appropriate improvements identified in the assessment, within the constraints of existing personnel and hardware, on a schedule to be determined by each licensee and communicated to the NRC, but in any event no later than December 31,1998.
Based on previous interactions between NEl and the NRC, we understand the NRC agrees with the nsed for licensee flexibility in their methods of assessing and establishing severe accident management guidance. Utilizing the associated implementing guidance (contained in NEl report 9104, Revision 1), our target date for completion of the assessme severe eccident management capabilities and implementation of any identifieu anhancements is Decembar 31,1997.
Although product development activities are progressing well, impacts on our schedule will be experienced short'y due to RFO #11 and the NRC requalification license examination in the Fall of 1997. We expect all products to be completed, except for Operator Training and finc! validation and verification, by December 1997. As such, we will complete fullimplementation by June 1998.
(BECo IADR RC 96.0001)
Commitment Hiitory/Proaress Progress and Summary of Changes February 1,1995 - July 31,1995 Multi disciplined Task Force and Project Manager assigned to Program.
e Integration with EOP update initiated e
Project goals, objectives, schedules, costs, and task ownership approved.
- Detailed task assignments have been made.
Continued interaction with the BWROG's Severe Accident Working Group.
. Detailed reviews of goveming guidance documents have been initiated.
Page 18 of 34
ATTACHMENT 2 SCHEDULE B Progress and Summary of Changes August 1,1995 January 31,1996 e Vendor selected to complement in house resources.
? Continued interaction with the BWROG's Severe Accident Working Group, e Data collection to support calculations initiated. l
. The following tasks have been initiated:
- develop Plant Specific Technical Guidelines and Plant Specific Seven Accident Guldelines evaluate Emergency Response Organization verify technical guidelines formulation of design decisions Progress and Summary or Changes February 1,1996 July 31,1996 e Continued interaction with BWROG's Severe Accident Working Group.
- Work !s continuing in the following areas:
Plant specific techr.ical guidelines / plant specific severe accident guidelines. ;
Evaluation of the Emergency Response Organization.
Verification of techrilcal guidelines and formulation of design decisions.
- Full task force review and approval of interim products is progressing.
Progress and Summary of Changes August 1,1996 January 31,1997
. Continued interactions with the BWROG's Severe Accident Working Group and the Nuclear Energy Institute (NEI) to follow emergent activities affecting program completion.
. Work is continuing in the following areas:
Development of proposed EOP revisions (including flow charts).
1- -
Preparation for revised EOP validation program.
Revision of EOP satellite procedures.
Existing EOP training provided to project task force.
Development of Pilgrim Station Severe Accident Management Guidelines (flow charts).
Revising portions of the Pilgrim Station Emergency Plan and implementing procedures.
Assessing the integration of the EOPs and Severe Accident Management Guidelines l with the Emergency Response Organization.
L Progress ano Gummary of Changes - February 1,1997 July 31,1997
. Participated as an observer in Virginia Power's North Anna Severe Accident I - - - -
Management demonstration (July 1997). Although North Anna is a PWR, the lessons learned will serve as a means to self assess the Pilgrim Station Severe Accident Management program for completeness.
Page 19 of 34 ;
ATTACHMENT 2 SCHEDULE B
. Work is continuing in the following areas:
- Verification and validation 'wsks are proceeding anc will be completed in the fourth quarter by working on the plant simulator with on operations crew.
Assessing the integration of the EOPs and Severe Accident Managemer" Guidelines with the Emergency Response Organization.
Defining training requirements based on functional responsibilities and developing training modules.
. Per schedule, organizational wide training should begin in the first quarter of 1998.
Progress and Summary of Changes- August 1,1997 January 31,1998
. Verification and validation activities are proceeding.
. Training moaules are being finalized to perform the required training.
. Program is on schedule for completion by June 1998.
Page 20 of 34
ATTACHMENT 2 '
SCHEDULEB BWR THERMAL-HYDRAULIC INSTABILITIES (GL 94-02) (LTP#504)
Commitment Description The NRC issued this Generic Letter (GL) 94 02 requesting each BWR licenses take appropriate actions to augment its procedures and training for preventing or responding to thermal-hydraulic Instabilities in their reactors. Each licensee is to submit a plan describing which long-term stability Solution hardware option it has selecied and provide a proposed implementation schedule for the necessary modifications, Boston F.dison implemer.ted the Stability Guidelines (Reference 3) coincident with startup from RFO #10. Boston Edison willinstall Enhanced Option 1A as its long-term stability solution. Milestones are: >
e Submit for NRC approval an evaluation October 30,1996 demonstrating that the existing Technical Specifications encompass Option 1A modifications (No Technical Specification amendment required) e Option 1 A modifications implemented 4th Qtr/1997 at PNPS '
(BECo lADB RL 95.0016)
References
- 1) M9C Letter dated 7/11/94, GL 94 02* "Long Term Solutions and Upgrade of Interim Operating Recommendations for Thermal-Hydraulic Instabilities in Boiling Water Reactors?
- 2) BECo Letter dated 9/9/94, BECo Response to GL 94 02,2.94.102,
- 3) BWR Owners Group Letter, dated 6/6/94, *BWR Owne.rs Group Guidelines for Stability Interim Corrective Action"
- 4) BECo Letter dated 11/7/96, ' Power Flow Stability Technical Specifications Related to Pilgrim's Installation o' BWROG Enhanced Option 1.
- 2,96.094 >
Commitment Historv/Proaress Progress and Summay of Changes July 31,1934 - January 31,1995.
In Reference 2, Boston Edison informed the NRC we would, within design and license
_ constraints, modify procedures and conduct operator training consistent with the -
guidelines provided in reference 3. These actions will be implemented coincident with startup from RFO #10, currently scheduled to start March 25,1995, i
Page 21 of 34
ATTACHMENT 2 SCHEDULE B Also in Reference 2, BECo stated we are presently planning to install the Enhanced Option 1A stability solution at Pilgrim Station by the end of 1997. The proposed milestones for Option 1 A were included in reference 2 as follows:
FIllestone Owner Qatt Submit PNPS specific power / flow map PNPS 3rd Qtr/1995 region boundaries to NRC for review and approval NRC approval of subroitted region NRC 2nd Otr/1996 boundaries Submit Tech Spec. changes for Option 1 A PNPS 3rd Qtr/1996 modifications NRC approval of Tech. Specs, NRC 3rd Otr/1997 Option 1 A modifications implemented at PNPS 4th Qtr/1997 PNPS We also stated we are continuing to monitor the Option 3 progress and would inform the NRC via the LTP Update process if Option 3 became a more viable long-term solution for PNPS, Progress and Summcry of Changes February 1,1995 July 31,1995 The milestones reported on the last LTP are unchanged except the NRC has indicated at a July 10,1995, BWROG meeting that we do not have to separately r,ubmit the .
PNPS specific power / flow MAP region boundaries to the NRC for review and approval.
We can submit the boundaries as part of the technical specification package 'or the hardware modifications. BECo may separately send these proposed boundaries to the NRC in support of requesting approval for our use if such boundaries offer significant relief from the in-place BWROG interim corrective action guidelines.
Progress and Summary of Changes - August 1,1995 January 31,1996 The design of hardware and software modifications is in progress. The project is on schedule.
Progress and Summary of Changes February 1,1996 - July 31,1996 BECo continues working with the BWROG and NRC in resolving final comments on the NRC safety evaluation of the BWR thermal _ hydraulic instability. BECo will provide an evaluation demonstrating PNPS does not need a Technical Specification change to address stability Isrues.
Page 22 of 34
ATTACHMENT 2 SCHEDULE B 1
Progress and Summary of Changes August 1,1996 January 31,1997 On November 7,1996, Bostor. Edison submitted (Ref. 4) to the NRC its review of the BWROG proposed Standard Technical Specifications for Enhanced Option 1 A vis s-vis Pilgrim s Technical Specifications and concluded our current Technical Specifications and administrative controls address this modification with minimal i changes being required. These changes will be part of the conversion to Standard Technical Specifications. We cordinua to work to a December 31,1997, completion date for fullimplementation of the Enhanced Option 1 A modification. .
Progress and Summary of Chances February 1,1997 July 31,1997 in February 1997, Boston Ediso i completed Phase 1 of modification implementation.
One new Flow Control Trip Refurence (FCTR) circuit card was installed in APRM A. '
One new Period Based Detaction System (PBDS) circuit card was installed in LPRM A and one in LPRM B. The digital port output from the PBDS cards was connected to a system to collect data and operational experience during downpower and power ascension for RFO #11 and to monitor the PBDS response during various plent operations.
The above data from Pilgrim and other BWROG Enhanced Option 1 A plants was reviewed by the BWROG in July. Utilities expenenced higher than expected counts at stable, rated power conditions with the least sensitive PBDS settings of period tolerance and corner filter frequency. The frequency of Hi plarm signals due to those high counts 's unacceptable because it is not a meaningful indication of stability conditions. The BWROG is modifying the firmware of the PBDS card to increase the filter rang. To accommodate this hardware improvement and additional testing, BECo is revising its final implementation date to June 30,1998.
Progress and Summary of Changes August 1,1997 January 31,1998 No change in status from previous period. Finalimplementation requires a letter from the NRC by March 1,1998 to complete by June 30.1998. Therefore, final imp!ementation will be 120 days after receipt of NRC letter.
- _ = .
Page 23 of 34 i
e ATTACHMENT 2 SCHEDULE B ECCS PUMP STRAINERS (Bulletin 95 02) . (Bulletin 9G-03)(LTP #723) l Commitment
Description:
Pilgrim has performed testing for the purpose of confirming suppression pool and strainer cleanliness. The testing confirmed strainer cleanliness, and the results were transmitted to the NRC (Reference 3). Pilgrim willinspect the ECCS suction strainers in RFO #11 and will also continue with pool cleaning in that outage. Future pool cleaning frequency will be based on a plan conslatent with generic studies currently on going via the BWROG. Pilgrim completed foreign material exclusion (FME) procedure enhancements on February 8,1996.
Bulletin 96 03 requested that appropriate procedural measures and plant modification to minimize the potential for clogging of ECCS suppression pool suction strainers by debris generated during a LOCA. BECo plans to inst #1 new ECCS suction strainers that will increase the design margin relative to the existing design basis.
(BECo IADB RL 95.0033)
References:
- 1) NRC Bulletin 95-02," Unexpected Clogging of a Residual Heat Removal (RHR)
Pump Strainer While Operating in Suppression Pool Cool Mode", dated 10/17/05 (BECo Letter 1.95.165)
- 2) BECo Response dated 11/16/95 (BECo Letter 2.95.118)
- 3) BECo 120-Day Response dated 2/13/96 (BECo Letter 2.96.007)
- Potential Plugging of Emergency Core Cooling Suction Strainers by Debris in Boiling Water Reactors",5/6/96 (BECo Letter 1.96.078)
, 5) NRC Regulatorv Guide 1.82, Rev. 2: Water Sources for Long Term Recirculation Cooling Following a Loss of Coolant Accident, dated May 1996 (BECo Letter 1.96.086) l 6) BECo Letter dated 11/1/96,2.96.062, Pilgrim's 180 Day Respese to NRC Bulletin 96-03.
- 7) BECo Letter dated 2/7/97,2.97.012, Additionalinformation regarding pump suction strainer installation at Pilgrim Station.
Commitment History /7roaress:
Progress and Summary of Changes - August 1,1995 January 31,1996 Pilgrim has conducted a review of ECCS capability and has determined that the ECCS systems are operable, the strainers are not clogged or degraded, and the suppression pool is free of debris that is or can become suspended and result in strainer clogging. This conclusion is based on previous pool cleaning activities and inspections and verified by representative pump performance testing.
Page 24 of 34
ATTACHMENT 2 SCHEDULE B Foreign material exclusion (FME) procedures are in place that should prevent the introduction of material with the potential to compromise ECCS capability. Further snhancements to drywell cleanliness practices are planned to reduce the potential for foreign material entering the torus. Trending in terms of water cleanliness and pump suction pressures are in place and will continue in order to monitor water quality with respect to this issue. Suppression pool cleaning is scheduled for RFO
- 11. This and subsequent cleaning / inspection are intended to be consistent with BWROG guidarv.e with respect to items such as sludge generation rate and cleanliness criteria. Pilgrim is active in the BWROG committee and intends to participate aggressively in the development of the Utility Resolution Guide (URG) currently being developed by the owners group.
Progress and Summary of Changes February 1,1996 - July 31,1996 Plans are being developed for the purpose of increasing design margin consistent with the Bulletin and Regulatory Guide identified above. Resources e 1 being applied to the design and procurement of extended surface area pas. a strainers and the review of opticas related to minimizing material transport post LOCA.
Pilgrim is active in the BWROG committee and intends to participate aggressively in the development of the Utility Resolution Guide (URG) currently being developed by the owners group. Based on the Bulletin / Regulatory Guide and the URG, Pilgrim will make modifications to inciease design margin at the earliest possible scheduled outage of sufficient duration to implement the respective modification. Based on the analytical and test data currently available, Pilgrim's licensing basis, and the BWROG preliminary recommendations, we would expect to install extended surface area passive strainers in RFO #11. In addition, we are evaluating the potential of modifying susceptible insulation. Our required 180 day response to the Bulletin / Regulatory Guide will provide specific detail.
Progress and Summary of Changes - August 1,1906 - January 31,1997 There are no significant changes to the co. *ments identified or referenced above.
Pilgrim continues to move forward with the ssign and installation of passive, extended surface area ECCS suction strainers in RFO #11 (February 1997). The installation of the new strainers willincrease design margin relatise to the existing li;.onsing basis. The new strainers will be installed per our design change process under 10CFR50.59 since the modification represents a design change improvement with!n our current licensing basis.
This modification may represent Pilgrim Staiton's final resolution of Bulletin 96-03.
This determination will be made when the NRC formally approves either the BWROG Utility Resolution Guide (URG) or the Pilgrim specific design criteria. BECo Letter 97 012, dated February 7,1997, also communicates this intent.
Pilgrim's request for schedule extension, BECo Letter 96-092, remains in place primarily due to the lack of approved generic design criteria relative to Bulletin 96-03 and the uncertainties relative to installation of the strainers in the suppression pool during RFO #11. NRC response to this request has not been received.
Page 25 of 34
\
ATTACHMENT 2 4
SCHEDULE B l Progress and Summarv of Changes February 1,1997 July 31,1997 New ECCS suction strainers were installed during RFO #11. Engineering is working on its analysis of the new t, trainers in accordance with Bulletin 96 03.
1 Frogless and Summary of Changes - August 1,1997 January 31,1998 An AutoCad 3D drywell model has been developed for use in the LOCA debris i generation and transport analysis. Bids have been solicited to obtain proposals for a debris generation / transport analysis as well as a strainer head loss analysis specific to Pilgrim. This work is to be done in conformance with RG 1,82, Rev. 2, and the BWROG URG including NRC SER Review Comments. Analysis work is expected to be completed by the end of 1998. However, there are related issues such as the GL on Coatings and GL97 04 on NPSH, which may affect Pilgrim's final Bulletin 96 03 Analysis and NRC submittal.
I t
Page 26 of 34
ATTACHMENT 2 SCHEDULE B l TECHNICAL SPECIFICATION CONVERSION PROJECT (LTP #706)
Commitment Description '
We committed to convert the current customized Pilgrim Station Technical Specifications to the NUREG-1433
- Standard Technical Specifications, General Electric Plants BWR/4", also known as improved Standard Technica' Specifications (ITS). This conversion is contingent upon agreement with the NRC that ITS requirements deleterious to Pilgrim Station and are outside the current license basis will not be incorporated in the converted Technical Specifications. This project, to the extent practical, willincorporate approved revisions to NUREG 1433.
The conversion project is expected to be complete and submitted to the NRC in the third quarter 1998.
(BECo IADB RC 96.0052)
References
- 1) NUREG 1433 " Standard Technical Specifications, General Electric Plante BWR/4" Commitment History /Proaress Progress and Summary of Changes - February 1,1996 - July 31,1998 The project team is being assembled and will consist of representatives from Operations, Operations Support, Regulatory Affairs, Engineering, and Training. It is expected that an administrative Technical Specification amendment request will be submitted in early 1997. This request will convert sections 4,5, and 6 to the standard format and content. The second and final submittalis scheduled for third quarter 1998.
Progress and Summary of Changes - August 1,1996 - January 1,1997 The project team has been assembled and consists of representatives from Operations, Operatioris Support, Regulatory Affairs, Engineering and Train:ng. It is expected that an ac'ministrative Technical Specification Amendment request will be submitted early in the second quarter of 1997. This request will convert sections 4,5, and 6 to the standard format and content. The second and final submittalis scheduled for first quarter 1998.
Progress and Summary of Changes - February 1,1997 - July 31,1997 The administrative Technical Specification amendment request will be submitted in September 1997. We are re-evaluating our schedule for the final submittal.
Page 27 of 34
.L -
ATTACHMENT 2
\
SCHEDULE B i
Progress and Summary of Changes August 31,1997 January 31,1998 The schedule has been revised to integrate this activity with the Design Basis Documentation effort committed to in our response to the 10CFR 50.54(f) RAI regarding Adequacy sad Availability of Design Basis Information. Submittal of the Technical Specification conversion amendment is planned for March 2000.
J Page 28 of 34
ATTACHMENT 2 SCHEDULE B BORAFLEX DEGRADATION IN SPENT FUEL POOLS (GL 96-04) (LTP #707)
Commitment Descrictl2B Generic Letter 96-04 (Reference 1, NRC Lttter dated June 26,1996,1.96.107) required utilities / licensees using Boraflex as a neutron absorber in spent fuel storage racks to provide a response within 120 days that: (1) assesses the capability of the Boraflex to maintain a 5 percent subcriticality margin, and (2) submits to the NRC a plan describing its proposed actions to provide assurance that the 5% suberiticality margin continues to be maintained in the future.
Boston Edison requested an extension to December 18,1996_(Reference 2, BECo Letter dated September 2,1996,2.96.107) to allow blackness testing to be conducted and an assessment of the test results, in Reference 3, Boston Edison committed to the following:
- Pertinent Boraflex analysis information concerning the >5% suberiticality margin will be incorporated into the UFSAR.
- Another blackness test of selected Boraflex cell panels will be conducted in 1998.
- The post 1998 schedule for direct material surveillance will be determined using the 1996 and 1998 blackness testing data and will consider spent fuel pool silica data.
(BECo iADB RC 96.0031)
Battrences
- 1) NRC Letter dated June 26,1996,1.96.107, Generic Letter 96-04, "Boraflex Degradation in Spent Fuel Pools".
- 2) BECo Letter dated September 23,1996,2.96.084, Request for Extension.
- 3) BECo Letter dated December 18,1996,2.96.107, Response to GL 06-04.
Commitment HistorvlProeress Progress and Summary of Changes - August 1,1990 - Jan'Jary 1,1997 Boston Edison performed a bicckness test of the Boraflex materialin its spent fuel pool racks; expected shrinkage of the Boraflex was observed. Re analysis of the spent fuel pool suberiticality was also performed assuming degradation of the Boraflex that far exceeded the level observed in the most recent tests; the analyset confirmed Pilgrim's margin to criticality is greater than the minimum required of SE Page 29 of 34
ATTACHMENT 2 l 0 SCHEDULE B Progress and Summary of Changes February 1,1997 July 31,1997.
We moved iuol in the spent fuel pool for blackness testing in 1998.
Progress and Summary of Changes August 1,1997 JanuLry 31,1998 Pertinent Botaflex analysis information concerning the >5% subcriticality margin was iricorporated into the UFSAR in Rev. 21 October 1997. Blackness testing will be conducted during the last quarter of 1998.
Page 30 of 34
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ATTACHMEN i 2 m SCHEDULE B M
ASSURANCE OF EQUIPMENT OPERABILITY AND INTEGR!TY DURING DESIGN-BASIS L '
ACCIDENT CONDlilONS (GL 96-06) s Commitment Description f
7 Generic Letter 96-06 (GL) (Ref.1) requested licensees to determine the susceptibility of their facility containment air cooler water systems to either water hammer or two-phase flow cona,(ions during pes'ulated accident co.iditions, determine the susceptibility of piping systems that penetrate the containment to thermal expansion of fluid and over pressurization, and assess the operability of Mfected systems and take corrective actir appropriate, to satisfy system design and operability requirements. Licensees were 3 requested to submit c written report within 120 days of the GL issuance.
i Boston Edison responded to Generic Letter 96-r3 in Reference 2, BECc Letter 97-06, datud January 28,1997.
L The reactor build;ng closed cooling water (RBCCW) system loop B prus des the cooling water for the containment air coolers. The containment air coolers at Pilgrim Station do not perform any active sa'ctf-related funcuon in response to any postulated design basis accidents. An evaluation of the RBCCW system inside cc itainment subject to heating during design basis icss-of coolant accidents was conducted and concluded the system is not susceptible to water hammer or two-phase flow. The system is operable and corrective actions are not required.
A review of drywell penetration piping was performed to determine the susceptibility of each line to thermal expansion of fluid such that the: mal pressurization of the !ine could occur.
As a result, Po,eton Edison committed to the following:
Add PSV-4033 to the IST program and test or iepWe with a new iciief valve during r RFO #11, Open Valves 14GO-64A and 1400-63A during 'RFO #11 to prevent build-up of pressure in the line. (Complete)
Aod a pressu 1 relieving device to the drywell ficar ard drywell equipment sumps dicharge lines ensuring pressure bu!'d-8.g due to lD'id thermai expansion is limited.
(Complete)
(BECo IADB RC 97.0002)
Referen :es
- 1) MRC Letter dated September 30,1996,1.96.143, GL 96-Oo, " Assurance of Equipment 3 Operability and Containment Integrity During Design-Basis Accident Condition."
i
- 2) BECo Letter dated January 28,1997,2.97.006, "120-Day Response to GL 96-06."
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ATTACHMENT 2 SCHEDU.l& R 4
- Commitment Historv/Proaress Progress and Summary of Changes - August 1,1996 - January 31,1997.
The committed actions are scheduled for implementation dusing RFO #11.
Progress and Summary of Changes - Februanj 1,1997 - July 31,1997 During RFO #11, the following action were completed:
. RBCCW valve PSV-4033 was replaced with a new relief valve.
1 Core Spray valves 1400-64A and 1400-63A were opened.
In lieu of adding a pressure relieving device to the dryweli floor and dryws I equipment sump pump discharge li.,es, a hole was drilled in a pump discharge check valve in each line to preclude pressure build-up due to fluid thermal expansion.
The inclusion of PSV-4033 into tiie IST program is in progress. The valve has been included in the IST program revision that is in the approval process and should be issued by St9tember 30,1997.
Progress and Summary of Changes - August 1,1997 - Janu ary 31,19,3 PSV-4033 was incorporated in the IST program, procedure 8.l.1.1. This LTP item is complete and will be removed from future updates.
9 Pay 32 of 34
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ATTACHMENT 2 SCHEDULE B 10 CFR 50.54 (f) RAI REGARDING ADEQUACY AND AVAILABILITY OF DESIGN BASES INFORMATION Commitment
Description:
' In response to the NRC's request for information about the adegacy and availability of design bases information (Reference 1), Pilgrim Station responded on February 10,1997, s (Reference 2). On June 24,1997, (Reference 3), we supplemented this response to '
provide the preliminary scope of our evaluation of the UFSAR as committeo in the Reference 1 resconse. An additional supplementa: response (Reference 4) was sJbmitted which affirmed design bases information activities to be undertaken at Pilgrim, as detailed in an enforcement conference at Region 1 Headquarters on November 21,1997.
Elements of the planned activities include:
Recover as design bases documents, the design and licensing bases for Pilgrim Station. Complete by December 31,2001. (RC 97.0018.2C)
Retrievc and review the licensing correspondence docket file and identify UFSAR discrepancies or omissions. Complete by December 31,1998. (RC 97,0018.21) 1 .
Update the UFSAR as appropriate as each design basis document is co,1pleted.
[ .
(RC 07.0018.22)
Update the status of this effort with a letter and/or presenta' ion to the NRC by March 31,1998. (RC 97.0018.24, RC 97.0018.25)
Update the Standard Technical Specification conversion project r 'hedu!e in accordance with the committed design and licensing bases documentation efforts.
(RC 97.0018.23)
The objectives of the above activities are to organize, verify, and validate the Pilgrim design basis document information as apprcpriate, ensure plant procedures contain complete and accurate design information, and create a living document supported by a sound document r
maintenance program.
E System design basis documents (DBDs) will be created for specified systems containing a consolidated summary of design basis values with explanations of the basis and relationship to design functions. The D8D will also provide the list of supporting references.
Special DBDs will be developed for topical areas not associated with a specific system such
- as the accident analysis, radiological, and equipment qualification. The Special DBDs will state the design and licensing basis and explain the inputs, assumptions, and evaluations used to address the topical Jue for Pilgrim Station. The overall scope includes system level documents and topical reports. System and topical reviews are prioritized based on risk significance in accordance with our Maintenance Rule program and IPE studies.
?
Pege 33 of 34
ATTACHMENT 2
, SCHEDULEB
References:
- 1) NRC letter dated October 9,1996 Request for Information Pursuant to 10 CFR 50.54(f)
Regarding Adequacy and Availability of Design Bases infom'ation.
- 2) BECo letter 2.97-014, dated February 10,1997, Response to NRC 50.54(f) Letter s Regarding Adequacy and Availability of Design Bases Information.
- 3) BECo letter 2.97-067, dated June 24,1997, Follow-up Response to NRC 50.54(f) Letter Regarding Adequacy and Availabi!Ry of Design Bases Information.
- 4) BECo letter 2.97.128, dated December 8,1997, Supplemental Response to NRC 50.54(f) Letter Regarding Adequacy and Availab!:ity of Design Bases Information.
Commitment History /Proaress Progress and Summary of Changes - August 1,1997 - January 31,1998 A DBD program pian has been developed and is currently being finalized. The plan describes the work scope, priorities, processes, and responsibilities of the participating organizations and individuals A presentation is planned at Region 1 Headquarters for March 10,1998, to provide the latest status and proj~.t scope.
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l Page 34 of 34
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ATTACHMENT 3 .
z Page 1 of 2 I
LTP SCHEDULE C ITEMS
- LTP No. Ti'le February 1998 Target Schedule Comme?_,s 108 Setpoint Calculation Project 1998 No Change 486 Intake Canal Dredging Complete. Phase I was approximately
, c yads aM nas Bathymetic (bottom) survey schedoled for been completed. Phase 2 spring / summer 1998. .
is approximately 40,000 Phase 2: 1999 cubic yards.
t 524 Replace Simplex Panels 1998 Revising SJA to make adequate spares ava'able.
546 Instrument Recirc. Pump Shaft RFO #'2 No Change 590 Turbine Building Effluent Monitoring October 1998 Training to be completed once monitors are retumed to service.
621 3D Monicore - Simulator Upgrade 1998 On - Schedule 628 Emergency Preparedness Facility Upgrade 1998 On - Uchedt fe
{
- This list represents a portion of major plant betterments at Pilgrim Station. The total LTP contains additional plant betterments, programs / projects, and issues.
KRD/dmc/LTP/1.TP97-A3
.m .
e n ,,
ATTACHMENT 3 .
- Page 2 of 2 LTP SCHEDULE C ITEMS
- LTP No. Title February 1998 Taroet Schedule Commen's 646 Gaitronics Mods On-hold 684 Augmented Offgas System Upgrade RFO #12 AOG system upgrade installed during RFO #11.
p Testing for PDC 95-08 will be done in RFO #12 under MR19403940.
687 EPIC Upgrade Complete 689 Simulator Core Model Upgrade 1998 No Changa 690 Electronic imaging 1998 System is in acceptance testing and validation for the distribution cf plant procedures.
691 Plant Material Condition Upgrade Ongoing - to be completed in 2000 Project to continue through 1998 with limited scope.
700 Personnel Contamination Monitor Upgrade Cancelled 722 Cher.lical Decontamination Project 1998 No Change
- This list represents a portion of major plant betterments at Pilgrim Station. The total LTP contains additional plant betterments, prcgrams/ projects, and issues.
KRD/dmc/LTP/LTP97-A3
-