ML20245C294

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Discusses Current Status of Rusty Drywell Spray Header Nozzles Issue.Spray Headers cut,hydro-lazed,inspected & Header Integrity Restored
ML20245C294
Person / Time
Site: Pilgrim
Issue date: 09/24/1987
From: Wessman R
NRC
To: Nerses V
NRC
Shared Package
ML20244D847 List:
References
FOIA-88-198 NUDOCS 8904270096
Download: ML20245C294 (12)


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.t hi t e io: V. tJor x c t, F r c.m : R ., ucr z a.c o Sub 3: F t l5T lit PILGFlti DRYWELL SPRAV HF(iDFP t!O!JLES. , ,

Rnf: .Rcquest From F. l1i rag] 2 a, dated'G/16/87 C ore a t ern perte2.uog +o P 2 i cir i m is idrntifiod ioF.

[13 r aq ) 1.' 'c nomo of 9/16/87. It concerns the runt found an the drywell nor:1c's tri June 1967 Basod on a 9/&B/87 conversat2on w2th T. J. Mam, rnandeo+.

Inspector, the curreist status of the rusty nr.:::I ns issuc et P21 gram it as fo))ois:

-BECo has evaluated the cause of the rust and at tribu tod i- t to cycling of containment inboard and outhoard valves rtu r i ng vtrious tests. This al low'd the. introduction of wat er own tie. Based or, EECo no::}e tests, the ut i 13 ty conc luriced i

'that the spray s yste.n w+s never rendered inoper ab1r by thr pensonce of rust; consequently no LFR has been subn.itird.

Thr a t t ac hc'd sun.ncr y , from BECo. sunime r i, rs the analytic of-operability.

-The spray headers havc bron cut , hyd"o-lared, ii sspec t ed ,

and headPr integrity has becin restored.

-Noe no::les, with modified spray pottorn as drsrribrd io the Pilgrim Safety Enhancement Progeam ( S!:P ) submi. t t a1 <'1 July 8, 1987, arc installed on the drywn11 spre.<y hnadro s. .

(The torus spray header was.found to be fret af rust and thn

' SEP Progr am did not spricif y tha'tXthe no::10sNecto-br i .

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-BECo has instelled headrr 'dr ain"plitos to a))ow di aini ori t-t ic spray header after isolation, valvc cycl.ing r to pror.lude. nny

' - buildup.of water and reducrWthe" potential' off rue,t i nr!. .

-The Region will evaluate the. BEco r.or er.ic tive act ion and document their findings in an insprction report. 7 tu t is enpected in the nent tuo months.

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M OFFICE HEMORAN00F, Boston Edison Company To: K. P. Roberts From: . .Swanho Record Type A4.08 Date: June 23, 1987 Dept. Doc. NED 87 607 Safety Related

Subject:

Containment Spray Operability -

. Distribution:

R. V. Fairbank S. Hudson P. T. Antonopoulos C. Minott J. L. Rogers P.-E. Mastrangelo R. E. Grazio' J. D. Keyes M. Clancy M. N. Brosee D. Heard G. V. M11eris J. A. Seery S&SA 87-79 D. Ger11ts .

Conclusion An analysis of the drywell spray subsystem of the Residual Heat Removal system has been performed, considering the presence of rust as found and documented in Failure and Malfunction Report 87-365. The Nuclear Engineering Department has determined that the drywell spray subsystem was operable.

A more detailed report, outlining the details of the investigation performed, will follow. This memorandum transmits the essential details which support  !

the recommendation of operability. .

Basis During the replacement of the drywell' spray . caps, rust flakes were found in a large number of the drywell ' spray caps in the upper spray header. For the s purposes of this meno, the term " nozzle" will refer to the single, orificed

- opening, and the term " cap" will refer to the seven nozzle assemblies that were being replaced. Based on interviews with the pipefitters who actually removed the caps, the amount of rust particles found varied widely from cap to cap. The variance was from none (" clean") to " rust filling the cap and halfway up the threads".

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A boroscopic inspection ca the upper spray ring header revealed a" layer of loose rust flakes, approximately 1/2 inch deep. in the bottom of the header.

The rust particles in the header ranged between 1/4 inch and 1/16 inch in length. W

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Sixty-four of the spray caps in the lower header were removed, end rust flakes were present in these spray heads. A boroscopic inspection of the lower spray ,

header was performed, and a thin 1syer of loose rust (approximately two rust flake layers thick) was found in the lower spray header.

D'oc. No. NED 87 607

.l To: K. P. Roberts Page 2 Subiect: Containment Sorav Operability The Final Safety Analysis Report, in section 5.2.3.2 entitled "Drywell" states that a single activation of one of the two drywell sprays any time before the drywell wall temperature reaches its design temperature of 281 degrees F would be effective in terminating the temperature rise associated with small steam line breaks inside containment. The recent GE analysis " Impact on Containment Pressure / Temperature Response of Proposed Capping of Certain Drywell Spay Sparger Mozzles" (G.E. Report No. EAS-52-0287 Rev. 1. SUDDS No.87-825)

' states that, "This analysis has determined that a drywell spray flow rate of 300 gpm is sufficient to limit the response of containment pressures and temperatures to below their respective design limit.". (The analysis assumed a 1 mm droplet size.)

The drywell spray subsystem is designed with two independent spray headers.

Either spray header is capable of delivering the required spray flow. The worst case single failure in the present case would be a failure of either MOV 1001-238 or MOV 1001-268 which would render the lower spray header inoperable, resulting in the need to use the, upper, more obstructed header.

Each spray header is designed to deliver 5000 gpe, with atomization, through the 104 spray caps attached to the header. In order to deliver the 300 gpm required for operability, only six percent of the spray caps (300/5000 .06), approximately 7 of the spray caps (or 44 spray nozzles),

would be required to pass full flow with atomization.

At least fifteen of the spray caps were found which would pass rated flow.

The amount of dry loose rust found in 5 of these fifteen caps was "none".

This would result in 35 (7 x 5) of the required 44 spray nozzles being functional. The amount in the other 10 was "just enough to fill the end hole", i.e., only enough to sit in the depression around the center spray nozzle. Since the rust in the spray caps was dry and loose, flow would be expected to occur in the 6 spray nozzles that did not have rust particles in them, and could occur in the spray nozzles that had rust particles present.

This is because once flow is established through each spray nozzle, clearing of the spray nozzle by the action of the impeller inside can occur. This clearing action was confirmed by on site testing, using a spray cap and rust particles from the upper spray header.

This results in a minimum of 95 nozzles being capable of full flow and atomization. A flow rate of this magnitude results in thefrequired flow and Lat least a hundred percent margin.

The loose rust in the bottom of the upper header could be entrained and carried to the spray heads as soon as flow was initiated. . This rust would be carried to the nozzles delivering flow. But once flow is established through a spray nozzle, discussion with the manufacturer and actual test' data indicated that the spinning action of the internal impeller helps to break up any incoming rust particles, and would help to ensure that proper flow through the spray nozzle will continue. Since the amount of rust indicated to be ,

present in the upper spray header was small in comparison to tha total volume of the header, the turbulent ' action of the water filling the header would tend {

to break up and entrain the rust particles as flow is initiated. This '

turbulent action would tend to deliver a dynamic, swirling, low rust density flow stream to each of the operating heads. It is unlikely that the operating spray heads would become saturated and clogged with rust particles.

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containment sorav coerability Page 3 Given the extent of the rust present in the uppe heads in the upper spray ring header take place. and that thereas e delivered by the spray required atomization would delivered with atomization,quired been operable. theflow drywell could be spray subTh system is considered to have DHG:1ar e

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-4 c Pilgrim - Activities Update - 09/30/87 On September 29, 1987, the licensee commenced core reload. As of September 30, 1987, eight bundles have moved into the reactor vessel. Region I is providing augmented inspection coverage.

BECo met with HQ management and the Region I Regional Administrator on September 24, 1987 to discuss facility status, emergency preparedness, major plant modifications, and their restart plan. (On the morning of September 24, BECo met with FEMA (R. Krimm) to discuss offsite emergency planning activities. NRC representatives attended as observers.) Significant matters discussed between NRC and BEco were:

-The BECo schedule is not firm but the utility expects the facility to be ready for restart in about two months.

-BECo has aggressively worked with State and local governments to develop off-site plans that are responsive to FEMA concerns. State-approved-plans are not expected to be available for FEMA review until 12/31/87.

BECo has requested an exemption from the required biennial exercise (due by12/31/87) until Spring 1988.

-The staff is requesting BEco submit recent revisions to their emergency procedures and procedures generation program (PGP) which are written to Revision 4 of the Emergency Procedure Guidelines (EPGs). (Revision 4 of the EPGs is not yet approved by the staff.) Staff review of the licensee's submittal may take about 2 months and needs to be completed prior to restart.

-Appendices to the BECo Restart Plan have not yet been provided, but are expected in about two weeks.

Region I met with BEco on 9/30/87 to discuss the licensee's corrective actions in response to recent security noncompliance issues.

Region I is planning an October 8, 1987 meeting with representatives of the State of Massachusetts. Tentative items for discussion include State participation in certain aspects of NRC inspections and State actions regarding off-site emergency preparedness issues.

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8, 1 OCTOBER 1987 OVERVIEW REPORT PLANT NAME: PILGRIM PROJECT MANAGER: R. H. WESSMAN j MONTHLY OPERATIONAL OVERVIEW FOR OCTOBER 1987 The plant continues to be down for an extended outage for refueling, resolbtion of eouipment and operational difficulties, management issues and emergency planning concerns Core reload completed 10/14/87 Restart readiness expected late December.

Monthly Licensing Action Summary:

TRIP 5 THIS 110 NTH 0 TRIPS LAST 12 MONTHS 0 NUMBER OF REPORTABLE I N 0 LICENSING ACTIONS TYPE CATEGORY 1 CAFEGORY 2 CATEGORY 3 TOTAL Licensing Actions Opened in 10/87 0 0 0 2 (Projected Categories)

Licensing Actions Closed in 10/87 0 0 0 5 Licensing Actions in Progress 0 0 0 43 (Sept.31 1987)

Licensing Actions Returned (Cat 1) in 10/87 0 For Applications received prior to 9/4/87 s .

Number under review by PM 0 Number reviewed and completed by PM 1 SIGNIFICANT ISSUES AND EVENTS Significant Activities During October 1987 In response to the Town Selectmen's request, the NRC attended a public meeting in Duxbury, MA on October 29, 1987 to respond to public questions regarding Pilgrim. (Staff participants included S. Collins, R. Bellamy and J. Wiggins of Region I and B. Boger of NRR). Comonw*alth and BEco representatives, State

. Senator Golden, Citizens Urging Responsible Energy (CURE), and other local officials also participated. The general tone of the meeting reflected opposition te plant restart until safety and emergency planning issues are resolved.

On October 15, 1987, the Massachusetts Attorney General James M. Shannon and Governor Dukakis jointly filed a 10 CFR 2.206 petition with the NRC requesting an order to show cacse why the Pilgrim Nuclear Power Plant should not remain closed until a full adjudicatory hearing resolves the issues identified in the petition. The request cites evidence of continuing managerial deficiencies, questions surrounding the GE Mark I containment and need for PRA, and deficiencies in the evacuation plans for the area. The petition also requests that, pending further review, the Boston Edison Company be prevented from proceeding any further with the restart of Pilgrim.

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On October 27, 1987 NRC filed a Motion to Dismiss State Senator Golden's e Appeal of October 1, 1987. (Senator Golden's Appeal requested NRC to suspend l Pilgrim's operating license until safety and emergency planning concerns are i resolved). The NRC Motion, filed in the U.S. Court of Appeals, 1st Circuit, is based on grounds that the Court lacks jurisdiction on the NRC refusal to 1 take enforcement action (i.e. The Director's Decision of August 21, 1987 in i Response to Senator Golden's 2.206 Petition of July 15, 1986). OGC will also )

file within a few days a Motion to Dismiss the Commonwealth of Massachusetts' Motion for Leave to Intervene in Senator Golden's Appeal.

On October 8, 1987, Region I and NRR met with representatives of the Commonwealth of Massachusetts, at the Commonwealth's request. Attendees included Peter Agnas (Asst. Secretary, Dept. of Public Safety), John Judge (Governor's staff assistant), Larry Alexander (State Representative), and two citizens from Duxbury. Massachusetts pressed the staff to commit to a public hearing prior to a restart decision and sought a comitment for the conduct of an offsite emergency preparedness exercise prior to restart. Although the Commonwealth stated that they are working on developing offsite emeraency preparedness plans that are responsive to the FEMA findinas, they indicated nn several occasions that there was some doubt regarding the capability to devise a safe plan.

Commissioner Bernthal visited Pilgrim on October 5, 1987. He was particularly interested in the Director Torus Vent System (DTVS) and appears to be in favor of this scheme of containmen: venting. He also appeared generally impressed with BECo progress in such areas as decontamination, management improvements, and plant enhancements.

A major segment of inspection activity was completed the week ending Octobar 9, 1987. A 8-man team, supported by the Region I mobile laboratory, inspected health physics, radiochemistry, environmental monitoring and radwaste handling activities. The licensee's current programs appear to be generally satisfactory.

Events No significant events Significant Meetings Scheduled Durino November 1987 (NRR, Region, etc.)

None Items for Management Attention BEco is preparing for the ILRT to be conducted in late November. BECo desires completion of Appendix J technical specification changes prior to the test; however completion of NRR review and issuance of the amendment may not meet this target. (The ILRT could still be conducted without the amendment but there would be minor uncertainties regarding the ILRT boundary due to several i valves involved in the amendment).

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Status or Items Previously Identified for Management Attention G. Requa, Pro.iect Engineer from FDII-I, has been loaned to the Pilgrim Project team for 6-8 weeks to assist with the licensing workload.

Owen Gormley is detailed back from Nuclear Regulatory Research for the month of Novenber to assist on Pilgrim tasks.

Next Scheduled Refueling Outage February 1989 cc: RouWessese PDI-3 R/F M. Rushbrook V. Rooney E. Adensam J. Wilson, Research I

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Pilgrim - Activities Update - 10/7/87 Core reload continues; as of October 6,1987 about 150 fuel bundles (out of 580) have been loaded. Region I continues to monitor refueling activities.

Commissioner Bernthal visited Pilgrim on October 5,1987 He was particularly interested in the Direct Torus Vent System (DTVS) and appears to be in favor of this scheme of containment venting. He also appeared generally impressed wit' BECo progress in such areas as decontamination, management improvements, and plant enhancements.

On October 1,1987, State Senator William Golden and others filed an appeal in the First U.S. Court of Appeals, requesting NRC suspend Pilgrim's operating license until safety and emergency planning concerns are resolved. 0GC has lead for NRC actions.

Staff is preparing responses to two letters from Congressman Gerry Studds,

1. (letter of 9/17/87, reouesting Hearing) - Staff opposes hearing, acknowledges various other public meetings (previous and planned),

and is suggesting a Commission Meeting that would allow public statements (0GC lead).

2. (letter of 9/18/87, requesting environmental assessment and deferral of containment vent) - Staff provides basis for not perfuming environmental assessment before restart (10 CFR 51.10(d)1 and states that containment venting will not be allowed by BEco pending full evaluation by NRC. (NRR Lead)

Region I is planning an October 8, lo87 meeting with State of Massachusetts at State's request. The public meeting will be attended by BECo. Citizens Urging Responsible Energy (CURE), et al. Issues to be discussed including emergency planning matters, BECo, SEP, and State involvement in certain aspects of NRC inspections.

NRC has been invited to attend a public meeting hosted by Duxbury Board of Selectmen on October 29, 1987, to discuss Pilgrim restart issues. BECo, State and othar local entities are also invited.

A total of 15 inspection personnel (including residents and 1 NRR participant) are on site this week. A major inspection activity involves health, physics, and radiological control items. Other inspections involve refueling; ILRT planning; hydrogen water chemistry; and procurement, receipt and storage activities.

Restart Panel will meet in Region I on October 8,1987

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-e pilorim - Astivitie's Update - 10/14/87 s

Core reload continues; as of October 14,1987 about 560 fuel bundles (out of M*

580) have been leaded. Reload should be completed by Detober 15, 1987. The Resident Inspectors view the licensee's approach during refueling as generally conservative and deliberate and that minor problems encountered during I refueling were properly identified and resolved in a satisfactory manner.

l On October 8,1987, Region I and NRR met with representatives of the Commonwealth of Massachusetts, at the Commonwealth's request. Attendees included Peter Agnes (Asst. Secutary, Dept. of Public Safety), John Judge (Governor's staff assistant). Larry Alexander (State Representative), and two citizens from Duxbury. Massachusetts pressed the staff to corsnit to a public hearing prior to a restart decision and sought a commitment for the conduct of an offsite emergency preparedness exercise prior to restart. Although the Comenwealth stated that they were working on developing offsite emergency preparedness i plans that are responsive to the FEMA findings, they indicated on several occasions that there was some doubt regarding the capability to devise a safe I plan.

On October 5.1987. Governor Dukakis announced that the new State liaison Officer was Charles V. Berry, the Secretary of Public Safety. Berry is ht expected to closely reflect the Governor's views.

On October 8,1987, the Restart Panel met in Region I to discuss coordination of staff activities regarding Pilgrim. Regional staff were tasked with developing the inspection plan for the Integrtted Assessment Inspection.

Conduct of this inspection is expected in December.

Appendices to the BEco Restart Plan have not yet been provided. Continuing delays in this submittal will delay timely completion of staff review.

NRR issued an exemption to Appendix R requirements on October 6,1987. It allows the licensee to use existing yard security lighting in lieu of installing lighting for certain pathways to safe shutdown equipment.

A major segment of inspection activity was completed the week ending October 9, 1987. An 8-man team, supported by the Region I mobile laboratory, inspected health physics, radiochemistry, environmental monitoring and radweste handling activities. The licensee's current programs appear to be generally satisfactory.

BECo is preparing for the ILRT to be conducted in early November. BEco desires completion of Appendix J technical specification changes prior to the test; however completion of NRR review and issuance of the amendment may not meet this target. (The !LRT could still be conducted without the amendment 1 but there would be uncertainties regarding the ILRT boundary due to several "

valves involved in the amendment).

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