ML20246F974
| ML20246F974 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 08/23/1989 |
| From: | Bird R BOSTON EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 89-126, NUDOCS 8908310187 | |
| Download: ML20246F974 (3) | |
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.osxw a sou Pilgrim Nuclear Power Station Rocky Hill Road -
Plymouth, Massachusetts 02360 Ralph G. Bird
' Seni r Vice President - Nuclea' August 23 1989-BECo Ltr. IF89-126 U.S. Nuclear Regulatory Commission
. Attn: Document Control Desk Hashington, D.C.,
20555-License No. DPR-35 Docket No. 50-293
Subject:
Change of Schedule for Completion of the Pilgrim Nuclear Power
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Plant Drawing Upgrades
References:
BECo Letter.#86-091 to NRC dated July 3, 1986 BECo Letter #87-206 to NRC dated' December 23, 1987
Dear Sir:
This ' letter. provides a status update and revises the expected completion date of' committed actions to resolve Inspector Follow Item 86-06-01.
In July of 1986, we committed to perform walkdowns' of plant systems -to ensure valves were properly labeled and identified on Piping and. Instrumentation Drawings (P& ids)-and in the system operating procedures. This review was to include valves in the system's flow path, vent and drain valves on process piping, and instrument root valves (an instrurnent root valve is defined as the first isolation valve from the process piping to an instrument).
In December of-1987, we further committed to upgrade the P& ids to show design modifications performed during RF0 #7 as well as to correct any major process line changes identified during initial walkdowns. At that time we expected the P&ID upgrade project to be complete 180 days after plant restart.
I 8908310187 890823 PDR ADOCK 05000293 G
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I NPage 2; Subsequently, the process to careful.ly control the P&ID upgrade' work was developed 1and hasl proved to require more time than previously. estimated.
'The P&ID upgrade project involves _(involved) the following steps:
Develop a system to control valve numbering.
System walkdowns to identify valves that-require labeling and annotation of P& ids showing the affected valves. These walkdowns are performed'by plant operators.
-Independent verification walkdowns. by Systems Engineers.
e Preparation of.P&ID revisions.
Preparation and. issuance of Plant Design (uanges (PDCs)to incorporate.
- the P&ID revisions.
Procedure revisions.
Preparation of valve labels and placement on appropriate valves.
Issuance of' final P& ids.
Progress to meet our commitments has been substantial; however, additional work remains.
The current status is as follows:
A Nuclear Engineering Work Instruction to cc r. trol valve numbering has been developed.
The test, vent and drain valve portion of the update is approximately 981, complete (approximately 3000 valves).
'The P& ids have been upgraded to show the design modifications performed during Refuel Outage #7 and the major process line changes identified during initial walkdowns.
To prepare for plant restart, approximately 1000 instrument root valves were identified by walkdowns as being important to operations and maintenance. These valves have been numbered, tagged and are included in operating procedures.
It should be noted that approximately 180 of these instrument root valves associated with measuring reactor vessel, drywell and torus parameters are also shown on the' appropriate P& ids.
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-( ~.The remaining instrument root valves are being addressed on a system basis.
Fifty (50) non-radwaste systems are included in the project scope. System walkdowns by plant operators.are complete for thirty three (33) systems.. Independent verification walkdowns are complete
'for_ twenty two.(22) systems. Two.PDCs (88-20A,88-20B) have been issued for implementation. These PDCs encompass nine (9) systems (Nuclear. Boiler, Control Rod Drive, Post Accident Sampling..
Hydrogen /0xygen Analyzer, Reactor Pressure Boundary Leak Detection, Containment Atmosphere Control, Residual Heat Removal,- High Pressure Coolant Injection and Core Spray). Additional PDCs will be. issued as progress continues.
Project completion including the revised scope is now estimated for September l.
1990. However, to be consistent with Pilgrim's commitment to maintain doses ALARA, root valves that are considered inaccessible and radwaste systems are excluded from the scope of the September.1990 commitment. Certain root valves L
are considered inaccessible based on either high radiation dose rates or. areas that require substantial. staging to access.
In these cases, valve labeling will be accomplished concurrent with some other need to access the valve (s) or general' location (s).
If no need to access the valve (s) or general location (s) arises, the valve (s) may not be tagged. Radwaste system P& ids are excluded from the ~ schedule due to modifications that are expected as part of the Radwaste Betterment long term plan. To minimize redundant efforts and unnecessary personnel radiation. exposure, radwaste system walkdowns and associated valve numbering, labeling and P&ID changes will be coordinated concurrently with the plant modifications.
The P&ID upgrade project will be included in the Long. Term Plan submittal as-a-schedule 'B' item. Subsequent semiannual submittals of.the Long Term. Plan will provide project status.
Please do not hesitate to contact me directly if you have any questions.
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p R. G. Bird cc:
Mr. William Russell Regional Administrator, Region I U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Sr. NRC Resident Inspector - Pilgrim Station
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