ML20154P959

Advises That Commonwealth of Ma Was Provided Opportunity to Review & Provide Input to Insp Scope of Recent Integrated Assessment Team Insp of Plant.Responses to Specific Issues Encl

ML20154P959
Person / Time
Site:	Pilgrim
Issue date:	09/26/1988
From:	Collins S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	Agnes P MASSACHUSETTS, COMMONWEALTH OF
References
IEB-88-005, IEB-88-5, IEIN-88-046, IEIN-88-048, IEIN-88-46, IEIN-88-48, NUDOCS 8810030245
Download: ML20154P959 (7)

Text

8EP 261988 Commonwealth of Massachusetts Executive Office of Public Safety ATTN: Mr. Peter W. Agnes, Jr.

Assistant Secretary One Ashburton Place Boston,. Massachusetts 02108

Dear Mr. Agnes:

This letter is in reply to your letters dated September 6,1588, which contain certain technical issues regarding the Pilgrim Nuclear Power Station.- Your letters request discussion on the issues before the final staff recommendation '

is made concerning the Pilgrim restart.

Again, I would emphasize that the Commonwealth was provided the opportunity,

, at its own request, to review and provide input to the inspection scope of the recently completed Integrated Assessment Team Inspection (IATI). The purpose of that request on July 13, 1988, was to ensure that the Commonwealth's con-cerns and technical questions were included for review within the IATI, and to provide for efficient dispositioning of the issues during the course of the inspection. Subsequently, the Commonwealth has forwarded to the NRC issues contained in your letters of September 6,1988 and those contained in the September 9, 1988 letter from Representative Lawrence R. Alexander. In ,

responding to the issues raised, I have assumed that the documents previously provided to the Commonwealth's State liaison Officer, will remain available for reference.

In regards to the issues contained in your letters, Attachments A and 8 to this letter contain specific responses to those issues which are under NRC review.

1 As you are well aware, the NRC is not accountable for those opinions expressed by the media as contained in the attachments to your September 6,1988 letter.  ;

If you have questions regarding the above matters, please contact me at (215) 337-5126 or the State Liaison Officer for Region I, Ms. Marie Miller at i

(215) 337-5246. '

Sincerely, 5NY Samuel J. Collins, Deputy Director

, Division of Reactor Projects i Attachments:

As stated j OFFICIAL RECORD COPY COLLINS 344 9/22/88 - 0001.0.0 i g' ?

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g PDR ADOCK 05000293 PDC ' J C /)-/ /

Peter W. Agnes :2 SEP 261988 cc w/ Attachments:

R. Bird, Senior Vice President - Nuclear K. Highfill, Station Director R. Anderson, Plant Manager J. Keyes, Licensing Division Manager E. Robinson, Nuclear Information Manager R. Swanson, Nuclear Engineering Department Manager The Honorable Edward J. Markey The Honorable Edward P. Kirby The Honorable Peter V. Forman The Honorable Lawrence R. Alexander '

B. McIntyre, Chairman, Department of Public Utilities Chairman, Plymouth Board of Selectmen Chairman, Duxbury Board of Selectmen Plymouth Civil Defense Director S. Pollard, Massachusetts Secretary of Energy Resources R. Shimshak, MASSPIRG Public Document Room (PDR)

Local Public Document Room (LPDR)

Nuclear Safety Information Center (NSIC)

NRC Resident Inspector Commonwealth of Massachusetts (2) bec w/ Attachments:

Region I Docket Room (with concurrences)

W. Russell, RI R. Bellamy, RI J. Wiggins, RI R. Blough, RI L. Doerflein, RI M. Kohl, RI R. Bores, RI R. Wessman, NRR D. Mcdonald, NRR RI:DRP RI:DPR :DRP RBlough/mjd JWiggins S lins 9/d/88 9h/88 9ep/88 0FFICIAL RECORD COPY COLLINS 344 9/22/88 - 0002.0.0 1 09/22/88

ATTACHMENT A

Reference:

Integrated Assessment Team Inspection Letter of September 6,1988 Item 1: Recommendation by Mr. Sholly that, in view of the difficulty in one case with implementation of a satellite E0P, there should be an effort to validate all new plant procedures before restart.

Discussion: Inspection Report 50-293/88-21, dated September 7, 1988 documents this issue in Section 3.2.4. Licensee Commitment 2.4.1 identifies required Boston Edison Company action to be reviewed by the NRC prior to any restart of the plant.

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1 ATTACHMENT B

Reference:

Technical Issues Latter of September 6, 1988 Item 1: Status of Various NRC Open Items 87-22-01: This item was updated in NRC Inspection Report (IR) 50-293/88-19. Based on that inspection it was determined that the licensee's development of an Appendix R design bases document is on schedule.

87-26-02: This item is being closed in IR 50-293/88-31 based on IATI inspection.

87-30-01, 87-30-02, 87-50-02: Th Me items were inspected and the results documented in IR 50-293/88-16. Technical closure is completed.

87-50-08: This item was reviewed and closed as a result of the IATI.

87-50-07, 87-53-03, 88-07-01, 88-07-02, 88-07-03, 88-08-02: All of these items have been inspected and are either closed or being closed in irs, 50-293/88-21, 88-27, 88-31 or 88-32.

Item 2: Safety Enhancement Program Effects and Review The modifications performed by Boston Edison were performed under the provisions of 10 CFR 50.59. NRC chose to review the licensee's 50.59 analyses for the SEP modifications as well as some of the design documents. The results of these reviews have previously been forwarded to the Commonwealth of Massachusetts.

The licensee analyzed the effects of SEP on plant accidents using two methodologies, (Individual Plant Assessment and Probabalistic Safety Assessment) and determined both methods confirmed that SEP was beneficial.

Item 3: Questions Regarding an NRC Program to Guard Against the Effects of Aging The original design objectives for the Pilgrim Station included consideration of the forty year minimum required life of plant structures and equipment. Plant systems were designed to meet this objective. As part of the licensing process the NRC staff reviewed the licensee's site specific design and concluded that it would support the safe operation of the facility over the proposed forty year life. Based on this conclusion the Commission issued an Operating License authorizing operation of the facility, in accordance with the provisions of the license, until August 26, 2008.

OFFICIAL RECORD COFY COLLINS 344 9/22/88 - 0004.0.0 '

09/23/88

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Attachment B 2 The facility Technical Specifications (TS), a part of the Operating License, establish limits within which the plant must operate. They also establish minimum equipment inspection, testing and performance requirements. This ensures that the assumptions made in the original design and construction of the facility are maintained throughout the plant operating life. For example, the reactor pressure vessel was designed for a forty year life. Implicit in this design is an assumption of the expected cumulative radiation exposure and its effect on the material properties of the vessel. Operating limits were included in the Technical Specifications which account for the potential materials behavior change during plant life. In order to assure the accuracy of the assumed relacionship, the original design included the location of removable material samples at locations in the vessel. Technical Specifications require removal, testing and comparison of these samples against the expected condition at

specific intervals.

Establishment of a routine surveillance program and an effective maintenance program ensures that any degraded condition is identified and repaired. The effectiveness of these programs is the subject of routine inspection.

The NRC Office of Nuclear Regulatory Reseat ch is currently implemen-ting an extensive program to evaluate the causes and effects of aging on important plant equipment. Expenditures on this program are expected to total one million dollars this year and 55 million dollars over the next six years. The goal of the program is to identify the significant problem contributors, to develop effective preventive, predictive and surveillance techniques, and to factor these findings as appropriate into regulatory actions and the NRC inspection program.

In summary, the plant as designed and licensed can be operated safely provided that it is surveilled anJ maintained in accordance with the Operating License. However the NRC is implementing an ongoing effort to better understand and deal with the potential impact of plant aging.

Item 4: a) Systematic Analysis by the NRC Staff of Licensee Event heports (LER)

The individual events which ultimately result in the generation of LERs as well as the written reports thmselves are routinely reviewed onsite by the resident inspectors. Where appropriate, augmented resources are applied. Licensee corrective actions are evaluated for acceptability. A tabular breakdown of LERs versus functional area and root cause is included in the SALP.

0FFICIAL RECORD COPY COLLINS 344 9/22/88 - 0005.0.0 05/23/88

Attachment B 3 As part of the Systematic Assessment of Licensee Performance (SALP) process AEOD performed a site specific analysis of LERs to evaluate whether causal linkages exist. The results of this analysis are contained in section 5 of the SALP Report. Indi-vidual LERs and any causal linkages identified by AE00 are con-sidered during development of each SALP functional area analysis. These activities are targeted at identifying adverse trends, significant weaknesses and generic issues, b) What is the Status of the As Yet Unclassified Violations and Enforcement Action That May be Contemplated?

Enforcement action is pending completion of ongoing reviews.

Item 6: Boston Edison Company's Response to Engineering Safety Features Actuation Boston Edison is required to respond to this item by September 22, 1988. NRC will review this response as part of its routine inspec-tion activities and will document that review in a future resident report.

Item 7: Boston Edison Company and NRC Activities Regarding Defective Component Concerns The NRC has been closely monitoring the BECo actions taken in re-sponse to NRC Bulletin (NRCB) 88-05 and Information Notice (IN) 88-46 and IN 88-48. Based on data gathered to date and testing performed on components installed at Pilgrim there will be no material replace-ment required under NRCB 88-05. Discussion of licensee and NRC activities on NRCB 88-05 will be documented in a future resident inspection report. Although the licensee has not yet concluded their investigation into IN 88-46, there is no evidence to suggest that any materials detailed in the No'. i c e have been installed at Pilgrim.

With respect to IN 88-48, the licensee has reviewed records and con-ducted walkdowns and determined it does not have the V0GT Valves in question and it has not done any business with CMA International.

These items will be tracked by the resident office and documented in a future inspection report.

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Item 8: Boston Edison Company and NRC Actions Regarding the Power Oscillation Event at LaSalle Station The NRC has forwarded a Bulletin to all BWR licensees detailing the events at LaSalle Station. In the past, the General Electric Company made operating recommendations to BWR owners that would prevent power oscillations in the event of a dual recirculation pump trips. Boston-Edison has implemented these operating recommendations. NRC review of the initial licensee actions is contained in IR 50-293/88-25 and subsequent actions will be documented in a future inspection report.

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