ML20076M899

Responds to NRC Ltr Re Violations Noted in IE Insp Repts 50-293/82-04 & 50-293/82-19.Corrective Actions:Procedures 8.2.3 Retired & 8.7.1.5 Re Local Leak Rate Test of Primary Containment Penetrations & Isolation Valves Revised

ML20076M899
Person / Time
Site:	Pilgrim
Issue date:	06/16/1983
From:	Harrington W BOSTON EDISON CO.
To:	Starostecki R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
Shared Package
ML20076M866	List: ML20076M899
References
83-153, NUDOCS 8307210140
Download: ML20076M899 (3)

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EOSTON ' EDISON COMPANY 800 BOYLSTON STRErr BOSTON. MAmeADMUSETTS O2199

- WILLIAM D. HARRINGTON

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- MW%eAE June 16, 1983 BECo Letter No.83-153 Mr. Richard W. Starostecki, Director Division of Project and Resident Programs

U.S. Nuclear Regulatory Commission Region I

-631' Park Avenue King of Prussia, PA 19406 License No. DPR-35 Docket No. 50-293 Clarification and Status Report for Supplemental Response-to

-IE Inspection Report 82-04 and 82-19

Reference:

( A) Letter from Mr. W.D. Harrington to Mr.

R.W.

Starostecki, dated February 17, 1983.

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(B) Telephone conversation between Mr. J.D. Keyes (Boston Edison) and f

Mr. J.R. Johnson (NRC) conducted on June 2,1983.

Dear Sir:

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.This ~ submittal is to clarify a commitment 'date, provide a brief-summary of pro-gress on the commitment, and' revise a commitment date.

It responds to a request 1

contained in Reference (B)'.

. Response of February 17, 1983 In Reference (A), we trarismitted the following in response to Item of Non Com-

.pliance 82-04-03:

t 1.

Procedure 8.2.3, " Visual & Manual Inspection'of. Primary Containment Isolation

-Valves 1" and Smaller," will have all of the valves identified in the procedure transcribed ;into the Appendix A valve checklists of the affected system pro-cedures by 6/1/83.. At the conclusion of this work item,- Procedure 8.2.3, Visual & Manual Inspection of ' Primary Containment Isolation Valves '1" and Smaller, will be retired.

2.. All of the ' verified sketches associated with Procedure '8.7.1.5, " Local Leak Rate Testing of Primary Containment Penetrations and Isolation Valves," will

.be. redrawn and retyped to incorporate new data identified as a result of this

. effort by 6/15/83.

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8307210140 830714 q

PDR ADOCK 05000293 Q - -.

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COOTON EDISON COMPANY

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.Mr. Richard W. Starostecki, Director Page 2 3.

The affected systems with valves located outside of the primary containment will have t' eir Appendix A valve checklists updated to incorporate the devia-n tions identified between them and the Procedure 8.7.1.5 sketches by 7/15/83.

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The affected systems with valves located inside the primary containment will have their Appendix A valve checklists updated to incorporate the deviations identified between them and the Procedure 8.7.1.5 sketches af ter the next

-refueling outage. This delay is necessary because, in some cases, the actual location of the valves (a requirement of the valve checklist) must be identi-fled by a plant walkdown; therefore, this item will be scheduled as a task for the next refueling outage.

Present Status and Clarification All of the system procedures referred to in Item _ I have been updated and emplaced with the exception of one.

This procedure is currently in the Operation Review Committee (ORC) pre-review cycle, and is to be emplaced by July 15, 1983.

A review of the Item 1 commitment indicated that a strict interpretation would

-imply that not having all the subject procedures completed by June 1,1983 would be a deviation.

Boston Edison therefore wishes to clarify Reference (A).

We believe that to ensure a meaningful set of procedures in a timely manner neces-4 sitates that Item 3, the updating of checklists to reflect the current configura-tion of Pilgrim, be performed concurrently with Item 1.

I Item 1 was an interim step consisting of attaching the existing Appendix A check-lists from Procedure 8.2.3 to system procedures.

This would produce a product which could then be updated through the effort described in Item 3.

This process would ensure that procedures accurately reflect the existing Pilgrim configurs-tion before being reviewed by ORC and implemented.

We do not _believe a deviation exists because the sequence described above is

-logically dictated, and we regret that Reference (A) inadvertently implied that the completion of Item 1 would be by June 1,1983 rather than the correct date, July 15, 1983.

We also wish to submit a new completion date for Item 2, the redrawing and retyp-ing of new data into Procedure 8.7.1.5.

This commitment has been adversely impacted by a. variety of demands on the cog-nizant personnel.- _ The data for upduting has been developed, but the formal redrawing and retyping has slipped behind schedule; therefore a new schedule has q

' been developed, _ and completion will be August 15, 1983.

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BOETON EDISON COMPANY Mr. Richard W. Starostecki, Director Page 3 We wish to stress that Boston Edison is actively completing th above.

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Very truly yours, I

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Mr. J.R. Johnson, Senior Resident Inspector cc:

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