ML20070D809

Submits Supplemental Response to NRC 820816 Ltr Re Violation Noted in IE Insp Repts 50-293/82-04 & 50-293/82-19.Plan to Correct Deviations Between Local Leak Rate Testing Sketches & Valve Lineup Checklists Encl

ML20070D809
Person / Time
Site:	Pilgrim
Issue date:	10/22/1982
From:	Harrington W BOSTON EDISON CO.
To:	Starostecki R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
Shared Package
ML20070D801	List: ML20070D802 ML20070D809
References
82-275, NUDOCS 8212150233
Download: ML20070D809 (3)

Text

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o BO STO N EDISDN COMPANY B00 BovLsTON STREET BOSTON. MABBACHUBETTm 02199 WILLIAM D. HARRINGTON N316 4.

October 22, 1982 BECo. Ltr. #82-275 Mr. Richard W. Starostecki, Director

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Division of Project and Resident Programs Region I U.S. Nuclear Regulatory Commission 631 Park Avenue King of Prussia, PA 19406 License No. DPR-35 Docket No. 50-293 Supplemental Response to IE Report 82-04 and IE Report 82-19 Ref. (a): BECo. Letter (W. D. Harrington to R. W. Starostecki) dated September 15, 1982 " Response to Inspection 82-19"

Dear Sir:

In response to Confirmatory Action Letter #82-05, Items 3a&b, Boston Ed'- mo.

conducted a walkdown of safety systems to include the following: 'has.

which contain automatic and/or manual containment isolation valves, tae emergency core cooling systems, and those portions of the containment a' phere control system which pertain to nitrogen supply and containment rurge We revised system operating and valve lineup procedures and updated the associated P&ID to reflect as-built configuration. We stated that this action would be completed prior to startup from the 1981 Refueling oc _.

This extensive system walkdown and verification project generated a large number of minor deviations (primarily test, vent and drain conriectionsi ;or which corrective actions were initiated. We are currently in the formal I

P&ID review process.

We recognize that we may still have some deviations that have not been identified; however, they are of the same minor nature as those found in the subsequent verification of the walkthroughs. Further refinements in our configuration control process are being made as drawings, procedures, and manuals are updated.

I wish to stress that when any deviations are identified between as-built configuration, P&ID's and/or valve lineup checklists, appropriate action will be taken.

8212150233 821210 PDR ADOCK 05000293 0 PDR t

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BO; TON ED120N COMPANY Mr. Richard W. Starostecki, Director October 22, 1982 Page 2 Attachment A to this letter outlines the plan to correct the deviations identified in IE Report 82-04 and IE Report 82-19, related to the following documents:

1. Sketches associated with Procedure 8.7.1.5, " Local Leak Rate Testing of Primary Containment Penetrations and Isolation Valves".

2. System P&ID's which were subjected to a walkdown just prior to restart from the 1981 Refueling Outage.

3. Valve lineup check lists associated with the system procedures.

The plan was to be submitted by October 15, 1982, but a one week extension was granted by your office due to our maintenance outage and unavailability of the proper corporate personnel to review the plan before submittal.

Should you require any further information concerning this response please contact us.

Very truly yours, Commonwealth of Massachusetts)

County of Suffolk )

Then personally appeared before me Willaim D. Harrington, who, being duly sworn, did state that he is Senior Vice President - Nuclear of Boston Edison Company, the applicant herein, and that he is duly authorized to execute and file the submittal cor.tained herein in the name and on behalf of Boston Edison Company and that the statements in said submittal are true to the best of his knowledge and belief.

My Commission expires:C 74tJ/, /198 >ki Notarygublic d

Attachment A .

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< Attachment A PLAN OBJECTIVE The objective of this plan is to resolve the deviations addressed in IE Reports 82-04 and 82-19 related to test, vent and drain valves. This plan will correct the deviations between LLRT Sketches, Key P&ID's, valve lineup checklists and Procedure 8.C.13.

OUTLINE OF THE PLAN The Procedure 8.7.1.5, Local Leak Rate Testing of Primary Containment & Isolation Valves, shall be validated by station test personnel.

The Procedure 8.7.1.5 will then be compared to Procedure 8.C.13, Locked Open, Locked Closed Valve Lineup Surviellance, and updated as necessary.

The Procedure 8.7.1.5, will then be compared to operating system procedure line-ups & P&ID's.

Data contained in Procedure 8.2.3, Visual & Manual Inspection of Primary Containment Isolation Valves 1" & smaller will be transcribed into the appropriate cystem procedure valve lineups. At the conclusion of this effort Procedure 8.2.3 will be retired.

Deviations identified between Procedure 8.7.1.5, P&ID's, and system procedure valve lineups shall be corrected by updating the appropriate document.

SCHEDULE Phase I - Identification of Deviations The scoping effort has been ongoing since September 13, 1982.

There are 63 primary containment penetrations involved which account for 136 individual leak rate tests. The test lineups affect greater than 700 valves.

Procedure 8.7.1.5 will be validated by station test personnel. Procedure 8.7.1.5 will then be compared to Procedure 8.C.13, and updated as necessary.

Then the affected procedures & P&ID's will be marked up to duplicate the validated procedure 8.7.1.5 data.

Phase I will be completed by February 15, 1983.

Phase II - Corrective Action The P&ID's and the affected procedures will be revised based on the deviations identified in Phase I.

i The completion of this Phase is contingent upon the number of deviations identi-fled in Phase 1. Because this information is not available at this time, we will not be able to predict when the item of non-compliance will be completely resolved; however, when Phase I is complete we will produce a new schedule identifying the date when full compliance will be achieved.

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