ML20206A481

Responds to Re Questions Raised in Testimony to ACRS Concerning Plant & 880826 Testimony.Responses to Issues Contained in 880826 ACRS Subcommittee Testimony Encl

ML20206A481
Person / Time
Site:	Pilgrim
Issue date:	11/01/1988
From:	Collins S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	Alexander L MASSACHUSETTS, COMMONWEALTH OF
References
CAL-86-10, IEB-88-005, IEB-88-007, IEB-88-5, IEB-88-7, IEIN-88-046, IEIN-88-048, IEIN-88-46, IEIN-88-48, NUDOCS 8811150142
Download: ML20206A481 (18)

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NOV 011988 The Honorable Lawrence R. Alexander Chairman, Committee on Energy House of Representatives State House Room 540 Boston, Massachusetts 02133 5

Dear Mr Alexander:

This is in reply to your letter of September 9,1988, regarding questions you raised in testimony to the Advisory Committee on Reactor Safeguards (ACRS) con-corning the Pilgrim Nuclear Power Station. This letter responds to your August 26, 1988 testimony since we understand tr.at you have provided the September 7,1988 supplemental testimory directly to the ACRS for response.

1 I would like to acknowledge that in our letters dated June 1,1988 and

. July 13, 1988, the Comonwealth was provided the opportunity, at its own request, to review snd provide input to the inspection scope of the recently j completed Integrated Assessment Team Inspection (IATI). The purpose of that i request was to ensure that the Commonwealth's concerns and technical questions i were included for review within the IATI, and to provide for efficient dispo-j sitioning of the issues during the course of the inspection in conjunction with participation by the two designated Commonwealth inspection observers. We l received no input to the IATI inspection scope; however, subsequent to the

. completion of the inspection, the Commonwealth has forwarded to the NRC, issues

contained in two letters of September 6,1988 and those contained in your j letter of September 9,1988.

I In responding to the issues raised, I have assumed that the documents pre-

! viously provided 6.o the Commonwealth's State Liaison Officer will remain l available for reference. Attached are specific responses to those issues con-tained in your August 26, 1988 ACRS Subcommittee testimony which are under NRC

! staff review. Some of these issues and the NRC repiv were discussed with

! Mr. Michael Ernst of your staff on October 4 and 18,1988.

a l Thank you for your interest in these matters.

i l Sincerely,

$11$$oh ! [ M MM.N N W o Samuel J. Collins, Deputy Director

Division of Reactor Projects l Att + .its

J As st.ited

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The Honorable Lawrence R. Alexander 2 NQy g } Jggg 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 7.. Swanson, Nuclear Engineering Department Manager The Honorabla Edward J. Markey The Honcrable Edward P. Kirby The Honorable Peter V. Forman B. McIntyre, Chairman, Department of Public Utilities Chairman, Plymouth Board of Selectmen Chairman, Duxbury Board of Selectmen Plymouth Civil Defense Director P. Agnes, Assistant Secretary of Public Safety, Commonwealth of Massachusetts S. Pollard, Massachusetts Secretary of Energy Resources R. Shimshak, MASSPIRG Public Document Room (POR) local Public Document Room (LPOR)

Nuclear Safety Information Center (NSIC)

NRC Resident Inspector Commonwealth of Massachusetts (2)

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The Honorable Lawrence R, Alexander 3 NOV 011988 i

bec w/ attachments- I

' Region I Docket Room (with concurrences) i W. Russell, RA )

5. Collins, ORP  !

J. Wiggins, DRP i R. Blough, ORP L. Doerflein, DRP M. Kohl, DRP C. Warren, SRI - Pilgrim R. Bel'iamy, DRSS R. Boros, DRSS J. Ourr, DRS B. Boger, NRR D. Wessman, NRR D. Mcdonald, NRR P. Boehnert, ACRS a

RI.ORP RBlough/mjd S1Sh je

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n 10/'/ /88 4c/\/S8 0FFICIAL RECORD COPY COLLINS 359 10/17/88 - 0003.0.0 10/28/88

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f ATTACHMENT A

Reference:

August 25, 1988 lestimony to ACRS Subcommittee Item 1: Conditions For Restart The NRCDhas est:blished and discussed in public meetings the restart critoria for the Pilgrim Nuclear Power Station. Most recently, those criteria were discussed and provided as a handout (Slide 33) at the August 26, 1988 ACRS Subcommittee Meeting, held in Plymouth and are provided below:

• Stable and Effective Management and Staff at Pilgrim

• Resolution of Major Technical Issues

• Ocmenstrated Improvement in SALP Problem Areas 4,

Maintenance Program and Work Backlog Issues AJdressed

+ NRC satisfied that certain Emergency Plan Improvements have been made OFFICIAL RECORD COPY COLLINS 359 10/17/88 - 0004.0.0 10/28/83 l

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. i Attachment A 2 Item 2: No one has ever yet been able to explain adequately why the Residual Heat Removal System shutdown twice in 1986 The technical issue of intersystem leakage through the motor-operated injection valves and the check valves of the residual heat removal system was discussed in Confirmatory Action Letter (CAL) 86-10 of April 12, 1986, Section 5.a. The CAL required Boston Edison Company to provide a written report to the NRC containing an evaluation of the issue.

NRC Inspection Report No. 50-293/86-17, May 16, 1986, Section 5.0, contained a detailed NRC discussion of the RHR system in-leakage issue and its safety significance. The resolution of this issue was documented in Inspection Report No. 50-293/87-42, and was discussed at the Aug ist 26, 1988 ACRS Subcommittee Meeting held in Plymouth.

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. i Attachment A 3 Item 3: How can Pilgrim be ready for Restart when MIT scientists are still studying the cracking of an RHR motor housing and valve l Cracking in the yoke of motor-operated valve (MOV) 1001-28B in the "B" loop of the Residual Heat Removal System (RHR) was discovered by the licensee on June 7, 1988 and subsequent inspection of the counterpart valve in the "A" RHR loop identified indications of +

cracking in the lower portion of the yoke of MOV 1001-28A. The

! licensee's response to this issue, including the results of the completed material analysis conducted by the Massachusetts Institute of Technology (MIT), is discussed in NRC Inspection Report Nos.

i 50-293/88-27, September 21, 1988, and 50-293/88-31, October 26, 1988, and was discussed at the September 29, 1988 NRC public meeting held

in Plymouth.

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Attachment A 4 Item 4: Could Pilgrim experience the same wild power oscillations that occurred at the LaSalle Boiling Water Reactor in Illinois this year?

Has Boston Edison Company analyzed Pilgrim's vulnerability in this regard, and have its operators been thoroughly trained to take the appropriate responses?

In response to this issue, the NRC issued a Bulletin Notice (NRC Bulletin 88-07), dated June 15, 1988, to all Boiling Water Reactor (BWR) licensees detailing the events at the 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 trin such as occurred at the LaSalle Station, Boston Edison has implemented those recommendations. Further, in the event that a dual recirculation pump trip occurs, BEco's procedures I direct the reactor operators to immediately trip the reactor to prevent the development of power oscillations, t

The licensee has provided training to their operations staf f on the appropriate actions to prevent or mitigate power oscillations should they occur, NRC review of the initial licensee actions is contained in Inspection Report 50-293/88-25 and subsequent actions are documented in Inspection Report 50-293/88-31, 1

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. i Attachment A 5 Item 5: Has Boston Edison Company tested all the potentially defective pipes, circuit breakers and other safety equipment that were recently revealed to have been fraudulently certified as safety grade?

The NRC has been closely monitoring the Boston Edison Company's actions taken in response to the issues identified in NRC Bulletin (NRCB) 88-05, "Non-conforming Materials," and Information Notices (IN) 88-46, "Licensee Report of Defective Refurbished Circuit Breakers," and 88-48, "Licensee Report of Defective Refurbished Valves." Based on data gathered to date and testing performed on ccmponents installed at Pilgrim, there will be no material replacement required under NRC8 88-05. Discussions of licensee and NRC activities on NRCB 88-05 is documented in Resident Inspection Report 50-293/88-31. The licensee has concluded an investigation into IN 88-46; there is no evidence that any materials detailed in the Notice have been installed at Pilgrim. With respect to IN 88-48, the licensee has reviewed records and conducted walkdowns and I

determined it does not have the counterfeit V0GT valves in question and has not done any business with CMA International (the supplier in question in the Notice). These items will continue to be tracked l by the resident office and documented in future inspection reports.

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. i Attachment A 6 Item 6: What is the extent of embrlttlement of key reactor equipment at Pilgrim?

original des i gn objectives for the Pilgrim Station included con-

, a .t W of the forty year minimum required life of plant struc-p 4 41 pet r Plant systems were designed to mest this objec-tiv. Es pW of t e licensing process, the NRC staff reviewed the lict s sita spvific design and concluded that it would support the 4 n,wr av f the facility over the proposed forty year life.

Based - 9 is c; ssion, the Commission issued an Operating License authoril, opt.4 tion of the facility.. in accordance with the pro-visions of the license, until August 26, 2008.

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 performante requirements. This ensures that the assumptiens n'ade in the original design and construction of the facility are maintained throughout the plant operating life. For example, the resctor pressure vessel was designed for a forty year life. Implicit in this design is an assumption of the expected cumulative radiation exposure and its ef fect 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 relationship, 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.

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. i Attachment A 7 Item 6 (Continued)

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

In addition to existing requirements, the NRC Office of Nuclear Regulatory Research is currently implerr.enting an extensive program to evaluate the causes and ei.'ects of aging on importent plant equip-ment. Expenaitures en this program are expected to total one million dollars tiils year and 55 r.iillion dollars over the next six years.

The goals of the program are to identify the significant contributors to plant aging; to develop effective preventive, predictive and surveillance techniques; and to factor these findings, as appro-priate, into regulatory actions and the NRC inspection progren.

In summary, the plant as designed and licensed can be operated safely provided that it is surveilled and tr.aintaine.d in accordance with the

Operating License. However, the NRC is implementing an ongoing effort to better understand and deal with the potential mpact of i plant aging. ,

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. e Attachment A 8 Item 7: Thirteen years after the Browns Ferry fire, has Boston Edison Company j finally completed the fire protection improvements required by l

10 CFR 50, Appendix R? -

Boston Edison Company is in compliance with 10 CFR 50, Appendix R fire protection requirements. These actions include the submittal by [

Boston idtson Company and approval of fire protection licensing requirements by the NRC including exemptions to address site specific equivalent measures and plant modifications or temporary compensatory measures to implement the program. The status of the fire protection i program was also discussed at the Septernber 29, 1988 NRC public maeting held in Plymouth, i r

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Attachment A 9 I

l Item 8: Have the problems with the Main Steam Isolation Valves finally been resolved?

In April of 1986, the NRC conducted a special Augmented Inspection to review the technical issues leading to the April 11, 1986 decision by Boston Edison Company to shutdown the Pilgrim facility. This special inspection was conducted from April 12-25, 1986, and results including an evaluation of the Main Steam Isolation Valve problems I

is contained in Inspection Report 50-293/86-17, issued May 16, 1988. ,

Final NRC review and closecut of the issue is contained in Inspection t Report 50-293/88-13, issued May 26, 1988.

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Attachment A 10 Item 9: Manyoftheseproblems(genericsafetyissues)directlyaffectsafety at Pilgrim, yet because they have been labelled "generi:", the NRC may allow Pilgrim te restart before they are resolved and corrected.

Generic safety issues under consideration by the staff are initially screened for any immediate safety concerns necessary to be addressed by the NRC or licensees. The NRC does not hesitate to impose addi-tional requirements or requests for information based on the need to ensure that the health and safety of the public are protected.

Examples of the tools available to impose requirements or request licensee response include the modification of a facility license by I

an order, and required licensee actions promulgated by Generic Letters and NRC Bulletins.

Following the initial safety concern review, generic issues currently under consideration will be considered for applicability to Pilgrim in conjunction with those requirements imposed on other power reactors licensed to operate, i

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Attachment A 11 I Item 10: Another major reactor safety problem involves the flawed Mark I containment design of the Pilgrim reactor.

The Mark I containment design consideration is the subject of two ,

Petitions filed by representatives of the Commonwealth oa '

July 15,1986 and October 15, 1987. NRC Interim Director's Decisions were issued by the NRC on August 21, 1987 and May 27,1988 which responded to this issue.

In addition, this issue has been discussed at length in numerous meetings conducted in the Plymouth area and most recently at the September 29, 1988 public meeting.

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Attachment A 12 i Item 11: Boston Edison Company has constructed one measure, a vent to relieve overpressurization, but it has not been allowed to connect it to Pilgrim yet. Certainly, the owners of Pilgrim should wa't until the NRC issues its recommendations on corrective measures, so thht they can implement them before they are allowed to restart the plant. {

Boston Edison Company initiated the Safety Enhancement Program (SEP) to enhance the overall plant safety and performance of the Pilgrim L facility. The modifications performed by Boston Edison were per-formed under the provisions of 10 CFR 50.59, which allows licensees to make changes without prior Commission approval provided certain conditions are met. NRC chose to review certain cf the licensee's 10 CFR 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 Probabilistic Safety ,

Assessment) and determined both methods confirmed that SEP was beneficial. [

NRC assessment of the SEP is contained in letters dated i August 21, 1987 and October 12, 1988, which were provided to the f Commonwealth. The NRC has not precluded the installation of the vent i valve (Direct Toros Vent - OTV) and, i n f a r. . , a letter to the NRC l dated August 18, 1938, indicated that Boston Edison Company was proceeding with installation of the OTV, i

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Attachment A 13 Item 12: Furthermore, I urge you to call for th'e prompt initiation of a site-specific probabilistic risk assessment for Pilgrim, so that appro-priate additional, plant-specific improvements can be implemented as soon as possible.

This issue was the subject of the Petition filed b" the Commonwealth on October 15, 1987. In particular, the Petitioners requested the NRC to (1) modify the Pilgrim license to bar restart of the facility until a plant-specific probabilistic risk assessment (PRA) is per-formed for Pilgrim and all indicated safety modifications are imple-mented, (2) ... .

On May 27,1988, an Interim Director's Decision in response to this concern was issued to the Commonwealth.

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Attachment A 14 Item 13: No plant is allowed to operate unless workable emergency response plans are in place that will protect the public's health and safety.

The Code of Federal Regulations provides NRC with a range of options and a degree of discretien in the event emergency response plans fcr an operating plant are four.d deficitent at any time. This does not preclude, in all cases, plant operation, and plants have in the past been permitted to operate while deficiencies were corrected. As previously noted in Item No.1, the NRC has committed to ensuring certain Emergency Planning Improvements have been made prior to restart.

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l Ites 14: The recent SALP, which places Pilgrim with the 13th worst SALP l average in the nation, has provided little solace to the residents of communities surrounding Pilgrim.

This issue was the subject of the Petition filed by the Corranonwealth on October 15, 1987. The staff has addressed this concern in the further response to the Petition issued on October 6, 1988. It ,

should be noted that the NRC does not rank plants numerically by SALP i average ratings and does not eadorse any such rankings generated outside NRC.

l The NRC staff's concerns with respect'to management not only ,

encompassed but went beyond the specific items raised by the Petitioners. It is in this broader context that the staff has evaluated actions taken by Boston Edison Company to resolve ,

management deficiencies. The staf f's conclusions on the adequacy of l management arise from the augmented site inspectiori program, SALP c

Report No. 87-99 and the report on the Integrated Assessment Team [

Inspection (IATI) performed in August 1988, i

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