ML19256F314
| ML19256F314 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 11/02/1979 |
| From: | Andognini G BOSTON EDISON CO. |
| To: | Grier B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| References | |
| IEB-79-14, NUDOCS 7912180485 | |
| Download: ML19256F314 (3) | |
Text
,h c4N hrt A g, BOSTON EDISON COMPANY GENEliAL OFricES 800 GOYLETON STREET GOSTON M ASEACNUSETTE O2199 G. CARL ANDOGNINI SUPERINTENDENT NUCLEAP OPERATIONS CEPARTMENT November 2, 1979 BECo. Ltr. #79-216 Mr. Boyce H. Grier, Director Office of Inspection and Enforcement Region !
U.S. Nuclear Regulatory Commission 631 Park Avenue King of Prussia, PA.
19406 License No. DPR-35 Docket No. 50-293
Reference:
A. Response to IE Bulletin 79-14 dated August 1, 1979 - BECo.
Ltr. #79-156 B. IE Inspection Report 79-18 dated October 15, 1979
Dear Sir:
In our initial response to IE Bulletin #79-14, dated August 1, 1979 (Ref. A)
Boston Edison expressed its intent to inspect all normally accessible
- safety-related systems within the 120 day deadline stated in Item #2 of Ref. A. and proposed an extended inspection schedule for those safety-related systems normally inaccessible.
Questions and comments to that proposal were solicited at that time.
Prior to the issuance of IE Inspection Report 79-18 on October 15, 1979 (Ref. B)
Boston Edison has received neither a formal nor informal response to its August 1, 1979 proposal.
Reference B emphasized strict adherence to the 120 day deadline as originally presented in IE Bulletin 79-14 unless an affirmative response from the NRC had been received granting an extension.
To resolva this obvious incongruity, Boston Edison's Licensing Group contacted Mr. W. Baunack of your office on October 29, 1979 to request a clarification of the criteria required to obtain the affirmative response required to extend the 120 day deadline.
The purpose of this letter is therefore to document the resubmittal of our request for the extension of 120 day deadline to the next refueling outage scheduled to begin on January 5, 1980.
- Normally accessible refers to those areas of the plant, excluding high radiation areas, that can be entered during reactor operation.
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4 BOSTON EDISON COMPANY Mr. Boyce H. Grier, Director November 2, 1979 Page 2 All normally accessible safety-related systems have been inspected and a description of the results of this inspection will be submitted within the 120 day deadline. Of the safety related systems normally inaccessible, the entire recirculation system (both loops) and branch piping as well as two of the main steam lines were subjected to a walk-down, during the May outage, to verify the following:
1.
Critical dimensions agreed upon by both Boston Edison and NRC:RI and NRR.
2.
Seismic restraints including applicable snubbers, hangers and guides.
The walk-down of the system was witnessed by the Region I Inspector; no non-conformances were identified with regards to as-builts.
Additional as-built verification of inaccessible portions of systems had also been conducted previously.
The Core Spray piping was modified during the August 1977 refueling outage; the as-built condition was verified as a result of the design change process.
During the same outage, the Control Rod Drive Return Line was cut and capped at the vessel.
The inspections that still remain to be conducted are restricted primarily to the drywell, and steam tunnel. Within these areas the following portions of systems will be inspected: the head spray piping of the RHR System, feedwater piping, two main steam lines and interconnected branch piping.
Some areas of the normally accessible systems were found to be inaccessible because of radiation and physical barriers. Where physically possible these areas will be included with the inaccessible areas that are presently scheduled for in-spection during the 1980 refueling outage which will commence on January 5, 1980.
As of November 1, 1979, Boston Edison Company has completed the physical in-spection of all normally accessible safety-related systems.
In completing this inspection approximately 1200 stress isometric and support detail drawings were reviewed and based on the inspection criteria described in IE Bulletin 79-14, ' forty-two (42) deviations were found.
Of these thirty-one (31) were judged to have an insignificant effect on the piping stress analysis and eleven (11) have been judged to have a minor effect (i.e. system operability is maintained but further detailed evaluation was required). However, none of the reported deviations from either category jeopardized the operability of the safety related systems.
The results of the inspections to date provide confidence that if similar deviations are encountered during the inspection of the remainder of inac-cessible safety-related systems, the operability of these systems will not be jeopardized.
Boston Eidson believes that there is reasonable assurance that the health and safety of the public will not be endangered by extending the deadline for the inspection of the inaccessible safety-related systems through gf80{pffeling U/
outage.
' BQilTON EDISON COMPANY Mr. Boyce H. Grier, Director November 2, 1979 Page 3 We believe that this letter is responsive to your concerns.
However, should you have any further questions or coments please contact me.
Very truly yours, r
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Director, Division of Operating Reactors Office cf Nuclear Reactor Regulation U.S. Nuclear Regulatory Comission Washington, D. C.
20555 1609 078