BECO-94-022, Forwards Semiannual Long Term Program Update in Accordance W/Section V.A of Plan for Long Term - Pilgrim Nuclear Power Station, Including Schedules for a & B Regulatory Items & Commitment Descriptions & Process Since Last Update

Forwards Semiannual Long Term Program Update in Accordance W/Section V.A of Plan for Long Term - Pilgrim Nuclear Power Station, Including Schedules for a & B Regulatory Items & Commitment Descriptions & Process Since Last Update

ML20064C342
Person / Time
Site:	Pilgrim
Issue date:	02/28/1994
From:	Boulette E BOSTON EDISON CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
BECO-94-022, BECO-94-22, NUDOCS 9403090315
Download: ML20064C342 (51)

Text

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BOSTON EDISON Pilgnm Nuclear Power Staton  !

Rocky Hill Road l Plymouth, Massachusetts o236o February 28, 1994 E. T. Boulette, PhD senor Vice President -Nuclear BEco 94-022 U.S. Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 License DPR-35 Docket 50-293 LONG TERM PROGRAM: SEMI-ANNUAL REPORT This letter provides the semi-annual Long Term Program (LTP) update in accordance with Section V.A of the " Plan for the Long Term Program - Pilgrim Nuclear Power Station". Attachment 1 includes schedules for the A and B regulatory items'.

Attachment 2 includes commitment descriptions, progress since the last update, and summaries of changes.

Since the last update, we determined that rescheduling the planned 94 Mid-Cycle Outage would be prudent for numerous reasons. The new planned start of the Mid-Cycle Outage is October 1, 1994. Refueling Outage #10 remains scheduled to begin on April 1, 1995.

In addition to Schedule A and B items, we are implementing plant betterment modifications and activities. These additional items, identified in Schedule C, are included in Attachment 3. Schedule C items are outside the regulatory scope of the Long Term Program and are exempt from the license conditions imposed on Schedule A and B items.

Progress has continued on the majority of Sciedule A and Schedule B items.

Changes in status since our last submittal are found in the lightly shaded sections of Attachment 2.

_C_ompleted Items

• 10CFR20 Standards for Protection Against Radiation

• Class 1 Piping Seismic Damping Ratio

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BOSTON EDISON COMPANY U. S. Nuclear Regulatory Commission i Page 2 ,

Schedule Revisions

• Detailed Control Room Design Review

• EDSFI HVAC New Items

• Neutron Flux Monitoring (separated from RG 1.97)

O 'I fbu.Q9e E. T. Boulette, PhD Attachments nas/LTPLTR cc: Mr. R. Eaton, Project Manager Division of Reactor Projects - I/11 Office of Nuclear Reactor Regulation Mail Stop: 1401 U. S. Nuclear Regulatory Commission 1 White Flint North 11555 Rockville Pike Rockville, MD 20852 U. S. Nuclear Regulatory Commission Region I 475 Allendale Road King of Prussia, PA 19406 Senior NRC Resident Inspector Pilgrim Nuclear Power Station

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~ - - - ---- -- - - . > - -

1994 1995 , 1996 1997 , 1998 1999

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=:w LONG TERM PROGRAM BOSTON EDISON - NUCl. EAR ORGANIZATION .

I____________ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ . _ _ . _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _

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Rpo sit niapp98 30 APR98 MCO - CYCLE #12 =

RFOA PR *12 gMAY99 i SCHEDULEB 1JdN94 310CT4A CTRL ROOM DESIGN REVIEW . PANEL ENHANCEMENT (LTP # 300;328) 1JAN94 310CT9A' CTRL ROOM DESIGN REVIEW - PANEL C7 MODS.

Il TJAN94 30 MAYO 4 CTRL ROOM DESIGN REVIEW - REPLACE ANNUNCIATOR (LTP

• 327)

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l ldN94 1J 100CTe4 !

I, 1JAN94 31 dei:4A SEISMIC VERIFICATION PROGRAM ( LTP #410)

Ii GECUR!TY UPGRADE - NEW SECURITY COMPUTER (LTP 029) i1JAN94 30MAve7 GL 89-10 MOV TESTING & SURVEILLANCE (LTP #437) i l l I , [

=/ LONG TERM PROGRAM BOSTON EDISON - NUCLEAR ORGANIZATION

, 1994 1995 , 1S96 . 1997 , 1998 1999

, 1 2 .3._..  ; 4 ._ __ _ 11 . __ .._ 2 _ 3 . __ .4 _ _;1 .2 _ __3 .4 1. _ _ :2_ 3.__ . 4 ._. .1 __.2 ._;3._ _ 4____.._.1 _.__.2 ._.___.3.._.__.4 i  :

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SCHEDULE B ,

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ELD FAILURES (LTP 292)

I: GL 69-13 SALT SERVtCE WATER PIPING (LTP #473) 1JAN94 01 jut 4t GL B3-20 iPEEE - SUPPL. 4 0 TP #567)

It  !

WCU PlPiNG REPLACEMENT (LTP #600)

ED FI HVAC (LTP #583) 1.

1JAN94 30MAY44 TURBINE ROTOR REPLACEMENT (LTP 401) h I

== LONG TERM PROGRAM BOSTON EDISON - NUCLEAR ORGANIZATION

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ATTACHMENT 2 MAINTENANCE RULE (LTP #584)

Commitment Description

)

10CFR50.65 " Requirements for Monitoring the Ef fectiveness of Maintenance at Nuclear Power Plants " was issued as a final rule on July 10, 1991 (Reference 1). Licensees are required to have in place by July 10, 1996, a program capable of monitoring the overall continuing effectiveness of their maintenance programs to ensure that safety related and certain non-safety related structures, systems, and components are capable of performing their intended functions; failures of non-safety related equipment will not occur which could prevent the fulfillment of safety related funcuans; and failures resulting in scrams and unnecessary actuations of safety related systems are minimized.

The rule has a five year implementation schedule with supporting regulatory guide development and promulgation expected within the first two years. This schedule allows three years for licensee development beyond the time that final guidance is expected to be available.

References

1. Federal Register Vol. 56 No.132, dated July 10, 1991 Commitment History / Progress Progress and Summary of Changes - March 1991 to August 1991 A program for ensuring compliance with the maintenance rule is being developed and will be provided in the next regular report for the LTP.

Progress and Summary of Changes - August 1991 to February 1992 Our implementation approach for the maintenance rule consists of two major aspects:

• A program to monitor the performance of specified structures, systems and components (SSCs) against established goals, and

• Use of the reliability centered maintenance (RCM) concept to upgrade the Station's Preventive maintenance program.

Development of our monitoring program is evolving in concert with the.

guidance documents being established by NUMARC and the NRC. The NUMARC guidance is being established to address.four areas: selection of SSCs to be covered by the rule; goal setting .and performance monitoring; demonstrating equipment functionality by inherent SSC characteristics or by appropriate preventive maintenance; and the removal of plant systems from service without '

affecting overall plant safety. We understand the NRC guidance will describe acceptable methods for Licensees to monitor the overall continuing effectiveness of their maintenance activities, while offering flexibilities in establishing goal setting, monitoring, and preventive maintenance ,

activities.

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ATTACHMENT 2 (Continued) l SCHEDULE A The RCM program commenced in January 1992 with the formal establishment of an RCM team. The EPRI " Work Station" RCM software was selected for use in RCM system analysis. RCM team training on this software and RCM methodology was completed in January 1992.

The RCM program scope identifies and prioritizes 47 plant systems, each I requiring approximately 16 weeks of work. A number of systems will be worked i in parallel. Completion of the identified program scope is scheduled for May 1994.

Progress and Summary of Changes - March 1992 to August 15, 1992 ,

PNPS is continuing with a preventive maintenance program upgrade utilizing i RCM methodology. An additional system has been added to the RCM program scope bringing the total number of systems to 48. The analysis of three

, systems has been completed. The identification of SSCs within the scope of the maintenance rule is underway and scheduled for completion in 1992.

Progress and Summary of Changes - August 15, 1992 - February 15. 1993 The overall project continues on schedule. The RCM analysis of fourteen systems has been completed. The preliminary list of SSCs within the scope of the maintenance rule has been developed and issued for comment. A tailored collaboration with EPRI has been established and is in progress to develop a "Living PM Program" to assist in the programmatic aspects of the maintenance rule implementation plan.

Progress and Summary of Changes - February 15, 1993 - July 31, 1993 The project is on schedule. A total of 23 system RCM analyses are complete.

The Maintenance Rule Project plan is written, an implementation procedure is written, and three pilot systems have been completed.

Progress and Summary of Changes - August 1,1993 -. January 31, 1994 This project is on schedule. A total of 36 system RCM analyses are complete.

. We.have' started the production mode.of operation with 4 Maintenance Rule systems complete.

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ATTACHMENT 2 (Continued)

SCHEDULE A 10C 820 STANDARDS FOR PROTECTION AGAINST RADIAT10J (LTP #551)

't Commitment DescriptioD In Reference 1, the NRC issued a revision to the 10CFR20 requirements,

" Standards for Protection Against Radiation." These revisions became effective on June 20, 1991, and are required to be implemented by January'1, 1993, in their entirety. Licensees have the choice of implementing the new requirements in their entirety prior to January 1, 1994, with notification to the NRC, or continuing with the existing requirements until January 1, 1994, after which they must adopt the new requirements. Implementation of selected portions of the revised rule is not allowed prior to the January 1, 1994 deadline.

The revised rule changes the existing radiation protection requirements and practices, accounting of occupational exposures, maintenance of exposure records, General Employee Training, and Health Physics training. The NRC is also revising certain Regulatory Guides and issuing new Regulatory Guides to provide regulatory positions and guidance for implementing the revised requirements.

In reference 3, the NRC extended the original January 1,1993 implementation date for 10CFR20 until January 1, 1994.

Beferences

1. Federal Register Vol. 56 No. 98, dated May 21, 1991

2. 57FR21216 Extension of Implementation Date, Proposed Rule, dated May 19, 1992

3. 57FR38588 Standards for Protection Against Radiation, Extension of Implementation Date, dated August 26, 1992 Commitment History / Progress Progress and Summary of Changes - March 1991 to August 1991 A program is being developed to ensure compliance with the revised requirements within the prescribed implementation schedule and will be provided in the next regular report for the LTP.

Progress and Summary of Changes - August 1991 to February 1992 Selected personnel in the Nuclear Organization were trained in the requirements of the revised 10CFR20, and program elements for the implementation of the requirement:: have been developed. These are: a new system for Radiological Information Management, revision and development of new procedures, development of a training module and training of personnel, and equipment evaluation for potential modifications. These elements are in various stages of implementation. Additionally, we worked with NUMARC in the development of comments on several draft regulatory guides issued by the NRC in the October / November 1991 time frame. We are continuing our effort for the implementation of the requirement by using NRC guidance from draft regulatory guides.

Implementation of the final rule is on schedule for completion by January 1, 1993.

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ATTACHMENT 2 (Continued)

SCHEDVl.E A Progress and Summary of Changes - March 1992 to August 15, 1992 We are continuing implementation of various elements of the Radiation Protection Program requirements to comply with the revised 10CFR20. We plan to be in full compliance with 10CFR20 requirements by the NRC proposed new schedule of January 1,1994.

Progress and Summary of Changes - August 15, 1992 - February 15, 1993 RP program revision work continues to implement revised 10CFR20.

Approximately 55 procedure revisions are in progress. Policy meetings are being held to resolve issues such as monitoring individuals in the controlled area, monitoring declared pregnant radiation workers, air sampling counting techniques, and equipment and Technical Specification revisions.

PNPS is replacing its current Radiological Information Management System and is in the software design and programming stage.  !

Incorporation of Part 20 requirements into GET training has begun and more will be added as the year end approaches. 'Special training sessions are planned for Operations, Maintenance, and other station personnel. RP technician training has been completed and refresher training will be provided throughout the year. BECo has been invited to present its training program at the March NRC Region 1 NUMARC 10CFR20 workshop.

We plan to be in compliance with the revised 10CFR20 requirements by the NRC scheduled date of January 1,1994.

Progress and Summary of Changes - February 15, 1993 to July 31, 1993 The station continues in its program revisions to incorporate the changes for compliance with the new 10CFR20. The majority of procedure revisions are complete. An assessment of their content by an outside consultant was completed with positive results. Policies have been established for dose control, monitoring of personnel, air sample counting techniques and equipment changes.

The software design for the new computerized radiological information management system has been completed and testing on the new system begins in August 1993.

Formal site-wide training materials are complete and training will begin in the fall. Weekly information packages and small group meetings on topics from Part 20 are in progress. Special training sessions for Operations, Maintenance and other station personnel will also be presented in the fall.

PNPS will be in compliance with the revised 10CFR20 requirements by the NRC 4 scheduled date of January 1, 1994.

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a 8 ATTACHMENT 2 (Continued)

P SCHEDULE A t

Progress and Summary of Changes - August 1, 1993 - January 31,.1994 All procedure revisions were issued on 1/1/94.

The PRORAD radiological information system was'successfully' implemented on i 1/1/94.

Formal-site wide training has been completed. Revised Part 20 requirements have.

been incorporated into GET. Small. group meetings on the revisions were conducted for all personnel requesting them.

All work is complete and we were in compliance with'the revised 10CFR20 requirements on 1/1/94. This item will be removed from future LTP submittals.

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ATTACHMENT 2 (Continued)

SCHEDULE B DETAILED CONTROL ROOM DESIGN REVIEW (G.L. 82-33) (LTP #299, 300, 327, 328, 375)

Commitment Description References 6, 7, and 8 provided a DCRDR Supplementary Summary Report with update information, panel enhancement program information, and a revised DCRDR program plan, respectively. Reference 9 revised the schedule commitments for enhancements to three control panels singled out by BECo for completion ahead of ,

the others.

A final DCRDR Summary Report, Reference 10, was submitted on November 30, 1990.

This summary report included detailed scope and schedules _ for the remainder of DCRDR issues to be implemented at Pilgrim Station. The following summarizes the ,

remaining CRDR commitment schedule:

Complete installation of control room ceiling lighting improvements (LTP 375) by December 31, 1991 (complete)

I Complete remaining " Category 7" HEDs (non-engineered actions) by March 31, 1992 (complete).

Complete control panel enhancements (LTP 300 plus portion of LTP 328) by ,

end of MC010, except for panel _ C7.

Complete control panel improvements (balance of LTP 328) by end of RF0 9 (outage portion) and December 31,1993 (on-line portion), except for panel C7 (complete).

Begin installation of replacement annunciator in RF0 9 (and complete by RF0  ;

10) (LTP 327).

Complete work related to panel C7 by MC010 (Reference 12).  ;

References ,

1) NUREG 0737: Item 1.D.1

2) BEco Letter 84-159, dated September 24, 1984 i

3) NRC Letter 85-157, dated May 16, 1985

4) NRC Letter 86-002, dated January 6, 1986 -

5) BECo Letter 87-008, dated January 20, 1987 ,

6) BEco Letter 89-064, dated May 2, 1989

7) BECo Letter 89-102, dated July 6, 1989

8) BECo Letter 89-112, dated July 24, 1989

9) BECo Letter 90-008, dated January 11, 1990 ,

10) BEco Letter 90-147, dated November 30, 1990

11) BECo Letter 91-099, dated July 31, 1991

12) NRC Letter 92-178, dated July 13, 1992  ;

13) BEco Letter 92-128, dated November 13, 1992 Commitment History / Progress Progress and Summary of Changes - March 1989 to February 1990 Submit Supplementary Summary Report - Complete Page 6 of 41

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ATTACHMENT 2 (Continued)

SCHEDULE B

' Progress and Summary of Changes - February 1990 to November 1990 l

- The final DCRDR Summary Report was submitted November 30, 1990.

- As a result of ongoing human factors evaluations, the scope of control room panel enhancements has expanded beyond those committed in Ref. 7. The on-line portion is planned to be completed by June 30, 1992; the outage portion is planned for completion by the end of RF0 #9. The extent of enhancements to be performed in RF0 #8 and those to be performed on a later schedule are detailed in the November 30, 1990 Final DCRDR Summary Report submittal. The next LTP update will reflect the revised scope and schedule of the summary report.

- We have determined improvements to control room lighting can be implemented on line. Therefore, we are revising the previous completion date of the end of RF0

1. 8 to completion by December 31, 1991. We plan to install the lighting l improvements on-line before RF0 #8. However, in the event they are not i completed before RF0 #8, we will complete them by December 31, 1991. l Progress and Summary of Changes - December 1990 to February 1991 Currently, work to accomplish the items listed in Reference 10 is on schedule.

Progress and Summary of Changes - March 1991 to August 1991 The following improvements were implemented during RF0 #8:

• Installed welded patches to restore all main control panels to uniform flat, flush, smooth surface suitable for painting and for installation of improvements.

• Repainted all control panels in main operating area, and began effort to  !

repaint the "back panels." j i

• Replaced labels and installed new mimics and demarcations on 10 panels, -i plus revisions to mimics and labels on additional panels. l

• Completed removal of abandoned equipment from Main Control Panels.

• Replaced approximately 325 switch escutcheons and 200 switch handles.

• Rewired or replaced 17 switches, continuing a program to achieve uniform switch positions and patterns.

• Rearranged 3 groups of switches and 3 groups of indicators to achieve more j logical arrangement. j i

. Installed an additional set of scram and MSIV indicators on Panel C905.

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ATTACHMENT 2 (Continued)

SCHEDULE B e Replaced 6 meter scales with scales improved in readability; more to be ,

installed on-line, after RF0 #8. l l

In Reference 11, we notified the NRC that we will not be implementing switch rearrangements for the Safety Relief Valves. The work to accomplish the remaining Reference 10 items is on schedule.

Progress and Summary of Changes - August 1991 to February 1992

• Planned construction of improved ceiling lighting was completed by December 1991. Post-work testing was completed in January 1992,. Post-work testing identified the need for one additional fixture in the back panel area that will be installed during the next report period.

• Procedure revisions and other non-engineered corrective actions in

" Category 7" were completed except for one HED relating to an E0P display space. An improved E0P display stand is expected to be installed by June 30, 1992.

. Installation of control panel enhancements (labels, mimics, demarcation) were continued in the control room and simulator.

• Efforts continue on the preparation of design packages for panel improvements to be installed in the 1992 Mid-cycle Outage and in RF0 9 (1993).

• We continued the signal-by-signal review of annunciator system and initiated the planning effort to establish scope and schedule for the annunciator upgrade.

• Plans are being made to finish re-painting the Control Room back panels with a target completion date of September 1, 1992.

• Installation of improved instrument scales continued in RF0 #8. Some of the instrument scales originally scheduled for replacement in RF0 8 were not installed because of emergent technical issues. It is expected that the scale replacement program will be completed by the end of RF0 9 as originally scheduled.

Progress and Summary of Changes - March 1992 to August 15, 1992

+ Completed installation of one additional light fixture in control room ceiling which completes physical work on control room lighting.  :

• Completed installation of E0P support stands in control room and simulator which completes Category 7 actions, as previously planned.

• Completed installation of control panel labels, mimics, and demarcations on control room panels in original (LTP 300) scope, as planned, including marking of RG 1.97 devices.

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ATTACHMENT 2 (Continued)

SCHEDULE B

+ Completed preparation of engineering change packages for CRDR modifications to be implemented in 1992 mid-cycle outage and in RF0 9, as planned.

• Initiated detailed design of annunciator replacement project.

• Continued re-painting of control room panels and began repainting of simulator panels. All front panels and the majority of the back panels are now complete.

• Conducted task analysis and prepared conceptual designs of panel C7 redesign in preparation for decision on scope and final design. The changes related to Panel C7 are as follows: (a) redesign of Panel C7, referred to in Reference 10, Appendix D as Package 16; (b) redesign N2 portion of C904, Package 20; (c) Replace Kaye Recorder, Package 22; and (d) rewire C7 switches (no package number). As previously documented in Reference 12, this work will be done in MC094 due to the long lead time for the design and procurement of the new panel.

• The following establishes schedules for two items: (a) Replacement of instrument scales is now expected to be completed by the end of RF0 9. (b)

The " priority paging" modification (Page III-18 of Reference 6) was installed in 1989. We are re-evaluating the adequacy of the priority paging feature as well as possible changes to the basic Gai-Tronics configuration. If more extensive modifications are undertaken, the scope and schedule will be provided in the next LTP update letter.

• Colored zone markings on instrument scales as described in Reference 10 (Page Ill-16) and the use of Light Emitting Diodes (LEDs) to replace indicator light bulbs continue to be worked as elective actions being done as part of the DCRDR project.

Progress and Summary of Changes - August 15, 1992 - February 15, 1993

• Implemented the following modifications during the 1992 mid-cycle outage, as planned:

- Rearranged post-accident sampling panels C174-C175

- Relocated reactor water cleanup control switches

- Relocated feedwater block valve control switches

- Rearranged area temperature annunciator modules

- Modified position indication lights for HPCI and RCIC turbine control and stop valves. One portion of this package (related to the HPCI governor valve) could not be completed owing to late material delivery and will be completed in RF0 9.

- Replaced RBCCW temperature recorder  !

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• Completed re-painting control panels in the Main Control Room and at the simulator.

• Completed the evaluation of LEDs as potential replacements for ET-16 indicator lamps. Concluded that currently-available products are not adequate for replacement of ET-16s. This modification will, therefore, not be implemented.

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ATTACHMENT 2 (Continued) i SCHEDULE B

• Continued engineering change packages for annunciator replacement project including portions to be implemented in 1994 mid-cycle outage and in RF0 10, as planned. Placed purchase order for replacement annunciator system, having selected a Beta microprocessor-based system.

• Continued on-line work to install replacement meter and recorder scales.

• The following establishes a schedule for the annunciator replacement project (LTP 327). The annunciator will be installed beginning in RF0 9 as previously committed, and will be completed by the end of RF0 10 (previously uncommitted).

• Continued evaluation of the prospective changes to the plant paging system.

As indicated in our previous LTP submittal, we no longer plan to complete the " priority paging" system. Instead, we are developing scope of work for-changes that will include efforts to address the difficulty of communicating to and from rotating machinery spaces. This was the subject of the initial HED. We expect to be able to provide a scope and schedule '

in the next LTP update.

Progress and Summary of Changes: February 15 - July 30, 1993

• Implemented the following modifications during the 1993 refueling outage  !

(RF0 9) as planned:

Rewired or replaced 29 control switches, continuing the program to achieve uniform switch positions and patterns. This completes the switch rewiring effort, except for switches on panel C7.

Replaced colored lens caps on approximately 1400 indicating lamps to standardize on lamp colors.

Rearranged indicating lights for electrical buses and breakers.

Continued the program to replace meter and recorder scales. We now  :

expect to complete action on the remaining meters by the end of the 1994 mid-cycle outage; meters will be replaced on-line to the extent practical. i Installed digital indicators to replace analog indicators for torus i temperature, RHR flow, and drywell temperature. l Completed the installation of valve position indication for the HPCI governor valve.

Installed direct indication of valve position for CV9068A/B by replacing the solenoid valves with valves containing integrated reed

, switches for position indicators.

Relocated two conductivity recorders to allow easier monitoring, j Installed power-available indication for the 120VAC busses.

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ATTACHMENT 2 (Continued)

. SCHEDULE B s Rewired field terminations in preparation for annunciator installation (begin in RF0 9 and complete on-line). ,

Installed enhancements on scram breakers.

Continued engineering change packages for the annunciator replacement  :

project; completed the package for the installation of the central -'

processor and associated components planned for installation in 1994.

Completed Factory Acceptance Test of microprocessor system;. system delivered.  :

• Currently re-evaluating the scope and schedule for the remaining work 1 pertaining to panel C-7 and the annunciator. These will be discussed in the next LTP update or an interim submittal.

. Reconsidered and cancelled the replacement of analog reactor water level and reactor pressure indicators with digital indicators. A sample digital indicator installed at the simulator did not meet operator needs for clarity. Replacement was not essential for CRDR because the original HED has been resolved by changes to the Emergency Operating Procedures.

= Continued evaluation and planning related to the plant paging system. To address the initial HED related to communicating to and from noisy areas, we have procured and satisfactorily tested wireless headsets for use in-such areas. This will close the initial HED.

• Completed installation of labels, mimics, demarcations and other.

enhancements under LTP 300. This completes the scope of LTP 300 except for the meter scale efforts described above.

• Continued installation of enhancements under LTP328. We expect to complete the on-line scope of LTP 328, including remaining enhancements, by December 31, 1993, as planned.

Progress and Summary of Changes - August 1, 1993 - January 31, 1994

• Completed installation of new Gai-Tronics page stations in the main control room, as planned.

• Continued installation of meter scales and replacement meters,. as. planned. .

We expect to complete the meter scale program before .or. during the'.1994 1 mid-cycle outage (MC010).

• Continued installation of other enhancen,ents on-line in 1993 and continuing in 1994. Remaining enhancements under LTP328 (2 sets of panel' labels) are expected to be completed next month which will complete the planned' enhancements program.

In summary, remaining corrective actions for this project will be implemented by the j end of MC0 #10, except for the Annunciator which will be installed in RF0 #10. l 1

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ATTACHMENT 2 (Continued)

SCHEDULE B l

• Reached final agreement on .the scope of panel C7 modifications (containment )

ventilation and gas treatment panel). Selected high-priority .HEDs will be- i resolved by equipment modifications, relocations, and enhancements. The  !

Kaye multi-channel recorder. now on Panel C7 will be replaced by-a l microprocessor-based system to-be installed'in'the main control area.

Installation of modifications that began in late 1993 is continuing during I on-line operations in 1994 and will be' completed in MC010. The Kaye replacement system has been delivered and is being tested in preparation for installation.

• Continued engineering, procurement and installation of the annunciator replacement. Field wiring termination work-that began in the.1993 refueling outage was completed. The replacement microprocessor system was-delivered and tested. Training was conducted on operation and maintenance of the system.

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AfTACHMENT 2-(Continued)

SCHEDULE B SEISMIC VERIFICATION PROGRAM (G. L. 87-02_1 (LTP #410)

Commitment Description The NRC's final Supplemental Safety Evaluation Report (SER) on Revision 2 of the Generic Implementation Procedures (GIP-2) for A-46 was issued via Generic Letter 87-02, Supplement 1, on May 22, 1992 (Reference 4). By September 21, 1992, each licensee was required to respond to the SER stating whether they intend to follow the GIP-2 guidance, provide a schedule for implementation of the GIP including ,

submission of a report summarizing the results of the A-4G review, and provide information on the procedures and criteria used to generate the in-structure response spectra used for A-46 implementation. Evaluation of equipment is to include (a) adequacy of equipment anchorage; (b) functional capability of essential  ;

relays; (c) identification of potential outliers and deficiencies; and (d) seismic systems interactions.

In our response (Reference 5), we committed to implement GIP-2 in its entirety and provided a description of the procedures and criteria used to generate the in-structure response spectra. A schedule of GIP-2 implementation and submission of a summary report was deferred to the February 1993 LTP semi-annual update (provided below).

In Reference 6, the NRC issued a Safety Evaluation Report (SER) approving our response. The SER assumed a commitment on BECo's part to implement the GIP-2 in its entirety and noted our in-structure response spectra should be treated as median-centered. We affirmed the NRC assumption to be correct in Reference 7 and clarified our continued commitment to implement the seismic verification program at Pilgrim Station through the GIP-2 and its subsequent revisions.

Our schedule for completion of the GIP and submission of a summary report is 120 days following completion of Refueling Outage #10, currently planned to commence in ,

April, 1995. This schedule is consistent with the 3-year completion recommended in '

SSER Section II 4.2.3 that specifies commencement of the 3-year period will begin when one of the following conditions is met:

• Receipt of staff approval of the in-structure response spectra to be used to resolve the USI A-46 (i.e. Reference 6). '

. 60 days following the licensee's initial submittal of acceptable procedures and criteria in generating those in-structure response spectra.

References

1) NRC Letter dated February 19, 1987, GL 87-02 l

2) BECo Letter 88-145, dated October 11, 1988, Response to GL 87-02 l

3) NRC Letter dated June 7, 1989, Acknowledgment of BEco Response 1

4) NRC Letter dated May 22, 1992, Generic letter 87-02, Supplement 1, I

5) BECo Letter 92-109, dated September 21, 1992, Response to GL 87-02, Supplement 1

6) NRC Letter dated November 18, 1992, SER of PNPS Response to GL 87-02, Supplement 1

7) BECo letter 93-019, dated February 11, 1993, Additional Information Regarding NRC SER of PNPS Response to GL 87-02, Supplement 1

8) BECo Letter 94-16 dated February 9,1994 Additional Response to GL 87-02, Supplement 1 Page 13 of 41 1

' ~

ATTACHMENT 2 (Continued)

SCHEDULE B Commitment History /Proaress Progress and Summary of Changes - March 1989 to February 1990 ,

A. Develop safe shutdown equipment list - Schedule Revised B. Recreate original seismic design basis documentation - Schedule Revised C. Training and commence walkdown of accessible areas - Schedule Revised The schedule for performing these three items was revised from Cycle 8 to Cycle  :

9 as a result of our re-assessment of the work to be performed for this seismic '

issue, with respect to the generic work scope for other similar existing and emerging seismic issues. By incorporating the similarities of work scope for each of the below listed issues into one set of physical activities, we can best optimize our resources. Other seismic issues include:

. Seismic Design Basis (USI A-40)

• Eastern Seismicity and Seismic Design Margins a

External Events (seismic) for Individual Plant Examinations Progress and Summary of Changes - February 1990 to November 1990 A revised schedule for implementation of the seismic verification program will be developed after issuance of the NRC SER resolving the GIP open issues.

Progress and Summary of Changes - December 1990 to February 1991 No changes from the previous report period.

Progress and Summary of Changes - March 1991 to August 1991 A schedule for implementation of the seismic verification program will be developed af ter issuance of the NRC SER resolving the GIP open issues. I Progress and Summary of Changes - August 1991 to February 1992 A schedule for implementation of the seismic verification program will be 1 developed after issuance of the NRC SER resolving the GIP open issues.  ;

Progress and Summary of Changes - March 1992 to August 15, 1992 Reference 4, issued the final NRC SER (SSER No. 2) resolving the GIP open issues and superseded all previous NRC SER documents. A response containing the following information will be made by September 21, 1992:

A statement whether we commit to use both the SQUG commitments and the l implementation guidance provided in GIP-2 as supplemented by the SSER No. 2 for the resolution of USI A-46.

• A plant-specific schedule for the implementation of the GlP and submission of a report summarizing the results of the USI A-46 review.

i Page 14 of 41

i 1

ATTACHMENT 2 (Continued) l SCHEDULE B

. Detailed description of the procedures and criteria used to generate the in-structure response spectra.

Progress and Summary of Changes - August 16, 1992 - February 15, 1993

. Three BECo personnel and a contractor have completed the GlP Seismic Walkdown and Evaluation SQUG Training Program.

• A safe shutdown equipment list has been developed and is undergoing final review and approval.

. A portion of the seismic walkdowns began in MCO #9, On-line walkdowns  ;

continue during operating cycle 9. Outage walkdowns are planned for RF0 9  !

with any further on-line portions in operating cycle 10. Remaining off- '

line portions will be done in MCO 10 and RF0 10.

• At BEco's request, a meeting was held in our Braintree offices on September 3, 1992, in which we presented our intended approach to A-46 resolution and solicited NRC feedback prior to preparing our Generic Letter 87-02 response letter.

Progress and Summary of Changes - February 16, 1993 - July 31, 1993

. Walkdowns . scheduled for RF0 9 were completed and other walkdowns are continuing while on-line. The goal is to minimize the impact of performing walkdowns during an outage where safe and practicable. ,

. Relays associated with the safe shutdown equipment list are being assessed- ,

via a full circuit analysis. This is a task being worked by Engineering and Operations. ,

• The majority of the SSEL equipment and relay evaluations are expected to completed by RF0 10.

• Cable tray walkdowns have been completed and the evaluations are expected to completed by RF0 10.

• Four more engineers have completed the SQUG Walkdown Screening and Seismic Evaluation Training Course (Total of 7 engineers now certified).

Progress and Summary of Changes - August 1, 1993 - January 31, 1994

• Remaining SSEL walkdowns have been planned and scheduled for MC0 #10.

• Relay evaluations are nearing completion. Discussions between engineering and operations concerning essential relay ~ designation is progressing'.

• A letter requesting a review of our A-46 plan has been sent (Ref 8)'. .We have completed an initiative that demonstrates the conservatism of the PNPS -

design basis spectra. This would justify it to be classified as a

" conservative design" spectra for A-46 implementation.

• Documentation packages are being assembled to support close-out.

Page 15 of 41

ATTACHMENT 2 (Continued)

SCHEDULE B PHYSICAL SECURITY IMPROVEMENTS (LTP #029)

C_ommitment Description In response to NRC inspection findings, and as a plant betterment activity, BEco committed to replace the security computer and improve certain security activities. This includes miscellaneous perimeter improvements (completed in December 1989), installation of new security computer facilities, a new security computer and access control system, and a backup power supply.

i References

1) NRC Letter 85-119, dated April 30, 1985 (RCR Report)

2) I&E Inspection Report 86-08 dated 5/29/86 Commitment History / Progress Progress and Summary of Changes - March 1989 to February 1990 A. Misc. perimeter improvements - Ccmplete B. Facilities change to house new computer - On Schedule for completion by December 31, 1990.

C. Backup power supply changes - Schedule revised D. Develop & install new computer & access control equipment - On Schedule for completion by December 31, 1991.

The schedule for backup power supply completion was revised from December 1990 to June 1991. This change was made to properly reflect the actual integration of this activity with respect to the remaining security improvement activities.

Progress and Summary of Changes - February 1990 to November 1990

+ Facilities change to house new computer - Schedule revised from December 31, 1990 to December 31, 1991.

• Backup power supply changes - Schedule revised from June 1991 to December 31, 1991.

. Develop & install new computer and access control equipment - On schedule for completion by December 31, 1991.

. System cutover of alarms and access control will be in full operation by June 30, 1992.

These changes in schedule are the result of unanticipated delays encountered during construction such as the procurement of materials to relocate existing fire water lines, removal of asbestos during building demolition, and contaminated material handling.

Page 16 of 41

ATTACHMENT 2 (Continued)

SCHEDULE B Progress and Summary of Changes - December 1990 to February 1991 Based on improvements undertaken to address NRC evaluations of our security perimeter conducted in 1990, and recent events in the Persian Gulf, we have re-focused our efforts involving physical security improvements to include additional work activities aimed at strengthening perimeter security. These additional activities will be completed in 1991 and include:

Upgrading the E-Field to a Series 5000 Installing a new Video Capture System Enhancing site lighting The integration of these activities with the present LTP activities necessitate changes to the projected completion dates. Progress summary and schedule changes are as follows:

• Construction has begun on a new facility to house the new security system computer. Renovations to the bottom floor of the Main Gate House have also begun. This is part of the revised security facilities scope. This work will continue through 1992; thus, the completion date is changed from December 31, 1991 to December 31, 1992.

• A new backup power supply (diesel generator) has been ordered, and expected.

delivery is March 1991. Final completion of installation is revised to December 31, 1992 to coincide with the computer facilities upgrade schedule.

• Performance acceptance testing of the new security computer system at the manufacturer's facilities has identified system problems that have delayed delivery. Delivery is anticipated within the next several months; therefore, staging and commencement of training and security operating procedure revisions are planned for 1991. The final completion date for the computer and access control equipment is changed to December 31, 1992.

• The system cutover of alarms and access control operational completion date is similarly revised to December 31, 1992 to accommodate the above schedule revisions.

Progress and Summary of Changes - March 1991 to August 1991

• Construction of a new facility to house the new security system computer is on schedule for completion by December 31, 1992.

Page 17 of 41 4

ATTACHMENT 2 (Continued)

SCHEDULE B e The new backup power supply (diesel generator) was received on July 19, 1991. Installation is on schedule for completion by December 31, 1992.

• Delivery of the new security computer syster has been delayed and is not anticipated until early 1992. The final (unpletion date of the computer and access control equipment is on scheduie fer December 31, 1992.

. System cutover of alarms and access cont,ol operational is on schedule for completion by December 31, 1992.

. We are shifting the implementation schedule from 1991 to 1992 for upgrading the E-Field to a Series 5000. This revision is based on resource re-allocations for 1991 necessitated by work scope increases on other non-security tasks during RF0 #8. The installation of a new Video Capture System and enhancement of site lighting remain on schedule for completion during 1991.

Progress and Summary of Changes - August 1991 to February 1992

• Construction of a new facility to house the new security system computer is on schedule for completion by December 31, 1992.

• Installation of the new backup power supply (diesel generator) is on schedule for completion by December 31, 1992.

• The security computer manufacturer has been unable to meet all of the contractual obligations to deliver the specified system on schedule. We are currently evaluating new manufacturers to complete the software ,

requirements for the security computer system. Selection of a new manufacturer is expected by April 1992 at which time an implementation schedule will be prepared. This delay also affects the system cutover of alarms and access control operations. A new schedule for these items will be provided in our next LTP semi-annual update.

. Upgrade of the E-Field is complete.

Installation of the Video Capture System is complete.

• All construction work on the enhancement of the site lighting is complete. ,

During post work testing, we discovered 2 areas (lights) that did not meet the light intensity requirements. One area (light) was corrected in January 1992. The remaining area (light) was completed in February 1992.

Page 18 of 41

ATTACHMENT 2 (Continued)

SCHEDULE B Progress and Summary of Changes - March 1992 to August 15, 1992

• Construction of a new facility to house the new security system computer is on schedule for completion by December 31, 1992.

• Installation of the new backup power supply (diesel generator) is on schedule for completion by December 31, 1992.

• The security computer manufacturer was unable to meet contractual obligations to provide the specified system. All involvement with this vendor has been terminated and we are currently evaluating proposals from new manufacturers to supply the specified system. Selection of a new manufacturer is expected in September 1992 at which time an implementation schedule can be prepared. This action also affects the access control system upgrade and system cutover of alarms. Resources are being expended to support completion by December 31, 1993 or sooner if possible. This will be clarified in our next submittal after selection of a computer manufacturer.

Progress and Summary of Changes - August 15, 1992 to February 15, 1993

• Construction of facilities to house the new security system is essentially complete except installation of a sprinkler system actuation panel and performance of fire system tests on the sprinkler, CO2 and alarm system.

Completion of these items and approval of occupancy permits is expected in March 1993.

• Completion of the new backup power system (DG/UPS) has experienced delay due to manufacturer supplied system / equipment problems and their resolutions. Items being resolved are the replacement of DG room louvers +

to support successful C02 system testing and UPS room HVAC' system replacement to handle heat load generation. Successful testing of fire suppression equipment will permit fuel loading, DG/UPS testing and commencement of secondary security load cutovers. Completion is now planned in May 1993.

• In December 1992, BECo contracted a new security computer manufacturer.

System shipment to PNPS is planned for January 1994 to be followed by installation, site acceptance and availability testing for a June 1994 completion, Access Control System upgrades and cutovers will be integrated with this effort to achieve project completion by December 31. 1994.

Progress and Summary of Changes - February 15, 1993 to July 31, 1993

• Construction of facilities to house the new security computer system is complete.

• Construction of the new backup power system (DG/UPS) is complete and all security power loads are now on the new supply and in final turnover to operations.

• In December 1992, BECo contracted a new security computer manufacturer.

System shipment to PNPS is planned for January 1994 to be followed by installation, site acceptance and availability testing for a June 1994 Page 19 of 41

ATTACHMENT 2 (Continued)

SCHEDULE B completion. Access Control System upgrades and cutovers will be integrated with this effort to achieve project completion by December 31, 1994. This project is on schedule with supporting activities focused on project completion in 1994.

Progress and Summary of Changes - August 1, 1994 - January 31, 1994

• Final turnover to operations of the new backup power system (DG/UPS) is complete.

. Shipment of the new Security Computer System, previously planned for January 1994 is now planned for March 1994. Following installation, site acceptance and availability testing, we expect an August 1994 completion.

The delay is a result of a partially successfully Factory Acceptance Test effort. Plans for Access Control System upgrades and cutovers and project completion still support completion by December 31, 1994.

{

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I Page 20 of 41

- - - - - -=. .

ATTACHMENT 2 (Continued)

SCHEDULE B GENERIC LETTER 89-10 SAFETY-RELATED M0V TESTING AND SURVEILLANCE (LTP #487)

Commitment Description Generic Letter 89-10 (Ref.1) expands the scope of the motor operated valve program required by NRC Bulletin 85-03 and its Supplement, to include additional testing, inspecting, and maintenance for all safety-related motor operated valves.

In our Reference 2 response to the Generic Letter, we committed to develop a program to enhance the maintenance, analysis, and testing already being conducted on M0Vs at Pilgrim. The Generic Letter calls for the development of this program within 1 year or one refueling outage from the date of the letter, whichever is later. For BECo, this schedule translates to RF0 #8. Our plan was to begin a design basis review of MOVs in the first quarter of 1991 and to begin testing in RF0 #9. Based on resource constraints in 1990, we revised the design basis review schedule to commence in the last quarter of 1991. This revision continues to support our commitment to begin testing in RF0 #9 and supports our program development schedule. We anticipate the testing will require three refueling outages, based on the extent of known scope. Additional scope determinations as a result of NUMARC and BWROG involvement will be factored into our final scope and schedule as appropriate.

Reference 6 requested Licensees to perform a plant specific safety assessment to determine if generic safety assessments performed by the NRC staff and the BWR Owners' Group are applicable. If MOVs are discovered with potential deficiencies of greater significance than the HPCI, RCIC, and RWCU MOVs, planned activities to address the generic letter were to be re-prioritized accordingly.

Notification within 30 days of receipt of Supplement 3 was required verifying a plant-specific safety assessment was performed and identifying whether there were MOVs with deficiencies of greater safety significance than in the HPCI, RCIC, and RWCU systems. An additional notification within 120 days of receipt was also requested to provide the criteria reflecting operating experience and.

the latest test data applied in determining whether deficiencies exist ~ in the HPCI, RClC, and RWCU MOVs.

In our Reference 7 letter, we concluded the subject valves in the HPCI, RCIC, and RWCU systems were capable of performing their safety function to provide I containment isolation in the event of a line break outside containment. This i submittal provided our 30 and 120 day response to the generic letter and l precluded having to perform a plant specific safety assessment. We also committed in Reference 7 to conduct diagnostic testing on the Reactor Water Cleanup (RWCU) M0-1201-2 valve during RF0 #8. We expanded our planned RF0 #8 testing to include 2 additional valves: RWCU M0-1201-5 and Closed Cooling Water MO-4010A.

The NRC issued a Request for Additional Information (RAI) (Reference 10) after reviewing our Reference 7 and 8 responses to GL 89-10 Supplement 3. BECo responded to the RAI on August 29, 1991 (Ref. 11).

4 Page 21 of 41

ATTACHMENT 2.(Continued)

SCHEDULE B ,

During the week of March 9-13, 1992, the NRC conducted an inspection of the PNPS GL 89-10 MOV program. As a result of this inspe-! ion Boston Edison committed to resubmit the GL 89-10, Supplement 3, response and accelerate the schedule for priority 1 valves to have the GL 89-10 actions completed by the end of RF0 10.

RF010 is scheduled for 1995. The remaining safety-related valves will be completed by the end of RF0 #11.

References

1) Generic Letter 89-10, dated June 28, 1989

2) BECo Letter 90-13, dated January 15, 1990

3) NRC Letter dated June 7, 1990, Respense to Generic Letter 89-10

4) NRC Letter dated June 13, 1990, Supplement I to Generic Letter 89-10

5) NRC Letter dated August 3,1990, Supplement 2 to Generic Letter 89-10

6) NRC Letter dated October 25, 1990, Supplement 3 to Generic Letter 89-10 '

7) BEco letter 90-158 dated December 17, 1990

8) BECo Letter 91-022, dated February 26, 1991

9) NRC Letter dated April 1,1991, Meeting Summary BECo/NRC

10) NRC Letter dated-June 24, 1991, RAI regarding GL 89-10 Supplement 3

11) BECo Letter 91-111, dated August 29, 1991 '

12) NRC Letter dated February 18, 1992, Closure of GL 89-10, Supplement 3

13) NRC Letter dated February 12, 1992, Generic Letter 89-10 Supplement 4

14) NRC Letter dated June 3, 1992, Inspection 50-293/92-80 Motor Operated Valve .

Inspection.

15) NRC Letter dated May 5, 1992, Motor Operated Valve Inspection at PNPS (NRC Inspection Report 50-293/92-80).

16) BEco Letter 92-044, Revision to GL 89-10, Supplement 3, Response

17) NRC Letter dated June 28, 1993,'GL 89-10 Supplement 5'

18) BECo Letter 93.135,l dated October 21",-1993, Response to GL89-10 Supplement 5

19) BECo Letter 94.005, dated January 7, 1994,.. Update to.GL89-10, Supplement 3

' Response Commj_tment History /Proaress Progress and Summary of Changes - February 1990 to November 1990

- Begin a design basis review of MOVs is on schedule for first quarter of 1991. i

- Begin testing is on schedule for RF0 #9 (completion within 3 refueling outages).

- 30 day notification in accordance with Generic Letter 89-10, Supplement 3 is planned for submittal by December 13, 1990.

120 day notification efforts are planned for submittal by March 13, 1991.

Progress and Summary of Changes - December 1990 to February 1991

- The schedule for commencement of design basis reviews of MOVs is being changed from the first quarter of 1991 to the last quarter of 1991. This schedule e revision continues to support our commitment to begin testing in RF0 #9.

- Begin testing is on schedule for RF0 #9 (completion within 3 refueling outages).

- 30 day and 120 day notifications are complete. '

3 safety related valves are on schedule for diagnostic testing during RF0 #8 (M0-1201-2, 1201-5, and 4010A).

- Development of a Program Plan is on schedule for completion by May 1,1991.

Page 22 of 41

l ATTACHMENT 2 (Continued)

L SCHEDULE B Progress and Summary of Changes - March 1991 to August 1991

- Commencement of design basis reviews of MOVs is on schedule for -the last quarter of 1991.

- Begin testing is on schedule for RF0 #9 (completion within 3 refueling outages).

- Diagnostic testing of M0-1201-2, 1201-5, and 4010A was conducted during RF0 #8.  ;

In addition to this testing, we completed diagnostic testing on the remaining GL i 89-10 Supplement 3 MOVs (4 valves) and on another 10 safety related MOVs. l

- Development of a Program Plan is complete. '

Progress and Summary of Changes - August 1991 to February 1992

- Design basis reviews of MOVs continue to support our commitment to begin testing in RF0 #9.

- Testing is on schedule to begin in RF0 #9 (completion within 3 refueling outages).

- Procedures are in preparation describing design basis review methodology, control of switch settings, and degraded voltage analysis. Additionally, a Nuclear Organization Procedure establishing our MOV program is in final review.

- The schedule for static testing of MOVs has been accelerated and some testing will be done during our mid-cycle outage prior to RF0 #9,

- MOVs tested using MOVATS test equipment were reviewed and have been retested using more accurate diagnostic test equipment or been reviewed to ensure there is sufficient margin.

Progress and Summary of Changes - March 1992 to August 15, 1992 Design basis reviews of MOVs continue to support our commitment to begin testing in RF0 #9.

Testing is on schedule to begin RF0 #9, GL 89-10 activities will be completed for priority 1 valves by the end of RF0

1. 10.

Reference 16 submitted a revision to GL 89-10, Supplement 3, response (Reference 8).

Nuclear Organization Procedure 92M1 " Motor Operated Valve Program" has been approved.

Precedures describing design basis review methodology and control of switch settings are approved. Draft procedures for degraded voltage of motors are being revised to include temperature effects on available torque. Additional procedures are being developed as necessary.

Progress and Summary of Changes - August 15, 1992 - February 15, 1993 Design basis review is on schedule to support commitment to complete Priority I valves by RF0 #10.

Static testing was performed during MCO 9.

New state of the art test equipment was purchased that provides direct stem torque and thrust measurements.

Significant MOV testing, maintenance, and inspections scheduled for RF0 9.

Page 23 of 41

ATTACHMENT 2 (Continued)

SCHEDULE B Progress and Summary of Changes - February 15, 1993 - July 31, 1993 Design Basis Reviews (DBR) and Diagnostic Testing are on schedule to complete Priority I MOVs (55 valves) by RF010. DBR and Testing related to the remaining Safety Related (SR) MOVs (35 valves) is also on schedule and is expected to be completed by RF0 11.

Significant MOV testing, maintenance and inspections were completed in RF0 9.

Maintenance and inspections were conducted on 56 SR MOVs. Diagnostic Testing was completed on 21 SR MOVs.

Through RF0 9, 46 out of a total population of 90 SR MOVs have been set up via diagnostic testing techniques. Through RF0 9, 29 of 55 Priority 1 MOVs have been set up via diagnostic testing techniques.

MOV testing, maintenance, and inspections are scheduled to continue in MCO 10, including the first phase of Dynamic Testing.

Progress and Summary of Changes - August 1, 1993 - January 31,.1994

. Design Basis Reviews (DBR), Diagnostic Testing, Inspections,-Maintenance and Modifications are on schedule to support the commitment to complete Priority 1 M0Vs (55 valves) by RF0 10. Similar efforts related to the remaining Safety Related (SR) MOVs (35 valves) are also on. schedule and are expected to be completed per the current commitment, RF0 11.

. The first phase of Dynamic Testing is on schedule'to commence in.MC010.~

• The.use of an alternative valve and actuator design _is under consideration for implementation on a certain population of MOVs. Candidate MOVs are those which would require significant modifications utilizing typical manufacturer product design and applications. The alternative design has:

several advantages including a -solid-state control system, enhanced-repeatability, _ reduced electrical power demand and a reduced preventative maintenance frequency. The alternate design would also decrease-the probability of potential common mode failure issues and diversify plant design.

• Our response to Generic Letter 89-10, Supplement 5. (Reference'18),

indicated actions to be taken to resolve the accuracy issues associated with the use of Liberty Technologies V0TES equipment. ~The following actions were required:

Update the VOTES test results using the revised property constants and.

torque correction _ factors. This action is complete. Subsequent to this action, Liberty issued Customer Service Bulletin (CSB) 031 that-requires review of test results due to a software problem in the V0TES equipment. This new action will be completed and updated by our next LTP submittal'.

Page 24 of 41

ATTACHMENT 2 (Continued) l l

SCHEDULE B

~

Revise Liberty Technologies test results to use a curve fit' algorithm and determine extrapolation error. This action is complete.

Subsequent to completion, Liberty issued CSB-031' causing a need to review post test results. This new action will be completed and updated by our next LTP submittal, d

Page 25 of 41

ATTACHMENT 2 (Continued)

SCHEDULE B IMPLEMENT ROOT CAUSE AND CORRECTIVE ACTIONS TO ADDRESS CAUSES OF WELD FAILURE (LTP #292)

Commitment Description Provide operator access to RHR Vent Valves, Low Pressure Emergency Core Cooling System (LPECCS) Vibration Monitoring, replace RHR Discharge Pressure Switches (Low Pressure Alarm), collect data on throttling globe and gate valves that could cause erosion and vibration problems and determine if alternatives are required. Review of methods to establish MOV thrust will be performed as part of our Generic Letter 89-10, Motor Operated Valve Testing effort.

Reference BECO Letter 88-140, dated September 28, 1988 (Appendix 10 Items #01-013-01 & #03-916-06)

Commitment History /Proaress Progress and Summary of Changes - March 1989 to February 1990 On Schedule for RF0 #8.

Progress and Summary of Changes - February 1990 to November 1990

- Operator access to RHR Vent Valves is on schedule for completion by RF0 #8.

LPECCS Vibration Monitoring is on schedule for completion by RF0 #8.

Investigate alternatives to throttling globe and gate valves and review methods to establish MOV thrust are on schedule for completion by RF0 #8.

Replace RHR Discharge Pressure Switches (Low Pressure Alarm) is on schedule for completion by RF0 #8.

Progress and Summary of Changes - December 1990 to February 1991  !

- Operator access to RHR Vent Valves is on schedule for completion by RF0 #8. ,

- One area has been determined to require a permanent modification to facilitate l venting. Re-routing of the vent lines for valves 10-H0-397/398 will be '

performed during RF0 #8.

LPECCS Vibration Monitoring is installed. Additional monitoring will be performed during RF0 8.

- Collect data un throttling globe and gate valves that could cause erosion and vibration problems will be performed during RF0 #8.

Page 26 of 41

ATTACHMENT 2 (Continued) i SCHEDULE B Evaluate collected data on throttling globe and gate valves to determine if alternatives are required will be performed post RF0 8.

Review of methods to establish MOV thrust will be performed as part of our ,

Generic Letter 89-10, Motor Operated Valve Testing effort (LTP #487).

- Replace RHR Discharge Pressure Switches (Low Pressure Alarm) is on schedule for  !

completion by RF0 #8.

Progress and Summary of Changes - March 1991 to August 1991

- Operator access to RHR Vent Valves is complete

- Re-routing of the vent lines for valves 10-H0-397/398 is complete.

- Additional LPECCS vibration monitoring was performed during RF0 #8. The LPECCS vibration monitoring system was activated to monitor during the shutdown cooling mode. The system was set to continuously monitor various accelerometer locations to trigger an alarm upon high vibration due to a water hammer event or valve cavitation. No system activation occurred at the established setpoints and no failure of vent or drain welds were discovered during the last operating cycle. We attribute this reduction in water hammer events to the activities undertaken to enhance venting capabilities as mentioned above and changes made to operator venting instructions such as backflushing to remove any steam bubbles prior to venting. Therefore, we intend to continue the monitoring ,

during the present fuel cycle with lower setpoints. More attention will.now be ,

focused on vibration related to steady-state flow and valve . cavitation.- Steady-state vibration data will be recorded from'each data point with the system operating in the torus cooling and mixing modes at various flow rates. An analysis of this steady-state vibration will then be performed. Based on the results of the analysis, additional vibration surveys of the piping system may be performed using portable vibration instrumentation. . During the next mid-cycle outage, similar monitoring will be performed with the system in the shutdown cooling mode. Once the vibration under these conditions has been analyzed, we will determine the need for any alternative activities.

Replace RHR Discharge Pressure Switches (Low Pressure Alarm) is complete.

Progress and Summary of Changes - August 1991 to February 1992  !

Vibration monitoring has been conducted since RF0 #8 for ten monitoring I locations identified as areas of particular interest by previous investigations.

Based upon preliminary monitoring to date, the trigger level for alarming and-data acquisition was lowered. Previously, the system was set to trigger on potentially high level transients caused by water hammer events. In the absence j of any of these transients, the alarm levels are now set to detect lower '

vibration levels indicative of valve throttling and/or cavitation. Monitoring and data recording of these ten locations will continue. Particular attention will be given to shutdown cooling, suppression pool cooling, and surveillance testing.

Page 27 of 41 ,

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._ ~ . . - - ---

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ATTACHMENT 2 (Continued)

SCHEDULE B Progress and Summary of Changes - March 1992 to August 15, 1992 Monitoring and data recording of the ten locations is continuing. Shutdown cooling, suppression pool cooling, and surveillance testing monitoring will be performed during MCO 9. The need for alternative activities will be determined once the vibration under these conditions has been analyzed. Corrective actions previously taken appear successful; no failures occurred during this report period.

Progress and Summary of Changes - August 15, 1992 - February 15, 1993 Monitoring of the original ten locations was completed in MCO 9. The data evaluation is in progress' ISI inspections during MC0 9 found one RHR lateral restraint with failed structural welds. Additional strain gauge and vibration monitoring was done immediately after repair of the support. A root cause analysis has shown that normal system startup transients were the primary cause_

of low cycle fatigue failure. Support modifications are being designed to l prevent recurrence. A schedule will be provided in the next LTP submittal.

Progress and Summary of Changes - February 15, 1993 - July 31, 1993 The final root cause evaluation and related calculations for the failed RHR lateral restraint (H10-1-102S) determined that steady-state vibration stress levels are negligible versus the normal system startup transient stresses.

Steady-state vibration, therefore, did not contribute to the failure of this support. The final evaluation included a conceptual design for a new RHR lateral restraint to be added to share the startup transient loads with the existing seismic restraints. The detailed piping aesign calculation for RHR.is-now being revised to include the conceptual support modifications so that the suitability of the modification can be evaluated. The detailed support design will then be done to produce a Plant Design Change package. It is anticipated that the modifications can be done with the plant on-line in 1994.

Progress and Summary of Changes - August 1,1993 - January 31,l1994 A plant design change to address vibration related support failures on _the RHR piping is being prepared by engineering and the modifications will be completed in 1994. ' RHR lateral restraint H10-1-102S will. be modified to withstand the system startup transient loads that were found to have caused the previous weld failure. No other piping or pipe support weld failures have been detected since this LTP monitoring _ effort began in 1990. This LTP will be closed when the RHR pipo support modification is completed. If any piping or support' failures occur in the future, they will be addressed within the station's Problem Report process.

i Page 28 of 41 )

i

ATTACHMENT 2 (Continued)

SCHEDULE B GENERIC LETTER 89-13. SALT SERVICE WATER SYSTEM (LTP #255, 473)

Commitment Description Generic Letter 89-13 required licensees to review and evaluate the adequacy of the service water system and all safety related heat exchangers. The review identified a number of enhancements to the PNPS programs and procedures. As a result, BECo committed via Reference 2 to the following:

• Prior to end of RF0 #8, modify the RBCCW heat exchanger test procedures to include an analytical model to calculate RBCCW heat exchanger performance at test and design conditions (complete). Conduct tests with modified procedures during Cycle 9. (Complete)

• Prior to end of RF0 #9, modify the RHR heat exchanger test procedures to ,

include an analytical model to calculate RHR heat exchanger performance at test and design conditions. Conduct tests with modified procedures during Cycle 10.

• Develop a regular maintenance / test program on heat transfer capability of.

the remaining heat exchangers by RF0 #9, (Complete)

• Conduct a Single Failure Analysis for the RBCCW subsystem by end of RF0 #8.

(Complete)

• Prior to end of RF0 #8, upgrade the licensed operator training module to include a loss of all service water. (Complete)

Credit was also taken in Reference 2 for the SSW piping inspection and replacement program already underway at Pilgrim, which henceforth will be integrated as part.of our Generic Letter 89-13 implementation efforts.

R_ferences e

1) Generic Letter 89-13, " Service Water System Problems Affecting Safety-Related Equipment"

2) BEco letter 2.90.047, dated April 2, 1990, " Response to Generic Letter 89-13" Commitment History / Progress Progress and Summary of Changes - March 1990 to November 1990 The licensed operator training module upgrade is complete.

There are no changes to the other above-described commitments and schedules.

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ATTACHMENT 2 (Continued) .

SCHEDULE B Progress and Summary of Changes - December 1990 to February 1991 A single failure analysis of the RBCCW subsystem has been performed.

There are no changes to the other above-described commitments and schedules.

Progress and Summary of Changes - March 1991 to August 1991 RBCCW heat exchanger test procedures have been modified to include an analytical model to calculate RBCCW heat exchanger performance at test and design conditions.

In addition, activities associated with SSW piping inspection and replacement are being integrated under our GL 89-13 effort. Further inspections of the SSW '

piping will be scheduled during each planned mid-cycle or refueling outage of sufficient duration. It remains our intention to replace SSW piping when the inspection of piping shows that to be necessary.

Progress and Summary of Changes - August 1991 to February '1992 Efforts to enhance the Salt Service Water System are proceeding as indicated in our response to Generic Letter 89-13. There are no changes to the above-described commitments.

Progress and Summary of Changes - March 1992 to August _ 15, 1992 A decision was made to replace the buried SSW piping with corrosion-resistant titanium. Five Plant Design Change Packages were prepared to facilitate replacement of the pipe. Construction of a. pipe vault at the intake structure is in progress. Replacement activities will continue through MC09 and RF09.

Above ground piping will be routinely examined by non-destructive technology (typically UT) and will be replaced as required. Efforts ~to enhance the SSW system are proceeding as indicated above.

Progress and Summary of Changes - August 15, 1992 - February 15, 1993

• There are no changes to the GL 89-13 (LTP 473) commitments described above.

• We are currently installing replacement SSW underground piping (LTP 255) in preparation for system tie in RF0 #9 (4/93). To support this effort, during MC0 9 (10/92) we replaced spool pieces in the Auxiliary Bay and Screen House. We also plan to replace the remainder of the Intake Structure and Auxiliary Bay above ground inlet piping and tie in the new inlet loop buried piping in RF0 #9.

Progress and Summary of Changes - February 15, 1993 - July 30, 1993

• RBCCW Heat Exchanger testing was completed on schedule in cycle 9. The RHR Heat Exchanger Test Procedure and Analytical Model was completed on schedule in RF0 9. The Heat Exchanger Maintenance and Test Program for Heat Transfer Capability was also completed on schedule in RF0 9. There are no changes to the remaining'GL 89-13 (LTP 473) commitments described l above. l Page 30 of 41 i 1

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ATTACHMENT 2 (Continued)

SCHEDULE B

• Replacement of the SSW piping (LTP 255) was completed on schedule in RF0 9.

Through RF0 9, 250 feet of above ground rubber lined carbon steel pipe has been replaced. In addition, 430 feet of buried rubber lined carbon steel pipe has been replaced with Titanium pipe. Augmented ISI of above ground rubber lined carbon steel pipe was also completed on schedule in RF0 9.

Future ISI will be captured under LTP 473. LTP 255 is completed.

Progress and Summary of Changes - August 1, 1993 - January 31, 1994

• There are no changes to the remaining GL-89-13 commitments described-above.

In summary, RHR heat exchanger tests will be conducted with modified

procedures during Cycle 10. Ongoing inspections of the Salt Service Water System have been incorporated into our ISI program.

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ATTACHMENT 2 (Continued)

SCHEDULE B -1

-l GENERIC LETTER 88-20 Supplement 4. Individual Plant Examination - External Events l (LTP# 567) ,

Commitment Description In response to GL 88-20 Supplement 4 (Ref. -1), BEco provided a program plan for completing an Individual Plant Examination of External Events (IPEEE) for severe accident vulnerabilities for the Pilgrim Nuclear Power Station (Ref. 2). The JPEEE scope will include seismic events, internal fires, high winds, external floods, and transportation and nearby facility accidents.

Our schedule for completing the IPEEE and submitting the results is July 1, 1994. Significant milestones include:

• Initiate Fire PRA tasks

• Initiate Seismic PRA tasks

• Initiate remaining external event tasks

• Screening walkdowns for fire and seismic

• Final seismic walkdowns

• Complete Fire PRA

• Complete remaining external events

• Complete Seismic PRA

• Integrate IPE/IPEEE The NRC confirmed the acceptability of our schedule and program plan in Reference 3.

References

1) Generic Letter 88-20, Supplement 4, dated June 28, 1991

2) BECo Letter 91-155, dated December 24, 1991

3) NRC Letter 92-159, dated June 16, 1992 Commitment History / Progress Progress and Summary of Changes - August 1991 to February 1992 Pilgrim Station is a USI-A-46 plant and a member of the Seismic Qualification

, Utility Group (SQUG). Because of the similarities of the A-46 and seismic IPEEE programs, we intend to conduct walkdowns at the same time to avoid repetition of essentially the same work within a short time span. This is consistent with the Generic Letter 88-20, Supplement 4, guidance that states; "USI-A-46 should be coordinated with the IPEEE so the objectives of both activities may be accomplished with a single walkdown effort." However, the anticipated Supplemental Safety Evaluation Report (SSER) on the SQUG's Generic Implementation Procedure (GIP) for resolution of USI-A-46 has not been made available within the October 1991 time frame, as expected by the NRC when Supplement 4 was issued. The issuance of the SSER will affect the achievement of the above-planned walkdown tasks and ultimately the IPEEE completion date.

The final issuance date, the content of the SSER, and the resolution of open issues, will be factors in establishing a program schedule for conducting the seismic IPEEE.

Page 32 of 41

ATTACHMENT 2 (Continued)

SCHEDULE B Progress and Summary of Changes - March 1992 to August 15, 1992 IPEEE is on schedule for completion and submittal to the NRC by July 1,1994.

Progress and Summary of Changes - August 16, 1992 - February 15,-1993 IPEEE is on schedule for completion and submittal to the NRC by July 1,1994.

Progress and Summary of Changes - February 16, 1993 - July 31, 1993 The fire PRA has been completed and is undergoing both peer review'and organization-wide independent review The "other" events assessment has been completed. Both peer review and organization-wide independent review has been completed and the report is being finalized.

The seismic PRA is progressing well and quantification should begin next month. ,

The full IPEEE is on schedule for completion and submittal to the NRC by July 1, 1994.

Progress and Summary lof Changes August 1, 1993 - January 31, 1994

• Comments from peer and independent reviewers for the fire PRA are being.

resolved and the report is being finalized.

• Seismic PRA quantification is ongoing and should be completed in the near-term.

• The documentation for the IPEEE submittal is progressing and will support submittal- of the report as scheduled.

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ATTACHMENT 2 (Continued)

SCHEDULE B CLASS I PIPING SEISMIC DAMPING RATIO (LTP #599)

Commitment Description In Reference 1, BECo committed to re-evaluate two changes to the Final Safety ,

Analysis Report (FSAR) in which certain Class I piping seismic damping ratios were increased and NRC approval for the damping ratio changes was not sought under 10CFR50.59. Planned actions included identification of stress analyses where the higher damping ratios were used, resolution of discrepancies between the existing design and the regulatory guidelines, development of enhanced design specifications for piping and supports, and systematic review of safety grade piping systems to demonstrate conformance with the appropriate specification. These activities were planned for completion by RF0 #9.

During the implementation of these actions, we decided to integrate a segment of our GL 87-02, Supplement 4, activities involving soil / structure interaction studies and floor response spectra methodologies. Doing so would optimize resources and effect consistency in the seismic design basis.

This approach was initially discussed with the NRC in Reference 2 during which we also committed to provide a summary level detail of scope and projected schedule in the next LTP update. Our plan is as follows:

• Develop New Reactor Building Floor Spectra (complete)

This task produce new floor spectra for the Reactor Building for both the Housner and R.G. 1.60 ground response spectra, anchored at 0.089 OBE and 0.15g SSE. The spectra includes the benefit of soil structure interaction and time history inputs that produce ground response spectra closely fitting the Housner and R.G.1.60 spectral shapes.

- Perform Spectra Comparisons and confirmatory stress analyses (complete).

The seismic demand imposed by the new Housner floor spectra at original design basis damping levels will be compared to the spectra with elevated damping levels used pursuant to R.G.1,61 and Code Case N411. The new Housner floor spectra essentially envelope the spectra with elevated damping. This means piping analysis with the new spectra would produce .

lower stresses and hanger loads. Confirmatory pipe stress analyses are also being performed. We expect the final results will demonstrate we can meet the original design basis damping requirements with the new floor spectra as the seismic demand basis.

. Assess Results and Determine Design Basis Application (compl ete) .

This includes a decision on whether to propose adopting the new Housner floor spectra as our design basis and the new R.G.1.60 floor spectra in conjunction with the use of R.G. 1.61 and Code Case N411 damping as well as developing a final LER response.

= Forward Licensing Submittals to NRC, as necessary, in Accordance With Above Assessment Results (complete).

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ATTACHMENT 2 (Continued)

SCHEDULE B References

1) BEco Letter 92-014, dated February 21, 1992

2) BECo/NRC phone call dated January 14, 1993.

Commitment History /PCo.gress o

Progress and Summary of Changes - March 1992 to August 15, 1992 We are presently re-evaluating the effects of using Code Case N-411 damping ratios with the design basis seismic response spectra in the analysis of safety-related piping systems. The conservatisms of our original design damping ratios and response spectra will be compared to conservatism of the more recent seismic damping ratios of. Code Case N-411 when used in conjunction with the response spectra of Regulatory Guide 1.60. The Scram Discharge piping will be the first system to be re-analyzed with this revised amplified response spectra.

Progress and Summary of Changes - August 15, 1992 - February 15, 1993 In Reference 2, we notified the NRC of planned changes to the original Reference 1 plan of action. The revised action plan is described above under the commitment description section. Future reporting of status and scope will continue via LTP Program updates.

Progress and Summary of Changes - February 15, 1993 - July 31, 1993 New Reactor Building Floor Spectra were generated. Final acceptance of the spectra by our Engineering Department occurred in August 1993.

Spectra comparisons and confirmatory stress analyses are planned to be completed by September 30, 1993. Resulting applicable Licensing correspondence is planned for submittal on or before December 1,1993.

Progress and Summary of ChangesL- August 1, 1993 - January 31, 1994 The results of our Spectra comparisons and confirmatory stress analyses demonstrated the original design basis damping requirements are met with the new.

floor spectra as the seismic demand basis. Based on these results we concluded >

existing R.G.1.61/N-411 damping spectra analyses have substantial margins and are conservative when compared to the new Housner floor spectra and the new R.G.

1.60 spectra with N-411 damping. Since these results are less than design basis allowables, we concluded no further systematic piping re-analyses are required and the new spectra calculations are valid for design basis considerations. The specific details of the methodology and results were presented to the NRC during ,

a meeting at our facilities on October 14, 1993.

We consider the application of the new spectra applicable only to the resolution of the damping issues identified in LER 92-001-00 and any future design basis reviews, evaluations, analyses, or other considerations will be based on existing FSAR design criteria. We are considering, further, the submittal ofi the new spectra to the'NRC for review and approval as an FSAR amendment, but this decision is. beyond the resolution scope for. closure of this LTP item.

Based on the above actions and resulting conclusions'we consider this item closed and it will be removed from future LTP submittals.

Page 35 of 41

ATTACHMENT 2 (Continued)

SCHEDULE B RWCU PIPING REPLACEMENT (LTP #600)

Commitment Description Generic Letter 88-01 was issued to address Intergranular Stress Corrosion Cracking (IGSCC) in stainless steel pipe materials. BEco replaced the recirculation system and IGSCC susceptible material in the drywell. BECo responded to the NRC and committed to comply with Generic Letter 88-01 except for the RWCU system between valves 1201-5 and 1201-80. This response was rejected by the NRC Safety Evaluation of the BECo Generic letter 88-01 response (NRC Letter 1.90.104, 4/26/90). BECo responded (BECo Letter 2.90.140, 11/15/90) by stating the following for the non-safety portion of the RWCU system: "We will perform an inspection of 10% of these welds during each refueling cycle. If a flaw is discovered in the 10% sample and IGSCC is determined as the probable cause, another 10% will be inspected. If an IGSCC induced flaw is discovered in the second 10% sample, no further inspections will be conducted. The identified flaws will be repaired and plans will be made to replace RWCU non-code piping in subsequent refueling outages."

IGSCC susceptible pipe per Generic Letter 88-10 is non-resistant austentic stainless steel pipe 4" NPS and greater operating at a temperature greater than 200 F.

During RF0 #8 inspections were made of the safety and 10% of the non-safety (non-code) pipe. IGSCC was found. There was a discussion with the NRC at that time and the commitment quoted above was altered. Rather than inspect an additional 10% of the non-safety pipe, the areas of the safety and non-safety pipe that had IGSCC would be replaced and all IGSCC susceptible pipe would be replaced in future outages. This increased the original scope by adding the safety-related RWCU pipe into the replacement commitment. Piping was replaced in the areas where IGSCC was found during RF0 #8 by Plant Design Change 91-39.

References

1) NRC Generic Letter 88-01

2) NRC Letter 90-104, dated April 26, 1990

3) BECo Letter 90-140, dated November 15, 1990 Commitment History / Progress Progress and Summary of Changes - March 1992 to August 15, 1992 A Plant Design Change has.been developed to replace remaining safety related and ,

non-safety related IGSCC susceptible pipe in the RWCU system. Plans are being l made to replace the balance of susceptible piping in RF0 #9 and MC0 #10.

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ATTACHMENT 2-(Continued)

SCHEDULE B Progress and Summary of Changes - August 15, 1992 to February 15, 1993 A Plant Design Change was approved and issued for construction to replace the remaining safety related and non-safety related IGSCC-susceptible pipe.

Replacement of the safety related IGSCC susceptible pipe in the RWCU System Heat Exchanger Room and some of the non-safety related piping is scheduled to take place in RF0 #9, with the balance of safety related piping outside the Heat Exchanger Room to be replaced in MCO #10. We are currently reassessing our plans to replace the remaining non-safety related piping. This reassessment is-to consider the alternatives presented in Generic Letter 88-01, Supplement I relative to replacement / inspection plans.

Progress and Summary of Changes - February 15, 1993 to July 31, 1993 Replacement of a portion of the safety and non-safety related piping with IGSCC resistant material in the RWCU System Heat Exchanger room was completed in RF0

1. 9. _ The balance of the safety related piping, most of which is outside the heat exchanger room, was planned for MCO #10. The planned duration of MC0 #10 has been shortened and provides too small a window for replacement activities.

Hence, this work has been deferred to RF0 #10 when an adequate replacement.

window exists. We are also considering the alternatives presented in GL 88-01, Supplement 1, relative to replacement / inspection plans as they relate to the balance of IGSCC susceptible non-safety related piping.

Progress and Summary or Ch=nces - August 1,1993 - January 31, 1994 No changes have taken place or are planned.

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SCHEDULE B EDSFJ HVAC (LTP# 583)

Commitment Description The Switchgear and Battery Rooms contain safety-related electrical equipment.

Area cooling is provided by the non-safety related Turbine Building Ventilation System. An analysis of the electrical equipment operability was conducted in I

response to a concern raised by the NRC during the Electrical Distribution System functional Inspection. Compensatory measures were established to ensure the electrical equipment would perform its intended function. An analysis of the temperature response of the Switchgear and Battery Room due to a loss of HVAC will be conducted. Compensatory measures will remain in place until this is resolved.

References

1) BECo Letter 91-101, dated August 8, 1991, " Response to NRC Electrical Distribution System Functional Inspection (EDSFI), Switchgear/ Battery Room HVAC Concern

2) BECo Letter 91-117, dated October 11, 1991, " Revised Response to NRC Electrical Distribution System Functional Inspection (EDSFI) 3 Switchgear/ Battery Room HVAC concern  !

3) NRC Letter 91-287, dated October 18, 1991, " Electrical Distribution System l

Functional Inspection (EDSFI), inspection Report No. 50-293/91-80

4) BEco Letter 91-145, dated October 24,1991, " Update to Electrical I Distribution System Functional Inspection (EDSFI) Switchgear/ Battery Room l HVAC issue"

5) BEco Letter 91-999, dated November 25,1991, " Reply to Notice of Violation, Unresolved items and Observations Identified During the Electrical Distribution System Functional Inspection (EDSFI) (Reference IR 91-80)" i

6) BECo Letter 92-004, dated January 17, 1992, "EDSF1 - HVAC Review"

7) BECo Letter 92-068, dated June 30, 1992 " Update to Unresolved Item 50- ,

293/91-80-02 Identified During the Electrical Distribution System Functional Inspection" Commitment History / Progress Progress and Summary of Changes - March 1992 to August 15, 1992 i

An analysis of the temperature response of the Switchgear & Battery Room was 4 conducted. In addition, a test of the Turbine Building HVAC system was conducted to support the operability. evaluation. The test results reinforced the conclusions previously derived in the operability assessment. The tests results were factored into the temperature prediction model. These predictions correlated well with the actual field data. A plant design change to provide SR ventilation utilizing the temperature model results is being evaluated to restore full design margin. An implementation schedule will be provided in the next LTP submittal.

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ATTACHMENT 2 (Continued)

SCHEDULE B Progress and Summary of Changes - August 15, 1992 to February 15, 1993 This issue is currently being reanalyzed. There is a reasonable chance that the reanalysis will demonstrate modifications are not necessary. -However, should the reanalysis support a modification, a plant design change to provide safety-related ventilation to the switchgear & battery rooms is being prepared. The design and procurement of long lead materials is expected to be completed by September 1993. The ventilation system modifications are ,

expected to be completed by June 30, 1994.

Progress and Summary of Changes - February 15, 1993 to July 31,-1993 ,

This issue continues to be analyzed to confirm that plant design and >

procedural guidance is adequate to assure safety-related equipment operability.

Should the reanalysis support a modification, a plant design change to provide safety-related ventilation to the switchgear and battery rooms is being prepared as a contingency, and is nearing completion. If modifications are required it is expected they would be completed by June 30, 1994.

Progress and Summary of Changes - August 1, 1993 - January 31, 1994 Reanalysis of plant design and procedural guidance demonstrates a modification to provide safety-related ventilation to'the switchgear and battery rooms is necessary to restore full' design margin.

The plant design change to provide safety-related ventilation toithe switchgear and battery room-has been completed. Procurement of long lead  :

items is in progress.' Based on the rescheduling of the MCO. from April to October 1994, we anticipate completion of this modification by December. 31, l 1994.

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ATTACHMENT 2 (Continued)

SCHEDULE 8 LOW PRE 15URE TURBINE ROTOR REPLACEMENT PROJECT (LTP #401)

C J mmitment Description As a result of a generic industry concern of cracking in shrunk-on wheels of low pressure rotors, General Electric issued TIL857-3 in 1978 which outlined a newly designed testing process known as the " Wheel Sonic Test". When General E hctric inspected the PNP 3 low pressure rotors for this phenomenon in 1980, these cracks were discovered in the axial keyway. Inspactions ?n subsequent refueling outages have determined that some of the existing cracts have propagated and a few new cracks have formed over the succeeding operating cycles.

The shrunk-on wheels on the low pressure rotors have identified cracks in the hub and web regions of the keyways on 8 stages of LP B rotor and 8 stages of the LP A rotor. These cracks are individually less than the lower bound critical crack sizes. Dovetail cracking near the tangential entry slot was indicated by ultrasonic test performed on LP A rotor during RF09. Some buckets were removed from the 6G-stage and additional cleaning, magneti ,

particle testing, and grinding were performed. Removal of 30 mils at two of the worst indications showed that the crack size was decreasing and further grinding was suspended. The buckets were reinstalled and the turbine was reassembl ed . Other indications were noted on the SG & 6T wheels.

Erosion / corrosion of the inner castings for LP A and B required repairs in RF0 8 and RF0 9, respectively. Deterministic analysis of the keyway cracks was performed by Structural Integrity Associates and showed that the rotor could be safely operated for an additional cycle. New LP rotors are scheduled for installation during RF010.

Commitment History / Progress Progress and Summary of Changes - February 15, 1993 - July 31, 1993

• Bids were received and evaluated for various replacement options. A letter of intent was issued to General Electric Company on July 2,1993.

• The scope of work for this project includes replacement of existing rotors with new monoblock rotors, new inner casings and new L-0 and L-1 stage diaphragms.

• The new LP rotors are scheduled for installation during RF0 #10.

Progress and Summary of Changes - August 1, 1993 - January 31, 1994

• The project continues on schedule for installation during RF0 #10.

• A joint design review of the rotors and inner casings was successfully_

completed in December,1993,

• Forgings for both rotors are in rough ~ machining and heat treating phases'of production The inner casing sub supplier to General Electric Company has becii Atd and will . start ordering materials approximately February 1, 1994.

Page 40 of 41

ATTACHMENT 2 (Continued)

SCHEDULE B NEUTRON FLUX MONITORING (LTP #377)

Commitment Description Generic Letter 82-33 required utilities to report on implementation of R'egulatory Guide 1.97. Boston Edison, and some other utilities with Boiling Water Reactors, took exception to requirements related to neutron flux monitoring systems. Subsequently, the BWR Owners. Group submitted NED0-31558 that proposed alternate criteria for neutron flux monitoring. NRC issued a safety evaluation and accepted the NED0-31558 criteria in Reference 1.

In Reference 2, the NRC requested utilities to review the neutron flux monitoring instrumentation against the NEDO-31558.to determine whether the installed system meets the criteria and to submit a letter to the NRC with the results of the review.

Boston Edison's reply (Reference 3), identified that Pilgrim Station met _the ~

criteria of NED0-31558 with certain clarifications and exceptions.

Our- exception concerned the requirements for uninterruptible power supplies (Criterion 5.2.8 of NED0-31558). Boston Edison took exception and provided a basis for the acceptability of the present Pilgrim Station design (Reference 3).

We are taking no further action on this item.

In Reference 3, Boston Edison committed to perform an analysis of the ATWS conditions in the drywell for comparison with NMS design specifications. We further stated we would be working with other BWR owners on this issue.

References

1) NRC Letter dated January 13, 1993 from A. Boyer to C.L. Tully, BWR Owner's Group

2) NRC letter dated August 11, 1993, Reg Guide 1.97, BWR Neutron Flux.

Monitoring (TAC M77660)

3) BEo letter 93-136 dated October 2i,1993 Commitment History /Proaress Progress and Summary of Changes - August 1, 1993 - January 31, 1994 As planned, Boston Edison has joined with several other BWR owners throuch the BWR Owners Group to sponsor an analysis to determine-the ATWS environment and to compare the calculated temperatures with design ' specifications'. The BWROG task is underway and expected to be complete in approximately 6 months. We will-provide an update on the analysis and its results in the next LTP update at which time we expect to be able to identify what,'if any, additional efforts will be required.

Page 41 of 41

ATTACHMENT 3 .

ADDITIONAL ITEMS LIST (SCHEDULE C)* .

AUGUST 1993 ITEM TARGET SCHEDULE CURRENT STATUS Degraded Voltage Study (LTP #015) Cycle 8 & Ongoing. No further work  ;

Specific identified planned modifications were transferred to Schedule B. Schedule B items complete.

Radwaste Betterment (LTP #022) Project completion End of 1997 planned in 1996 Spent Resin Storage Tank Replacement (LTP #023) Schedule being re- Cancelled evaluated Additional Spent Fuel Storage (LTP #085) Prior to RF0 #10 On Schedule ,

Setpoint Control Program Study (LTP #108) Design info 90% complete Proposed TS on Tech Spec Set Points. Amendment submitted Expect 9/93 completion to NRC 12/93 Setpoint control program options being evaluated Valve Betterment III (LTP #126) Ongoing End of 1994

• Represents a portion of major plant betterments. Total LTP data base contains additional plant betterments, programs / projects and issues. ,

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ATTACHMENT 3 .

ADDITIONAL ITEMS LIST (SCHEDULE C)=

AUGUST 1993 ITEM TARGET SCHEDULE CURRENT STATUS Logic System Functional Test Mods (LTP #224) MCO #10 RF0 #10 ,

Exciter Cubicle CO2 Modification (LTP #235) To be provided in next Cancelled update Turbine Trucklock Sprinkler (LTP #236) MCO #11 Cancelled Fire Training Facility (LTP #239) -------

1995 Design Basis Information System (LTP #264) Cycle 11 On Schedule Radiation Source Reduction (LTP #266) Ongoing thru 1995 Closed-remaining work to be done under ,

other projects

. Abandon In-Place Program (LTP f:70) Will be provided in next update Priority work completed. remaining items cancelled Cooling Water Betterment (LTP #322) RF0 #10 No change Design Configuration Control (LTP #367) End of 1993 June 1994

• Represents a portion of major plant betterments. Total LTP data base contains additional plant betterments, programs / projects and issues.

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t ATTACHME.NT 3 ,

ADDITIONAL ITEMS LIST (SCHEDULE C)*

AUGUST 1993 ITEM TARGET SCHEDULE CURRENT STATUS Inspect / Replace Lower Core Support Plate Flow RF0 #10 No change Plugs (GE SIL 359) (LTP #448)

Replace Embrittled Cables (LTP #479) --- ---

MCO #10 NUORG Consolidation (LTP #483) December 1993 Complete Intake Canal Dredging (LTP #486) Cycle 10 Spring 1995 Low Level Radwaste Interim Storage (LTP #496) 1996 On Schedule Replace RPV Studs (LTP #520) RF0 #10 5/25/95 Replace Simplex Panels (LTP #524) On hold due to funding 1997 restrictions

• Represents a portion of major plant betterments. Total LTP data base contains additional plant betterments, programs / projects and issues.

Page 3 of 5

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ATTACHMENT 3 ,

ADDITIONAL ITEMS LIST (SCHEDULE C)*

AUGUST 1993 ITEM TARGET SCHEDULE CURRENT STATUS Disposable Filter Demin (LTP #528) December 1994 No Change Instrument Recirc. Pump Shaft (LTP #546) Instrumentation partially End 1994 completed - on hold Shaft testing completed.

No cracks per REM testing (LTP #396)

Replace ISI Shield Blocks with Shield Doors Initial analysis Cancelled (LTP #572) indicated shield blocks can be removed.

Decision to be made by RF0 #10 Steam Tunnel HVAC Evaluation (LTP #576) No modifications planned Ongoing Change HPCI Booster Pump Impeller RF0 #10 No Change to Five Vene Impeller (LTP #577)

Replace Effluent Monitors (LTP #590) Installation partially Complete. No Change Final completion scheduled for 1995 Maximum Extended Load Line Limit -------

RF0 #10 Analysis (LTP #591)

• Represents a portion of major plant betterments. Total LTP data base contains additional plant betterments, programs / projects and issues.

Page 4 of 5

ATTACHMENT 3 o-ADDITIONAL ITEMS LIST (SCHEDULE C)* i AUGUST 1993 ITEM TARGET SCHEDULE CURRENT STATUS Replace Batteries (LTP #603) RF0 #10 No Change 3D Monicore (LTP #621) -------

December 1994 i

Central Plant Access (LTP #635) December 1993 March 1994 Breakwater Repair (LTP #638) End 1994

]

Gaitronics Mods (LTP #646) -------

End 1995 Replace Bleeder Trip Valve (LTP #649) -------

RF0 #10

, RF0 Invessel Work -------

5/25/95 i

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• Represents a portion of major plant betterments. Total LTP data base contains additional plant betterments, programs / projects and issues.

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