t t REG,

_e 0 •UNITED STATES NUCLEAR REGULATORY COMMISSION

WASHINGTON, D. C. 20555

September 27, 1989

Docket No. 50-293

Mr. Ralph G. Bird Senior Vice President - Nuclear Boston Edison Company Pilgrim Nuclear Power Station RFD #1 Rocky Hill Road Plymouth, Massachusetts 02360

Dear Mr. Bird:

SUBJECT: EXEMPTION FROM THE REQUIREMENTS OF APPENDIX J TO 10 CFR PART 50 FOR THE CONTAINMENT INTEGRATED LEAK RATE TEST INTERVAL, SECTION III.A.6(b) AND ONE-TIME SCHEDULE EXEMPTIONS FOR LOCAL LEAK RATE TESTS REQUIRED BY SECTION IlI.D.2(a) AND III.D.3 FOR SIX SPECIFIC PENETRATIONS - TAC NO. 73773

By letter dated July 7, 1989 and supplemented on September 1, 1989, Boston Edison Company (BECo) requested schedule exemptions from specific requirements of Appendix J to 10 CFR Part 50 for the Pilgrim Nuclear Power Station (PNPS).

You requested an Exemption from 10 CFR Part 50, Appendix J, Section III.A.6(b), which currently requires a Type A primary containment integrated leak rate test (PCILRT) be conducted every 18 months or during a plant refueling, whichever occurs first. The request was to resume the PCILRT schedule at the PNPS specified in 10 CFR Part 50, Appendix J, Section III.D.1(a), which requires three tests be performed during each 10-year service period at approximately equal intervals. This request results in approximately a 22-month schedule extension for the required Type A test. The basis for the request is an alternative Local Leak Rate Testing (LLRT) Corrective Action Plan included in your submittal in accordance with the guidance provided in NRC Information Notice 85-71, "Containment Integrated Leak Rate Tests," dated August 22, 1985.

In addition, you requested one-time schedule exemptions from the requirements of 10 CFR Part 50, Appendix J, Section III.D.2(a) and III.D.3, for Type B and C LLRTs as they apply to four specific valves, the drywell head, and drywell access hatch. The request is to extend the 2-year test interval by approximately 6 months and allow the required testing to be accomplished during the next refueling outage (RFO-8).

Based on our evaluation, we have granted an exemption from the accelerated test schedule requirements of Section III.A.6(b) of Appendix J to 10 CFR Part 50. The exemption allows BECo to resume the normal Type A retest schedule in accordance with Section III.D.1(a) of Appendix J. However, if the as-found Type A test results are deemed unsatisfactory when performed during RFO-8 you will revert to the accelerated schedule of Section III.A.6(b). In addition, the one-time schedule exemptions of approximately six months for the Type B and C LLRTs have been granted to allow the required testing to be accomplished during RFO-8.

" ,=•100(40)21q' 8;:'P0927 F'DR (-D1OC:K- 0ý15-000125':3 Iz• 1E1(

September 27, 19'oj

Mr. Ralph G. Bird -2-

Enclosed is a copy of the Exemption and supporting Safety Evaluation for the requested schedule exemptions for the Type A, B and C tests. The Commission has granted the exemptions pursuant to 10 CFR Part 50.12. A copy of the notice of exemption is being filed with the Office of the Federal Register for publication.

A Notice of Environmental Assessment and Finding of No Significant Impact was published in the Federal Register on September 25, 1989 (54 FR 39236). This completes our action related to-the above-referenced TAC number.

Sincerely,

Original signed by Morton Fairtile

Daniel G. McDonald, Senior Project Manager Project Directorate 1-3 Division of Reactor Projects I/I1 Office of Nuclear Reactor Regulation

Enclosures: 1. Exemption 2. Safety Evaluation

cc w/enclosure: See next page [PILGRIM EXEMPTION TAC-73773]

DISTRIBUTION: Docket NRC PDR Local PDR TMurley/JSniezek JGPartlow ERossi SVarga BBoger MRushbrook DMcDonald OGC EJordan BGrimes TMeek (4) ACRS (10) GPA/PA OC/LFMB J. Johnson, Regi

OFo f

I) 1

on I

*For previous concurrences see attached ORC

OFC: PDI-3 :PDI-3 :PDI-3 :OGC* :PSB* :ADRI :NRR/DRP -- -..... ... ...... . .......... ............ NAME:EPeyton :DMcDohald:RWe-- an• :McCracken:BBer

DATE:9A389 :9/2-0/89 :9/z/89 :9/18/89 :9/13/89 :9/RD/89. OFFICIAL RECORD COPY

Mr. Ralph G. Bird - 2 - September 27, 1989

Enclosed is a copy of the Exemption and supporting Safety Evaluation for the requested schedule exemptions for the Type A, B and C tests. The Commission has granted the exemptions pursuant to 10 CFR Part 50.12. A copy of the notice of exemption is being filed with the Office of the Federal Register for publication.

A Notice of Environmental Assessment and Finding of No Significant Impact was published in the Federal Register on September 25, 1989 (54 FR 39236). This completes our action related to-the above-referenced TAC number.

Sincerely,

Daniel G. McDonald, Senior Proje t Manager Project Directorate 1-3 Division of Reactor Projects I/If Office of Nuclear Reactor Regulation

Enclosures: 1. Exemption 2. Safety Evaluation

cc w/enclosure: See next page

Mr. Ralph G. Bird

cc w/enclosure: Mr. K. L. Highfill Vice President of Operations/

Station Director Pilgrim Nuclear Power Station RFD #1 Rocky Hill Road Plymouth, Massachusetts 02360

Resident Inspector U. S. Nuclear Regulatory Commission Pilgrim Nuclear Power Station Post Office Box 867 Plymouth, Massachusetts 02360

Chairman, Board of Selectmen 11 Lincoln Street Plymouth, Massachusetts 02360

Office of the Commissioner Massachusetts Department of

Environmental Quality Engineering One Winter Street Boston, Massachusetts 02108

Office of the Attorney General One Ashburton Place 20th Floor Boston, Massachusetts 02108

Mr& Robert M. Hallisey, Director Radiation Control Program Massachusetts Department of

Public Health 150 Tremont Street, 2nd Floor Boston, Massachusetts 02111

Regional Administrator, Region I U. S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, Pennsylvania 19406

Mr. John Dietrich Licensing Division Manager Boston Edison Company 25 Braintree Hill Park Braintree, Massachusetts 02184

Mr. Richard N. Swanson, Manager Nuclear Engineering Department Boston Edison Company 25 Braintree Hill Park Braintree, Massachusetts 02184

Ms. Elaine D. Robinson Nuclear Information Manager Pilgrim Nuclear Power Station RFD #1, Rocky Hill Road Plymouth, Massachusetts 02360

Mr. Charles V. Barry Secretary of Public Safety Executive Office of Public Safety One Ashburton Place Boston, Massachusetts 02108

-3 -

7590-01

UNITED STATES OF AMERICA

NUCLEAR REGULATORY COMMISSION

In the Matter of ) )

BOSTON EDISON COMPANY ) Docket No. 50-293 )

(Pilgrim Nuclear Power Station) )

EXEMPTION

I.

The Boston Edison Company (BECo), the licensee, is the holder of Operating

License No. DPR-35 which authorizes operation of the Pilgrim Nuclear Power

Station (PNPs). The license provides, among other things, that the PNPS

is subject to all rules, regulations, and Orders of the Commission now or here

after in effect.

The plant is a boiling water reactor at the licensee's site located in

Plymouth County, Massachusetts.

If.

Section III.D.(a) of Appendix J to 10 CFR Part 50 requires that a Type A

Primary Containment Integrated Leak Rate Test (PCILRT) be performed at approxi

mately equal intervals during each 10-year service period. Section III.A.6(a)

of Appendix J to 10 CFR Part 50 requires that if any periodic Type A test fails

to meet the applicable NRC acceptance criteria, a review of the test schedule be

performed and approved by the Commission. Section III.A.6(b) of Appendix J

also requires that if two consecutive periodic Type A tests fail to meet the

applicable NRC acceptance criteria, a Type A test shall be performed at each

9' c) . ... .! , ",

FD' ADC' U F,:

-2-

subsequent refueling outage or approximately every 18 months, whichever comes

first, until two consecutive Type A tests meet the acceptance criteria given in

Section III.A.5(b).

Section III.D.2.(a) of Appendix J to 10 CFR Part 50 requires that Type B

Local Leak Rate Tests (LLRTs), except tests for air locks, shall be performed

during reactor shutdowns for refueling, or other convenient interval, but in no

case at intervals greater than two years.

Section III.D.3 of Appendix J to 10 CFR Part 50 requires that Type C LLRTs

shall be performed during each reactor shutdown for refueling, but in no case

at intervals greater than two years, for containment isolation valves.

III.

The PCILRTs performed during the 1982, 1983, and 1987 refueling outages of

the PNPS were deemed failures in the "as-found" condition due to penalties as

the result of leakage from the pathways of the Type B and C LLRTs. Accord

ingly, the licensee would be required to perform a PCILRT during the surveil

lance outage scheduled for October 1989. As an alternative to performing the

required Type A test, the licensee has submitted a Corrective Action Plan to

eliminate excessive local leakage in accordance with the guidance provided in

NRC Information Notice 85-71, "Containment Integrated Leak Rate Tests," dated

August 22, 1985. The Corrective Action Plan is in lieu of the increased test

frequency required by Section III.A.6(b) of Appendix J to 10 CFR Part 50.

Therefore, an exemption from this requirement is needed.

- 3 -

The Corrective Action Plan includes a LLRT Failure Analysis Team to

investigate LLRT failures, determine root causes, and recommend corrective

actions. The plan also includes a trending program, test method improvements

and augmented testing. Analysis of failures during the last refueling outage

(RFO-7) and corrective actions for all LLRT failures were implemented resulting

in the "as-left" PCILRT at PNPS in December of 1987, being the lowest leakage

in the plant's history. As part of the augmented testing portion of the plan,

two additional LLRTs have been performed subsequent to the corrective actions

implemented in December of 1987. These tests verified that the root cause

analyses and corrective actions were successful. LLRTs will be performed during

the upcoming maintenance outage in the Spring of 1990, with the exception of

specific penetrations which will be discussed later. The licensee further

indicates that LLRTs will be conducted during any planned outage of greater

than 30 days at PNPS. The penetrations selected for the tests will be based on

the results of the trending portion of the Corrective Action Plan. This Plan

will result in the completion of five full sets of LLRTs between June 1987 and

June 1991; this exceeds Appendix J requirements. In addition, the licensee

previously initiated a Valve Betterment Program which has resulted in the

replacement of 17 valves and modifications to 12 other valves which were

identified as having excessive leakage.

The Corrective Action Plan includes long term corrective actions in

addition to augmented testing and trending. These actions include the opening

and inspection of at least one feedwater check valve and line loading or

replacement of packing in the main drain outboard isolation valves during each

refueling outage; and procurement of spare parts, such as seats, bronze bushings

and associated hardware for the torus main exhaust valves. It should be noted,

-4-

that the major portion of the leakage (about 83%) as the result of the LLRTs

performed in December 1987, was due to the feedwater check valves. The short

term replacement of problem components in the valves and the long-term effort

previously discussed, has resulted in successful testing to date.

The licensee's Corrective Action Plan, Valve Betterment Program and recent

results of the LLRTs will provide an equivalent level of protection as that

provided by the more frequent testing requirement by Section III.A.6(b) for

Type A PCILRT. The staff concludes that a one-time extension until RFO-8 and a

return to the normal Type A test schedule of Section III.D of.Appendix J to 10

CFR Part 50 is justified. This conclusion is based on the next Type A test,

which will be performed during RFO-8, meeting the established NRC acceptance

criteria. If the criteria is not met, the licensee shall revert to the more

frequent testing requirement of Section III.A.6(b).

A one-time schedule exemption from the test interval requirement of

Section IIl.D.2(a) of Appendix J to 10 CFR Part 50 for the drywell head and the

drywell head access hatch is needed due to the extent of the work required to

be performed and resultant worker exposure to radiation, which would result, if

the tests were required to be performed during the upcoming outage in October

1989. Nine shield blocks above the drywell must be removed. These are normally

removed only during refueling outages, such as the upcoming RFO-8, to allow

removal of the reactor head for fuel unloading and loading.

The drywell head and access hatch have exhibited minimum leakage which is

only detectable on the most sensitive scale of the measuring instrumentation

for all previous LLRTs. The request provides only temporary relief for

approximately six months from the maximum two-year test interval required by

Section III.D.2(a) of Appendix J to 10 CFR Part 50.

- 5 -

The staff concludes that the accelerated LLRTs, previous test history,

the *extent of work required, resulting worker exposure to radiation and the

short interval of the extension, support the requested one-time schedule

extension of six months.

The one-time schedule exemption from the requirement of Section III.D.3 of

Appendix J to 10 CFR Part 50 is requested for the Shutdown Cooling Suction

Isolation Valves (MO-1001-47 and MO-1001-50) and Reactor Building Closed

Cooling Water (RBCCW) Isolafion Valves (MO-4002 and Check Valve 30-CK-432).

The schedule extension for the Shutdown Cooling Suction Isolation valves

is needed to defer the leak rate testing until the next scheduled refueling

outage. The shutdown cooling system is the only normal means of removing decay

heat from the reactor vessel during short outages, such as the upcoming

October 1989, surveillance outage. The valves have been tested four times

since May 1987. Only one failure occurred in MO-001-50. As a result, the

valve was refurbished and has successfully passed three subsequent LLRTs.

The schedule extension for the RBCCW system isolation valves is needed

because the testina would impact components cooled by the RBCCW system during

the upcoming short outage. The RBCCW system is a closed-water system and does

not provide a direct leakage flow path from the drywel7 to the secondary

containment. In addition, staging to provide access must be built and removed

resulting in considerable exposure of workers to radiation. The water in the

system is also required to be drained and treated which will result in an

increase in the production of radioactive waste. The previous LLRTs performed

on these valves, which include three since 1987, have demonstrated minimal

leakage, similar to that discussed above, related to the drywell head and access

hatch.

-6-

In relation to the shutdown cooling suction isolation valves and the

RBCCW valves, the staff concludes based on the accelerated LLRTs, the previous

test history, the required system functions that would be needed during the

upcoming October outage, added worker exposure, increased production of

radioactive waste, and the short interval of the extension, that the requested

one-time schedule extension of six months is acceptable.

The staff's Safety Evaluation dated September 27, 1989, provides additional

details and bases supporting the requested exemptions.

IV.

As discussed above, the underlying purpose of the requirements of Section

III.A.6(b) of Appendix J to 10 CFR Part 50 is to ensure the integrity of the

primary containment and its penetrations. The underlying purpose is achieved

and served by the licensee's Corrective Action Plan, Valve Betterment Program

and recent good test results of the LLRTs. ThVs, an equivalent level of

protection is provided.

Therefore, the Commission's staff finds that there are special circum

stances in this case which satisfy the standards of 10 CFR Part 50.12(a)(2)(ii).

Also as discussed above, the underlying purpose of the requirements of

III.D.2(a) and III.D.3 of Appendix J to 10 CFR Part 50 are to detect local

leaks and measure leakage across primary reactor penetrations and containment

isolation valves at intervals of no greater than two years. The licensee has made

a good faith effort to comply with the regulations by performing an increased

number of LLRTs on containment penetrations and valves, including the ones

discussed above. In addition, the previous test history, corrective actions,

- 7 -

and need for the Shutdown Cooling System and RBCCW system during the October

outage, support the requested one-time schedule extension of six months. Thus,

the exemption which is only to provide temporary relief, and in that the licensee

has made a good faith effort to comply with the regulations; thus, again an

equivalent level of protection is provided.

Therefore, the Commission's staff finds that there are special circumstances,

in these instances, which satisfy the standards of 10 CFR Part 50.12(a)(2)v.

V.

Based upon the above evaluation, the staff considers the licensee's

alternate test schedule to be equivalent to that achieved by conformance to

Appendix J to 10 CFR Part 50. Accordingly, the Commission has determined that,

pursuant to 10 CFR 50.12(a)(1), this exemption is authorized by law, will not

present an undue risk to the public health and safety, and is consistent with

the common defense and security. The Commission has further determined that

special circumstances, as set forth in 10 CFR 50.12(a)(2)(ii) are present,

justifying the exemption; namely, that application of the regulation in this

particular circumstance is not necessary to achieve the purpose of the rule.

Accordingly, the Commission hereby grants an exemption to Section

III.A.6(b) of Appendix J to 10 CFR Part 50 to allow the licensee to perform

the next Type A test during RFO-8 and to resume the Type A retest schedule of

Section III.D.1(a) for the PNPS. This exemption does not apply if the next

Type A test is deemed a failure based on the NRC acceptance criteria. Such a

- 8 -

failure would require the licensee to comply with the retest schedule of

Section III.A.6(b) until two consecutive Type A tests meet the NRC acceptance

criteria.

The Commission has further determined that the special circumstances, as

set forth in 10 CFR 50.12(a)(2)(v) are present, justifying the one-time schedule

extension of approximately six months, in that the licensee has made a good

faith effort to comply with the regulations.

Accordingly, the Commission hereby grants a one-time exemption to the

schedule requirements of III.D.2(a) and III.D.3 for the required Type B and C

LLRTs as follows:

IIl.D.2.(a) (Type B Tests) - Drywell Head

- Drywell Head Access Hatch

I1I.D.3 (Type C Tests) - Isolation Valve MO-1001-47

- Isolation Valve MO-1001-50

- Isolation Valve MO-4002

- Check Valve 30-CK-432

The LLRTs on the penetrations and valves identified above will be performed

during RFO-8.

Pursuant to 10 CFR 51.32, the Commission has determined that the granting

of this exemption will not have a significant effect on the quality of the

human environment (54 FR 39236).

-9

This exemption is effective upon issuance.

FOR THE NUCLEAR REGULATORY COMMISSION

Division of Reactor P i cts-I/II Office of Nuclear Reactor Regulation

Dated at Rockville, Maryland this 27thday of September, 1989.

"• ,i UNITED STATES NUCLEAR REGULATORY COMMISSION

WASHINGTON, D. C. 20555

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION

FACILITY OPERATING LICENSE NO. DPR-35

BOSTON-EDISON COMPANY

PILGRIM NUCLEAR POWER STATION

DOCKET NO. 50-293

INTRODUCTION

By letter dated July 7, 1989 and supplemented on September 1, 1989, Boston Edison Company (BECO/Licensee) requested an exemption from the requirements of 10 CFR 50, Appendix J, Sections III.A.6.(b), "Additional Requirements-Type A Test," III.D.2(a), "Type B test" and III.D.3., "Type C test." BECO has proposed to extend the test period for the Type A (Primary Containment Integrated Leakage Rate Test) test and certain Type B and C tests (Local Leakage Rate Tests) until the next refueling outage which will begin in the March 1991 timeframe. This would be approximately a 22-month extension for the Type A test and approximately a six-month extension for the Type B and C tests. These exemptions are necessary to prevent a midcycle shutdown to perform the Type A, B and C tests. BECO has also requested, as part of the exemption to be allowed to resume the Type A test schedule of Section III.D.1(a 3 of Appendix J; the staff will grant this request only on the condition that the next Type A test is successful, as discussed below.

DISCUSSION

1. Section III.A.6.(b) of 10 CFR 50, Appendix J, requires that:

"If two consecutive periodic Type A tests fail to meet the applicable acceptance criteria in III.A.5.(b), notwithstanding the periodic retest schedule of III.D, a Type A test shall be performed at each plant shutdown for refueling or approximately every 18 months, whichever occurs first, until two consecutive Type A tests meet the acceptance criteria in III.A.5(b), after which time the retest schedule specified in III.D may be resumed."

The Type A tests performed at Pilgrim during the last three refueling outages (1982, 1984, and 1987) failed the "as-found" acceptance criteria. BECO contemplated performing the next test during a Maintenance Outage originally scheduled for October 1989 (since rescheduled to Spring 1990). Pilgrim's next refueling outage will begin in the March 1991 timeframe. The refueling outage schedule is due to the length of the Pilgrim Restart Program. The 1991 Type A retest date would exceed Appendix J's 18-month requirement by approximately 22 months.

• ').4o27!'5 -B890927 PF'R Aft5-P 050Z P'F't

2

A review of the 1982, 1984, and 1987 Type A test results indicates that the "as-left" condition of the containment satisfactorily met the requirements of Appendix J. However, "as-found" Type A tests did not meet the acceptance requirements and were deemed failures. The cause for the "as-found" failures was due to excessive Type B and C test leakages.

2. Section III.D.2.(a) of 10 CFR 50, Appendix J, requires that:

"Type B tests, except tests for air locks, shall be performed during reactor shutdown for refueling or other convenient intervals but in no case at intervals greater than 2 years."

An exemption is requested only for the Drywell Head and Drywell Head Access Hatch. These Type B local leak rate tests (LLRT) leakages have historically not been a source of significant "as-found" leakage.

The exemption is requested to prevent the necessity of testing during a midcycle shutdown and allow the tests to be performed during the next refueling outage (RFO-8).

3. Section III.D.3 of 10 CFR 50, Appendix J, requires that:

"Type C tests shall be performed during each reactor shutdown for refueling but in no case at intervals greater than two years."

Exemption is requested for four valves in two systems because testing at other than refueling outages presents significant difficulties for these systems. BECO requests a schedular exemption be granted because the next scheduled refueling outage will exceed the provision of this requirement by approximately six months. Currently this testing would be required by November or December 1990.

The subject valves have good test histories, having passed at least the last three Type C tests.

EVALUATION

Type A Test

Pilgrim has failed three consecutive "as-found" Type A primary containment integrated leak rate tests (PCILRTs). BECO was required by Appendix J to increase the testing frequency for the ILRT from three times in ten years to once per outage until two consecutive "as-found" tests are acceptable.

BECO has stated that the cause for the "as-found" PCILRT failures has been due exclusively to Type B and C leakages. As such, BECO has increased its efforts to minimize Type B and C leakage.

NRC Information Notice 85-71, "Containment Integrated Leak Rate Tests," dated August 22, 1985, states in part:

3

"If Type B and C leakage rates constitute an identified contributor to this failure of the "as-found" condition for the PCILRT, the general purpose of maintaining a high degree of containment integrity might be better served through an improved maintenance and testing program for containment penetration boundaries and isolation valves. In this situation, the licensee may submit a Corrective Action Plan with an alternative leakage test program proposal as an exemption request for NRC staff review. If this submittal is approved by the NRC staff, the licensee may implement the corrective action and alternative leakage test program in lieu of the required increase in Type A test frequency incurred after the failure of two successive Type A tests."

As an alternative to performing a Type A test in the near term, BECO proposes that a more effective approach to maintaining a high degree of containment integrity is through implementing an improved maintenance and testing program for containment isolation valves and penetrations. The Local Leak Rate Testing Corrective Action Plan described in Attachment B to the subject letter provides details of the program for implementation at Pilgrim. This Corrective Action Plan was developed using the guidance of NRC Information Notice 85-71, and is designed to eliminate the root cause of the successive Type A failures at Pilgrim by aggressively addressing leakage observed from the pathways of Types B and C LLRTs.

Prior to the development of the Corrective Action Plan, BECO established a LLRT Failure Analysis Team in October 1986 as a "standing entity" to conduct root cause analyses and to recommend and follow up on corrective actions for all local leak rate test failures that occurred during the last refueling outage. By intensifying the level of attention at resolving the actual root causes for Type B and C test failures, the results of the "as-left" PCILRT conducted at Pilgrim in December 1987 were the lowest leakage in the plant's history. Enclosure 1 of the subject letter summarizes the root cause analyses aad corrective actions taken for the LLRT failures at the last refueling outage. Also, BECO has already initiated more frequent LLRTs. Two additional LLRTs have been performed since the December 1987 ILRT "as-found" failure, and more testing is planned for Spring 1990.

The staff has reviewed BECO's submittal and concluded that it would be acceptable to extend the Type A test period until the next refueling outage. The staff's conclusion is based on the following.

The "as-found" failure of the ILRT was due to excessive Type B and C leakage. As such BECO has taken and will take actions to improve the Type B and C leakages. An important example of these actions follows:

The majority (83%) of the net equivalent LLRT leakage that caused the "asfound" failure of the Type A test in December 1987 was due to excessive leakage past the feedwater check valves. These feedwater check valves had a history of LLRT failures due to worn soft seats, leaking hinge pins, and cracked welds on bushings.

4

The failure root cause analysis performed by the LLRT Failure Analysis Team determined that the failure was caused by degraded soft seat material (Sargent SR740-70), and bushings and hinge pins from an older design. As short-term corrective action, the old hinge pins and bushings were replaced with new desi gns and the soft seat material was replaced with a new material (Parker E692) which has passed thermal aging tests simulating six years of accelerated thermal aging.

The following long-term corrective actions were identified:

0 Continue to closely trend the LLRT performance of the refurbished valves.

o BECO will open and inspect at least one feedwater check valve during each refueling outage to evaluate the new soft seat material's performance.

The minimal leakage experience during tests of these feedwater check valves thus far indicates the repairs have been successful.

The staff has reviewed the actions described by BECO and agrees these actions should improve leakage through historically poor penetrations and provide BECO a method to detect and focus its attention on future bad performers. Therefore, the staff would expect that the containment integrity will be maintained during the extension of the test period.

However, the staff is not prepared to grant the request to return to the normal Type A test schedule of Section III.D.1(a) of Appendix J until Pilgrim has passed at least one "as-found" Type A test. Such a success would demonstrate the effectiveness of the Corrective Action Plan and justify the full exemption from the increased test schedule that BECO seeks. Therefore, the staff has determined that Pilgrim may return to the normal test schedule of Appendix J, Section IIl.D.1(a), on the condition that the next Type A test passes on an "asfound" basis. Also, the staff has determined that the next Type A test may be performed during RFO-8.

Type B and C Tests

BECO has requested that the Type B and C test intervals be extended for four valves in two systems and for the Drywell Head and Drywell Head Access Hatch, as follows:

1. Exemption from the Type C LLRT Retest Requirement for Shutdown Cooling Suction Isolation Valves MO-1001-47 and M0-1001-50

Section III.D.3 of 10 CFR 50, Appendix J requires a Type C LLRT to be performed on all primary containment isolation valves during each refueling outage, but in no case at intervals greater than two years. LLRTs on Shutdown Cooling Suction Isolation Valves MO-1001-47 and MO-i001-50 were last performed on November 28, 1988, near the end of RFO 7. Accordingly, the next LLRT on these in-series isolation valves

5

for primary containment Penetration X-12 would be required on or before November 28, 1990. However, because RFO-8 will not occur until at least March 1, 1991, the two-year interval would be exceeded.

These valves are used to isolate the single suction line from the reactor water recirculation system to the shutdown cooling system pumps. LLRTs on these valves during outages other than refueling outages would have an adverse impact on the control of reactor coolant temperature because the shutdown cooling system is the only normal means of removing decay heat from the reactor vessel during short outages. A more appropriate alternative would be to perform the LLRTs on these two valves during RFO-8 while the reactor is refueled and shutdown cooling is not required. Accordingly, BECO requests a one-time exemption from the maximum two-year LLRT retest interval for Shutdown Cooling Suction Isolation Valves MO-1001-47 and MO-I001-50. These valves will be tested during RFO-8 and the retest interval will exceed two years by approximately six months.

Shutdown Cooling Suction Isolaton Valves MO-1001-47 and MO-1001-50 have been LLRT tested four times each since May 1987. The only LLRT failure on these valves occurred in May 1987, when leakage of 13.5 slm was observed past Isolation Valve MO-l001-50. The valve was disassembled, reworked, and components were replaced. Since the failure, Isolation Valve MO-1001-50 has successfully passed three LLRTs. The last LLRTs were performed on these valves on November 28, 1988 in anticipation of startup for Cycle 8. The maximum two-year retest was required. However, because of the length of the Pilgrim Restart Program, Cycle 8 will exceed this maximum two-year retest interval.

The requested exemption would provide only temporary relief from the requirements of Section III.D.3 of 10 CFR 50, Appendix J to the extent that the Type C LLRTs for Shutdown Cooling Suction Isolation Valves MO-1001-47 and MO-1O01-50 would be permitted to exceed the maximum two-year retest interval by approximately six months. BECO has made good faith efforts to comply with the regulation based on the increased LLRT retest frequency on these valves since May 1987.

2. Exemption from the Type C LLRT Retest Requirement for Reactor Building Closed Cooling Water (RBCCW) Isolation Valve MO-4002 and Check Valve 30-CK4 32

LLRTs on RBCCW Isolation Valve MO-4002 and Check Valve 30-CK-432 were last performed on December 19, 1988, near the end of RFO-7. Accordingly, the next LLRT on these valves would be required by December 19, 1990. However, because RFO-8 is not scheduled to begin until at least March 1, 1991, the two-year interval would be exceeded.

Train B of the RBCCW is the only closed-water system that penetrates the Pilgrim drywell. It is used to provide component cooling inside the drywell for the drywell coolers, the oil coolers to both recirculation pumps, and the drywell fans. Outside the drywell, Train B of the RBCCW is used to provide component cooling for both control rod drive (CRD) pumps,

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both reactor water cleanup (RWCU) pumps, and the heat exchanger on Train B of the fuel pool cooling system. Containment isolation for Train B of the RBCCW is provided by Isolation Valve MO-4002 on the line from the drywell (Penetration X-24) and by Check Valve 30-CK-432 on the line to the drywell (Penetration X-23). Only one isolation valve is provided on each penetration because Train B of the RBCCW is a closed-water system and it does not provide a direct leakage flowpath from the drywell to secondary containment.

LLRT testing of RBCCW Isolation Valve MO-4002 and Check Valve 30-CK-432 requires plant operators to close the valves to each component in the drywell served by Train B of RBCCW. This is done to isolate any leakage that would remain within the drywell and need not be measured. in addition, staging must be built above the torus to provide access to the valves for the LLRTs. After the tests, the staging must be removed. All of this work to manipulate the valves of affected drywell components, build and remove staging, and perform the LLRTs would result in radiation exposure (approximately 1.41 person rem) of plant workers.

RBCCW water contains nitrites for corrosion control and approximately 2,500 gallons of this water must be drained and treated by the radwaste demineralizer during the LLRT tests on these valves. Because nitrites act to break down the demineralizer resins, this water must be carefully collected and treated by the radwaste demineralizer in measured amounts. In any case, the treatment of this high-nitrite water would result in more frequently changed resin and ultimately result in greater production of radwaste. In addition, performance of the LLRT tests on RBCCW Isolation Valve MO-4002 and Check Valve 30-CK-432 would have a large impact on plant operation because all components cooled by Train B of the RBCCW would be inoperable during the tests. The affected systems include the drywell coolers, both recirculation pumps, both CRD pumps, both RWCU pumps, and Train B of the fuel pool cooling system.

LLRTs on RBCCW Isolation Valve MO-4002 and Check Valve 30-CK-432 performed since December 1981 have been successful, with indicated leakage on each valve measuring 0.1 slm. A leakage of 0.1 slm corresponds to the minimum sensitivity of the leakage detection instrumentation. In addition, LLRTs on these valves have been performed successfully three times each since July 1987.

The requested exemption would provide only temporary relief from the requirements of Section III.D.3 of 10 CFR 50, Appendix J to the extent that the Type C LLRTs for RBCCW Isolation Valve MO-4002 and Check Valve 30-CK-432 would be permitted to exceed the maximum two-year retest interval by approximately six months. BECO has made good faith efforts to comply with the regulation based on the increased LLRT retest frequency on these valves since July 1987.

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3. Exemption from the Type B LLRT Retest Requirement for the Drywell Head and Drywe•l Head Access Hatch

Section III.D.2(a) of 10 CFR 50, Appendix J requires a Type B LLRT to be performed on all primary containment penetrations, whose design incorporates components such as resilient seals and gaskets, during each refueling outage, but in no case at intervals greater than two years. The LLRTs on the Drywell Head and Drywell Head Access Hatch were last performed on November 29, 1988, near the end of RFO-7. Accordingly, the next LLRT on these penetrations would be required by November 29, 1990. However, because RFO-8 is currently not scheduled to begin until at least March 1, 1991, the two-year interval would be exceeded.

To perform the LLRT tests on the Drywell Head and Drywell Head Access Hatch, seven of the nine shield blocks that rest above the drywell must be removed. The shield blocks are normally removed only during refueling outages when the Drywell Head must be removed for fuel loading and unloading. In this circumstance, the shield blocks would be moved only to allow the LLRTs. Also, the work to perform these LLRTS would be in a high radiation area and would result in radiation exposure (approximately 0.6 person rem) of plant personnel.

The Drywell Head and Drywell Head Access Hatch have lifetime histories of successful LLRTs at Pilgrim, with indicated leakage on each penetration measuring 0.1 slm. A leakage of 0.1 slm corresponds to the minimum sensitivity of the leakage instrumentation.

The requested exemption would provide only temporary relief from the requirements of Section III.D.2(a) of 10 CFR 50, Appendix J to the extent that the Type B LLRTs for the Drywell Head and Drywell Head Access Hatch would be permitted to exceed the maximum two-year retest interval by approximately six months.

Based on the above review, the staff has determined that extending the surveillance intervals as described is acceptable and the requested temporary exemption for Type B and C test schedules should be granted.

CONCLUSION

The staff has concluded, based on the above, that the next Type A test may be performed during RFO-8 and the licensee may return to the normal test schedule of Section III.D.l(a) of Appendix J to 10 CFR Part 50. This conclusion is based on the condition that the next Type A test meets the NRC acceptance criteria on an "as-found" basis. The staff further concludes that a one-time schedule extension from the required test intervals of Section III.D.2(a) and III.D.3 of Appendix J to 10 CFR Part 50 should be granted for the containment pentrations discussed above. The required tests will be performed during RFO-8.

Principal Contributor: J. Pulsipher

Dated: September 27, 1989

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