ML020860742
| ML020860742 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 03/26/2002 |
| From: | Richards S NRC/NRR/DLPM |
| To: | Parrish J Energy Northwest |
| References | |
| 02-6-001 | |
| Download: ML020860742 (6) | |
Text
March 26, 2002 Mr. J. V. Parrish Chief Executive Officer Energy Northwest P.O. Box 968 (Mail Drop 1023)
Richland, WA 99352-0968
SUBJECT:
NOTICE OF ENFORCEMENT DISCRETION FOR ENERGY NORTHWEST REGARDING COLUMBIA GENERATING STATION (NOED NO. 02-6-001)
Dear Mr. Parrish:
By letter dated March 22, 2002, you requested that the NRC exercise discretion not to enforce compliance with the actions required in Technical Specification (TS) 3.6.1.3. Your letter documented information previously discussed with the NRC in a telephone conference on March 21, 2002, at 3:30 a.m. eastern standard time (EST). The principal NRC staff members who participated in that telephone conference included Stuart Richards, Project Director, Project Directorate IV; Elmo Collins, Acting Director, Division of Reactor Projects, Region IV; George Thomas, Reactor Systems Branch; and David Loveless, Region IV. You stated that on March 20, 2002, at 6:20 p.m. pacific standard time (PST), the plant was determined to not be in compliance with TS Surveillance Requirement (SR) 3.6.1.3.6., which would require the closure of two main steam isolation valves (MSIVs) within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />, in effect a plant shutdown, in conformance with TS Action Statement 3.6.1.3.A. You requested that a Notice of Enforcement Discretion (NOED) be issued pursuant to the NRC's policy regarding exercise of discretion for an operating facility, set out in Section VII.C, of the "General Statement of Policy and Procedures for NRC Enforcement Actions" (Enforcement Policy), NUREG-1600, and be effective until the TS amendment request to be submitted by the licensee can be approved.
This letter documents our telephone conversation on March 21, 2002, from 3:30 a.m. to 4:30 a.m. EST, when we verbally issued this NOED.
You identified a potential error in your testing methodology for MSIV closure time as a result of a review of an Operating Experience Report from the Monticello facility. Specifically, the circuit delay time was included in the measured time for MSIV closure. With the circuit delay time subtracted from the measured times, two MSIVs were determined to have closure times of 2.74 and 2.88 seconds. This time is less than the TS 3.6.1.3.6. required range of 3 and 5 seconds. While this rendered the two MSIVs inoperable, you also determined the safety significance of this reduced closure time to be minimal. Two of the main steam lines MSIVs closed within the allowed range (approximately 3.4 seconds), with an average closure time for the main steam lines of 3.1 seconds. Since the accident analysis models the steam lines as one line, this closure time is within the accident analysis. Additionally, with a closure time of 2.5 seconds the increase in reactor pressure is on the order of 3 to 4 psi, however, the analysis includes a margin of 36 psi. Based on the minimal impact on reactor coolant system pressure, you determined that the safety impact of operation with two MSIVs having a low closure time until the next planned outage of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or greater was acceptable.
Mr. J. V. Parrish The staff has reviewed your request and determined the following. Columbia Generating Station is in violation of TS Action Statement 3.6.1.3.A. Your staff identified a failure to meet surveillance requirement 3.6.1.3.6 as a result of a review of MSIV surveillance test data.
Analysis by your staff determined that the proposed NOED would not result in exceeding minimum critical power ratio (MCPR) or ASME vessel overpressure protection limits. This was based in part on two of the steam lines closing in 3.42 seconds which results in a reduced pressure wave to the reactor vessel, and available pressure margin in the supporting analyses.
You determined that the proposed NOED would not be detrimental to public health and safety and that no significant hazards consideration was involved. This was based in part on the Cycle 16 licensing analysis remaining bounding when the MSIV isolation times were averaged.
Analysis by your staff determined that the noncompliance did not involve adverse consequences to the environment since the ASME overpressure limit is still satisfied and therefore no breaching of the primary pressure boundary would occur. No compensatory measures were proposed and the NOED would remain effective until the proposed TS amendment could be processed. The NOED request was reviewed by your Plant Operations Committee and approved by the Plant General Manager. Columbia Generating Station requested a "regular" (not weather related) NOED to avoid an unnecessary plant transient which would involve plant risk, and submitted an associated license amendment request on March 22, 2002. The staff concurs that the NOED is bounded by your current analyses and poses no significant hazards consideration. This NOED involved no increase in risk because there was no adverse impact on safety functions. We specifically note that NRC IM Part 9900 Section B, Criteria 2.0(1) and 2.1.1.a. are satisfied.
On the basis of the staff's evaluation of your request, we have concluded that an NOED is warranted because we are clearly satisfied that this action involves minimal or no safety impact, is consistent with the enforcement policy and staff guidance, and has no adverse impact on public health and safety. Therefore, it is our intention to exercise discretion not to enforce compliance with TS 3.6.1.3, Action A., for the period from March 21, 2002, 4:26 a.m. EST until the issuance of a license amendment consistent with your request. You submitted your license amendment on March 22, 2002. The staff plans to complete its review and issue the license amendment within four weeks of the date of this letter.
As stated in the Enforcement Policy, action will be taken, to the extent that violations were involved, for the root cause that led to the noncompliance for which this NOED was necessary.
Sincerely,
/RA/
Stuart A. Richards, Director Project Directorate IV Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket No. 50-397 cc: See next page
Mr. J. V. Parrish The staff has reviewed your request and determined the following. Columbia Generating Station is in violation of TS Action Statement 3.6.1.3.A. Your staff identified a failure to meet surveillance requirement 3.6.1.3.6 as a result of a review of MSIV surveillance test data.
Analysis by your staff determined that the proposed NOED would not result in exceeding minimum critical power ratio (MCPR) or ASME vessel overpressure protection limits. This was based in part on two of the steam lines closing in 3.42 seconds which results in a reduced pressure wave to the reactor vessel, and available pressure margin in the supporting analyses.
You determined that the proposed NOED would not be detrimental to public health and safety and that no significant hazards consideration was involved. This was based in part on the Cycle 16 licensing analysis remaining bounding when the MSIV isolation times were averaged.
Analysis by your staff determined that the noncompliance did not involve adverse consequences to the environment since the ASME overpressure limit is still satisfied and therefore no breaching of the primary pressure boundary would occur. No compensatory measures were proposed and the NOED would remain effective until the proposed TS amendment could be processed. The NOED request was reviewed by your Plant Operations Committee and approved by the Plant General Manager. Columbia Generating Station requested a "regular" (not weather related) NOED to avoid an unnecessary plant transient which would involve plant risk, and submitted an associated license amendment request on March 22, 2002. The staff concurs that the NOED is bounded by your current analyses and poses no significant hazards consideration. This NOED involved no increase in risk because there was no adverse impact on safety functions. We specifically note that NRC IM Part 9900 Section B, Criteria 2.0(1) and 2.1.1.a. are satisfied.
On the basis of the staff's evaluation of your request, we have concluded that an NOED is warranted because we are clearly satisfied that this action involves minimal or no safety impact, is consistent with the enforcement policy and staff guidance, and has no adverse impact on public health and safety. Therefore, it is our intention to exercise discretion not to enforce compliance with TS 3.6.1.3, Action A., for the period from March 21, 2002, 4:26 a.m. EST until the issuance of a license amendment consistent with your request. You submitted your license amendment on March 22, 2002. The staff plans to complete its review and issue the license amendment within four weeks of the date of this letter.
As stated in the Enforcement Policy, action will be taken, to the extent that violations were involved, for the root cause that led to the noncompliance for which this NOED was necessary.
Sincerely,
/RA/
Stuart A. Richards, Director Project Directorate IV Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket No. 50-397 DISTRIBUTION:
See next page cc: See next page ACCESSION NO.: ML020860742
- See Previous Concurrence OFFICE PDIV-2/PM PDIV-2/LA SRXB/BC RGN-IV/ DRP PDIV-2/SC PDIV/PD NAME JHickman EPeyton* JWermiel* ECollinsE-mail SDembek* SRichards DATE 3/26/2002 3/26/2002 3/26/2002 3/26/2002 3/26/2002 3/26/2002 OFFICIAL RECORD COPY
DISTRIBUTION FOR LETTER TO NORTHWEST ENERGY - COLUMBIA GENERATING STATION - NOTICE OF ENFORCEMENT DISCRETION (NOED NO. 02-6-001)
DISTRIBUTION:
PUBLIC PDIV-2 R/F RidsNrr Od (SCollins/JJohnson)
RidsNrrAdpt (BSheron)
RidsNrrDlpm (JZwolinski/TMarsh)
JZimmerman RidsNrrDlpmLpdiv (SRichards)
RidsNrrDlpmLpdiv (SDembek)
RidsNrrPMRSubbaratnam RidsNrrLAEPeyton RidsNrrPMJHickman RidsNrrPmJCushing RidsOgcRp RidsNrrDssaSrxb (JWermiel)
GThomas RidsAcrsAcnwMailCenter RidsOeMailCenter (FCongel)
KBrockman, Region IV ECollins, Region IV Senior Resident Inspector (GDR@NRC.GOV)
NOED OEWEB Scott Morris, EDO
Columbia Generating Station cc:
Mr. Greg O. Smith (Mail Drop 927M) Mr. Rodney L. Webring (Mail Drop PE08)
Vice President, Generation Vice President, Operations Support/PIO Energy Northwest Energy Northwest P. O. Box 968 P. O. Box 968 Richland, WA 99352-0968 Richland, WA 99352-0968 Mr. Albert E. Mouncer (Mail Drop 1396) Thomas C. Poindexter, Esq.
Chief Counsel Winston & Strawn Energy Northwest 1400 L Street, N.W.
P.O. Box 968 Washington, DC 20005-3502 Richland, WA 99352-0968 Mr. Bob Nichols Ms. Deborah J. Ross, Chairman Executive Policy Division Energy Facility Site Evaluation Council Office of the Governor P. O. Box 43172 P.O. Box 43113 Olympia, WA 98504-3172 Olympia, WA 98504-3113 Mr. D. W. Coleman (Mail Drop PE20) Ms. Lynn Albin Manager, Regulatory Affairs Washington State Department of Health Energy Northwest P.O. Box 7827 P.O. Box 968 Olympia, WA 98504-7827 Richland, WA 99352-0968 Mr. Paul Inserra (Mail Drop PE20)
Manager, Licensing Energy Northwest P.O. Box 968 Richland, WA 99352-0968 Regional Administrator, Region IV U.S. Nuclear Regulatory Commission Harris Tower & Pavilion 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011-8064 Chairman Benton County Board of Commissioners P.O. Box 69 Prosser, WA 99350-0190 Senior Resident Inspector U.S. Nuclear Regulatory Commission P.O. Box 69 Richland, WA 99352-0069