ML17058B876

Informs of Intention to Exercise Discretion Not to Enforce Compliance W/Lco 3.6.3,ACTION a.2 for Hydrogen Recombiner Sys Inboard Valves,Per Licensee 930805 Request

ML17058B876
Person / Time
Site:	Nine Mile Point
Issue date:	08/06/1993
From:	Calvo J Office of Nuclear Reactor Regulation
To:	Sylvia B NIAGARA MOHAWK POWER CORP.
References
TAC-M87149, NUDOCS 9308240220
Download: ML17058B876 (10)

Text

SI 8 REGS gG+ g 4p0

+w*e+

Docket No. 50-410 HOED No. 93-6-019 UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, O.C. 20555-0001 August 6, 1993 Hr. B. Ralph Sylvia Executive Vice President, Nuclear Niagara Hohawk Power Corporation 201 Plainfield Road

Syracuse, New York 13212

SUBJECT:

NOTICE OF ENFORCEMENT DISCRETION FOR NIAGARA MOHAWK POWER CORPORATION REGARDING NINE MILE POINT NUCLEAR STATION, UNIT 2 (TAC NO. M87149)

By letter dated August 5, 1993, Niagara Mohawk Power Corporation (NMPC) requested the U.S. Nuclear Regulatory Commission (NRC) to exercise its discretion not to enforce compliance with the required actions in Technical Specification Limiting Condition for Operation (LCO) 3.6.3, Primary Containment Isolation Valves, ACTION a.2, for Hydrogen Recombiner System inboard containment isolation valves 2HCS*HOV 4A,B and 6A,B.

NHPC informed the NRC on August 4, 1993, that these containment isolation valves had been declared inoperable after it was discovered that they had been improperly leak tested.

This determination required entry into LCO 3.6.3, ACTION a.2, which states that "with one or more primary containment isolation valves inoperable, maintain at least one isolation valve OPERABLE in each affected penetration that is open and within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> isolate each affected penetration by the use of at least one deactivated automatic valve secured in the isolated position or be in at least hot shutdown within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />."

Valves 2HCS*MOV 4A,B and 6A,B are located inside primary containment and cannot be leak tested as required during power operations.

In addition, deactivating the outboard OPERABLE valves (2HCS*MOV 1A,B and 3A,B) in accordance with ACTION a.2 would render the hydrogen recombiner inoperable, and it is likely that the valves could not be reactivated under post design basis loss-of-coolant-accident conditions due to the potential inaccessibility of associated motor control centers.

In order to support continued plant operations, NMPC proposed to deviate from the requirements of LCO 3.6.3, ACTION a.2, to the extent that the outboard valves would not be deactivated but instead would be maintained closed by administrative controls.

The NRC staff granted verbal enforcement discretion to NHPC to operate in this manner at 10:04 p.m.

on August 4, 1993.

NHPC's letter dated August 5, 1993, provided as justification for continued operation a discussion that concluded that primary containment integrity would be assured

~ince the outboard containment isolation valves are OPERABLE and the hydrogen recombiner system is a closed system outside containment.

NHPC also concluded that the safety-related functions of containment and the hydrogen recombiner s following a design basis loss-of-coolant-accident would be minimally affected and any adverse consequences associated with the 9308240220 930806 PDR ADOCK",050004i0 P

'DR~

MC FEE ~ySI~

I

-P C4p R

I g

Qp lb 0'g<

Mr. B. Ralph Sylvia August 6, f993 proposed request are negligible.

In addition, NMPC identified compensatory measures to include administrative controls to maintain the outboard containment isolation valves closed, make related procedure

changes, and provide briefings for operations personnel.

On the basis of our review of your justification, including the compensatory measures identified above, the staff has concluded that this course of action involves minimum or no safety impact, and we are clearly satisfied that this exercise of enforcement discretion is warranted from a public health and safety perspective.

Therefore, it is our intention to exercise discretion not to enforce compliance with LCO 3.6.3, ACTION a.2, for Hydrogen Recombiner System inboard valves 2HCS*MOV 4A,B and 6A,B for the period from 10:04 p.m.

on August 4, 1993, until either (1) completion by NMPC of an evaluation of a change in the design basis of the Hydrogen Recombiner System to permit restoration of containment integrity based on the operable outboard valves and the closed system features of the Hydr'ogen Recombiner

System, or (2) completion of the staff's review of,a one-time emergency technical specification (TS) amendment request that will be submitted by NMPC if the issue cannot be resolved by the design basis change.

The amendment will specify that the compensatory measures would provide an acceptable level of safety until the subject valves would be tested at the first outage of sufficient duration or during the next refueling outage, whichever occurs first.

NMPC's letter of August 5, 1993, stated that NMPC anticipates completing evaluation of the design basis change prior to submitting a TS change request

and, should the evaluation of the design basis change be insufficient to resolve the issue, NMPC will submit the request for an emergency TS change within 3 working days after receiving written approval of the request for enforcement discretion.

We accept this schedular commitment from NMPC and include it as an element of this enforcement discretion.

Sincerely, cc:

See next page Jose A. Calvo, Assistant Director for Region I Reactors Division of Reactor Projects - I/II Office of Nuclear Reactor Regulation

Hr. B. Ralph Sylvia Niagara Mohawk Power Corporation Nine Mile Point Nuclear Station Unit 2 CC:

Hark J. Wetterhahn, Esquire Winston 5 Strawn 1400 L Street, NW.

Washington, DC 20005-3502 Mr. Richard Goldsmith Syracuse University College of Law E. I. White Hall Campus

Syracuse, New York 12223 Resident Inspector Nine Mile Point Nuclear Station P. 0.

Box 126

Lycoming, New York 13093 Gary D. Wilson, Esquire Niagara Mohawk Power Corporation 300 Erie Boulevard West

Syracuse, New York 13202 Hr. David K. Greene Manager Licensing Niagara Mohawk Power Corporation 301 Plainfield Road

Syracuse, New York 13212 Hs.

Donna Ross New York State Energy Office 2 Empire State Plaza 16th Floor

Albany, New York 12223 Supervisor Town of Scriba Route 8, Box 382

Oswego, New York 13126 Regional Administrator, Region I U. S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Charles Donaldson, Esquire Assistant Attorney General New York Department of Law 120 Broadway New York, New York 10271 Hr. Richard M. Kessel Chair and Executive Director State Consumer Protection Board 99 Washington Avenue

Albany, New York 12210 Mr. John H. Hueller Plant Manager, Unit 2 Nine Mile Point Nuclear Station Niagara Mohawk Power Corporation P. 0.

Box 32

Lycoming, New York 13093 Vice President - Nuclear Generation Nine Mile Point Nuclear Station Niagara Mohawk Power Corporation P. 0.. Box 32

Lycoming, New York 13093

Hr. B. Ralph Sylvia August 6, 1993 proposed request are negligible.

In addition, NHPC identified compensatory measures to include administrative controls to maintain the outboard containment isolation valves closed, make related procedure

changes, and provide briefings for operations personnel.

On the basis of our review of your justification, including the compensatory measures identified above, the staff has concluded that this course of action involves minimum or no safety impact, and we are clearly satisfied that this exercise of enforcement discretion is warranted from a public health and safety perspective.

Therefore, it is our intention to exercise discretion not to enforce compliance with LCO 3.6.3, ACTION a.2, for Hydrogen Recombiner System inboard valves 2HCS*HOV 4A,B and 6A,B for the period from 10:04 p.m.

on August 4, 1993, until either (1) completion by NHPC of an evaluation of a change in the design basis of the Hydrogen Recombiner System to permit restoration of containment integrity based on the operable outboard valves and the closed system features of the Hydrogen Recombiner

System, or (2) completion of the staff's review of a one-time emergency technical specification (TS) amendment request that will be submitted by NHPC if the issue cannot be resolved by the design basis change.

The amendment will specify that the compensatory measures would provide an acceptable level of safety until the subject valves would be tested at the first outage of sufficient duration or during the next refueling outage, whichever occurs first.

NMPC's letter of August 5, 1993, stated that NMPC anticipates completing evaluation of the design basis change prior to submitting a TS change request

and, should the evaluation of the design basis change be insufficient to resolve the issue, NHPC will submit the request for an emergency TS change within 3 working days after receiving written approval of the request for enforcement discretion.

We accept this schedular commitment from NHPC and include it as an element of this enforcement discretion.

cc:

See next page Distribution:

See attached sheet Sincerely, Original signed by:

Jose A. Calvo, Assistant Director for Region I Reactors Division of Reactor Projects I/II Office of Nuclear Reactor Regulation PDI-

'Vo an PDI-1: PH JMennin

iN 4

93 NRR DSSY AThad'

'M 93 Ro ion I C, C.ceeg Co'o er

%C 93 PDI-1:

RACa ra 93 AD:RI JCalvo S 493 OFFI IAL RECORD COPY FILENAME: G:iNHP2iNHP2LTR.ENF

.~

1

Transmittin Notices of Enforcement Discretion DATED August 6, 1993

<Do'cket File l NRC L Local PDRs PD1-1 Reading T. Murley, 12/G/18 F. Miraglia, 12/G/18 J. Partlow, 12/G/18 W. Russell, 12/G/18 SVarga JCalvo RACapra CVogan JMenning OGC D. Hagan, MNBB 3206 G. Hill (2)

C. Grimes, ll/E/22 A. Thadani, 8/E/4 ACRS (10)

OPA OC/LFDCB J.

Lieberman, OE, 7/H/5 S.

Dembek T. Martin, RGN-1 C. Cowgill, RGN-1 cc:

Plant Service list

0 k

J t