ML17059A427
| ML17059A427 | |
| Person / Time | |
|---|---|
| Site: | Nine Mile Point  |
| Issue date: | 09/02/1994 |
| From: | Chris Miller Office of Nuclear Reactor Regulation |
| To: | Sylvia B NIAGARA MOHAWK POWER CORP. |
| References | |
| TAC-M90255, NUDOCS 9409070174 | |
| Download: ML17059A427 (10) | |
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1 UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555.0001 September 2,
1994 Hr. B. Ralph Sylvia Executive Vice President, Nuclear Niagara Hohawk Power Corporation Nine Nile Point Nuclear Station P.O.
Box 63
- Lycoming, NY 13093
SUBJECT:
NOTICE OF ENFORCEHENT DISCRETION REGARDING PLANT SERVICE MATER SYSTEH FOR NINE NILE POINT NUCLEAR STATION, UNIT 2 (NHP-2)
(TAC NO. H90255)
Dear Hr. Sylvia:
By letter dated August 31,
- 1994, Niagara Hohawk Power Corporation (NHPC) requested the U.S. Nuclear Regulatory Commission (NRC) to exercise its discretion not to enforce compliance with the required actions in Technical Specification (TS) 3.0.3 and Action of TS 3.7. 1. 1 regarding inoperable plant service water system pumps and inoperable deicing heaters.
NHPC informed the NRC staff on August 30, 1994, that all of the plant service water system pumps and both divisions of intake deicing heaters had been declared inoperable because TS Surveillance Requirements 4.7. 1. l.l.d.4, 4.7. 1.1. l.d.5, 4.7. 1.2. l.d.4, and 4.7. 1.2.l.d.5 had not been performed at least once per 18 months during shutdown as required by the TSs.
- Rather, these surveillance requirements had been performed at least once per 18 months during power operations.
The failure to perform the required surveillance requirements during shutdown had been discovered by NHPC personnel at 2:30 p.m.
on August 30, 1994.
TS 3.0.3 and Action f of TS 3.7. 1. 1 require that for the observed inoperability, action be initiated within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> to place the unit in cold shutdown within the following 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.
- However, TS 4.0.3 provides that these shutdown requirements may be delayed for up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> when the inoperability is due to failure to perform a surveillance requirement within the allowed surveillance interval.
Therefore, initiation of a plant shutdown would have been required by 3:30 p.m.
on August 31, 1994.
NIIC FII.I'. CBfI'BI COPY I
o, TSs 4.7. 1. l.l.d and 4.7. 1.2. l.d each contain five identical test requirements to be performed at least once per 18 months during shutdown with TS 4.7.1.1.1.d being applicable during OPERATIONAL CONDITIONS 1, 2, and 3 while TS 4.7.1.2.1.d is applicable during OPERATIONAL CONDITIONS 4 and 5.
The first three test requirements of each of these two TSs require verification of automatic functions on simulated test signals.
NHPC stated that these test requirements should continue to be performed during shutdown.
NHPC verified that these three test requirements have been properly performed in the past during shutdowns.
The NRC staff reviewed these testing requirements and concluded that these tests should continue to be required to be performed 9'409070i74 "940902 poR soooz ooooo4xo PDR-C5~JOC ~,
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B. Sylvia September 2, 1994 during shutdowns.
The other two test requirements of TSs 4.7. 1.1. l.d and 4.7. 1.2. l.d concern verification of the service water system pumps performance and verification of deicing heater integrity.
NHPC stated that performance of these two test requirements is unaffected by the operational condition of the unit.
The NRC staff reviewed these two testing requirements and concluded that performance of these two test requirements is unaffected by the operational condition of the unit.
Therefore, we concluded that performance of these two tests at the specified test frequency in any operational condition provides adequate demonstration of the pumps performance and the integrity of the deicing heaters.
Based on their evaluation, NHPC requested enforcement discretion to provide relief from the shutdown requirements of TS 3.0.3 and the requirements of Action f of TS 3.7. 1. 1 until the NRC could approve an emergency TS amendment
- request, to be submitted by September 2,
1994.
The emergency TS amendment request would delete the "during shutdown" requirement for TSs 4.7. l. 1. I.d.4, 4.7.1. 1. l.d.5, 4.7. 1.2.1.d.4, and 4.7. 1.2.l.d.5.
After review of NHPC's
- request, the NRC staff granted verbal enforcement discretion to NHPC to operate NHP-2 in the requested manner at 10:22 p.m.
on August 30, 1994.
- However, we will consider enforcement
- action, as appropriate, for the conditions that led to the need for this exercise of enforcement discretion.
Sincerely, Docket No. 50-410 NOED No. 94-6-016 cc:
See next page Charles Hiller, Acting Assistant Director for Region I Reactors Division of Reactors Projects I/II Office of Nuclear Reactor Regulation
B. Ralph Sylvia Niagara Hohawk 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 Hr. Richard Goldsmith Syracuse University College of Law E. I. White Hall Campus
- Syracuse, NY 12223 Resident Inspector Nine Mile Point Nuclear Station P.O.
Box 126
- Lycoming, NY 13093 Gary D. Wilson, Esquire Niagara Mohawk Power Corporation 300 Erie Boulevard West
- Syracuse, NY 13202 Mr. David K. Greene Hanager Licensing Niagara Mohawk Power Corporation Nine Mile Point Nuclear Station P.O.
Box 63
- Lycoming, NY 13093 Hs.
Donna Ross New York State Energy Office 2 Empire State Plaza 16th Floor
- Albany, NY 12223 Supervisor Town of Scriba Route 8, Box 382
- Oswego, NY 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, NY 10271 Mr. Richard M. Kessel Chair and Executive Director State Consumer Protection Board 99 Washington Avenue
- Albany, NY 12210 Hr. Kim A. Dahlberg Plant Manager, Unit 2 Nine Mile Point Nuclear Station Niagara Mohawk Power Corporation P.O.
Box 63
- Lycoming, NY 13093 Mr. Louis F. Storz Vice President - Nuclear Generation Niagara Hohawk Power Corporation Nine Mile Point Nuclear Station P.O.
Box 63
- Lycoming, NY 13093 Hr. Martin J. HcCormick, Jr.
Vice President Nuclear Safety Assessment and Support Niagara Hohawk Power Corporation Nine Mile Point Nuclear Station P.O.
Box 63
- Lycoming, NY 13093
0
B. Sylvia September 2,
1994 during shutdowns.
The other two test requirements of TSs 4.7. 1. l.l.d and 4.7. 1.2.l.d concern verification of the service water system pumps performance and verification of deicing heater integrity.
NHPC stated that performance of these two test requirements is unaffected by the operational condition of the unit.
The NRC staff reviewed these two testing requirements and concluded that performance of these two test requirements is unaffected by the operational condition of the unit.
Therefore, we concluded that performance of these two tests at the specified test frequency in any operational condition provides adequate demonstration of the pumps performance and the integrity of the deicing heaters.
Based on their evaluation, NHPC requested enforcement discretion to provide relief from the shutdown requirements of TS 3.0.3 and the requirements of Action f of TS 3.7. 1. 1 until the NRC could approve an emergency TS amendment
- request, to be submitted by September 2,
1994.
The emergency TS amendment request would delete the "during shutdown" requirement for TSs 4.7. 1.1. l.d.4, 4.7. l.l.l.d.5, 4.7.1.2.1.d.4, and 4.7. 1.2. l.d.5.
After review of NHPC's
- request, the NRC staff granted verbal enforcement discretion to NHPC to operate NHP-2 in the requested manner at 10:22 p.m.
on August 30, 1994.
- However, we will consider enforcement
- action, as appropriate, for the conditions that led to the need for this exercise of enforcement discretion.
Sincerely, Original signed by:
Docket No. 50-410 NOED No. 94-6-016 cc:
See next page Charles Hiller, Acting Assistant Director for Region I Reactors Division of Reactors Projects - I/II Office of Nuclear Reactor Regulation Distribution:
See next page DOCUMENT NAME: G:II,NHP2iNM290255.LTR
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