ML17157C467

Confirms That on 930908,NRC Orally Granted Util Request to Exercise Discretionary Enforcement from Action 3.6.1.8.b, Requiring That Inboard Suppression Chamber Purge Valve HV-25703 Be Restored to Operable Status within 24 H

ML17157C467
Person / Time
Site:	Susquehanna
Issue date:	09/10/1993
From:	Calvo J Office of Nuclear Reactor Regulation
To:	Byram R PENNSYLVANIA POWER & LIGHT CO.
References
NOED-93-6-021, NOED-93-6-21, PLA-4019, TAC-M87449, NUDOCS 9309160165
Download: ML17157C467 (6)

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Docket No. 50-388 NOED No. 93-6-021 UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON. D.C. 20555-0001 September 10, 1993 Mr. Robert G.

Byram Senior Vice President-Nuclear Pennsylvania Power and Light Company 2 North Ninth Street Allentown, Pennsylvania 18101

SUBJECT:

NOTICE OF ENFORCEMENT DISCRETION FOR PENNSYLVANIA POMER AND LIGHT COMPANY, SUS(UEHANNA STEAM ELECTRIC STATION, UNIT 2 (PLA-4019)

(TAC NO. M87449)

This letter confirms that on September 8,

1993, we orally granted your request to exercise discretionary enforcement from Action 3.6.1.8.b, which would have required that inboard suppression chamber purge valve 'HV-25703 be restored to operable status within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or that Unit 2 be placed in a shutdown condition.

By letter dated September 8,

1993, you requested the U.S. Nuclear Regulatory Commission (NRC) to exercise its discretion not to enforce compliance with the required action in Technical Specification (TS) Section 3.6.1.8.b which would require that the 18" suppression chamber purge valve HV-25703 be restored to oper able status within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or the unit must be placed in a shutdown condition.

You informed the NRC at 1730 on September 7,

1993, that the 18" inboard suppression chamber purge valve HV-25703 had been declared inoperable due to its inability to pass TS requirement 4.6.1.8.2 (which requires that the measured leakage rate is less than or equal to 0.05 L, when pressurized to P,)

and outlined the actions you were taking and proposed to take overnight to restore the valve to operable status.

You kept the staff apprised of the actions and test being conducted throughout the next day.

At 1530 on September 8,

1993, you submitted the request for enforcement discretion and discussed with the Region I and NRR staff the results of your analysis,

tests, and proposed compensatory measures.

The requirements of TS 3.6.3a were accomplished within the required time limits by isolating the affected penetration.

The inboard and outboard purge

valves, HV-25703 and HV-25704, respectively, as well as the 2" bypass valve HV-25705 were deactivated and secured closed.

An acceptable containment boundary is currently in place for this penetration

and, based on administrative controls, per TS 3.6.3, is not subject to the single failure

~fI-i/-

criterion.

As permitted by TS Section 3.6.3, the inboard valve, HV-25703, and the 2" bypass valve, HV-25705, may be reopened intermittently under administrative control for short periods to ensure. containment pressure is controlled within TS limits.

Pressure in containment can increase for various 9309160165

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Hr. Robert G. Byra September 10, 1993

reasons, such as during performance of the monthly surveillance testing of the High-Pressure Coolant Injection system that adds heat to the suppression pool.

Periodically opening the 2" bypass (HV-25705) pathway does not threaten Standby Gas Treatment System integrity because the small size piping and orifice does not allow a significant pressure surge even under postulated loss of coolant accident conditions.

You also agreed to reperformance of the vacuum leak test on HV-25704, as discussed in your letter of September 8,

1993, on a monthly basis for the first 3 months.

If the leakage is less than or equal to 0.01 L,,

a test frequency of once every 3 months may be used thereafter to confirm that there is no significant increase in the leakage of this valve.

The leakage criterion should continue to be 0.01 L.

You also agreed to verify once-per-31-days that the penetration flow pat(i is isolated and power is removed to all valves.

In addition, an independent check to assure closure and power removal will be performed after each opening of HV-25703 and HV-25705.

Based on our review of your justification, including the compensatory measures identified above, we have 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 the requirements of TS Action 3.6. 1.8.b until such time as an amendment to the TS can be processed.

However, we may consider enforcement

action, as appropriate, for the condition that led to the need for the exercise of enforcement discretion.

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CGrimes Sincerely, Original signed by Jose A. Calvo Jose A. Calvo, Assistant Director for Region I Reactors Division of Reactor Projects - I/II Office of Nuclear Reactor Regulation ACRS(10)

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reasons, such as during performance of the monthly surveillance testing of the High-Pressure Coolant Injection system that adds heat to the suppression pool.

Periodically opening the 2" bypass (HV-25705) pathway does not threaten Standby Gas Treatment System integrity because the small size piping and orifice does not allow a significant pressure surge~ggen under postulated loss of coolant accident conditions.

You also agreed to~reperformance of the vacuum leak test on HV-25704, as discussed in your letter of September 8,

1993, on a monthly basis for the first 3 months.

If the leakage is less than or equal to 0.01 L, a test frequency of once every 3 months may be used thereafter to confirm that there is no significant increase in the leakage of this valve.

The leakage criterion should continue to be 0.01 L.

You also agreed to verify once-per-31-days that the penetration flow pat(i is isolated and power is removed to all valves.

In addition, an independent check to assure closure and power removal will be performed after each opening of HV-25703 and HV-25705.

Based on our review of your justification, including the compensatory measures identified above, we have 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 the requirements of TS Action 3.6. 1.8.b until such time as an amendment to the TS can be processed.

However, we may consider enforcement

action, as appropriate, for the condition that led to the need.for the exercise of 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

Mr. Robert G.

Byram Pennsylvania Power

& Light Company Susquehanna Steam Electric Station, Units 1

& 2 CC:

Jay Silberg, Esq.

Shaw, Pittman, Potts

& Trowbridge 2300 N Street N.W.

Washington, D.C.

20037 Bryan A. Snapp, Esq.

Assistant Corporate Counsel Pennsylvania Power

& Light Company 2 North Ninth Street Allentown, Pennsylvania 18101 Mr. J.

M. Kenny Licensing Group Supervisor Pennsylvania Power

& Light Company 2 North Ninth Street Allentown, Pennsylvania 18101 Mr. Scott Barber Senior Resident Inspector U. S. Nuclear Regulatory Commission P.O.

Box 35 Berwick, Pennsylvania 18603-0035 Mr. William P. Dornsife, Director Bureau of Radiation Protection Pennsylvania Department of Environmental Resources P. 0.

Box 8469 Harrisburg, Pennsylvania 17105-8469 Mr. Jesse C. Tilton, III Allegheny Elec. Cooperative, Inc.

212 Locust Street P.O.

Box 1266 Har risburg, Pennsyl vani a 17108-1266 Regional Administrator, Region I U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, Pennsylvania 19406 Mr. Harold G. Stanley Vice President-Nuclear Operations Susquehanna Steam Electric Station Pennsylvania Power and Light Company Box 467 Berwick, Pennsylvania 18603 Mr. Herbert D. Woodeshick Special Office of the President Pennsylvania Power and Light Company Rural Route 1,

Box 1797 Berwick, Pennsylvania 18603 George T. Jones Vice President-Nuclear Engineering Pennsylvania Power and Light Company 2 North Ninth Street Allentown, Pennsylvania 18101