ML17158C045
| ML17158C045 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna  |
| Issue date: | 03/31/1997 |
| From: | Stolz J NRC (Affiliation Not Assigned) |
| To: | Byram R PENNSYLVANIA POWER & LIGHT CO. |
| References | |
| NEOD-97-6-8, NOED-97-6-008, NOED-97-6-8, TAC-M98247, TAC-M98248, NUDOCS 9704040165 | |
| Download: ML17158C045 (7) | |
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NUCLEAR REGULATORY COMMISSION WASHINGTON> D.C. 20555-0001 March 31, 1997 go-rs ~/~m t
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UNITED STATES Hr. Robert G.
Byram Senior Vice President-Nuclear Pennsylvania Power and Light Company 2 North Ninth Street Allentown, PA 18101
SUBJECT:
NOTICE OF ENFORCEHENT DISCRETION FOR SUS(UEHANNA STEAM ELECTRIC STATION, UNITS 1
AND 2 (TAC NOS H98247 AND H98248)
Dear Hr. Byram:
By letter dated Harch 26,
- 1997, you requested that the NRC exercise discretion not to enforce compliance with the actions required in Technical Specifications (TS) Surveillance Requirements (SR) 4.3. 1, 4.3.2, and 4.3.3, related to instrument response time testing of the reactor protection
- system, isolation system response, and emergency core cooling system, respectively.
Specifically, you requested a one-time exemption from completion of the response time testing requirements for selected instruments for Susquehanna Steam Electric Station (SSES) Unit 1 currently operating at 100% power and for Unit 2 which is in a refueling and maintenance outage.
That letter documented information discussed with the NRC in a tel'ephone conversation on Harch 26, 1997, at 8:30 p.m. Eastern Standard Time (EST) between members of the NRC and your staff.
Your staff stated, during that call, that on Harch 26,
- 1997, 8:25 p.m.
- EST, SSES Unit 1 had entered Action Statement 3.0.3 based on not meeting the above surveillance requirements and that reactor 'shutdown would be commencing.
Further, Unit 2 would have restrictions for fuel movement and other activities based on the TS compliance issue.
Your determination was based on the consideration of a similar TS compliance issue at Washington Nuclear Project No.
2 and an internal evaluation of the testing being conducted at the site and a determination that a TS noncompliance existed.
You have requested in your letter that a Notice of Enforcement Discretion (HOED) be issued pursuant to the NRC's policy regarding exercise of enforcement discretion for an operating facility.
The granting of such discretion is set out in Section VII.c, of the "General Statement of Policy and Procedures for NRC Enforcement Actions" (Enforcement Policy),
It was requested that the discretion be granted until Pennsylvania Power
'ight Company (PP&L) could submit an emergency amendment to the NRC and until the NRC approves this amendment, which would make the necessary changes to the technical specifications for both units.
Your staff indicated that the amendment request would be submitted not later than April 4, 1997.
It is expected that some discussions with our technical staff will be required to ensure that the requested TS change will be consistent with the types of changes being made at other plants with the same compliance problem.
This communication and evaluation process will require a few days for processing, which is acceptable to the staff.
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You stated that you had applied for (letter dated April 10, 1995) and received (letter dated July ll, 1995) a license amendment to relocate response time limit tables from the technical specifications (TS) to the Final Safety Analysis Report (FSAR) in accordance with Generic Letter 93-08, "Relocation of Technical Specification Tables of Instrument
Response
Time Limits," dated December 29, 1993.
You did not perceive subsequent changes to the tables to require a TS change and believed that they could be implemented under the provisions of 10 CFR 50.59.
You stated that you subsequently reviewed and assessed the implementation requirements of GE Nuclear Energy, BWR Owners'roup Licensing Topical Report NEDO-32291-A "System Analysis for the Elimination of Selected Instrument
Response
Time Testing Requirem'ents,"
dated October
- 1995, and determined that they could be implemented under the provisions of 10 'CFR 50.59.
You stated that you believed this to be a revised testing methodology and did not require a change to the TS or involve an unreviewed safety question.
The NRC staff had previously reviewed and approved BWR Owners'roup Licensing Topical Report (LTR), NED0-32291, "System Analysis for the Elimination of Selected Instrument
Response
Time Testing Requirements,"
dated January
- 1994, by lette} dated December 28, 1994.
You also included two components in this implementation that were not identified in the table of components in NEDO-32291-A.
Specifically, Barksdale sensor model series B2T and PlH.
You noted that the B2T sensor model series was addressed in the LTR in the table for Hatch as a candidate for elimination of response time testing but had been inadvertently omitted from the summary Table 1 in the LTR.
Further you indicated that you had concluded that the PlH series model was similar to those included in NEDO-32291 based on information provided to you by General Electric and could also be. included in this implementation effort.
You acknowledged that the NRC staff has determined that the changes to the testing requirements constitute a change to the TSs, and determined that the root cause was the erroneous assumption that TS changes were not required prior to implementation of the LTR methodology.
You stated further that it would be more appropriate to rely on the results of the existing response time testing rather than testing at power or forcing an unnecessary plant challenge by taking the plant to cold shutdown to resolve the process issue.
You proposed that the qualitative testing being performed in accordance with the LTR serves as acceptable compensatory measures.
You stated that as demonstrated by the qualitative testing the instruments are capable of performing their intended safety functions within their required response time.
You also stated that PP&L believes that the el'imination of the selected response time testing requirements does not have a detrimental effect on plant safety and that the change improves plant safety by reducing the time safety systems are unavailable, reducing safety system actuations, reducing shutdown risk, limiting radiation exposure to plant personnel, and by eliminating the diversion of key personnel to conduct testing with minimum added value.
You have also determined that there is no unreviewed safety question or significant hazards consideration. as a result of the proposed HOED.
The. NRC staff has determined, as stated in the March 26, 1997, letter that the
~
technical approach to verification of instrument operability by you is generally consistent with an approach that the staff has determined to be acceptable, as documented in the December 28, 1994, safety evaluation.
The NRC staff stated in that safety evaluation that the qualitative testing performed by you constitutes an acceptable basis for elimination of response time testing.
The staff agrees that the conti'nued performance of qualitative verification of instrument response doe's not constitute any adverse safety consequences.
The staff has accepted your request based upon its satisfaction of Criterion l(a) of Section B of Part 9900 of the NRC Inspection
- Manual, specifically with regard to the minimizing of potential safety consequences and operational risks by forcing compliance with the TS Action Statements.
On the basis of the staff's evaluation of your request, including the compensatory measures described
- above, the staff has concluded that an NOED is warranted because we are clearly satisfied that this action involves minimal or no safety impact and has no adverse radiological impact on public health and safety.
Therefore, it is our intention to exercise discretion not to enforce compliance with the specific required action in Technical
. Specifications 4.3. 1, 4.3.2, and 4.3.3, for instruments included in your implementation of NEDO-32291 for SSES Units 1 and 2 until a license amendment request changing the Technical Specifications can be issued.
This letter documents our telephone conversation on March 26,
- 1997, when John A. Zwolinski, Deputy Director, Division of Reactor Projects I/II, orally issued this notice of enforcement discretion at 9:00 p.m.
on March 26, 1997.
- However, as stated in the Enforcement Policy, action will normally be taken, to the extent that violations were involved, for the root cause that led to the noncompliance for which this HOED was necessary.
Docket Nos.
50-387 and 50-388, NOED No. 97-6-008 Sincerely,,
/sJ John Stolz, Director Project Directorate I-2 Division of Reactor Projects - I/II Office of Nuclear Reactor Regulation cc:
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The NRC staff has determined, as stated in the March 26, 1997, letter that the technical approach to verification of instrument operability by you is generally consistent with an approach that the staff has determined to be acceptable, as documented in the December 28, 1994, safety evaluation.
The NRC staff stated in that safety evaluation that the qualitative testing performed by you constitutes an acceptable basis for elimination of response time testing.
The staff agrees that the continued performance of qualitative verification of instrument response does not constitute any adverse safety consequences.
The staff has accepted your request based upon its satisfaction of Criterion l(a) of Section B of Part 9900 of the NRC Inspection
- Manual, specifically with regard to the minimizing of potential safety consequences and operational risks by forcing compliance with the TS Action Statements.
On the basis of the staff's evaluation of your request, including the compensatory measures described
- above, the staff has concluded that an NOED is
, warranted because we are clearly satisfied that th'is. action involves minimal or no safety impact and has no adverse radiological impact on public health and safety.
Therefore, it is our intention to exercise discretion not to enforce compliance with the specific required action in Technical Specifications 4.3. 1, 4.3.2, and 4.3.3, for instruments included in your implementation of NEDO-32291 for SSES Units 1 and 2 until a license amendment request changing the Technical Specifications can be issued.
This letter documents our telephone conversation on March 26,
- 1997, when.
John A. Zwolinski, Deputy Director, Division of Reactor Projects - I/II, orally issued this notice of enforcement discretion at 9:00 p.m.
on March 26, 1997.
- However, as stated in the Enforcement Policy, action will normally be taken, to the extent that violations were involved, for the root cause that led to the noncompliance for which this HOED was necessary.
Sincerely, Docket Nos.
50-387 and 50-388 NOED No. 97-6-008 cc:
See next page J
h Stolz, Director Project Directorate I-Division of Reactor Projects - I/II Office of Nuclear Reactor Regulation
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