ML17158C305
| ML17158C305 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna  |
| Issue date: | 09/17/1997 |
| From: | Stolz J NRC (Affiliation Not Assigned) |
| To: | Byram R PENNSYLVANIA POWER & LIGHT CO. |
| References | |
| TAC-M99567, NUDOCS 9709290173 | |
| Download: ML17158C305 (5) | |
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UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 September 17, 1997 Hr. Robert G.
Byram Senior Vice President-Generation and Chief Nuclear Officer Pennsylvania Power and Light Company 2 North Ninth Street Allentown, PA 18101
SUBJECT:
NOTICE OF ENFORCEMENT DISCRETION (NOED)
FOR PENNSYLVANIA POWER AND LIGHT COMPANY (PP&L),
SUS(UEHANNA STEAM ELECTRIC STATION (SSES),
UNIT 1
(TAC NO. H99567)
Dear Hr. Byram:
By letter dated September ll, 1997, as supplemented by letter dated September 12,
- 1997, PP&L requested that the U.S. Nuclear Regulatory Commission (NRC) exercise discretion for Susquehanna Steam Electric Station (SSES),
Unit 1, not to enforce compliance with the actions required in Technical Specification (TS) Sections 3.4.2, "Safety Relief Valves," Action c, 4.4.2 and 3.3.7.5, "Accident Monitoring Instrumentation,"
(Table 3.3.7.5-1, "Accident Monitoring Instrumentation," Action 80).
This action would permit the plant to continue operation with the acoustic monitor on the "S" safety/relief valve (SRV) tailpipe inoperable, until the next unit shutdown of sufficient duration to allow for containment entry for repair, not to exceed the 10th refueling and inspection outage.
The referenced TS would have required that the plant begin an orderly shutdown on September 12, 1997.
These requirements will be waived until a proposed emergency amendment can be processed.
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),
The PP&L letters reflect information discussed with the NRC in a telephone conversation held on September 12, 1997, at approximately 2:00 p.m.
between members of the NRC and your staff.
Your staff stated during that call that, on September 10, 1997, at 5:50 p.m.,
SSES Unit 1, which had been operating at 100X power, entered Action 80 of TS Table 3.3.7.5-1 based on the determination that the acoustic monitor for SRV "S" had become inoperable.
Action 80 requires that the inoperable acoustic monitor be restored to "...OPERABLE status within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> 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 />."
During the call, your staff discussed the information included in the September ll and September 12, 1997, letters and in addition, your staff agreed to provide the emergency amendment request by September 15, 1997.
With regard to the NRC staff's assessment of safety impact, the NRC believes that minimal safety impact would occur even if the inoperable acoustic monitor remains inoperable until the next refueling outage, which is scheduled for Spring 1998.
This conclusion is based on the confirmation that the "S" SRV is in the closed position and the existence of multiple indications such as suppression pool temperature for determination of the SRV position.
In this
- regard, the suppression pool temperature monitoring system provides the 9709290173 970917 PDR ADQCK 05000387 P
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Byram operator with safety grade, redundant suppression pool temperature information from which operators can utilize to detect an open SRV.
In your letter of September ll, 1997, you provided a'>discussion of the need for prompt action to avoid an unnecessary transient on SSES Unit 1, which-would occur should the reactor be shut down for repair of the inoperable.
acoustic monitor.
The staff has accepted your request for enforcement discretion based on its satisfaction of Criterion 1 of Section B of Part 9900 of the NRC Inspection Manual, specifically with regard to avoiding undesirable transients as a
result of forcing compliance with license conditions.
- Further, on the basis of the staff's evaluation of your request, the staff has concluded that a
NOED is warranted because we are satisfied that this action involves minimal or -no safety impact and has no adverse radiolo'gical impact on public health and safety.
The licensee's letters dated September ll and 12, 1997, satisfy the information requirements of Section E of Part 9900.
The staff noted that PPEL submitted an application for the Improved Standard Technical Specifications (ISTS) on August 1, 1996, currently under NRC review.
The ISTS would relocate the subject TS requirements to PP&L's Technical Requirements
- Manual, under which changes can be controlled pursuant to 10 CFR 50.59.
The need for the NOED request would depend on the results of a 10 CFR 50.59 analysis.
Therefore, it is our intention to exercise discretion not to enforce compliance with the specific required actions in TSs 3.4.2, 4.4.2 and 3.3.7.5 (Table 3.3.7.5-1, Action 80) for SSES Unit 1 until an emergency license amendment changing the TSs can be issued.
This letter documents our telephone conversation on September 12,
- 1997, when John Stolz, Director, Project Directorate I-2, Division of Reactor Projects I/II, verbally issued this notice of enforcement discretion at approximately 2:30 p.m., to be effective until an emergency license amendment can be processed modifying the appropriate TS sections.
- However, as stated in the NRC 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 NOED was necessary.
Sincerely, Js/
John Stolz, Director Project Directorate I-2 Division of Reactor Projects - I/II Office of Nucle'ar Reactor Regulation Docket No. 50-387 NOED ¹97-6-014 cc:
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Byram operator with safety grade, redundant suppression pool temperature information from which operators can utilize to detect an open SRV.
In your letter of September 11, 1997, you provided a discussion of the need for prompt action to avoid an unnecessary transient on SSES Unit 1, which would occur should the reactor be shut down for repair of the inoperable acoustic monitor.
The staff has accepted your request for enforcement discretion based on its satisfaction of Criterion 1 of Section B of Part 9900 of the NRC Inspection Manual, specifically with regard to avoiding undesirable transients as a
result of forcing compliance with license conditions.
- Further, on the basis of the staff's evaluation of your request, the staff has concluded that a
NOED is warranted because we are satisfied that this action involves minimal or no safety impact and has no adverse radiological impact on public health and safety.
The licensee's lette} s dated September ll and 12, 1997, satisfy the information requirements of Section E of Part 9900.
The staff noted that PP&L submitted an application for the Improved Standard Technical Specifications (ISTS) on August 1, 1996, currently under NRC review.
The ISTS would relocate the subject TS requirements to PP&L's Technical Requirements
- Manual, under which changes can be controlled pursuant to 10 CFR 50.59.
The need for the NOED request would depend on the results of a 10 CFR 50.59 analysis.
Therefore, it is our intention to exercise discretion not to enforce compliance with the specific required actions in TSs 3.4.2, 4.4.2 and 3.3.7.5 (Table 3.3.7.5-1, Action 80) for SSES Unit 1 until'n emergency license amendment changing the TSs can be issued.
This letter documents our telephone
,conversation on September 12,
- 1997, when John Stolz, Director, Project Directorate I-2, Division of Reactor Projects I/II, verbally issued this notice of enforcement discretion at approximately 2:30 p.m., to be effective until an emergency license amendment can be processed modifying the appropriate TS sections.
- However, as stated in the NRC 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 NOED was necessary.
Sincerely, Docket No. 50-387 NOED ¹97-6-014 cc:
See next page J
h tolz, Director r
ect Directorate I D vision of Reactor Projects I/II Office of Nuclear Reactor Regulation
Letter to R.
Byram, Pennsylvania Power and Light Company, regarding Notice of Enforcement Discretion, dated September 17, 1997.
DISTRIBUTION Docket File PUBLIC PDI-2 Reading HThompson SCollins/FMiragli a RZimmerman BSheron BBoger GHolahan JStolz NOED (E-Mail NOED)
MO'Brien(2)
OGC WBeckner
Mr. Robert G.
Byram Pennsylvania Power 5 Light Company Susquehanna Steam Electric Station, Units 1
8 2
CC:
Jay Silberg, Esq.
- Shaw, Pittman, Potts
- 5. Trowbridge 2300 N Street N.W.
Washington, D.C.
20037 Bryan A. Snapp, Esq.
Assistant Corporate Counsel Pennsylvania Power
- 8. Light Company 2 North Ninth Street Allentown, Pennsylvania 18101 Licensing Group Supervisor Pennsylvania Power
& Light Company 2 North Ninth Street Allentown, Pennsylvania 18101 Senior Resident Inspector U. S. Nuclear Regulatory Commission P.O.
Box 35 Berwick, Pennsylvania 18603-0035 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 Harrisburg, Pennsylvania 17108-1266 Regional Administrator, Region I U.S. Nuclear Regulatory Commission 475 Allendale Road King of'russia, Pennsylvania 19406 General Manager Susquehanna Steam Electric Station Pennsylvania Power and Light Company Box 467
'erwick, 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 Operations Pennsylvania Power and Light Company 2 North Ninth Street Allentown, Pennsylvania 18101 Dr. Judith Johnsrud National Energy Committee Sierra Club 433 Orlando Avenue State College, PA 16803 Chairman Board of Supervisors 738 East Third Street
- Berwick, PA 18603