ML17159A389
| ML17159A389 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna  |
| Issue date: | 06/16/1998 |
| From: | Capra R NRC (Affiliation Not Assigned) |
| To: | Byram R PENNSYLVANIA POWER & LIGHT CO. |
| References | |
| TAC-MA2068, NUDOCS 9806220040 | |
| Download: ML17159A389 (6) | |
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UNITED STATES NUCLEAR REGULATORYCOMMISSION WASHINGTON, D.C. 205554001 June 16, 1998 Mr. Robert G. Byram Senior Vice President-Generation and Chief Nuclear Officer Pennsylvania Power and Ught Company 2 North Ninth Street Allentown, PA 18101 SUBJECT'OTICE OF ENFORCEMENT DISCRETION (NOED) FOR PENNSYLVANIA POWER ANDLIGHTCOMPANY (PP&L), SUSQUEHANNA STEAM ELECTRIC STATION (SSES), UNIT2 (TAC NO. MA2068, NOED NO. 954409)
Dear Mr. Byram:
By letter dated June 15, 1998, as supplemented by letter dated June 16, 1998, PP&L requested that the U.S. Nuclear Regulatory Commission (NRC) exercise discretion for Susquehanna Steam Electric Station (SSES), Unit 2, not to efiforce compliance with the actions required in Technical Specification (TS) Sections 3.4.2, "Safety/Relief Valves," Action c; 4.4.2; 4.3.7.5, "Surveillance Requirements," (Table 4.3.7.5-1, "Accident Monitoring Instrumentation Surveillance Requirements," 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 "J" 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 9th refueling and inspection outage (Spring 1999). Certain of theTS sections mentioned above would have required that the plant begin an orderly shutdown on June 15, 1998. These requirements willbe waived until a proposed exigent amendment can be processed.
The granting of such discretion is set out in Section Vll.cof the "General Statement of Policy and Procedures for NRC Enforcement Actions," (Enforcement Policy), NUREG-1600, Rev.1.
The PP&L letters reflect information discussed with the NRC in a telephone conversation held on June 15, 1998, at approximately 9:35 a.m. between members of the NRC and your staff. Your staff stated during that call that, on June 13, 1998, at 12:39 p.m., SSES Unit 2, which had been operating at 49% 'power, entered Action 80 of TS Table 3.3.7.5-1 based on the determination that the acoustic monitor for SRV "J" 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 June 15, and June 16, 1998, letters and in addition, your staff agreed to provide the exigent amendment request by June 17, 1998.
With regard to the NRC staffs assessment of safety impact, the NRC believes that minimal safety impact would occur even ifthe inoperable acoustic monitor remains inoperable until the next refueling outage, which is scheduled for Spring 1999. This conclusion is based on the confirmation that the "J SRV is in the dosed position and the availability of backup methods for determining SRV position such as suppression pool temperature.
In this regard, the suppression pool temperature monitoring system provides the operator with safety grade, redundant suppression pool temperature information from which operators can utilize to detect an open SRV.
9806220040 9806i6 PDR ADOCK 05000387 P
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R. Byram In your letter of June 15, 1998, you provided a discussion of the need for prompt action to avoid an unnecessary transient on SEES Unit 2, which would occur should the reactor be shut down for repair of the inoperable acoustic monitor. Also, you stated, as a compensatory measure, a
procedure change to procedure ON-283-001 identifying the condition of the acoustic monitor for the "J" SRV and identifying alternate means of determining ifthe "J" SRV is open.
You noted that control room operators willreceive Hotbox training on the procedure changes to ON-283-001.
The staff has accepted your request for enforcement discretion based on its satisfaction of Criterion I 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 staffs 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 letters dated June 15, 1998 and June 16, 1998, 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 PP8L'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 Action c, 4.4.2, 4.3.7.5 (Table 4.3.7.5-1) and 3.3.7.5 (Table 3.3.7.5-1, Action 80) for SSES Unit 2 until an exigent license amendment changing the TSs can be issued.
This letter documents our telephone conversation on June 15, 1998, when Robert Capra, Director, Project Directorate l-2, Division of Reactor Projects - I/II, verbally issued this notice of enforcement discretion at approximately 11:45 a.m.,
to be effective until an exigent license amendment can be processed modifying the appropriate TS sections.
However, as stated in the NRC Enforcement Policy, action willnormally be taken, to the extent that violations were involved, for the root cause that led to the noncompliance forwhich this NOED was necessary.
Docket No. 50-387 DISTRIBUTION:
Docket File NEED ¹97-&014 PUBLIC cc: See next page PDI-2 Reading
. HThompson SCollins/FMiraglia BBo er Sincerely,
/s/
Robert A. Capra, Director Project Directorate I-2 Division of Reactor Projects - I/II Office of Nuclear Reactor Regulation BSheron MO'Brien(2)
JLieberman JZwolinski OGC CAnderson GHolahan WBeckner E-mail NRC WEB RCapra WHehl, RGNI VNerses ACRS NOED E-mail NOED See revious concurrence OFFICE D -2/PM P
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GHolahan WHehl DATE 06/'98 06/ ~/98
~ />/98 06/16/98 06/16/98 OFFICIALRECORD COPY DOCUMENT NAME: SUMA2068. NOED
R. Byram ln your letter ofJune 15, 1998, you provided a discussion of the need for prompt action to avoid an unnecessary transient on SEES Unit 2, which would occur should the reactor be shut down for repair of the inoperable acoustic monitor. Also, you stated, as a compensatory measure, a
procedure change to procedure ON-283-001 identifying the condition of the acoustic monitor for the "J" SRV and identifying alternate means of determining ifthe "J" SRV is open. You noted that control room operators willreceive Hotbox training on the procedure changes to ON-283401.
The staff has accepted your request for enforcement discretion based on its satisfaction of Criterion I 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 stafPs evaluation ofyour 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 letters dated June 15, 1998 and June 16, 1998, 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 re'quirements 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 Action c, 4.4.2, 4,3.7.5 (Table 4.3.7.5-1) and 3.3.7.5 (Table 3.3.7.5-1, Action 80) for SSES Unit 2 until an exigent license, amendment changing the TSs can be issued.
This letter documents our telephone conversation on June 15, 1998, when Robert Capra, Director, Project Directorate l-2, Division of Reactor Projects -'I/II,verbally issued this notice of enforcement discretion at approximately 11:45 a.m.,
to be effective until an exigent license amendment can be processed modifying the appropriate TS sections.
However, as stated in the NRC Enforcement Policy, action willnormally be taken, to the extent that violations were involved, for the root cause that led to the noncompliance forwhich this NOED was necessary.
Docket No. 50-388 NOED ¹98-6-009 cc: See next page Robert A. Cap a, Director Project Directorate I-2 Division of Reactor Projects - I/II Office of Nuclear Reactor Regulation
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Mr. Robert G. Byram Pennsylvania Power & Light Company Susquehanna Steam Electric Station, Units1 &2 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 Licensing Group Supervisor Pennsylvania Power & Light Company 2 North Ninth Street Allentown, Pennsylvania I8I01 Senior Resident Inspector U. S. Nuclear Regulatory Commission P.O. Box 35 Benvick, Pennsylvania 18603-0035 Director-Bureau of Radiation Protection Pennsylvania Department of Environmental Resources P. O. 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 Prussia, Pennsylvania 19406 General Manager Susquehanna Steam Electric Station Pennsylvania Power and Light Company Box 467 Beiwick, 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