ML17284A702
| ML17284A702 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 07/17/1998 |
| From: | Bateman W NRC (Affiliation Not Assigned) |
| To: | Parrish J WASHINGTON PUBLIC POWER SUPPLY SYSTEM |
| References | |
| NOED-98-6-012, NOED-98-6-12, TAC-MA2281, NUDOCS 9807240064 | |
| Download: ML17284A702 (5) | |
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qO 4p**4 UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINQTON, D.C. 205554001 Guly 17, 1998 Mr. J. V. Parrish Chief Executive Officer Washington Public Power Supply System P.O. Box 968 (Mail Drop 1023)
Richland, Washington 99352-0968
SUBJECT:
NOTICE OF ENFORCEMENT DISCRETION FOR NUCLEAR PROJECT NUMBER 2 (WNP-2) (TAC NO. MA2281) (NOED 98-6-012)
Dear Mr. Parrish:
By letter dated July 16, 1998, the Washington Public Power Supply System (Supply System or the licensee) requested that the NRC exercise discretion in order that WNP-2 need not comply with the actions required in Technical Specification (TS) Surveillance Requirement (SR) 3.8.4.7 for Class 1E 125V battery E-B1-2 (Division 2). This TS surveillance requires that every 24 months a service test be conducted on Class 1E batteries or that a modified discharge test be performed in lieu of the service test.
(Neither surveillance can be performed at power according to the TS.) This letter documents information previously discussed with the NRC in a telephone conversation on July 16, 1998, that began at approximately 1600 EDT. During this conversation, Supply System staff stated that SR 3.0.3 would expire at 1900 EDT on July 16, 1998, which would require that the unit begin an orderly shutdown in order to bring the plant to operational Mode 4 (cold shutdown) to support completion of the missed surveillance.
Supply System staff requested that a Notice of Enforcement Discretion (NOED) be issued pursuant to the NRC's policy regarding exercise of discretion for an operating facility, which is set out in NUREG-1600, Revision 1, "General Statement of Policy and Procedures for NRC Enforcement Actions (Enforcement Policy)." This enforcement discretion willbe in effect until the NRC can process a forthcoming amendment request that would credit the April 1997 performance discharge test required by SR 3.8.4.8 in lieu of the service test in SR 3.8 4.7 for the Division 2 battery, E-B1-2, until the plant enters Mode 4 for the R-14 maintenance and refueling outage (scheduled for mid-1999), or during an outage of sufficient duration, whichever occurs first. At that time, the Supply System would perform the service test for this battery.
The need for this NOED request resulted from the licensee's failure to include in a surveillance procedure the changes enacted through the implementation of the Improved Technical Specifications (ITS). Specifically, under the previous TSs, the two surveillances of interest for the Class 1E batteries were the performance test conducted every 60 months which subjects the battery to a constant discharge rate and the service test performed every 24 months with discharge rate and test length corresponding to the design duty cycle as per the Final Safety Analysis Report (FSAR).
The previous TSs permitted the licensee to receive credit for the service test by only performing the performance test. The ITS permits the use of a modified performance test (a 6-second discharge rate of 400 amps followed by a longer discharge rate of 350 amps) to be performed in lieu of a separate service test which is more rigorous than the
/0 I performance test.
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Mr. J. V. Parrish Ouly 17, 1998 During a recent inspection at the plant, the NRC identified that the procedure for conducting a modified performance test to include the 6-second peak discharge was not prepared to support ITS implementation.
In response to the NRC finding, the Supply System subsequently determined that it had not completed the required surveillance for the Division 2 battery in accordance with the ITS, and promptly determined that the battery needed to be declared inoperable.
This ultimately required initiation of an orderly shutdown within a prescribed allowed outage time. The Supply System indicated that it is preferable to rely on the demonstrated capability of this battery to perform its intended safety function rather than performing an unnecessary plant shutdown.
The staff evaluated the safety consequences of partially validated Class 1E battery performance along with mitigation actions and compared this to the small, but measurable amount of risk associated with an unnecessary plant shutdown.
Key facts provided by the Supply System that were considered by the staff are as follows. The battery has a manufacturer's 1-minute discharge rating of 922 amps which is significantly higher than the design performance peak load of400 amps.
The service test performed on April28, 1995, measured 111 volts after a 2-hour discharge which exceeded the acceptance limitof 105 volts.
Further, the April 1997 performance test demonstrated a capacity of 104.7% which exceeded the replacement limitof 80% capacity.
This battery has only been in service for less than 5 years.
Other TS-required surveillances of this battery, including inspection of intercell connector resistance, specific gravity, visual condition, and terminal voltage, have reflected no evidence of degradation.
The Supply System has also committed to a compensatory measure to verify the resistance of the battery connections along with performing a standard visual corrosion inspection on a 92-day interval. Based on the above, the staff finds that the extension of the surveillance frequency for the service test is not safety significant relative to the demonstrated capacity and capability of the Division 2 Class 1E battery.
The staff applied the criteria similar to those in 10 CFR 50.91 to verify that the emergency condition leading to the request for enforcement discretion was unavoidable.
The staff concluded that based on the large number of surveillance procedures that were modified as part of the ITS implementation that this requirement to develop a new procedure was a subtle one, and that human errors are sometimes unavoidable.
H The staff agrees with the licensee that an unnecessary plant shutdown constitutes an undesirable transient involving a small amount of risk and, therefore, considers the option of requiring a shutdown specifically to perform SR 3.8.4.7 to be unwarranted.
Section VII.Cof the Enforcement Policy states that, "For an operating plant, this exercise of enforcement discretion is extended to minimize the potential safety consequences of unnecessary, transients with the accompanying of operational risks...."
On the basis of the staffs evaluation of your request, 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 intent to exercise discretion not to enforce compliance with LCO 3.8.4 for the period beginning 1741 EDT on July 16, 1998, when the NOED was officiallygranted by William Bateman, Project Director, PDIV-2. This discretion will be in effect until a license amendment is issued by the
Mr. J. V. Parrish duly 17, 1998 staff that will revise the surveillance requirement for the battery on a one-time basis as discussed above.
As indicated in your letter, the Supply System willsubmit the necessary amendment within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> of the request of this NOED. The staff willprocess this amendment on an exigent basis.
The staff also understands that the Supply System will provide a separate amendment request in the near term to address the surveillances for the other two Class 1E batteries for routine processing.
This letter documents our telephone conversation on July 16, 1998, when we orally, issued'this NOED. However, as stated in the Enforcement Policy, action willnormally 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, Ori ginal Si gned By William H. Bateman, Director Project Directorate IV-2 Division of Reactor Projects III/IV Office of Nuclear Reactor Regulation Docket No. 50-397 cc: See next page DISTRIBUTION:
Docket File PUBLIC PDIV-2 Reading H. Thompson S. Collins/F. Miraglia B. Boger B. Sheron G. Lainas E. Adensam W. Bateman H. Wong C. Poslusny E. Peyton W. Beckner J. Calvo ACRS J. Lieberman P. Gwynn, RIV OGC EMail - NOED EMail - NRCWEB DOCUMENT NAME: WNPNOED.BAT OFC NAME DATE PDI -
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Mr. J. V. Parrish Ouly 17, 1998 CC:
Mr. Greg O. Smith (Mail Drop 927M)
WNP-2 Plant General Manager Washington Public Power Supply System P. O. Box 968 Richland, Washington 99352-0968 Mr. Albert E. Mouncer (Mail Drop 1396)
Chief Counsel Washington Public Power Supply System P.O. Box 968 Richland, Washington 99352-0968 Ms. Deborah J. Ross, Chairman Energy Facility Site Evaluation Council P. O. Box 43172 Olympia, Washington 98504-3172 Mr. D. W. Coleman (Mail Drop PE20)
Regulatory Affairs Manager Washington Public Power Supply System P.O. Box 968 Richland, Washington 99352-0968 Mr. Paul Inserra (Mail Drop PE20)
Manager, Licensing Washington Public Power Supply System P.O. Box 968 Richland, Washington 99352 Regional Administrator, Region IV U.S. Nuclear Regulatory Commission Harris Tower & Pavilion 611 Ryan Plaza Drive, Suite 400 Arlington, Texas 76011-8064 Chairman Benton County Board of Commissioners P.O. Box 69 Prosser, Washington 99350-0190 Mr. Scott Boynton, Senior Resident Inspector U.S. Nuclear Regulatory Commission P.O. Box 69 Richland, Washington 99352-0968 Mr. Perry D. Robinson, Esq.
Winston 8 Strawn 1400 L Street, N.W.
Washington, DC 20005-3502 Mr. Rodney L. Webring (Mail Drop PE08)
Vice President, Operations Support/PIO Washington Public Power Supply System P. O. Box 968 Richland, Washington 99352