ML17285A080

Requests Discretionary Enforcement Re Tech Spec 3/4.3.3 Re ECCS Actuation Instrumentation & Applicability Spec 3.0.3 for 24 H Period Beginning 881121

ML17285A080
Person / Time
Site:	Columbia
Issue date:	11/21/1988
From:	Powers C WASHINGTON PUBLIC POWER SUPPLY SYSTEM
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
GO2-88-244, TAC-71445, NUDOCS 8812020098
Download: ML17285A080 (8)

Text

. AP. CEIZRATED DISTR BUTION DEMONSTRATION SYSTEM REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS) j ACCESSION NBR:8812020098 DOC.DATE: 88/11/21 NOTARIZED: NO DOCKET g FACIL:50-397 WPPSS Nuclear Project, Unit 2, Washington Public Powe 05000397'i AUTH. NAME AUTHOR AFFILIATION l POWERS,C.M. Washington Public Power Supply System RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)

SUBJECT:

Requests discretionary enforcement re TS 3/4.3.3 ECCS actuation instrumentation S applicability Spec 3.0.3.

DISTRIBUTION CODE: A001D COPIES RECEIVED:LTR ENCL SIZE: I TXTLE: OR Submittal: General Distribution

'D NOTES:

RECXPIENT COPIES RECIPIENT COPIES 8 ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR,ENCL PD5 LA PD5 PD SAMWORTH,R INTERNAL: ACRS 6 ARM/DAF/LFMB A'g NRR/DEST/ADS 7E 1 NRR/DEST/CEB 8H NRR/DEST/ESB 8D 1 NRR/DEST/MTB 9H I NRR/DEST/RSB 8E 1 NRR/DOEA/TS B 1 1 NRR/PMAS/ILRB12 1 C BSTRACT 9 OGC/HDS2 RES/DSXR/EXB l.

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EXTERNAL: LPDR NRC PDR NSIC R'i'>>

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'A NOTE KO ALL RIDS" RECIPIENTS:

PLEASE HELP US K) REDUCE HASTE! CXRVACZ KSE DOCUMENTS CONSOL DESK D RCjQM Pl-37 (EXT. 20079) TO EZZKQCQF YOUR NAME PROM DISTEKBUTION LISTS H)R DOCtlMEZZS YOU DON'T NEEDf TOTAL NUMBER OF COPIES REQUIRED: LTTR 25 ENCL ~R

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ti WASHINGTON PUBLIC POWER SUPPLY SYSTEM P.O. Box 968 ~ 3000 George Washington Way ~ Rfchland, Washtngton 99352 November, 21, 1988 G02"88"244 Docket No. 50"397 U. S. Nuclear, Regulatory Commission Attn: Document Control Desk Mail Station Pl-137 Washington, D.C. 20555 Gentlemen:

Subject:

NUCLEAR PLANT NO. 2 REQUEST FOR DISCRETIONARY ENFORCEMENT MITH RESPECT TO TECHNICAL SPECIFICATION 3/4.3.3 EMERGENCY CORE COOLING SYSTEM ACTUATION INSTRUMENTATION AND APPLICABILITY SPECIFICATION 3.0.3

Reference:

Generic Letter, 87-09 "Sections 3.0 and 4.0 of the Standard Technical Specifications on the Applicability of Limiting Conditions for, Operation and Surveillance Requirements", dated June 4, 1987 Technical Specification Action Statement 3/4.3.3.a reads:

"With an ECCS actuation instrumentation channel trip setpoint less conservative than the value shown in the Allowable Values column of Table 3.3.3-2, declare the channel inoperable until the channel is restored to OPERABLE status with its trip set-point adjusted consistent with the Trip Setpoint value."

The 4. 16 kV Emergency Bus Undervoltage Degraded Voltage Time Delay Relay (TDR) descr.ibed in Table 3.3.3-2 consists of two time delay/relays; 5 seconds and 3 seconds. Recent internal SSFI review of the procedures associated with confirming the 8 second TDR settings has determined that only the 5 second TDR calibration is included in our, Technical Specification calibration procedures.

The 3 second TDR calibration is included in our, Scheduled Maintenance System (SMS) program and was deferred for, Emergency Bus SM-7. If considered inoperable due to not penforming the required calibration surveillance test, Action Statement 3/4.3.3.b. refers to Table 3.3.3-1 Action Statement 38.

However,, the action statement addresses a single channel inoperable condition only. Accordingly, Technical Specification 3.0.3 is then applied, requining a plant shutdown to be initiated within one hour.

881121 oat 881202 0098 CK pg000 i)o P

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'EQUEST FOR DISCRETIONARY ENFORCEMENT However as discussed in the referenced Generic Letter. the Staff has recognized that a missed surveillance does not, of itself, confirm inoperable equipment.

Hence a shutdown based on a missed surveillance would be an overly conservative action when the equipment could be proven operable upon completion of the missed surveillance. Fur ther, the Staff concluded that 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> was an accep-table time limit for, completing a missed surveillance when the allowable outage time of the action requirements were less than the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, limit. Such is the case'with the relays discussed above.

Therefore the Supply System is requesting discretionary enforcement with respect to the subject Technical Specifications for, the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period contem-plated in Generic Letter 87-09 beginning 0830 PST November. 21, 1988.

IH The concept that the 3 second time delay relay is part of the channel requir ed to be tested was not previously considered. That portion of the logic con-sidered to represent each channel is apart from the 3 second time delay relay function. The 3 second TDR is also identical to numerous other control relays providing safety functions and similar ly not tested. This was a recent NRC SSFI finding and the Supply System has committed to a test program. This condition represents a unique application of the Technical Specifications not previously considered and as such could not have been reasonably foreseen.

The confusion in surveillance requirements is believed to result from the 8 second time delay function including more of the protective circuit than the individual channels. This being the case the 3 second time delay relays were included in our, SNS versus Technical Specification calibration procedures.

As stated in Table 3.3.3-2 the allowable value tolerance for the combined TDRs is + .8 seconds. The manufacturers drift tolerance for. the 3 second relay is 5% 7.15 seconds). The 5 second relays were replaced in R-3 with solid state components having an in-plant tolerance of + .1 seconds. The tolerance then available to the 3 second TDRs is .7 seconds (.8 allowed by Technical Specifi-cation minus .1 associated with the new 5 second TDRs). The manufacturers drift tolerance (.15 seconds) is well within the .7 seconds remaining. Addi-tionally the TDR's having the same function on SN-8 were calibration checked in Nay 1987 with r esults within the drift tolerance above. A plant shutdown in light of these considerations would be overly conservative and subject the plant to an unnecessary thermal cycle. Avoidance of the shutdown is beneficial and far outweighs any disadvantages associated with the additional 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in which to perform the missed surveillance.

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RE/VEST FOR DISCRETIONARY ENFORCEMENT The performance of the calibration of the 3 second TDR's for SM-7 at power. is considered acceptable for the following reasons:

One TDR provides for annunciation only and as such removal from service to test the TDR does not affect the degraded voltage function. It will also provide an alert if the degraded voltage condition were to occur. during other TDR testing.

The remaining two TDR's monitor SM-1 and TR-B voltage conditions and actuate at 3 seconds dependent upon which source is tied to SM-7. A degraded voltage condition on SM-1 causes tr ansfer, to TR-B and diesel generator. ¹1 star t. A degraded voltage on TR-B causes diesel generator ¹1 to start and energize SM-7.

If the degr aded voltage existed during this short time the effect would be similar. to loss of a diesel generator, which is an analyzed design bases event.

The other, divisional bus remains functional and would alert the control room operators of the degraded voltage condition. The probability of the degraded bus voltage condition is considered remote due to the past operating experience of the BPA grid. The stability of the BPA grid is provided for, through (automatic degraded grid voltage condition) load shedding and the development of comprehensive contingency plans. Therefore the type of grid disturbance most probable is a loss of voltage which remains monitored by the primary undervoltage relays.

It should also be recognized that calibration of the 5 second TDR listed on Table 3.3.3-2 for, Division I and II ECCS requires an ECCS to become inoperable.-

In addition action statements for. the diesel generator associated with the TDRs to be calibrated will be applied during the calibration period to further maintain that divisions on site power supply.

The Supply System asserts that this request is in the public benefit and does not place the plant in an unsafe condition.

Yery truuly yours, BA4, C. M. Powers WNP-2 Plant Manager, PLP/bk cc: JB Martin - NRC RV NS Reynolds BCP&R RB Samworth - NRC DL -

Williams BPA/399 NRC Site Inspector, - 901A

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