ML17290A932

Confirms Verbal Granting of Enforcement Discretion During 940111 Telcon Re Compliance W/Ts 3.3.3 Action Statements for Components Identified in Util 940113 Request

ML17290A932
Person / Time
Site:	Columbia
Issue date:	01/14/1994
From:	Adensam E Office of Nuclear Reactor Regulation
To:	Parrish J WASHINGTON PUBLIC POWER SUPPLY SYSTEM
References
TAC-M88506, NUDOCS 9401270267
Download: ML17290A932 (5)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 Docket No. 50-397 DT January 14, 1994 Hr. J.

V. Parrish (Hail Drop 1023)

Assistant Hanaging Director, Operations Washington Public Power Supply System P.O.

Box 968

Richland, Washington 99352-0968

SUBJECT:

NOTICE OF ENFORCEHENT DISCRETION FOR MASHINGTON PUBLIC POWER SUPPLY SYSTEH REGARDING MASHINGTON NUCLEAR PROJECT UNIT NO.

2 (MNP-2)(TAC NO. H88506)

On January 11, 1994, at approximately 4:50 p.m.

EST, you requested the U.S.

Nuclear Regulatory Commission (NRC) to exercise its discretion not to enforce compliance with the required actions of Technical Specification (TS) 3.3.3, "Emergency Core Cooling System Actuation Instrumentation."

You informed the NRC that WNP-2 was not in compliance with the requirements of TS 3.3.3, Table 3.3.3-3 after 9:15 p.m.

EST on January 10,

1994, because portions of the Low Pressure Core Spray (LPCS) and Residual Heat Removal QRHR) valve actuation and pump start logic circuitry had not been fully response-time tested.

Mithout this enforcement discretion, the plant would be required to enter Action Statement 30 of Table 3.3.3-1 at 9:15 p.m.

EST on January ll, 1994, and with all low pressure emergency core cooling systems (ECCS) declared inoperable, TS 3.0.3 would require the plant to be in at least Startup within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, at least Hot Shutdown within the following 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, and at least Cold Shutdown within the subsequent 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

You requested that enforcement discretion be granted until an emergency TS change request is submitted to and approved by the NRC.

The emergency TS change requested by separate letter dated January 13,

1994, would defer the response time testing until startup from the next cold shutdown, but no later than the startup from the Spring 1994 refueling outage.

You requested this action to avoid the potential for unnecessary actuations or disabling of ECCS during testing, to avoid the potential for a plant trip during testing, and to avoid a plant transient and reduce both operational and shutdown risk.

Your letter dated January 13,

1994, documented your request.

You provided justification for continued operation based on completed functional testing of the affected circuitry, the historic reliability of the affected relays and associated

contacts, a typical relay operating time of approximately 100 milliseconds, and the margin between current operating times of tested portions of the circuit and the requirements of TS Table 3.3.3-3 for ECCS response time of the LPCS system.

You stated that the Plant Operations Committee (POC) had reviewed and approved your request before you initially contacted the NRC for enforcement discretion, and that the POC also reviewed 4~

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Mr. J.

V. Parrish January 14, 1994 and approved yo'ur written request.

You further stated that no additional compensatory measures were planned or necessary to support your request.

Based on our review of your justification, we have concluded that this course

'f'action involves minimal or no safety impact, and we are clearly satisfied that this exercise of enforcement discretion is warranted from a public health and safety perspective.

Therefore, we are exercising our discretion not to enforce compliance with TS 3.3.3 action statements for, those components

'dentified'in your January 13,

1994, Request for Enforcement Discretion for the. period from,4:50 p.m.

EST until we have completed action on your emergency TS request dated January 13, 1994.

This letter confirms our verbal granting of enforcement discretion during a conference call between the Supply System and NRC staff on January 11, 1994.

However, we will consider enforcement

action, as appropriate, for the conditions that led to the need for this exercise of enforcement discretion.

Sincerely, Original Signed by Theodore R. quay for Elinor G. Adensam, Assistant Director for Regions IV and V

Division of Reactor Projects III/IV/V Office of Nuclear Reactor Regulation cc:

See next page DISTRIBUTION:

Docket File FMiraglia EAdensam

OGC, 15B18 Tech.

Rev.

JLieberman, OE NRC 81 Local PDRs LJ Callan, Acting TQuay

DHagan, 3206 ACRS (10), P315 Region V (4)

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Parrish'nd approved your written request.

You further stated that no additional compensatory measures were planned or necessary to support your request.

Based on our review of your justification, we have concluded that this course of action involves minimal or no safety impact, and we are clearly satisfied that this exercise of enforcement discretion is warranted from a public health and safety perspective.

Therefore, we are exercising our discretion not to enforce compliance with TS 3.3.3 action statements for those components identified in your January 13,

1994, Request for Enforcement Discretion for the period from 4:50 p.m.

EST until we have completed action on your emergency TS request dated January 13, 1994.

This letter confirms our verbal granting of enforcement discretion during a conference call between the Supply System and NRC staff on January ll, 1994.

However, we will consider enforcement

action, as appropriate, for the conditions that led to the need for this exercise of enforcement discretion.

Sincerely, gg,~~ A cc:

See next page Elinor G. Adensam, Assistant Director for Regions IV and V

Division of Reactor Projects III/IV/V Office of Nuclear Reactor Regulation

Mr. J.

V. Parrish WPPSS Nuclear Project No.

2 Washington Public Power Supply System (WNP-2)

CC'r. J.

H. Swailes WNP-2 Plant Manager Washington Public Power Supply System P.

O.

Box 968

Richland, Washington 99352-0968 G. E.

C. Doupe, Esq.

(Mail Drop 396)

Washington Public Power Supply System 3000 George Washington Way P. 0.

Box 968

Richland, Washington 99352-0968 Mr. Warren Bishop, Chairman Energy Facility Site Evaluation Council P. 0.

Box 43172 Olympia, Washington 98504-3172 Mr. H. K. Kook (Mail Drop PE20)

WNP-2 Licensing Manager Washington Public Power Supply System P. 0.

Box 968

Richiand, Washington 99352-0968 Mr. 0.

Coleman (Mail Drop PE20)

Acting Regulatory Programs Manager Washington Public Power Supply System P. 0.

Box 968

Richland, Washington 99352-0968 Regional Administrator, Region V

U.S. Nuclear Regulatory Commission 1450 Maria Lane, Suite 210 Walnut Creek, California 94596 Chairman Benton County Board of Commissioners P. 0.

Box 190

Prosser, Washington 99350-0190 Mr. R.

C. Barr U. S. Nuclear Regulatory Commission P. 0.

Box 69

Richland, Washington 99352-0968 H. H. Philips, Jr.,

Esq.

Winston 8 Strawn 1400 L Street, N.W.

Washington, D.C.

20005-3502