ML17291B171

Submits Notice of Enforcement Discretion for WPPSS Re WNP-2

ML17291B171
Person / Time
Site:	Columbia
Issue date:	12/21/1995
From:	Callan L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Parrish J WASHINGTON PUBLIC POWER SUPPLY SYSTEM
References
NUDOCS 9512280035
Download: ML17291B171 (6)

Text

CATEGORY 2~

REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)

ACCESSION NBR:9512280035 DOC.DATE: 95/12/21 NOTARIZED: NO FACIL:50-397 WPPSS Nuclear Project, Unit 2, Washington Public Powe AUTH.NAME AUTHOR AFFILIATION CALLAN,L.J.

Region 4 (Post 820201)

RECIP.NAME RECIPIENT AFFILIATION PARRISH,J.".

Washington Public Power Supply Sys'em DOCKET I 05000397

SUBJECT:

Submits notice of enforcement discretion for WPPSS re WNP-2.

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UNITED STATES I UCLEAR REGULATORY COMMISSIO REGION IV 611 RYAN PLAZA DRIVE, SUITE 400 ARLINGTON,TEXAS 76011.6064 December 21, 1995 Washington Public Power Supply System ATTN:

J.

V. Parrish, Vice President Nuclear Operations 3000 George Washington Way P.O.

Box 968, HD 1023

Richland, Washington 99352

SUBJECT:

NOTICE OF ENFORCEMENT DISCRETION FOR WASHINGTON PUBLIC POWER SUPPLY SYSTEM REGARDING WNP-2 (NOED NO. 95-4-06)

By letter dated December 19,

1995, you requested that the NRC exercise discretion not to enforce compliance with the actions required in Technical Specification (TS) 3.8. 1. l.a to repeat the test of emergency Diesel Generators (DG-2 and DG-3) every 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> in accordance with Surveillance Requirement 4.8. 1. 1.2.a.4.

That letter documented information previously discussed with the NRC in a telephone conversation on December 18, 1995, at 6:05 p,m.

PST.

Because DG-1 was inoperable, TS 3.8. 1. l.a required that operability of the remaining A.C. sources, DG-2 and DG-3, be demonstrated by performing the Surveillance Requirements of 4.8. 1. 1.2.a.4 within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> and at least once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> thereafter.

TS 3.8. l.l.a allows 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> for restoration of DG-1 to operable status from the time of initial loss (initial loss or inoperability was declared at 8:33 p.m.

PST on December 17, 1995) or be in 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 /> and in Cold Shutdown within the following 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

Surveillance Requirement 4.8. 1. 1.2.a.4 requires diesel starts from ambient condition and acceleration to at least 900 rpm (60 Hz) in less than or equal to 10 seconds for DG-2 and 13 seconds for DG-3.

You requested that a

Notice of Enforcement Discretion (NOED) be issued pursuant to the NRC's policy regarding exercise of discretion for an operating facility, set out in Section VII.c, of the "General Statement of Policy and Procedures for NRC Enforcement Actions" (Enforcement Policy),

NUREG-1600, and be effective for the period from the time of issuance until 8:33 a.m.

PST on December 22, 1995.

Entry into the Technical Specification action occurred as a result of a DG-1 failure during normal monthly surveillance testing.

The safety basis for the requested enforcement discretion is the elimination of unnecessary wear of DG-2 and DG-3 which would occur as a result of the additional tests required by TS 3.8. 1. l.a.

Furthermore, as identified previously by the industry and the NRC in NUREG 1434, a single test of the operable DG's within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> is adequate to demonstrate the lack of a common mode failure condition upon failure of one DG.

In this case you had already successfully performed two such tests on each of the remaining two diesels (DG-2 and DG-3) to demonstrate their operability.

As compensatory action you proposed to 'perform Surveillance 95i2280035 95i221 PDR ADOCK 05000397 PDR

NOED 95-4-06 Requirement 4.8. l. 1. l.a every 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />.

Surveillance Requirement 4.8. 1. 1. l.a

quires verification o;. correct breaker alignments ind indicated power availability between the offsite transmission and the onsite Class 1E distribution system.

You further committed that Division 2 and 3 equipment would be maintained in a "protected" condition (i.e. non-mandatory work and testing on this equipment would not be allowed) for the duration of the NOED and that any significant reactor power changes would be discussed with the Region prior to implementation during the time period of the NOED.

The staff has evaluated your proposal and accepts the argument provided in support of your request based upon its satisfaction of Criterion l(b) of Section B of Part 9900 of the NRC Inspection Manual, specifically with regard to the elimination of testing that is inappropriate for the particular plant conditions.

We also noted that the actions you have already taken, when supplemented by the actions proposed in your request for enforcement discretion, would exceed the requirements in the Improved Standard Technical Specification, which you have submitted to the staff as an amendment request by letter dated December 8,

1995.

On the basis of the staff's evaluation of your request, including the compensatory measures described

above, the staff has concluded that an NOED was warranted because we were clearly satisfied that this action involved minimal or no safety impact and had no adverse radiological impact on public health and safety.

Therefore, it is our intention to exercise discretion not to enforce compliance with the specific action required in Technical Specification (TS) 3.8. 1. l.a to test emergency Diesel Generators (DG-2 and DG-3) every 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> in accordance with Surveillance Requirement 4.8. 1. 1.2.a.4 for the period from 6:05 p.m.

on December 18, 1995, until 8:33 a.m.

PST on December 22, 1995.

All other requirements of TS 3.8. 1. l.a still apply.

This letter documents our telephone conversation on December 18,

1995, at 6:05 p.m.

PST, when we orally issued this notice of enforcement discretion.

We understand that the condition causing the need for this NOED was corrected by you causing you to exit from Technical Specification 3.8. 1. I.a and this NOED at 0022 on December 20, 1995.

However, as stated in the 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, Regional Administrator Docket No. 50-397 License No.

NPF-21

NOEO 95-4-06 CC:

Vashington Public Power Supply System ATTN:

J.

H. Swailes, WNP-2 Plant Manager P.O.

Box 968, MD 927M

Richland, Washington 99352-0968 Washington Public Power Supply System ATTN:

Chief Counsel 3000 George Washington Way P.O.

Box 968, MD 396

Richland, Washington 99352-0968 Energy Facility Site Evaluation Council ATTN:

Frederick S. Adair, Chairman P.O.

Box 43172 Olympia, Washington 98504-3172 Washington Public Power Supply System ATTN:

D. A. Swank, WNP-2 Licensing Manager P.O.

Box 968 (Hail Drop PE20)

Richland, Washington 99352-0968 Washington Public Power Supply System ATTN:

P.

R. Bemis, Director Regulatory and Industry Affairs P.O.

Box 968 (Mail Drop PE20)

Richland, Washington 99a52-0968 Benton County Board of Commissioners ATTN:

Chairman P.O.

Box 190

Prosser, Washington 99350-0190 Winston

& Strawn ATTN:

H.

H. Philips, Esq.

1400 L Street, N.W.

Washington, D.C.

20005-3502

HOED 95-4-06 bcc to DMB ( IE51) i g bcc distrib.

by RIY:

L. J. Callan DRS-PSB Branch Chief (DRP/E, WCFO)

Senior Project Inspector (DRP/E, WCFO)

Leah Tremper (OC/LFDCB, MS:

TWFN 9E10)

S. Richards (NRR/HOLB)

L. Hurley Resident Inspector MIS System RIY File Branch Chief (DRP/TSS)

M.

Hammond (PAO, WCFO)

DOCUMENT NAME':i NOEDttWN5-006.DRP To receive copy of document, indicate in box: "C

~ Copy without enclosures E" ~ Copy with enclosures "N" ~ No copy C:DRP/E DECor poryggy or HJWon 12/20/95 D:WCFO KEP k ns 12/20/95 D:DRP JEDye 12/Zi/95 NRR JWRoe8.Lf~

12/21/95

NOED 95-4-06 bcc to DMB (IE51) bcc distrib.

by RIV:

L. J. Callan DRS-PSB Branch Chief (DRP/E, WCFO)

Senior Project Inspector (DRP/E, WCFO)

Leah Tremper (OC/LFDCB, MS:

TWFN 9E10)

S. Richards (NRR/HOLB)

L. Hurley Resident Inspector MIS System RIV File Branch Chief (DRP/TSS)

M.

Hammond (PAO, WCFO)

DOCUMENT NAME:

R:i NOED'ItWN5-006.DRP To receive copy of document, indicate ln boxt "C" Copy without enclosures "E" ~ Copy with enclosures "N" ~ No copy C:DRP/E DECorpor~gy or HJWon 12/20/95 D:WCFO KEP k ns 12/20/95 D:DRP JEDye 12/g /95 NRR JWRoegrQ~

12/21/95