ML17292A638
| ML17292A638 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 12/24/1996 |
| From: | Callan L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Parrish J WASHINGTON PUBLIC POWER SUPPLY SYSTEM |
| References | |
| NOED-96-4-001, NOED-96-4-1, NUDOCS 9612300026 | |
| Download: ML17292A638 (5) | |
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UNITED STATES NUCLEAR REGULATORY COMMISSION REGION IV 611 RYAN PLAZADRIVE, SUITE 400 ARLINGTON,TEXAS 76011.6064 DEC 24 l996 J. V. Parrish, Chief Executive Officer Washington Public Power Supply System 3000 George Washington Way P.O. Box 968, MD 1023 Richland, Washington 99352
SUBJECT:
NOTICE OF ENFORCEMENT DISCRETION FOR WASHINGTON PUBLIC POWER SUPPLY SYSTEM REGARDING WNP-2 (AOED NO. 96-4:.001) f By "GO2-96-247, Requests Enforcement Discretion from DG Testing Per TS 3.8.1.1.A.Request Specifically Asks That [[SR" contains a listed "[" character as part of the property label and has therefore been classified as invalid..a.4 Not Be Repeated for Duration of Current Entry to TS Action 3.8.1.1.a|letter dated December 20, 1996]], you requested that the NRC exercise discretion not to enforce compliance Technical Specification (TS) Action 3.8.1.1.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 20, 1996, at 3:00 p.m.
PST.
Because Standby Service Water Pump "A" was inoperable, TS Action 3.7.1
~ 1.d required taking the Action required by TS 3.8.1.1.a which requires that operability of the remaining A.C. sources, DG-2 and DG-3, be demonstrated by performing Surveillance Requirement 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 Action 3.7.1.1. 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 SSW Pump "A" to operable status from the time of initial loss (initial loss or inoperability was declared at 8:01 a.m. PST on December 20, 1996) 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.4requires 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 Vll.c, of the "General Statement of Policy and Procedures for NRC Enforcement Actions" (Enforcement Policy),
NUREG-1600, and be effective from the time of NOED issuance until 8:01 p.m. PST on December 24, 1996, or until exit from the action statement.
Entry into the Technical Specification action occurred as a result of a SSW Pump "A" failure during normal monthly surveillance testing due to an overcurrent trip. TS Action 3.7.1.1 required the entry into TS Action 3.8.1.1.a.
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 Action 3.8.1.1.a.
Furthermore, as identified previously in NUREG-1434, a single test of the operable DGs 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.
As compensatory action you proposed to perform Surveillance Requirement 4.8.1.1
~ 1.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
~ 1.1.a requires verification of correct breaker alignments and indicated power availability between the offsite transmission and the onsite 9612300026 9bi224 PDR ADQCK 05000397 P
Washington Public Power Supply System 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 position provided in support of your request based upon its satisfaction of Criterion 1(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 TS Action 3.8.1.1.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 from the approval of the NOED until 8:01 p.m. PST on December 24, 1996. All other requirements of TS 3.8.1.1.a still apply. This letter documents our telephone conversation on December 20, 1996, at 3:20 p.m. PST, when we orally issued this NOED. We understand that the condition causing need for this NOED was corrected, allowing you to exit Technical Specification Action 3.7.1
~ 1 and the NOED at 13:19 a.m. PST on December 21, 1996.
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, L. J. Callan Regional Administrator Docket No. 50-397 License No. NPF-21
Washington Public Power Supply System CC:
Frederick S. Adair, Chairman Energy Facility Site Evaluation Council P.O. Box,43172 Olympia, Washington 98504-3172 Mr. Paul R. Bemis (Mail Drop PE20)
Vice President, Nuclear Operations Washington Public Power Supply System P.O. Box 968 Richland, Washington 99352-0968 Mr. Rodney L. Webring" (Mail Drop"PE08)
Vice President, Operations Support/PIO Washington Public Power Supply System P.O. Box 968 Richland, Washington 99352-0968 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. David A. Swank (Mail Drop PE20)
Manager, Regulatory Affairs Washington Public Power Supply System P.O. Box 968 Richland, Washington 99352-0968 Mr. AI E. Mouncer (Mail Drop 396)
Chief Counsel Washington Public Power Supply System P.O. Box 968 Richland, Washington 99352-0968 Ms. Lourdes C. Fernandez (Mail Drop PE20)
Manager, Licensing Washington Public Power Supply System P.O. Box 968 Richland, Washington 99352-0968 Mr. Malcolm H. Phillips, Jr., Esq.
Winston 5 Strawn 1400 L Street, N.W.
Washington, D.C. 20005-3502
Washington Public Power Supply System OEC 2d I996 Pc~c,to,DIVllfgE51) bcc distrib. by RIV:
DEDR Regional Administrator Associate Director for Projects, NRR Associate Director for Technical Review, NRR Division Director, DRP III&IV,NRR Director, Office of Enforcement Public Document Room and Local Public Document Room Technical Assistant, DRP - I/II, NRR Electronic copy (WordPerfect file) to E-mail address:
NOED Electronic copy (WordPerfect file) to BBS Operator, E-mail address:
TGD Region IV NOED File (L. Thomas)
DOCUMENT NAME: R:lr NOED'tWN6-001.DRP AI 96-361 To receive copy of document, indicate in box: "C" = Copy without enclosures "E" = Copy with enclosures "N" = No copy RIV:PI:DRP/E GWJohnston:jb 1 2/$96 AC:DRP/E FRHuey 1 2/r.f96 D:DRP NRR/DRPW Batema JEDyer 12/ 96 12/
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OFFICIAL RECORD COPY
Washington Public Power Supply System DEC 24 l996 bcc to DMB (IE51) bcc distrib. by RIV:
DEDR Regional Administrator Associate Director for Projects, NRR Associate Director for Technical Review, NRR Division Director, DRP IIISIV, NRR Director, Office of Enforcement Public Document Room and Local Public Document Room Technical Assistant, DRP - I/II, NRR Electronic. copy. (WordPerfect file)-@ E-mail address:
NOED Electronic copy (WordPerfect file) to BBS Operator, E-mail address:
TGD Region IV NOED File (L. Thomas)
DOCUMENT NAME: R:t NOEDiWN6-001.DRP AI 96-361 To receive copy of document, indicate in box: "C" = Copy without enclosures "E" = Copy with enclosures "N" = No copy RIV:PI:DRP/E GWJohnston:jb 12 $96 AC:DRP/E FRHuey 1 2gP96 D:DRP JEDyer 12'6 NRR/DRPW Batema 12 96~ ~m<
OFFICIAL RECORD COPY