ML17300B367
| ML17300B367 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 09/10/1999 |
| From: | Merschoff E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Overbeck G ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR |
| References | |
| NUDOCS 9910120279 | |
| Download: ML17300B367 (7) | |
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UNITED STATES NUCLEAR REGULATORY COMMISSION B(GLQ( pvgcolvICH I IIQOI"I 611 RYAN PLAZADRIVE, SUITE 400 ARLINGTON,TExAs 7/011-IIII(4 53 99 gpp q (
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sap to l999 Gregg R. Overbeck, Senior Vice President, Nuclear Arizona Public Service Company.
P.O. Box 52034 Phoenix, Arizona 85072-2034
SUBJECT:
NOTICE OF ENFORCEMENT DISCRETION FOR ARIZONAPUBLIC SERVICE COMPANY REGARDING PALO VERDE NUCLEAR GENERATING STATION, UNIT 2, NOED NO. 99-4-002
Dear Mr. Overbeck:
During a telephone conservation on September 3, 1999, you requested that the NRC exercise discretion not to enforce compliance with the actions required by Technical Specification (TS) 3.8.1, "AC Sources - Operating." Specifically, you requested approval of an extension of the completion time specified in TS 3.8.1, Required Action,8.4, from 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to 108 hours0.00125 days <br />0.03 hours <br />1.785714e-4 weeks <br />4.1094e-5 months <br /> to complete repair and testing of Emergency Diesel Generator (EDG) 2A. Based on the information you presented, the NRC exercised discretion not to enforce compliance with the actions required by TS 3.8.1, "AC Sources - Operating." Your request was documented in a letter dated September 3, 1999, and supplemented in a subsequent letter dated September 8.
In the September 8 letter, you informed the NRC that repair and testing of the EDG was completed within the 72-hour completion time allowed by TS 3.8.1 and, therefore, the enforcement discretion was not needed.
This letter documents the circumstances and considerations which resulted in your request for and the NRC's granting of enforcement discretion.
Participants in the September 3, 1999, telephone conversation included Ellis Merschoff, Regional Administrator, Region IV, and members of his staff; Stuart Richards, Director, Project Directorate IV, Division of Licensing Project Management, Office of Nuclear Reactor R
t t'NRR) and members of lhe NRR staff; Gregg Dverbeck, Senior Vice President, that Nuclear, and members of his staff. During the telephone conversation, it was stated a
EDG 2A was removed from service at 4:47 a.m. (MST) on September 1, 1999, to repair a problem associated with Cylinder 3R. On September 3, during postmaintenance
- testing, EDG 2A d loped a leak in the jacket water subsystem.
Your staff determined that repairs to
'EDG 2A mair not be completed within lhe 72-hour completion time provided in TS 3..
eve th f
you requested an extension to the allowed outage time of 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> to facilitate ere ore, you r completing the repair and testing of EDG 2A. Without an extension, the 72-hour co p
m letion time would expire on September 4, 1999, at 4:47 a.m. (MST), and a plant shutdown would be require our requ
- d. Y equest for a Notice of Enforcement Discretion (NOED) was reviewed by the no eratin NRC t ff 'rdance with the NRC's policy regarding exercise of discretion for an op g
s a, in ace for NRC facility, set out in Section Vll.c, of the "General Statement of Policy and Procedures or Enforcement Actions," NUREG-1600.
The safety basis for the request for enforcement discretion was that extending the allowed outage time for EDG 2A for an additional 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> resulted in a minimal increase in core
Arizona Public Service Company damage frequency.
The request also stated that shutting the plant down to repair the EDG would result in an increase in expected risk that would be greater than that of the 36-hour extension of power operation.
Compensatory measures proposed by your staff for the duration of the NOED and considered in the NRC staff's evaluation included:
(1) prohibiting planned work in the switchyard that could potentially result in a loss of power to any unit, (2) prohibiting planned maintenance on either gas turbine generator, (3) prohibiting additional planned work on EDGs in any unit, (4) providing direction to the Unit 1 Shift Manager that offsite power to the units should not be interrupted during the repair of EDG 2A, (5) notifying system dispatchers of the work being performed on the EDG in order that appropriate precautions could be taken for the outside distribution system, and (6) suspending maintenance activities in the switchyard and in the vicinityof the incoming lines and associated 13.8 kV buses.
On the basis of the NRC staff's evaluation of your request, including the compensato'ry measures described above, the NRC staff concluded that an NOED would be 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.
Additionally, we determined that the
, request satisfied the NRC's policy for enforcement discretion.
As a result, the NRC was prepared to exercise discretion not to enforce compliance with TS 3.8.1 by granting approval of an extension of the allowed outage time specified in TS 3.8.1, Required Action B.4, from 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to 108 hours0.00125 days <br />0.03 hours <br />1.785714e-4 weeks <br />4.1094e-5 months <br /> to complete repair and testing of EDG 2A.
This NOED was orally approved on September 3, 1999, at 6:05 p.m. (MST). In your letter dated September 8, 1999, you informed the NRC that repair and testing of the EDG had been completed within the 72-hour completion time allowed by TS 3.8.1. This resulted in the enforcement discretion not being needed or applied.
Sincerely Ellis W. Mersc f
Regional Ad nistrator Docket No.:
50-529 License No.:
NPF-51 CC:
Steve Olea Arizona Corporation Commission 1200 W. Washington Street Phoenix, Arizona 85007 Douglas K. Porter, Senior Counsel Southern California Edison Company Law Department, Generation Resources P.O. Box 800
- Rosemead, California 91770
Arizona Public Service Company Chairman Maricopa County Board of Supervisors 301 W. Jefferson, 10th Floor Phoenix, Arizona 85003 Aubrey V. Godwin, Director Arizona Radiation Regulatory Agency 4814 South 40 Street Phoenix, Arizona 85040 Angela K. Krainik, Director Regulatory Affairs Arizona Public Service Company P.O. Box 52034 Phoenix, Arizona 85072-2034 John C. Horne, Vice President, Power Generation El Paso Electric Company 2702 N. Third Street, Suite 3040 Phoenix, Arizona 85004 Terry Bassham, Esq.
General Counsel El Paso Electric Company 123 W. Mills El Paso, Texas 79901 John W. Schumann Los Angeles Department of Water & Power Southern California Public Power Authority P.O. Box 51111, Room 1255-C Los Angeles, California 90051-0100 David Summers Public Service Company of New Mexico 414 Silver SW, ff1206 Albuquerque, New Mexico 87102 Jarlath Curran Southern California Edison Company 5000 Pacific Coast Hwy. Bldg. DIN San Clemente, California 92672 Robert Henry Salt River Project 6504 East Thomas Road Scottsdale, Arizona 85251
Arizona Public Service Company SEP l 0 l999 bcc to DMB (IE51) bcc distrib. by RIV:
F. Miraglia, DEDR E. Merschoff, Regional Administrator B. Sheron, Associate Director for Project Licensing & Technical Analysis J. Zwolinski, Director, Division of Licensing Project Management S. Richards, Project Director, Project Directorate IVand Decommissioning R. W. Borchardt, Director, Office of Enforcement Public Document Room and Local Public Document Room Electronic file copy to: E-mail address:
NOED (Michael Boyle)
Electronic file copy to: BBS Operator, E-mail address:
TGD Electronic file copy to: NRCWEB G. Sanborn,'Director, Allegation Coordination and Enforcement and Enforc K. Brockman, Director, DRP, RIV A. Howell, Director, DRS, RIV P. Harrell, Branch Chief, Branch D K.,Kennedy, Senior Project Engineer, Branch D L. Yandell, Branch Chief, TSS, RIV RIV File
'ITS Coordinator J. Calvo, BC, EEIB, NRR W. Becker, BC, RTSB, NRR R. Barrett, BC, SPSB, NRR ACRS OGS ement Staff DOCUMENT NAME: R:CANOED)PV99-4-002 To receive co of document, indicate in box: "C = Co without enclosures
"-E" = Co with enclosures "N = No co RIV:SPE:DRP/D C:DRP/D DRS/SRA.
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F. Miraglia, DEDR E. Merschoff, Regional Administrator B. Sheron, Associate Director for Project Licensing 8 Technical Analysis J. Zwolinski, Director, Division of Licensing Project Management S. Richards, Project Director, Project Directorate IVand Decommissioning R. W. Borchardt, Director, Office of Enforcement I lb Sl
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NOED (Michael Boyle)
Electronic file copy to: BBS Operator, E-mail address:
TGD Electronic file copy to: NRCWEB G. Sanborn, Director, Allegation Coordination and Enforcement and Enforce K. Brockman, Director, DRP, RIV A. Howell, Director, DRS, RIV P. Harrell, Branch Chief, Branch D K. Kennedy, Senior Project Engineer, Branch D L. Yandeli, Branch Chief, TSS, RIV RIV File BITS Coordinator J. Calvo, BC, EEIB, NRR W. Becker, BC, RTSB, NRR R. Barrett, BC, SPSB, NRR ACRS OGS ment Staff DOCUMENT NAME: R:5 NOEDEP V]9-4-002 To receive co of document, indicate in box: C" = Co without encfosures "E" = Co with enctosures "8" = No co RIV:SPE:DRP/D*
C:DRP/D DRS/SRA.
D:DRP PDIV/NRR KMKenned 09/ /99 DRA TPGwynn 09/ b'99 09/ /99 RA FW 09/I 09/
/99 PHHarrell fe" WBJones ~ ~> KEBrockman 094o/99 SARichards W4 09
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- previously concurred OFFICIAL,RECORD COPY
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