ML20057A034

Confirms That on 930825,NRC Orally Granted Util Request for Enforcement Discretion Re TS Surveillance Requirement 4.3.2.1 Applicable to Certain ESFAS Instrumentation Channels

ML20057A034
Person / Time
Site:	Seabrook
Issue date:	08/30/1993
From:	Calvo J Office of Nuclear Reactor Regulation
To:	Feigenbaum T NORTH ATLANTIC ENERGY SERVICE CORP. (NAESCO)
References
SEA-93-022, SEA-93-22, TAC-M87257, NUDOCS 9309100323
Download: ML20057A034 (5)

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NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 205%-0001 j

j August 30, 1993  ;

Docket No. 50-443  !

N0ED No. 93-6-022 Serial No. SEA-93-022 l

Mr. Ted C. Feigenbaum i Senior Vice President '

and Chief Nuclear Officer North Atlantic Energy Service Corporation Post Office Box 300 Seabrook~, New Hampshire 03874

SUBJECT:

NOTICE OF ENFORCEMENT DISCRETION RELATED TO ENGINEERED SAFETY FEATURES ACTUATION SYSTEM INSTRUMENTATION SURVEILLANCE REQUIREMENTS l (TAC M87257)

' This letter confirms that on August 25, 1993, the Nuclear Regulatory ,

Commission (NRC) granted orally North Atlantic Energy Service Corporation's '

(North Atlantic) request for enforcement discretion regarding Technical j Specification Surveillance Requirement 4.3.2.1 applicable to certain i Engineered Safety Features Actuation System (ESFAS) instrumentation channels.

On August 25, 1993, North Atlantic representatives requested the NRC to .}

exercise its discretion not to enforce compliance with Seabrook Technical l Specification Surveillance Requirement 4.3.2.1, Table 4.3-2, Functional Unit '

l 8.b, CHANNEL CHECK, commencing on August 25, 1993. The request for  !

enforcement discretion was presented during a teleconference between NRC and North Atlantic representatives. The request, along with supporting  :

information, was also submitted by letter dated August 26, 1993.

j North Atlantic informed the NRC that on August 24, 1993, it had determined that the subject CHANNEL CHECK of the Refueling Water Storage Tank (RWST) low-low level instrumentation (Functional Unit 8.b), had not been performed adequately in the past. North Atlantic determined that the present design of the RWST low-low level . instrumentation precludes performing an adequate CHANNEL CHECK.

i Upon determining that the required surveillances had not been performed adequately, North Atlantic performed an operational check (which meets the intent of the CHANNEL CHECK) on each of.the four level channels and.has continued to perform such operational checks every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. An operational check involves venting each level instrument and verifying that the low level bistable is actuated and that the transmitter is accurate at the zero level.

North Atlantic believes that performance of the operational check every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> to satisfy the current CHANNEL CHECK requirement warrants enforcement discretion because this activity has the potential to reduce the f

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Mr. Ted C. Feigenbaum level of protection to the health and safety of the public, increases occupational exposure, and imposes a significant burden upon the Station. '

During the licensing of Seabrook, a commitment was made to provide increased surveillance to ensure operability of the level transmitters to compensate for the lack of main control board indication. The operational check was developed to verify the operability of the RWST low-low level transmitters.

This check has been performed every 6 months on a staggered test basis.

North Atlantic believes that this check was intended to replace the requirement to perform a periodic CHANNEL CHECK and that during the review and approval of the original Technical Specifications an error was made which .

resulted in the inclusion of the CHANNEL CHECK requirement in the Technical  !

Specifications that were issued with Operating License, NPF-86, for Seabrook Station. Because the CHANNEL CHECK requirement remains in the Technical  ;

Specifications, North Atlantic has determined that a CHANNEL CHECK must be performed and has been performing the operational check every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> since August 24, 1993. '

As justification for the requested enforcement discretion, North Atlantic provided the following rationale:

1. At Seabrook Station the RWST low-low level narrow range instrument design precludes performing a channel to channel comparison and verifying that the transmitters have not failed high.

2. A CHANNEL CHECK, by definition, is a qualitative assessment of channel  :

~

behavior during operation. To perform a surveillance that meets the '

intent of a CHANNEL CHECK with the Seabrook design requires that the i channel being tested be placed in the tripped condition. This could i contribute to premature switchover of the Residual Heat Removal suction  ;

path from the RWST to the containment sump during accident conditions.

3. The performance of the operational checks on all four channels takes approximately 7 man-hours to complete and entails exposure of personnel to radiation (approximately 2 mrem per performance or 850 mrem if continued until the refueling outage) and has the potential to contaminate personnel with radioactive water due to the venting processes required by the procedure.

4. The manipulation of equipment to perform the operational checks greatly increases the potential for equipment malfunction and human error.

5. The RWST low-low level transmitters are highly reliable and fully functional. This is supported by a history of 7 years of satisfactory performance of calibrations and ANALOG CHANNEL OPERATIONAL-TESTS (ACOT),

, and three successful operational checks that have been performed since August 24, 1993. The narrow range RWST level transmitters have not experienced any gross failures and have not required significant l adjustment during periodic calibrations. '

i

Mr. Ted C. Feigenbaum 6. In lieu of performing CHANNEL CHECKS, North Atlantic has proposed an ,

amendment to the operating license that woulu replace the requirement for performing a CHANNEL CHECK on the RWST low-low level instruments pursuant to Technical Specification 4.3.2.1, Table 4.3-2, Functional Unit 8b, with a requirement to perform a TRIP ACTUATING DEVICE OPERATIONAL CHECK (TAD 01) at least once per 92 days. The proposed amendment would not affect the current requirement for performing an ACOT monthly. The TAD 0T would not include setpoint verification since l this is accomplished under the ACOT. North Atlantic asserts that the installed instruments are accurate and reliable and that a quarterly TADOT is sufficient to detect an instrument failure in the time period between channel calibrations.

Based upon our review of your justifications identified above, the staff has concluded that this course of action involves minimum safety impact, and we are satisfied that the exercise of enforcement discretion is warranted from a public health and safety perspective. Therefore, it is our intention to exercise discretion not to enforce compliance with Technical Specification Surveillance Requirement 4.3.2.1, Table 4.3-2, Functional Unit 8.b, CHANNEL CHECK, commencing on August 25, 1993, until a decision by the staff regarding the proposed amendment is issued. However, we will consider enforcement action, as appropriate, for the circumstances that led to the need for this exercise of enforcement discretion.  !

Sincerely, Original signed by Jose A. Calvo, Assistant Director for Region I Reactors Division of Reactor Projects - 1/II Office of Nuclear Reactor Regulation

. I cc: See next page  !

Distribution:

Docket File JPartlow SNorris CGrimes JLieberman, OE NRC & Local PDRs WRussell ADeAgazio JWermiel SDembek i I )f PD I-4 Plant SVarga 0GC ACRS (10)

TMurley JCalvo DHagan OPA JFRogge, RI [ b @g FMiraglia JStolz GHill (2) OC/LFDCB /M'<j9t#

OFFICE LA:PDI-4 PM:PDI-4/;/r[I S;SDTr/o BC#ilCB D:DRPk. AD_:DRPE NAME S ADeAgazfdkh JSto[ JWehNel Walvo i ,

DATE Sc/4Q93 f-1 #M93 0/e//93 f/)c/93 8/%/93 hF0/93 0FFICIAL RECORD COPY  ;

Document Name: G:\DEAGAZIO\87257NED  !

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Mr. Ted C. Feigenbaum  !

6. lieu of performing CHANNEL CHECKS, North Atlantic has proposed an '

an.cndment to the operating license that would replace the requirement e I

for performing a CHANNEL CHECK on the RWST low-low level instruments pursuant to Technical Specification 4.3.2.1, Table 4.3-2, Functional l Unit 8b, with a' requirement to perform a TRIP ACTUATING DEVICE  :

l OPERATIONAL CHECK (TADOT) at least once per 92 days. The proposed amendment would not affect the current requirement for performing an ACOT monthly. The TAD 0T would not include setpoint verification since this is accomplished under the ACOT. North Atlantic asserts _that the installed instruments are accurate and celiable and that a quarterly TAD 0T is sufficient to detect an instrument failure in the time period between channel calibrations. '

4 Based upon our review of your justifications identified above, the staff has concluded that this course of action involves minimum safety impact, and we are satisfied that the exercise of enforcement discretion is warranted from a public health and safety perspective. Therefore, it is our intention te '

exercise discretion not to enforce compliance with Technical Specification Surveillance Requirement 4.3.2.1, Table 4.3-2, Functional Unit 8.b, CHANNEL CHECK, commencing on August 25, 1993, until a decision by the staff regarding the proposed amendment is issued. However, we w'll consider enforcement action, as appropriate, for the circumstances that led to the need for this exercise of enforcement discretion. -

Sincerely, ,

Jose A. Calvo, Assistant Director for Region I Reactors Division of Reactor Projects - I/II Office of Nuclear Reactor Regulation cc: See next page

1 Mr. Ted C. Feigenbaum Seabrook Station i cc:

l Thomas Dignan, Esq. Mr. George L. Iverson, Director John A. Ritsher, Esq. New Hampshire Office of Emergency Ropes and Gray Management One International Place State Office Park South Boston, Massachusetts 02110-2624 107 Pleasant Street Concord, New Hampshire 03301 Mr. Peter Brann Assistant Attorney General Regional Administrator, Region I State House, Station #6 U.S. Nuclear Regulatory Commmission  !

Augusta, Maine 04333 475 Allendale Road King of Prussia, Pennsylvania 19406 Resident Inspector U.S. Nuclear Regulatory Commission Office c. *

- Attorney General Seabrrok Nuclear Power Station One Ashbu. ._ , Place Post Office Box 1149 20th Floor ,

Seabrook, New Hampshire 03874 Boston, Massachusetts 02108 Jane Spector Board of Selectmen Federal Energy Regulatory Commission Town of Amesbury 825 North Capital Street, N.E. Town Hall Room 8105 Amesbury, Massachusetts 01913 Washington, DC 20426 Mr. Jack Dolan Federal Emergency Management Agency Mr. T. L. Harpster Region I North Atlantic Energy Service J.W. McCormack Post Office &

Corporation Courthouse Building, Room 442 ,

Post Office Box 300 Boston, Massachusetts 02109 .

Seabrook, New Hampshire 03874 Mr. David Rodham, Director Massachusetts Civil Defense Agency Town of Exeter 400 Worcester Road 10 Front Street Post Office Box 1496 Exeter, New Hampshire 03823 Framingham, Massachusetts 01701-0317 ATTN: James Muckerheide Gerald Garfield, Esq.

Day, Berry and Howard Jeffrey Howard, Attorney General City Place G. Dana Bisbee, Deputy Attorney Hartford, Connecticut 06103-3499 General Attorney General's Office Mr. R. M. Kacich 25 Capitol Street Northeast Utilities Service Company Concord, New Hampshire 03301

Post Office Box 270 Hartford, Connecticut 06141-0270 Mr. Robert Sweeney l Bethesda Licensing Office  !

Suite 610 3 Metro Center Bethesda, Maryland 20814  :

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