ML20058F070
| ML20058F070 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 11/24/1993 |
| From: | Zwolinski J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Delgeorge L COMMONWEALTH EDISON CO. |
| References | |
| TAC-M88199, NUDOCS 9312070304 | |
| Download: ML20058F070 (6) | |
Text
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Docket No. SIN 50-456 NDED No. 93-6-027 Mr. L. O. DelGeorge, Vice President Nuclear Oversight and Regulatory Services Comnonwealth Edison Company Executive Towers West III, Suite 500 1400 Opus Place l
Downers Grove, Illinois 60515
Dear Mr. DelGeorge:
SUBJECT:
NOTICE OF ENFORCEMENT DISCRETION FOR COMMONWEALTH EDISON COMPANY REGARDING THE BRAIDWOOD STATION, UNIT 1 (TAC NO. M88199)
This letter documents our verbal granting, on November 5,1993, of our intention to exercise discretion not to enforce compliance with the Technical Specifications (TS) for Braidwood Station, Unit 1 (Braidwood).
On November 5, 1993, a conference call was conducted between the members of the NRC staff and Braidwood staff to discuss the results of your inspection of the tubes in the "lC" steam generator. The plant had been shut down on October 24, 1993. as a result of a primary-to-secondary leak in the rarce of 280 to 309 gallons per day (gpd).
After shutdown, the location of the leak was identified.
Subsequently, Braidwood plant management decided to perform 100% full length bobbin coil inspection on all tubes in the IC steam generator and to take the following actions:
- 1) plug all clear indications of greater than or equal to 40% through-wall degradation; and 2) plug any distorted indications which showed abnormal growth when compared to data from previous outages. As a result of the inspections, a total of 117 tubes were plugged.
During the telephone call, plant management stated that the plant was shut down due to an administrative limit of primary-to-secondary leakage of 300 gpd, which is below the plant TS limit of "500 gpd through any one steam generator" (TS 3.4.6.2.c).
Plant management believed TS 4.4.5.3.c did not apply because none of the four conditions contained therein were met.
Had it applied, the inspection results would have been classified as Category C-3 which would have required inspections in the other three steam generators in accordance with TS Table 4.4-2.
In reading the TS, I understood how the interpretation applied by the-Braidwood management was possible.
Further, as a result of the work done on the tubes of the 10 steam generator, it was considered operable.
During'the discussions, plant management stated that the IC steam generator had historically exhibited the greatest amount of tube degradation and that the tube degradation recently identified was consistent with that expected for the operational period since the last inservice inspection.
Yo'. r staff also stated that a 100% inspection of the tubes in all four steam generators is planned for the next refueling outage which is scheduled to begin on I D is" IJM MHg6 30 RE WHB MY d
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Mr. L. O. DelGeorge ~
March 5, 1994.
In addition, the following commitments for compensatory actions were made:
- 1) steam jet ejector and main steam line radiation monitor alert setpoints would be lowered; 2) the abnormal operating procedure for primary-to-secondary leakage would be revised to include guidance to personnel regarding monitoring when known leakages exists, including the use of portable N-16 monitors; 3) operating shifts would be briefed on the requirements of the revised procedures prior to assuming duties when the unit is critical; and 4) the administrative limit for primary-to-secondary leakage through any one steam generator would be lowered to 150 gallons per day.
I understand that these actions have been implemented.
At the conclusion of our discussions, I agreed with the proposed actions, including restart of the unit. The assurance that the actions taken involved minimal safety significance was of paramount importance in arriving at my decision. At that time I did not view my efforts to be a granting of a Notice of Enforcement Discretion (N0ED) and as such, actions taken were not initially documented as called for by the NRC's N0ED process.
During internal NRC discussions on November 8,1993, the staff subsequently determined that TSs 4.4.5.2.c and 4.4.5.4.b were applicable to the circumstances existing at Braidwood Unit I the previous week.
Further, the staff concluded that because the number of defective tubes found in the inspection of the IC steam generator exceeded 1% of the tubes inspected, the inspection results were in Category C-3, which would have required that additional inspections be performed. However, the NRC staff reaffirmed our earlier determination that the circumstances discussed on November 5,1993, involved minimal safety significance.
The results of the staff's review of the issues were conveyed to Commonwealth Edison Company (CECO) management on November 8, 1993. The staff position is that the situation that Braidwood encountered was in fact covered by its TS.
As a result, due to the low safety significance and the compensatory actions taken, the NRC actions on November 5, 1993, essentially constituted the granting of an N0ED.
CECO management subsequently submitted a written justification in support of the granting of the N0ED on November 10, 1993, and an associated emergency license amendment request on November 12, 1993, which the staff is currently reviewing.
In summary, based on our review of the justification, including the aforementioned compensatory actions, we concluded that this course of action involved minimal or no safety impact, and we were clearly satisfied that the exercise of enforcement discretion was warranted from a public health and safety perspective.
Therefore, this letter documents our verbal granting on Novecrber 5,1993, of our intention to exercise discretion not to enforce compliance with TSs 4.4.5.0, 4.4.5.2, and 4.4.5.5 for the period beginning-5:05 p.m. (CST) on November 5, 1993, until the staff acts on the request of November 12, 1993, for an emergency license amendment. Notwithstanding our
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granting of enforcement discretion, we will consider enforcement action, as appropriate, for the conditions tl. t led to the need for this enforcement discretion.
Sincerely, OriginalSigned By:
John A. Zwolinski, Assistant Director for Region III Reactors Division of Reactor Projects - liI/IV/V Office of Nuclear Reactor Regul 3n cc:
see next page DISTRIBUTION Docket File NRC & Local PDRs PDIII-2 r/f TA, DRPE TMurley FMiraglia LJCallan EGreenman, RIII WRussell JRoe JZwolinski JBMartin, RIII JDyer CMoore RAssa JStrosnider 0GC DHagan GHill(2)
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s Mr. D. L. Farrar Braidwood Station Commonwealth Edison Company Units 1 CC:
Mr. William P. Poirier Chairman Westinghouse Electric Corporation Will County Board of Supervisors Energy Systems Business Unit Will County Board Courthouse Post Office Box 355, Bay 236 West Joliet, Illinois 60434 Pittsburgh, Pennsylvannia 15230 Ms. Lorraine Creek Joseph Gallo, Esquire Rt. 1, Box 182 Hopkins and Sutter Manteno, Illinois 60950 888 16th Street, N.W., Suite 700 Washington, D.C.
20006 Attorney General 500 South 2nd Street Regional Administrator Springfield, Illinois 62701 U. S. NRC, Region III 799 Roosevelt Road, Bldg. #4 Michael Miller, Esquire Glen Ellyn, Illinois 60137 Sidley and Austin One First National Plaza Ms. Bridget Little Rorem Chicago, Illinois 60690 Appleseed Coordinator 117 North Linden Street George L. Edgar Essex, Illinois 60935 Newman & Holtzinger, P.C.
1615 L Street, N.W.
Mr. Edward R. Crass Washington, D.C.
20036 Nuclear Safeguards and Licensing Division Illinois Dept. of Nuclear Safety Sargent & Lundy Engineers Office of Nuclear Facility Safety 55 East Monroe Street 1035 Outer Park Drive Chicago, Illinois 60603 Springfield, Illinois 62704 U. S. Nuclear Regulatory Commission Commonwealth Edison Company Resident Inspectors Office Braidwood Station Manager Rural Route #1, Box 79 Rt. 1, Box 84 Braceville, Illinois 60407 Braceville, Illinois 60407 Mr. Ron Stephens EIS Review Coordinator Illinois Emergency Services Environmental Protection Agency and Disaster Agency Region V 110 East Adams Street 230 S. Dearborn Street Springfield, Illinois 62706 Chicago, Illinois 60604 Robert Neumann Howard A. Learner Office of Public Counsel Environmental Law and Policy State of Illinois Center Center of the Midwest 100 W. Randolph, Suite 11-300 203 North LaSalle Street Chicago, Illinois 60601 Suite 1390 Chicago, Illinois 60601
Mr. L. O. DelGeorge granting of enforcement discretion, we will consider enforcement action, as appropriate, for the conditions that led to the need for this enforcement discretion.
Sincerely, Ongin?J S!gned By:
John A. Zwolinski, Assistant Director for Region III Reactors Division of Reactor Projects - III/IV/V Office of Nuclear Reactor Regulation cc:
see next page DISTRIBUTION Docket File NRC & Local PDRs PDIII-2 r/f TA, DRPE TMurley FMiraglia LJCallan EGreenman, RIII WRussell JRoe JZwolinski JBMartin, RIII JDyer CMoore RAssa JStrosnider 0GC DHagan GHill(2)
CGrimes ACRS(10)
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i Mr. L. O. DelGeorge.
i Your November 10, 1993, letter provided your justification for continued operation and identified the following compensatory measures: lowering of steam jet air ejector and main steam line radiation monitor setpoints;
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revising abnormal operating procedures by providing guidance to operations and i
chemistry personnel regarding monitoring to detect increased primary to secondary leakage, use of portable N-16 monitors, and setting a new i
administrative limit for leakage above which shutdown would be required; and advising personnel and briefing operating shifts on the revised abnormal operating procedures prior to assuming duties when the Unit I reactor is critical.
Finally, you committed to submit a request for an emergency license amendment by November 12, 1993.
Based on our review of your justification, including the compensatory measures identified above, the staff concluded that this course of action involved minimal or no safety impact, and we were clearly satisfied'that this' exercise of enforcement discretion was warranted from a public health and safety i
perspective. Therefore, this letter documents our verbal granting on November 5, 1993, of our intention to exercise discretion not to enforce compliance with Technical Specifications 4.4.5.0, 4.4.5.2, and 4.4.E.5 for the period beginning November 5, 1993, at 5:05 p.m. (CDT) until the staff acts on your emergency license amendment request submitted on November 12, 1993.
Notwithstanding our granting of enforcement discretion, we will consider enforcement action, as appropriate, for the conditions that led to the need for this enforcement discretion.
I Sincerely, John A. Zwolinski, Assistant Director for Region III Reactors Division of Reactor Projects - III/IV/V Office of Nuclear Reactor Regulation cc:
see next page DISTRIBUTIQH Docket File NRC & Local PDRs PDIII-2 r/f TA, DRPE TMurley FMiraglia LJCallan EGreenman, RIII WRussell JRoe JZwolinski JBMartin, RIII JDyer CMoore RAssa JStrosnider
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