ML20073K135

Requests Enforcement Discretion from Several TS Surveillance Requirements Due to Extremely Hot Weather Conditions

ML20073K135
Person / Time
Site:	Davis Besse
Issue date:	06/16/1994
From:	Shelton D CENTERIOR ENERGY
To:	Martin J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
References
1-1045, NUDOCS 9410110031
Download: ML20073K135 (7)

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CENTERIOR ENERGY 003 Oca free Bosevo'c Mo1 Aco'e55 Donald C.Shoon f$cuperceve OH PO 6cs9460 senor vice Presicent 2it 447 3100 Clowwr0 QN aeso *Cc1 mceor Dorket Number 50-346 f.icence Number NPF-3 Serial Number 1 1045 June 16, 1994 Hr. J. B. Martin Regional Administratnr United States Nuclear Regulatory Commission Region III 801 Varrenville Road Lisle, Illinois 60532 4351 Subj e c t - Request for Enforcement Discretion from Several Technical Specification Surveillance Requirements Due to Veather Conditions

Dear Mr. Martin:

The purpose of this letter is to request enforcement discretion fron performing a limited number of Technical Specification surveillance tectc at the Davic-Besse Nuclear Fover Station (DBNPS). Enforcement discretion is being requested because the circumstances are temporary and involve one time deviations from Surveillance Requirements.

Furthermore, the period for which discretion is requested is of such chort duration it is not practical to obtain a license amendment. This request is being e.ade due to the current critical need for electricity during the ongoing extremely hot weather. These surveillance tests vould place the station into the situation where potentially an inadvertent reactor chutdown could result and, therefore, lead to the less of the nearly 900 MVe being provided by the DBNPS to the power grie. The loss of this power cource to a power grid already stretched to its lirit could result in severe grid instability.

The need for electricity during this hot weather resulted in Toledo Cdison's parent company Centerior Energy purchasing 1275 HVc on June 15, 1994, in an extremely tight supply market. Firm load is being disconnected from the grid in the Cleveland area today. As described herein, Centerior Energy has taken steps to quickly deal with the supply situation including efforts to restore two fossil plant units to the power grid.

Centerior Energy believes it to be in the best interest of the public's -

health and safety to extend the test intervals for certain Curveillance b

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rPf%# 45 1(A:PTd 012H:tJCFJ WO I WN;TNG 41 ci-P49!P%P 70: V1 F,A4 % ,1 Pfarp:m Docket Number 50-346 Licease Number NPF-3 Serial Nunber 1-1045 Page 2 8equirements up to an additional seven days in order to minimize the potential for an inadvertent shutdovn of the DBNPS during the ongoing hot weather. The following provides the justification for this request including the circumstances surrounding this situation, compensatory actions, the safety significance and potential consequences, the justification for the duration for which the discretion is being requested and the conclusions that a significant hazards consideration does not exist and that no irreversible environmental conseqc. ices would result.

Toledo Edison, as operator of the DBNPS, reauests that the NRC grant this request for enforcement discretion prior to June 17, 1994, 0430 hours0.00498 days <br />0.119 hours <br />7.109788e-4 weeks <br />1.63615e-4 months <br /> which is the due date for the first of the Surveillance -

Requirements. This due date, as well as the due dates cited belov, include the 25% extension allowed by Technical Specification 4.0.2.

1. Reauirements for Which Enforcement Discretion is Requested Enfortement discretion is requested from the following Technical Specification Surveillance Requirements (SR):

a. SR 4.3.1.1.1 (Reactor Protection System (RPS) Instrumentation):

Each Reactor Protection System instrumentation channel shall be demonstrated OPERABLE by the performance of the... CHANNEL FUNCTIONAL TEST operations during the MODES and at the frequencies shown in Table 4.3-1 (Functional Unit 12, Contrn1 Rod Drive Trip Breakers-Monthly Test), and SR 4.3.2.3 (Anticipatory Reactor Trip System (ARTS)

Instrumentation):

The Anticipatory Reactor Trip System shall he demonstrated OPERABLE by performance of the... CHANNEL FUNCTIONAL TEST for the MODES at the frequencias shown in Table 4.3.17 (Functional Unit 3, Output Logic).

This surveillante testing (Reactor Trip Breaker "C", Reactor Protection cysten Channel 4 THp Module Logic and Anticipatory Reactor Trip Syctem Channel 4 Output Logic) is due on June 17, 1994.

This surveillance testing requirement of one channel of the redundant four channel RPS and ARTS should be deferred until June 24, 1994 in order to minimize the potential for an inadvertent reactor trip.

b. SR 4.3.2.2.1 (Stear and Feedvater Rupture Control System Instrumentation): l Each SFRCS instrumentation channel chall be demonctrated OPERABLE by the performance of the... CHANNEL FUNCTIONAL TEST during the MODES and at the frequenciec chown in Table 4.3 11 (Functional Unit 1.d., Loss of Reactor Coolant Pumps-Monthly -

Test of Reactor Coolant Pump Monitor). '

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fr.T-n7 94 1G.np rRiri:tdirJ FAR 11FFtATtJG 419-P49-P33P TOITR1 SR4 NFA1 PAGP:04 Docket Numb 2r 50-346 Licensa Number NPF-3 Serial Number 1-1045 Page 3 This monthly surveillance testing of the Reactor Coolant Pump monitor /SFRCS Channels 1 and 3 is due on June 20, 1994 This surveillance test requirement should be deferred until June 27. 1994 because it poses a potential inadvertent trip source for SFRCS and RPS.

c. SR 4.8.2.3.2.a (DC Distribution - Operating):

Each 125-volt battery and charger shall be demonstrated OPERABLE at least once per seven days by verifying that the parameters in Table 4.8-1 meet the Category A limits, and verifying total battery terminal voltage is greater than or equal to 129 volts on float charge.

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This surveillance testing of the batteries and chargers is due 1 on June 23, 1994.

This surveillance testing requirement should be deferred until June 30, 1994, because of the proximity of personnel to vital electrical equipment while performing the testing, and the associated potential to induce a plant transient.

2. Discussion of Circumstances Surrounding the Situation The upper Midwest is presently experiencing extremely hot, unseasonable weather. In Northern Ohio, record or near record high temperatures are resulting in high customer demand for electricity.

On June 15, Toledo Edison experienced record customer power demand.

This veather pattern is expected to continue into the weekend.

Tn the Centerior Energy Corporation service area, the 580 MVe capacity fossil-fueled Avon Unit 9 is in a planned maintenance nurage, and the 1191 M'.'e capacity Perry Nuclear Plant is in a maintenance and refueling outage. The available plant capacity from the Toledo Edison (TE) and Cleveland Electric Illuminating (CEI) operating companies is unable to meet the unexpectedly high demand. At a remnit enngiderable amnants of power are being purchased from outside suppliers. For example, on June 15 vith temperature = near 100' F and high humidity, Centerior Energy's System Operations Center reported that 1275 MVe was being purchased to supply customer needs in an evtrerely tight supply market. Firm load is being disconnected from the grid in the Cleveland area today.

Vith the DBNFS operating at full capacity, supplying nearly 400 MUe to the grid, the System Operations Center has requested the station  :

forego any activitier that may place continued operation of the  !

station in jeopardy, at least until the current power supply )

situation has been abated. Efforts are underway to return Avon ,

Unit 9 to service and to restart Acme Unit 2, a 75 MVe fossil unit -

which was mothballed in 1993 I

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3. Compensatory Actions During the period for which enforcement discretion is requested, the following compensatory measures vill be taken:

a. No preventive maintenance activities vill be performed on redundant equipment for which surveillance testing is to be deferred. ,

b. Electrical distribution equipment, either normal, standby or reserve vill not be taken out of service.

c. Operating personnel vill be notified by Standing Order to ensure that these actions are maintained.

4. Preliminary Evaluation of Safety Significance and Potential Conseauences of the Proposed Request The following systems and components are directly affected by the proposed request:

a. 125 V Station Batteries and associated Battery Chargers

b. Reactor Trip Breaker "C", Reactor Protection System Channel 4 Trip Hodule Logic and Anticipatory Reactor Trip System Channel 4 Output Logic, and  !

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c. The Reactor Coolant Pump Monitors channels 1 & 3.

Each of these systems has been designed, built, and licensed with inherent redundancy and, where feasible, diversity.

Testing is performed on each of the systems in order to verify that i they are capable of performing their assigned safety functions, and j to incres=* the likallhood of discovering a random failure. )

Failure to perform a surveillance on safety related equipment 1 (although prohihired by station Technical Specification operability requirements) does not imply the equipcent is no longer capable of performing its safety fonctione(s). Am Stated in Generic Letter 87-09 (in the context of missed surveillances): "It is overly l concervative to assume that systems or components are innparable j vhen a surveillance requirenent has not been performed. The oppocite ic in fact the cases the vast majority of surveillancem demonstrate that systems or components in fact are operable." The Generic Letter discussion is applicable in thic ca=* ainee a  ;

one-time, rather than routine, extension of surveillance testing is requested. A review of the results from the surveillance testing conducted since the last refueling outage completed in April 1993 indicater that these componente have functioned reliably.

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. License Number NPF-3 serial Norther 1-1043 Page 5 Due to the redundancy built into each system, the potential consequences of an undiscovered random failure have already been minimized, as analyzed in the Updated Safety Analysis Report.

Therefore, it is concluded that the safety significance of not testing the affected equipment for an additional seven days is negligible.

The DENPS Probabilistic Safety Assessment (PSA) was reviewed.to determine the relative impact on the plant core damage ire 1uency (CDF), with the following noted:

a. The effects of equipment being out-of-service for testing has >

been explicitly factored into the PSA. These effects include .

t contributions to plant-specific initiating event frequencies (such as reactor trips) due to testing, and system and -

component unavailability during accident sequences due to -

rnutine testing. Therefore during the period of reduced testing for the previously identified systems, both initiating event frequencies and " maintenance unavailabilities" vill decrease. Although not directly proportional, this results in an assoetared decrease in the overall plant CDF.

b. As utilized in the PSA, equipment failure rates are assumed to be constant with respect to time. These failure rates are

.stimated from historical site-specific data, generic industry j data, or an appropriate combination of the two (such as use of i Bayesien updating techniquas). For the plant systems under  !

consideration, tested eouipment is actuated often enough that i estimated failure probabilities can he assumed to not he dependent on the duration between " demands." As such, a one-time short duration delay in testing the=e enmponents has no real effect on estimated equipment failure rates in the FSA.

Given the above FSA considerations, for a one-time short duration delay in the previously deceribed plant testing, no inerente in the plant CDF vould tse expected if explicitly calculated.

5. Justification for Enforcement Discretion Duration Due to the expected duration of the adverse veather pattern, the corresponding expected continued high demand for electrical power, and the expected continued need for power to se purchased from outoide supplicrc due to a chortage of available capacity, TE is requesting that the surveillance testing identified above be deferred for oeven days.

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6. Basis for Conclusion of No Significant Hazarde Concideration i Af ter evaluating the safety significance and potential concequences of the proposed request, it has been concluded that there vould be no detrimental effcet on public health and cafety se a recult of this activity. This is based on the conclusion that failure of the -

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affected equipnent is no more likely than at any other time, and that any random failure which may occur has been shown to have acceptable consequences on public health and safety in the USAR.

The Nuclear Begulatory Cor. mission has provided standards in 10CTR50.92(c) for determining whether a significant harard exists due to a proposed action. A proposed action involves no significant hazards consideration if operation of the facility in accordance with the proposed changes would: (1) Not involve a significant increase in the probability or consequences of an accident previously evaluated (2) Not create the possibility of a new or different kind of accident from any accident previously evaluated; or (3) Not involve a significant reduction in a margin .

of safety. Toledo Edison has reviewed the proposed action and determined that a significant hazards consideration does not exist because operation of the DBNPS in accordance with this action .

would:

la. Not involve a significant increase in the probability of an accident previously evaluated because no change is being made to any accident initiator or assumption. A limited extension to the period between testing components does not affect the probability of experiencing an accident.

Ib. Not involve a significant increase in the consequence of an accident previously evaluated because the random failures which might go undetected have already been analyzed. Since the failures are the same, the consequences of those failures are unchanged. Furthermore, the proposed action does not alter the  !

source term, containment isolation, allovable radiological ,

releases, or invalidate the assumptions used in evaluating '

radiological releases.

2a. Not create the possibility of a new kind of accident from any orbar accident previnucly evaluated because the station vill be operated in the same vay as before and, therefore, no new accident scenarine are postulated.

7h. Not create the poccibility of a di f ferent kind nf accident previously evaluated because the station vill be operated the same as before and no new failure modas or effects are heing introduced. Therefore, no different accident scenarios are postulated.

3. Not involve a significant reduction in a margin of safety as defined in the basis for any Technical Specification because any random failures which may result during the extended test interval have been included in the safety analyses which form the bases for the Technical Spscifications. Furthermore, the proposed action does not involve any new changes to the initial conditions contributing to accident severity or consequences.

and consectently there are no reductior.s in a margin of safety. .

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~' Docket Nu2bar 50-346

, License Numbsr NPF-3 Serial Number 1-1045 Page 7  ;

7. Basis for Conclusien of No Irreversible Environmental Consequences This request does not involve a change in the installation or use of the facilities or components located within the restricted areas as defined in 10 CFR Part 20. Toledo Edison has determined that this request for enforcement discretion involves no increase in the amounts, and no change in the types, of any etfluents that may be released offsite and that there is no increase in individual.or ,

cumulative radiation exposure. Accordingly, the request for enforcement discretion meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b) no environmental impact statement or environmental assessment need be prepared in connection with the granting of the enforcement discretion. I This request for enforcement discretion has been reviewed and approved .

by DBNPS Station Review Board.

In conclusion, Toledo Edison requests that the NBC grant this request for enforcer.ent discretion on June 16, 1994. If veather conditions improve and the current system power shortage abates, Toledo Edison does not intend to utilize the full seven day surveillance testing extension authorized by the enforcement discretion, and vould cenduct the testing expeditiously.

Should you have any questions or require additional information, please contact Mr. Villiam T. O'Connor, Manager - Regulatory Affairs, at (419) 249-2366.

Sin erely yours, ,

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.b c DRV/ eld cr S. Stasek, DB-1 NRC Senior Resident Inspector R. J. Stransky, Jr. , NRC Project Manager

.I . R. Williams Chief of Staff. Ohio Emergency Management Agency, State of Ohio (NRC Liaison)

IIMRF. Document Control Desk Utility Radiological Safety Board

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