ML20086T317
| ML20086T317 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 07/28/1995 |
| From: | Hagan R WOLF CREEK NUCLEAR OPERATING CORP. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| ET-95-0078, ET-95-78, NUDOCS 9508020310 | |
| Download: ML20086T317 (8) | |
Text
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l" W$LF CREEK NUCLEAR OPERATING CORPORATION Robert C. Hagan Vce Premdent Engineenng July 28, 1995 ET 95-0078 U.
S.
Nuclear Regulatory Commission ATTN: Document Control Desk Mail Station P1-137 Washington, D.
C.
20555
Reference:
Letter ET 95-0079, dated July 28, 1995, from R. C.
Hagan, WCNOC, to the NRC
Subject:
Docket No. 50-482: Request for Enforcement Discretion Regarding Compliance with License Condition 2.C (1), Attachment 1 Gentlemen:
Pursuant to 10 CFR Part 2,
Appendix C,
Wolf Creek Nuclear Operating Corporation requests that the Nuclear Regulatory Commission (NRC) exercise enforcement discretion regarding compliance with License Condition 2.C (1),
Attachment 1.
This License Condition, which is contained in Facility Operating License No. NPF-42 for Wolf Creek Generating Station, required that the emergency diesel generator lube oil keepwarm pumps for Wolf Creek Generating Station be replaced with ones satisfying ASME Section III, Class 3,
requirements prior to startup following the first refueling outage.
On July 27, 1995, the ASME Section III, Class 3,
keepwarm pump for emergency diesel generator "A"
failed and a qualified ASME Code replacement pump is unavailable.
Therefore, a non-ASME Section III, Class 3,
replacement pump will have to be installed.
Enforcement discretion will permit the installation of the replacement pump until an exigent Operating License change, which was submitted by the Reference, is considered for approval by the NRC staff.
This request for enforcement discretion was verbally discussed with the Office of Nuclear Reactor Regulation and the NRC Region IV Office on July 28, 1995, and subsequently verbally approved.
~ ~
'9508020310 950728 00 DR ADOCK 05000482 PDR i
i PO. Box 411/ Burhngton, KS 66839 / Phone: (316) 364-8831
\\
An Equal Opportunny Employer MINHC/ VET
l ET 95-0078 Page 2 of 2 If you should have any questions regarding this request, please contact me at (316) 364-8831, extension
- 4553, or Mr.
Richard D.
Flannigan at extension 4500.
Very truly ours,
.bW
,s Robert C.
Hagan RCH/jra Attachment cc:
L. J.
Callan (NRC), w/a D.
F.
Kirsch (NRC), w/a J.
F. Ringwald (NRC), w/a J.
C.
Stone (NRC), w/a
Attachment to ET 95-0078 Page l of 6 REQUEST FOR ENFORCEMENT DISCRETION REGARDING COMPLIANCE WITH LICENSE CONDITION A.
Introduction License Condition 2.C (1), Attachment 1,
contained in Facility Operating License No. NPF-42 for Wolf Creek Generating Station (WCGS), required that the non-ASME emergency diesel generator lube oil-keepwarm pumps for WCGS be replaced with pumps satisfying ASME Section III, Class 3, requirements prior to startup following the first refueling outage.
On July 27, 1995, at approximately 0215 CDT, the ASME Section III, Class 3,
keepwarm pump for emergency diesel generator "A" failed. The "A" emergency diesel generator was administrative 1y declared inoperable to prevent the emergency diesel generator I
from starting while personnel were working on the keepwarm pump and Technical Specification 3. 8.1.1, Action b was entered.
A qualified ASME Section III, L
Class 3 replacement pump is unavailable and no replacement parts are currently available to repair the failed pump.
On July 28, 1995, at approximately 2130 CDT, the governor on the "B" emergency diesel generator failed and the diesel generator was declared inoperable and Technical Specification 3.8.1.1, Action f was entered for having two inoperable emergency diesel generators.
Subsequently the "A" emergency diesel generator was started and operated until the lube oil temperature was returned to within the required temperature band.
The "A" emergency diesel generator was then declared operable with an isolated ASME Section
- III, Class 3 keepwarm pump.
WCNOC remains in Technical Specification 3.8.1.1, Action b, due to the inoperable "B"
emergency diesel generator. WCNOC will continue to periodically start the "A" emergency diesel generator until a non-ASME Section III, Class 3,
replacement pump can be installed or until the "B" emergency diesel generator governor is repaired and the engine is returned to operable status.
B.
Technical Specification or other License Condition that will be Violated A non-ASME Section III, Class 3,
replacement keepwarm pump for emergency diesel generator "A"
will be installed which will be in violation of the License Condition that requires that a ASME Section III, Class 3,
keepwarm pump be installed.
Enforcement discretion is required to permit the i
installation of the replacement pump until an exigent Operating License change, which was submitted by the Reference, is considered for approval by i
the NRC staff.
The replacement of the pump will prevent the need for i
continual starting and running of emergency diesel generator "A"
to maintain the lube oil temperature.
l i
C.
Circumstances Surrounding the Event On July 27, 1995, the lube oil keepwarm pump for emergency diesel generator "A"
failed. The lube oil keepwarm pump operates continuously while the diesel engine is in a standby mode of operation.
Following the failure of the keepwarm pump, emergency diesel generator "A"
was administratively declared inoperable and Technical Specification 3.8.1.1, Action b, was entered.
This technical specification requires, in part, that the inoperable emergency i
diesel generator be returned to operable status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or the unit
)
must be placed in at least hot standby within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in cold i
shutdown trithin the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.
The emergency diesel generator 'was
Attochment to ET 95-0078 Page 2 of 6 administrative 1y declared inoperable to maximize personnel safety while working on the keepwarm pump.
The "A"
emergency diesel generator could be maintained operable by periodically starting and running the emergency diesel generator to keep the lube oil temperature within the required temperature band.
The emergency diesel generator was declared inoperable since the lube oil keepwarm pump was unavailable to circulate the oil eithin the keepwarm system.
The oil must be circulated in order to maintain the oil in the emergency diesel generator sump in a warm condition to ensure a quick start of the engine.
On July 28, 1995, the mechanical overspeed trip device on the "B"
emergency diesel generator actuated due to a possible governor adjustment problem and the diesel generator was declared inoperable and Technical Specification 3.8.1.1, Action f, was entered.
The "B"
emergency diesel generator was being started to meet Technical Specification 3.8.1.1, Action 'o, which requires that with one emergency diesel generator inoperable, the operability of the remaining operable emergency diesel generator must be demonstrated by performing Technical Specification 4.8.1.1.1 within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
Technical Specification 3.8.1.1, Action f,
requires, in part, that one of the two inoperable emergency diesel generators be returned to operable status within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> or the unit must be placed in at least hot standby within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in cold shutdown within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.
Subsequently the "A"
emergency diesel generator was started and operated until the lube oil temperature was returned to the required temperature band.
The "A"
emergency diesel generator was then declared operable with an isolated ASME Section
- III, Class 3 keepwarm pump.
WCNOC remains in Technical Specification 3.8.1.1, Action b, due to the inoperable "B"
emergency diesel generator. WCNOC will continue to periodically start the "A"
emergency diesel generator until a non-ASME Section III, Class 3,
replacement pump can be installed or until the "B" emergency diesel generator governor is repaired and the engine is returned to operable status.
Previous attempts to obtain an ASME Section III, Class 3, replacement pump or parts have been unsuccessful.
The original manufacture of the pump no longer produces the pump or suitable replacement parts, and a qualified ASME Code replacement is unavailable.
WCNOC was in the process of having two keepwarm pumps manufactured under the guidance of Generic Letter 89-09, "ASME Section III Component Replacements," however, these pumps were not going to be available until early 1996.
A non-ASME Section III, Class 3 replacement keepwarm pump will have to be installed, which will be in violation of License Condition 2.C (1),
Attachment 1.
Therefore, this request to exercise enforcement discretion was initiated to permit the installation of the keepwarm pump until an exigent License Condition change can be considered for approval by the NRC.
_ _ _ _ _ _ _. _ ~
m.._
Attachmsnt to ET 95-0078 i
Page ' 3 of 6 D.
Safety Evaluation The purpose of the lube oil keepwarm pump is to circulate lube oil through the emergency diesel generator while it is in the standby mode.
This provides pre-lubrication to the engine, maintains the lube oil at approximately 120 degrees Fahrenheit, and provides a
continuous oil filtration path.
Pre-lubrication of the engine components is an economic consideration to reduce unnecessary wear and to ensure the long term performance of the emergency diesel generator.
Also, the filtration performed by the keepwarm system only provides a bypass filtration process to the primary filtration and is provided only to. eliminate unnecessary wear and to ensure the long term performance of the emergency diesel generators.
When the emergency diesel generator is in. operation the engine driven lube oil pump circulates the lube coil through the engine and the keepwarm pump is not required.
However the keepwarm pump continues to operate providing a secondary filtration path to that provided by the engine driven pump. The keepwarm pump performs no active safety-related function and must only maintain pressure boundary once the emergency diesel is in operation.
The emergency diesel generators were originally installed with non-ASME Section III, Class 3, lube oil keepwarm pumps which are similar in design to
}
the replacement keepwarm pump WCGS is currently installing on the "A"
The non-ASME keepwarm pumps were replaced with keepwarm pumps meeting the ASME Section III Class 3 requirements prior to startup testing of the emergency diesel generators.
However, the ASME keepwarm pumps proved unreliable and therefore were removed and the non-ASME keepwarm pumps were re-installed. During NRC Inspection 50-482/84-55, the re-inscallation of the non-ASME pumps was evaluated and determined to be a i
deviation from WCGS's design commitments. License Condition 2.C(1) was issued requiring the non-ASME pumps be replaced with ASME Section III, Class 3, pumps prior to startup from the first refueling outage.
WCGS attempted to redesign / rework the ASME pumps to assure they would perform reliably.
Upon completion of the redesign / rework effort the ASME pumps were reinstalled prior to startup from the first refueling outage, which satisfied the license condition.
The results of the redesign / rework effort have proven to be less than completely successful.
The ASME pumps continue to perform below the reliability expectations of WCGS.
However, the non-ASME pumps initially installed by the vendor and temporarily utilized by WCNOC have proven to be more reliable in the industry than the ASME Section III, Class 3 pumps currently utilized.
l The non-ASME pump to be installed at WCGS is designed and manufactured in accordance with an approved quality program.
The pump has been shown to be seismically qualified, hydro-tested, to assure pressure boundary integrity, and the integral relief valve on the top of the pump has been replaced with a cover plate to prevent interference with the existing relief line.
The cover plate was hydro-tested as was the pump.
The non-ASME Section III, Class 3,
pump weight and center of gravity is slightly less that the ASME Section III, Class 3, pump, thus seismic qualifications requirements are not affected.
As stated earlier, the non-ASME pump to be installed at WCGS has been seismically qualified at another nuclear unit.
The seismic qualification report for the pump used at the other nuclear unit has been reviewed and the pump meets WCGS
~,,
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Attachment to ET 95-0078 Page 4 of 6 seismic criteria. Therefore, the pump is capable of surviving a seismic event without loss of pressure boundary.
Therefore, the installation of a non-ASME keepwarm pump will improve the reliability of the emergency diesel generator and will have no adverse effect on the operability of the emergency diesel generator during the time the exigent Operating License change is being processed.
E.
Corrective Action / Compensatory Actions Until this request for enforcement discretion is approved and the non-ASME Code III, Class 3,
keepwarm pump is installed, the "A"
emergency diesel generator lube oil temperature is being monitored to assure the minimum acceptable temperature is maintained.
Periodic "A" emergency diesel generator runs are being performed to maintain the lube oil temperature above the minimum requirement.
Following the installation of the non-ASME Code III, Class 3 pump, no compensatory actions will be taken since the pump is equivalent to the ASME Code III, Class 3, pump.
Further, to enhance the reliability of the two independent offsite sources of power required by Technical Specification 3.8.1.1.a, all work in the WCGS Switchyard has been suspended.
In addition, all work and surveillances associated with the Plant's emergency core cooling system and subsystems has been suspended.
F.
Justification for Noncompliance Duration An exigent Operating License change, which was submitted by the Reference, is being processed by WCNOC to delete License Condition 2.C(1).
The deletion of this license condition will remove the requirement the keepwarm pump to meet ASME Section III Class 3 requirements.
Enforcement discretion is required until the exigent operating License change has been approved.
G.
Unreviewed Safety Question and No Significant Hazards Evaluation In accordance with 10 CFR 50.59 and 10 CFR 50.92 (c), WCNOC's evaluation of the proposed enforcement discretion for an unreviewed safety question and no significant hazards consideration is as fo3 m :
1.
The proposed reques t for enforcement discretion does not involve a significant increase in the probability or consequences of an accident or malfunction previously evaluated.
This request for enforcement discretion does not change the function or performance requirements for the keepwarm pump or the function or performance requirements for the emergency diesel generator as described in the Updated l
Safety Analysis Report (USAR) and Technical Specifications.
The purpose of this request is to allow the installation of a non-ASME qualified pump, designed to the same performance requirements as the ASME pump, on the emergency diesel generator.
The emergency diesel generator and its keepwarm pump will continue to perform in a manner consistent with the assumptions in the USAR.
As such there will be no degradation in system performance, nor will there be an increase in the number of challenges to equipment assumed to function during an accident situation.
t
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Attachm3nt to ET 95-0078 i
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' Page 5 of 6 4
Thus, the request for enforcement discretion will not result'in an increase in the consequences of or. the probability of occurrence of any accident or safety-related equipment malfunction.
2.
Does the request for enforcement discretion create the possibility of a new or different kind of accident from any accident previously evaluated?
The purpose of this request is to allow the installation of a non-ASME qualified pump, designed to the same performance requirements as the ASME pump, on the emergency diesel generator.
The emergency diesel generator and associated keepwarm pump will continue to perform in a manner consistent with the assumptions in th> USAR.
No new accident scenarios, transient precursors, failure mechanisms, or limiting single failures are introduced. There will be no adverse effect or challenges imposed on any safety-related system as a result of this request. Therefore, the possibility of a new or different kind of accident is not created.
3.
Does the enforcement discretion involve a significant reduction in the margin of safety?
The purpose of this request is to allow the installation of a non-ASME qualified pump, designed to the same performance requirements as the ASME pump,.on the emergency diesel generator.
The emergency diesel generator and associated keepwarm pump will continue to perform in a manner consistent with the assumptions in the USAR.
No new accident scenarios, transient precursors, failure mechanisms, or limiting single failures are introduced.
There will be no adverse effect or challenges imposed on any safety-related system as a result of this request.
Therefore, this request for enforcement discretion will not result in a significant reduction in the margin of safety.
Therefore, WCNOC has determined that the requested enforcement discretion does not:
involve a significant increase in the probability or consequences of an accident or other adverse condition over previous evaluations; create the possibility of a new or different kind of accident or condition over previous evaluations; nor involve a significant reduction in a margin of safety.
Therefore, the requested enforcement discretion meets the requirements of 10 CFR 50. 92 (c), and does not involve a significant hazards consideration.
In conclusion, based on the above safety evaluation, WCNOC believes that the activities associated with the enforcement discretion request satisfy the requirements of 10 CFR 50.59 and 10 CFR 50.92 (c). Accordingly, no significant hazards consideration is justified and no unreviewed safety question exists.
H.
Environmental Evaluation This request for enforcement discretion meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22 (c) (9) as specified below:
- 1. Involves no significant hazards consideration As demonstrated in Section G of this letter, the request does not involve any significant hazards consideration.
Attachment to ET 95-0078
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Page 6 of 6
- 2. There is no significant change in the types or significant increase in the amounts of any effluents that may be released offsite The request does not involve a change to the facility or operating procedures that would cause an increact' in the amounts of effluents or create new types of effluents. The request for enforcement discretion does not involve changes to any instrumentation setpoints, system operating parameters, or system accident mitigation capabilities, nor does this request affect the probability of any event initiators.
Thus, the request does not reduce the margin of safety to any licensed design parameter.
- 3. There is no significant increase in individual or cumulative occupational radiation exposure The request would not adversely affect the operation of the reactor, and would not affect any system that would affect occupational radiation exposure.
The proposed change does not create additional exposure to personnel nor affect levels of radiation present.
The enforcement discretion request will not result in any increase in individual or cumulative occupational radiation exposure.
Based on the above, it is concluded that there will be no impact on the environment resulting from the request, and that the request meets the criteria specified in 10 CFR 51.22 for a categorical exclusion from the requirements of 10 CFR 51.21 relative to requiring a specific environmental assessment by the Commission.
I.
Plant Safety Review Committee Approval The request for enforcement discretion and its basis were reviewed by the WCNOC Plant Safety Review Committee prior to the request being made to the NRC.
The Plant Safety Review Committee reviewed and concurred with this written request.
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