ML20141A768
| ML20141A768 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 06/18/1997 |
| From: | Merschoff E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Horn G NEBRASKA PUBLIC POWER DISTRICT |
| References | |
| NOED-97-4-001, NOED-97-4-1, NUDOCS 9706230163 | |
| Download: ML20141A768 (15) | |
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NUCLEAR REGULATORY COMMISSION
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611 RYAN PLAZA drive. SulTE 400 ARLINoToN. TEXAS 760118064 JUN 181997 G. R. Horn, Senior Vice President of Energy Supply Nebraska Public Power District 141415th Street Columbus, Nebraska 68601
SUBJECT:
NOTICE OF ENFORCEMENT DISCRETION FOR NEBRASKA PUBLIC POWER DISTRICT REGARDING COOPER NUCLEAR STATION (97-4-001)
Dear Mr. Horn:
i By letter dated June 14,1997, you requested that the NRC exercise discretion not to enforce compliance with the actions required by Technical Specification 3.7.A.5, " Oxygen Concentration." That letter documented information previously discussed with the NRC in a telephone conversation on June 14,1997. During that telephone conversation, you stated that, on June 14,1997, at 9:29 p.m. CDT, the plant would have to be in a cold shutdown condition required by the 24-hour TS Limiting Condition for Operation (LCO) which was entered on June 13,1997, at 9:29 p.m. CDT. A draft version of your June 14, i
1997, letter was provided to us prior to the telephone conversation and is enclosed. You requested that a Notice of Enforcement Discretion (NOED) be issued pursuant to the NRC's 1
policy regarding exercise of discretion for an operating facility, set out in Section Vll.c, of the " General Statement of Policy and Procedures for NRC Enforcement Actions" j
(Enforcement Policy), NUREG 1600, and be effective for a period not to exceed 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
((
j On June 5,1997, after restarting the unit from a refueling outage, your staff began monitoring and trending unidentified leakage into the drywell that was slowly increasing.
On June 13,1997, the unidentified leakage was measured to be 0.417 gpm. Your decision to place cameras in the drywell during the last refueling outage provided your staff the opportunity to estimate the actual leakage at 0.6 gpm. The Technical Specification limit for unidentified leakage within the drywell is 5 gpm. Your decision to reduce plant power, de-inert the primary containment, and enter the drywell to identify and repair the leakage was conservative.
Primary containment de-inerting began at 7:50 p.m. CDT on June 13,1997, and Technical Specification 3.7.A.5 LCO was entered at 9:29 p.m. CDT on June 13,1997, when containment oxygen concentration exceeded 4 percent. A drywell entry was made by your staff and the source of the leakage was determined to be from a quick disconnect fitting installed on the piping from the Train A reactor feedwater piping vent valves. The i
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fitting was removed and a plug was installed on the piping, successfully stopping the leakage. As a precautionary measure, the quick disconnect fitting was removed from the Train B reactor feedwater piping vent and a similar plug was installed.
At 9:05 a.m. CDT on June 14,1997, the primary containment inerting process began. At 9:18 a.m. CDT,1 of the 12 drywell-to-torus vacuum breakers opened for 7 minutes because of excessive purge rates while inerting. This was considered an unplanned engineered safety feature (ESF) actuation and was appropriately reported to the NRC headquarters opcations officer in accordance with 10 CFR 50.72(b)(2)(ii). Because of the difference in capacity between the 24-inch purge (supply) and the 2-inch bypass to the 24-inch vent piping, your operators had been tasked to closely watch the purge rate in order to avoid opening the drywell-to-torus vacuum breakers.
The inerting process, using the 2-inch vent pipe, reduced the torus oxygen concentration from about 25 to 19 percent over a 5-hour period. At 2:22 p.m. CDT on June 14,1997,a procedure change was approved by your staff that allowed operators to use the 24-inch vent. Using the 24-inch vent, the torus oxygen concentration was reduced from about 19 to 4 percent over a 41/2-hour period. At 11:59 p.m. CDT on June 14,1997, the oxygen concentration within the drywell was restored to less than 4 percent and the LCO for TS 3.7.A.4 was exited. Your staff indicated that, had you been able to approve the use of the 24-inch vent before re-inerting, you would have been able to re-inert primary containment prior to the expiration of the TS LCO at 9:29 p.m. CDT. Our review of the containment oxygen concentration data indicates that this is true. This aspect will be subsequently evaluated for possible applicability of our enforcement policy.
Although the attachment to your letter dated June 14,1997, indicated that no regulatory commitments were contained within the letter, the staff considered your compensatory actions to maintain reactor power to less than 15 percent an important regulatory commitment. As such, we verified that you did indeed maintain reactor power less than 15 percent for the duration of the enforcement discretion.
The safety basis for granting the NOED was that continued operation below 15 percent reactor power with the primary containment oxygen concentration greater than 4 percent by volume was bounded by the analysis discussed in both NUREG-1433, " Standard Technical Specifications, General Electric Plants, BWR/4," and the Cooper Nuclear Station Improved Technical Specifications submittat dated March 27,1997. The staff agreed with your determination that approving the request for enforcement discretion would avoid an undesirable pressure and thermal transient which would otherwise occur if compliance with the plant technical specifications was forced, in addition, the staff considered the reduction of radiation exposure to the plant staff an important factor in approving your request.
On the basis of the staff's evaluation of your request, including the compensatory measures described above, the staff has concluded that an NOED is warranted because we are clearly satisfied that this action involves minimal or na safety impact and has no
-.... -. ~ -.. -.... _. _ - -
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i i
l Nebraska Public Power District adverse radiological impact on public health and safety. Therefore, the NRC staff elected to exercise discretion not to enforce compliance with Technical Specification 3.7.A.5,
" Oxygen Concentration," for the period from June 14,1997, at 9:29 p.m. CDT until June 15,1997, at 9:29 p.m. CDT. This letter documents our telephone conversation on June 14,1997, at 11:37 a.m. CDT, at which time we orally issued this NOED. We understand that the condition causing the need for this NOED was corrected by you on June 14,1997, at 11:59 p.m. CDT and that you exited from TS 3.7.A.5 and from this NOED at that time.
However, as stated in the Enforcement Policy, &ction will normally be taken, to the extent that violations were involved, for the root cause that led to the noncompliance for which this NOED was necessary.
Sincerely, h Ellis W. Merschoff Regional Administrator Docket No.: 50-298 License No.: DPR-46
Enclosure:
As stated cc:
John R. McPhail, General Counsel Nebraska Public Power District P.O. Box 499 Columbus, Nebraska 68602-0499 P. D. Graham, Vice President of Nuclear Energy Nebraska Public Power District P.O. Box 98 Brownville, Nebraska 68321 B. L. Houston, Nuclear Licensing and Safety Manager Nebraska Public Power District P.O. Box 98 Brownville,' Nebraska 68321
.. ~ -.
Nebraska Public Power District 4 l
Dr. William D. Leech MidAmerican Energy 1
907 Walnut Street i
P.O. Box 657 Des Moines, Iowa 50303-0657 s
Mr. Ron Stoddard Lincoln Electric System 11th and O Streets i
Lincoln, Nebraska 68508 1
Randolph Wood, Director Nebraska Department of Environmental Qua!ity P.O. Box 98922 Lincoln, Nebraska 68509-8922
)
Chairman Nemaha County Board of Commissioners Nemaha County Courthouse 1824 N Street Auburn, Nebraska 68305 l
1 Cheryl Rogers, LLRW Program Manager i
Environmental Protection Section
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Nebraska Department of Health 301 Centennial Mall, South P.O. Box 95007 j
Lincoln, Nebraska 68509-5007 Dr. Mark B. Horton, M.S.P.H.
Director Nebraska Department of Health P.O. Box 9b0070 Lincoln, Net'raska 68509-5007 1
R. A. Kucera, Department Director of intergovernmental Cooperation Department of Natural Resources P.O. Box 176 Jefferson City, Missouri 65102 4
Kansas Radiation Control Program Director a
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5 Nebraska Public Power District JUN I 81997 bec to DCD (IE51) bec distrib. by RIV:
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MIS System Branch Chief (DRP/TSS)
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Associate Director for Technical Review, NRR Director, DRP lil/IV, NRR Director, Office of Enforcement Public Document Room and Local Public Document Room 4-l
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, June 14,1997 ENCLOSURE
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_3 U.S. Nuclear Regulatory Commission
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Attention: Document Control Desk
/
Washington, D.C. 20555-0001 Gentiemen:
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Subject:
Request for Enforcement Discretio Cooper Nuclear Station, NRC j
DPR4.
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Reference:
Teleconference between P hr---
=--RC contact) (NRC) dated o
D f
June 14,1997, Request :'
' 'In accordanceWtli'did8... :.
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.s.
g.; a;. r u$loils' th y ebraska Public Power District (District) 1 requests that4,he NRC ex
'on the requirements of Cooper Nuclear Station (%_ _ [=lwi n 3.7 en Concentration," for a period not to exceed' geD atifi e from the (system) into the drywell, and fisc sufficient time for repair and re-inerting the Primary requests e Containment. t ---
Miscretion would prevent inducing an additional enA_andg ally challenging plant safety systems.
thermal
'Ib e at,- ent to this.
es further description of the circumstances surrounding this issu assessment of1 and environmental significance in accordance with the ce contained in N dministrative Letter 95-05,"Rt. visions to StafrGuidance for I
- menting NRC P y on Notices of Enforcement Discretion." The District has evaluated tion and that this request meets the criteria outlined in Administrative Letter Mh=JaL uest is temporary, non-recurring, and consistent with protecting the public Accordingly, the District requests that the NRC grant this reqs.est to allow repair of the identified leakage while avoiding inducing a plant thermal transient and the potential challenge of plant safety systems.
06/13/97 15:16 12402,825 5827 CNS-LICENSING
% 002 U. S. Nuclear Regulatory Commission June 14,1997 Page 2 of 2 Should you have any questions concerning this matter, please contact me.
Sincerely,
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.:: I Vlec President -Nuclear II"~
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Attachment V
cc: Regional Administrator USNRC -Region IV Senior Project Manager
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Senior Resident Inspector L ", N II USNRC
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4 06/13/97 15:18 1F402 825 5827 CNS-LICENSING Q1003 l
j Attachment to NLS970123 Page 1 of 7 j
REQUEST FOR ENFORCEMENT DISCRETION FROM THE REQUIREMENTS OF t
j CNS TECHNICAL SPECIFICATION 3.7.A.
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... l The District requests that the NRC exercise temport at discre requirements of CNS Technical Specification 3.7.A od of 24 ho 15 i
(time) through June 16 (time). The District is req exercise this discretion to 4
enable sufIlcient time to (? adjust the valve packin re-inert the primary containment without inducing an additional plant ' <
potentially a
challenging plant safety systems by going to co wn.
ion below provides i
further details surrounding the situation,
- ofthes ficance.
II. DISCUSSION j
The following discussion provi infori onide
- acc in NRC Administrative Letter forI
- Ie JRC Policy On Notices of i
95-05," Revisions to Staff O
^ 's assess' request.
I Enforcement Discretion," fo 1.
TbdL -hnical S_
n or otHTHE conditions that will be violated.
i w
onM gen Concentration," will be violated. Specification test program and demonstration of plant electrical i
..gr output, utninment atmosphere shall be reduced to less than 4%
cxygen wi n gas during reactor power operation with reactor coolant y
pressure psig, except as specified in 3.7.A.S.b.
i l
b.
W!
4-hour period subsequent to placing the reactor in the Run mode fot a shutdown, the containment atmosphere oxygen concentration shall i~.
Kuce_d to less than 4% by volume and maintained in this condition. De-inerting y commence 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> prior to a shutdown.
l c.
When the containment atmosphere oxygen concentration is required to be less than 4%, the minimum quantity ofliquid nitrogen in the liquid nitrogen storage tank shall be 500 gallons.
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Attachment to NLS970123 Page 2 of 7 i
i d.
If the specifications of 3.7.A.5.a thru o cannot be met, an orderly shutdown shall be initiated and the reactor shall be in a cold shutdown condition witl ours.
e.
The specifications of 3.7.A.S.a thru d are not icable hour continuous
..g
,. period between the dates of March 22,1982 f$i
- 2. $ e i tmding the sit tion. In ing root j
n a
r action and identification of any relevant histori& vents #
WE _ _w' Ng The District recently completed its RE17 Re
. On May 22,1997, CNS synchronized to the grid, and on May 25,1997 wer operation. On June 5,1997, the District began closely monito *
- e into the drywell, as the amount of unidentified leakage (1 sump)was over
~
d[ $t determined that so 0.2 gpm, and appeared to be slowly, reasing na 10,1997, with the aid ofvideo cameras recently be Di of the leakage was traveling do outs
'pe, bypassing the drywell sump, to the suppression pool.
ss f
ouon resulted in an estimation that approximately 1/3 of e
bypass' 11 sumps.
On June 13,1997, at 08 e unid ed leakage was identified to be 0A17 gp
- However, leakag be approximately 50% greater or
- mmtely 0 -
e rate mcrease was fairly linear, increasing at ly i gpm/
CN - - - - - - -
9peci
, " Coolant Leakage," Section 3.6.C.1 states:
Am 4957 %
In te reactor vessel and reactor coolant 1
[t temperatu 212*F, reactor coolant leakage into the primary r
containm t exceed a 5 gpm unidentified leak rate,25 gpm identified leak rate, o increase in unidentified leak rate within the previous 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> If these limits cannot be met, an orderly SHUTDOWN shall be initi
_'d the reactor shall be in a COLD SHUTDOWN CONDITION wi hours."
, assuming a constant rate ofleakage increase, that the total unidentified
~
drywell leakage as measured by the drywell sump would approach 2 gpm in late July 1997, which the District recently set as its conservative criteria for initiating repair.
However, the District decided to reduce plant power, de-inert the primary containment, and make a drywell entry on June 14,1997, to identify and repair the leakage source.
The District began de-inerting primary containment at (time) on (date) and entered
ve/Ad/ws
.Aetzt usur ego oszt t,n a -t.a t,en a a nt' Id1005 Attachment to NLS970123 Page 3 of 7 Technical Specification 3.7.A.5 at (time) on (date). District personnel have entered the drywell, and determined that the leakage is originating from (7 valve pa on CIC, a
' valve description
- on the *systemname* system?). As a th ct is in the process of repairing (for has completed repair to IC.
- 4..,,,
'Ibe District'ws request'tliat the NRC exercise di ll
,s not uiremen
.of Sjecification 3.7;k5 for a period of 24 ho lom (ti 4;.
(time) on June 16,1997, would have the e l'
the acti completion time of SpeciScation 3.7.A.5 from 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />. 'I ow sufficient time to complete repair to (CIC), and containment to an oxygen concentration ofless than 4 volume uiring completion of the action statement to proceed to cold shutdown. '
r detail below, by exercising this enforcement discretion, uld avoid inducing additional thermal transients on the ential to plant safety systems As discussed above, the 1-*at to p
- originated from the (CIC),
and was apparently due to f or a t ca
. (This was either an isolated case
+ basis for that conclusi the t
ditional actions to ensure other problems not likely.
F eut N (CNS T ifications documented an cmergency
=J~
waiv requirements of 3.7.A.5 for a 48-hour period.
l was not the result of drywell leakage, the NRC conc te J
t was acceptable based on the low probability of i
occ t
this time frame, ami operation at a reduced power level, se ty of an accident.
gll Otherrelevant on includes the normal allowance provided with CNS Technical Specification 3.
.b which authorizes operation for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after entering the RUN jfj!; mode folio
- plant shutdown with the oxygen concentration requirement not met.
. }I This allo
'provides for a drywell entry to inspect for leakage, which has been I
vi termined by the NRC as an enhancement to plant safety.
1.
Letter to J. M. Pilant (NPPD) from B. L. Siegel (NRC) dated May 10, ? 982,
" Amendment No. 79 to Facility Operating License No. DPR-46" l
us wwi Ao:za usuz ezo oozy ens _t.acms ma liDoos
)
Attachment to NLS970123 Page 4 of 7 3.
The safety basis for the reauest. includino an evainntion of the safety sionifiennee and notentini consecuenan of the nronosed course of sction. This evaln* dn should include at least a aunlitative risk assessment derived from the liensee'+'tPA.
Granting this enforcement discretion would prev pc thermal
.4 li.
',tmnsletitThif thQlint, and potentially challengin at safe W=-=#d.in Sectidu 4 below, thE safety signifi ofco o
15% reactor thermal power with the Primary inm gen co -
greater than 4 volume percent has been previ and approveW NRC as documented in NUREO-1433, "Stan M1 Specifications, General Electric Plants, BWR/4."
Further, the District has determined that tive?l ted with remaining online below 15% power 24 ho than that associated with a plant shutdown.
r automatic, induces response ofplant standby syste level heat removal functions normally provided by the co
. Additionally, any plant shutdown has the potential allen plant Ety systems in response to the transient imposed durin wn.
M fore, ile the probability ofoccurrence of an accident for et isq
.,the et has determined that granting w
the enforcement d provi benefit.
ar any p anned shutdown und subsequent restart, CNS cifi
,b currently allow a total of 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> operation with the Burs prior to shutdown, and.24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> following s
and fe requested enforcement discretion would not result it operation time with the primary containment de-inerted; jit provide th
. time allowance while enabling avoidance of the plant
./G thermaltransie
~
l The District valuated the dose consequences associated with repair of the (valve) onl%ersus going to cold shutdown to repair the (valve) and has re.
iliat there is a slight reduction in personnel exposure estimated with 4
f YM.
' the repair online. 'I1 tis reduction is primarily due to the additional system M
ations which would be required to proceed to cold shutdown, and subsequent restart of the plant.
06/13/97 16:24 17402 825 5827 CNS-LICENSING
@ 007 Attachment to NLS970123 Page 5 of 7 Tne basis for the licensec's conclusion that the noncompliance will not be of 4.
notential detriment to the public health and safety and that neither an unreje' v,*ed safety ouestion nor a sirinificant hmrd consideration is involvedg,
,jp@
To?s@pdrt the iny'6stigation andtepah activities,, dYig e po reduced to,
' ft'termal f7
./
an'd Will be 'maintaided,at, approximately 10%
p eve! wi
'P tainm "p
's'ig' Fidiftbatfbtiritinhed operationiiit'this pow r
r.t
_en previo oxygen concentmtion at greater than 4 volume and bounded by both NUREG-1433,"Stan Specifications, M" proved Technical Itk,k Electric Plants, BWR/4/' (Section 3.6.3.3) and N&nts, once the Primary Specificatic is submittal 2'(Section 3.6.3.1) Pe)r Containment oxygen concentration becomes eqtl51 to if hg$pJ volume percent, S
, fs. volume percent
- on to the required action is to restore oxygen con rmal po ' " in the following k
limit within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, or reduce power con Indefinitely as the
~
eight hours. Operation at this red
'Is is low under these potential for an event that genera) ig conditions.
p t F kpliance with the existing Accordingly, the District
, nelu t no Technical Specificatio uirem 1n f potential detriment to the public safety question nor a significant health and safety an ither pg ued operation willbe within the hnd nside
$volved s evaluatedin the aforernentioned esta previ d
$ license sion that the noncomotinnee will not involve S.
p
=
Ady N U 0 th5Tnvironment.
ry n
[ Exercise of this
. ment discretion will not result in any planned increase in the ve material or other substance to the environment. Plant
' f release of any$. octed to remain within the existing Technical Specif effluents are e Granting thyjhforcement discretion will impact only the allowed time frame allo
~' ration with a de-Inerted containment. Primary containment integrity, "m CNS Tecimical Specification 1.0.P will continue to be met. Therefore,
~ likely event that an accident requiring primary containment integrity were to T
Letter to USNRC from O. R. Horn (NPPD) dated March 27,1997, " Proposed 2.
Change to CNS Technical Specifications, Conversion to Improved Standard Technical Specifications, Cooper Nuclear Station, NRC Docket No. 50-298, License No. DPR-46"
I 08,/is/97 15:2s e402 s2s ss27 cNS-LICENSING
@ 008 Attachment to NLS970123 Page 6.of 7 occurin this configuration, the environmental consequences would be bounded by that calculated in the CNS accident analyses.
I As discussed in Secdon'4 above, the NRC has previ ly eva "on of
~
th4ie-inerted containments, rid 4 1-j/T I
/ herbelow15% is not 1
'to result dmg i
M$l -
'g ~
heteidr'),4rh41on with a de '
e
'contain event of an accident, would not likely result.in tio
' ring contml, and therefore not exceed the conseg from the e accident analyses.
g 6.
Any pronosed comnenmatory actions.
'Ihe District will malatain reactor po
' power'
~
gen concentrations are restored to less nt.
w j
l 7.
'nte instification for the duratin f the n
...... J The duration of the none na la aad on ted time to e&ct repairs and to restore the
'ntain neentration to below4 volume l
S.
Plant Onsite Review Committee or its equivalentl.
l l
' n l
This d approved by the CNS Station Operations Review l
v l
' niant conditinnyWfied in eaction B is==tiafled.
~ ~
e reoneet mn:
---.cally addres how one of the NOED criteria for ar,erenrinte l$
Granting iforcement discretion will allow CNS to avoid inducing a thermal and s
t which would be introduced by proceeding to cold shutdown to
~
. As discussed further in Section 4 above, this enforcement on would also reduce overall risk by minimizing the potential for challenge of plant safety systems. These benefits meet the criteria outlined in Section B.1. (a) of NRC Administrative Letter 95-05.
i 5
l
ver w ei to:ze treur aza ooze ens-t.tcen3 no g oo, Attachment to NLS970123 Page 7 of 7
- 10. If a follow-up license amendment is required. the NOED reoneet must include marke21-un TS nages ahnwing the nroposed TS changes. h actual licen$
amendment reonest must follow within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />.
'uestis ' Mary, and expected to be non
'further in
$ +.
o-3%I' vir faiS14Mc/'flicIDistrict has submitted an d M ' ' ME W
6 t
ment the i
aYpecifications which woul low o i
containment at reduced power operations to en
- l. sim*
acti identified.
- 11. A =tatament thnt nrior adootion of anoroved fina - ----
.ients to the TS or the ITS would not have obviated the need for the MED7 E.g n
l The District is not aware of NRC-appr a impro dentified addressing this containment inertino trict has subadtted for NRC review, an application fn_yerj Technical SpecificaHons, which as di
.above 5uld need for this request.
III. CONCLUSION l
i I
The Diste et believes tiu,t i l quest f[
discretionis in the best interest of l
the p th and, j
(uchprok been previously reviewed and l
app '
aNR p
BO-1433 d Technied Specifications, General.
MVR/4." 3Sb-ct concludes that performance of this repair online
~'
l El Mainm ay de-inetted reduces the risk to the general public l
with the p,
l' compared A,lp c gto co% ffown, prevents intiation of a plant thermal transient cludes the consequences of any accident or otherwise result in adv,
environme?
uences. Therefore, the District requests that the NRC grant tl8 temporary enfo utscretion.
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