ML20198J535

Documents Basis of 980107 Verbal Request for Enforcement Discretion to TS 3.0.3 & TS 3.8.1.1 Action E Requirements. Written Confirmation of Enforcement Discretion That Was Granted,Requested

ML20198J535
Person / Time
Site:	Nine Mile Point
Issue date:	01/08/1998
From:	Sylvia B NIAGARA MOHAWK POWER CORP.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NMP2L-1745, NUDOCS 9801140152
Download: ML20198J535 (9)

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l NIAGARA MOHAWK G E N E R ATIO N BUSINESS GROUP B RALPH $YLVA n.cu vo noou January 8,1998 gigg NMP2L 1745 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555 RE:

Nine Mile Point Unit 2 Docket No. 50-410 NPF-69

Subject:

Requestfor Enforcement Discretion to Technical Specification 3.0.3 and TechnicalSpecification 3.8.1.1 Action e Requirements Gentlemen:

1 On January 7,1998, following discussions with the NRC Staff, Nine Mile Point Unit 2 (NMP2) was granted enforcement discretion with respect to Technical Specification (TS) 3.0.3 and TS 3.8.1.1 Action e. The enforcement discretion became effective at 1123 hours0.013 days <br />0.312 hours <br />0.00186 weeks <br />4.273015e-4 months <br /> on January 7,1998, and expires at 0900 hours0.0104 days <br />0.25 hours <br />0.00149 weeks <br />3.4245e-4 months <br /> on January 8,1998. The purpose of this letter is to document the basis of the verbal request and to request written confirmation of the enforcement discretion that was granted.

Niagara Mohawk Power Corporation (NMPC) requested enforcement fscretion from the requirements of TS 3.0.3. The failure of Division II Containment Monitoring System (CMS) while Division I CMS was out of service for preplanned maintenance forced the entry into TS Limiting Conditions for Operation 3.0.3. As a result, at 0441 hours0.0051 days <br />0.123 hours <br />7.291667e-4 weeks <br />1.678005e-4 months <br /> or. January 7,1998, NMPC entered TS 3.0.3, which required initiating actions within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and the plant to be in the Startup mode within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

NMPC also requested enforcement discretion from the requirements of TS 3.8.1.1 Action c.

The Division I Emergency Diesel Generator (EDG) was out of service for preplanned maintenance beginning at 0654 hours0.00757 days <br />0.182 hours <br />0.00108 weeks <br />2.48847e-4 months <br /> on January 6,1998. When the Division II CMS became inoperable at 0441 hours0.0051 days <br />0.123 hours <br />7.291667e-4 weeks <br />1.678005e-4 months <br /> on January 7,1998, TS 3.6.1.1 Action e was required to be entered, g

which required the plant to be in Hot Shutdown within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

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The enforcement discretion which was verbally requested by NMPC and gmnted by NRC Region I on January 7,1998, will permit restoration of the necessary equipment without the need to expose the plant to an unnecessary shutdown.-

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NMPC believes thete is less risk in continued operation than in forcing an unnecessary plant -

- challenge by taking the plant to Shuto_own to comply with the requirements of TS 3.0.3 and 3.8.1.1-Action e.. Attachment 1 provides NMPC's response to the 12 criteria identified in NRC Inspection Manual 9900, which provides the appropriate justification for this request for enforcement discretion.

t This request for enforcement discretion has i.een reviewed and approved by the NMP2 Station L Operations' Review Committee (SORC).~-

On January 7i1998, at 1820 hours0.0211 days <br />0.506 hours <br />0.00301 weeks <br />6.9251e-4 months <br />, repairs on Division II CMS were completed and TS 3.0.3 and TS 3.8.1.1 Action e were exited. During the period of the enforcement discretion, one :

' grab sample of the drywell atmosphere was taken. The results of that sample did not indicate any evidence ofleakage.

Very truly yours,

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B. Ralph Sylvia Chief Nuclear Officer t

BRS/GJG/Imc Attachment-xc:

- Mr. H. J. Miller, Regional Administrator, Region I Mr. A. W. Dromerick, Acting Director, Project Directorate I-1, NRR

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Mr. B.- S. Norris, Senior Resident Inspector Mr. D. S.' Hood, Senior Project Manager, NRR Records Management

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-UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of -

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Niagara Mohawk Power Corporation

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Doclict No. 50-410

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Nine Mlle Point Nuclear Station Unit No. 2

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AFFIDAVIT B. Ralph Sylvia, being duly sworn, states that he is Chief Nuclear Officer of Niagara Mohawk Power Corporation; that he is authorized on the part of said Corporation to sign and file with the Nuclear Regulatory Commission the documents attached hereto; and that all such documents are true and correct to the best of his knowledge, information, and belief.

NIAGARA MOIIAWK POWER CORPORATION o

O By B. Ralph Sy[via [

Chief Nuclear Officer Subscribed and sworn to before me this 8th day of January 199R.

ms/J MD

' NOTARY PDBLIC

'f BEVERLY W. RIPKA etary Public stateof New York aat.in Oswego Cct No. 4644879.

My ammisson En f

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ATTACHMENT 1 v

a REQUEST FOR ENFORCEMENT DISCRETION e

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he Technical Specification or other license conditions that will be violated.

i Niagara Mohawk Power Corporation (NMPC) has determined that the primary _-

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containment airborne particulate radioactivity monitoring system and the primary containment airborne gaseous radioactivity monitoring system required by Technical l

i Specification (TS) 3.4.3.1 are inoperable,? TS 3.4.3.1 requires that the primary -

containment airborne particulate and gaseous radioactivity monitoring systems, drywell -

- floor drain tank fill rate monitoring system and drywell equipment drain tank fill rate monitoring system be operable. TS 3.4.3.1 Action a does not cover the loss of both i

the primary containment airborne particulate radioactivity monitorink system and the.

primary containment airborne gaseous radioactivity monitoring system. Accordingly, Nine Mile Point Unit 2 (NMP2) must enter TS 3.0.3. Therefore, NMPC is requesting L

discretionary enforcement from the requirements of TS 3.0.3 which required initiating L.

actions within I hour and the plant to be in the Startup mode within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

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Since the Division I Emergency Diesel Generator (EDG) was out of service when the

- Division II Containment Monitoring System (CMS) system failed,- the shutdown portion of TS 3.8.1.1 Action e was required to be entered, due to the inoperability of C

both Divisions of CMS. Therefore, NMPC is also requesting discretionary enforcement from the requirements of TS 3.8.1.1 Action e, which required the plant to be in Hot Shutdown within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

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De chtumstances surrounding the situation, including root causes, the need for prompt action, and identification of any relevant historical events.

..On January 5,1998 at 0324 hours0.00375 days <br />0.09 hours <br />5.357143e-4 weeks <br />1.23282e-4 months <br />, Division I of the CMS was removed from service D

for preplanned corrective maintenance on the system heat trace. The CMS includes the

pnmary containment airborne particulate radioactivity monitoring system and the

- primary containment airborne gaseous radioactivity monitoring system. On January 7,

- 1998, at 0441 hours0.0051 days <br />0.123 hours <br />7.291667e-4 weeks <br />1.678005e-4 months <br />, Division II CMS experienced flow oscillations and was declared

inoperable. - Since there are no TS 3.4.3.1 Actions for this condition, entry into TS' S 3.0.3 was required. Attempts were made to restore Division I CMS. Those attempts E

failed. - Attempts' made to restore Division II CMS were also unsuccessful. -

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t Initially, the_ cause of the failure of both Divisions of CMS appeared to be moisture s

intrusiod.7After trei'bleshooting activities, it has been determined that the failure of the 1 Division II CMS was due to an electronic component failure. NMPC could not have j

1 anticipated these conditions based upon previous historical events.

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On January 6,1998 at 0654 hours0.00757 days <br />0.182 hours <br />0.00108 weeks <br />2.48847e-4 months <br />, Division I EDG was removed from service for preplanned maintenance. At the time, Division 11 CMS was available and the requirements of TS 3.8.1.1 Action e were met. When Division 11 CMS became inoperable at 0441 hours0.0051 days <br />0.123 hours <br />7.291667e-4 weeks <br />1.678005e-4 months <br /> on January 7,1998, entry into the shutdown portion of TS 3.8.1.1 Action e was required.

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The safety basis for the request, including an evaluation of the safety significance and potential consequences of the proposed course of action. This evaluation should Emlude at least a qualitative risk assessment derived from the licensee's PRA.

Each of the leakage detection systems inside the drywell is designed with the capability of detecting leakage less than the established leakage rate limits and providing appropriate alarms of excess leakage to the control room. A significant compromise to the reactor coolant pressure boundary exists if the boundary contains a crack that is large enough to propagate rapidly. Leakage rate limits are set low eno'igh to detect the leakage emitted from a single crack.

A control roon alarm allows the operators to evaluate the significance of the indicated leakage and, if necessary, shut down the reactor for further investigation and corrective action. The allowed leakage rates are well below the rates predicted for critical crack sizes.

With both primary containment airborne gaseous and particulate radioactivity monitoring systems inoperable, grab samples of the drywell atinosphere will be taken and analyzed to provide periodic leakage information. Provided a sample is obtained and analyzed every 12 iours, adequate information is obtained as to the condition of the drywell atmosiihcre. The Improved Standard Technical Specifications (ITS) allow continued operation fcr up to 30 days with no required drywell atmospheric monitoring system operable, provided grab samples are taken every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. Prior to our request, a review of both the drywell floor and equipment drain fill rates indicated no adverse trends. Also, the primary containment equipment and floor drain monitors will be monitored every 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> (versus the TS required 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />) during the period of enforcement discretion.

The NMP2 Individual Plant Examination (IPE) and Individual Plant Examination for External Events (IPEEE) evaluated the risk of core damage had radionuclide release events using Probabilistic Risk Assessment (PRA) methods. he PRA implicitly credits leak detection within the LOCA initiator frequency. However, since the drywell floor and equipment drain tank fill rate monitors are still available and because grab samples are being taken, the impact of shon-term operation without the other monitors is minimal.

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'Ihe basis for the licensee's conclusion that the noncompilance will not be of potential deir! ment to the public health and safety and that neither an unreviewed safety question nor a significant hazard consideration is involved.

NMPC has evaluated this issue and has concluded that there is no significant hazards consideration involved with the requested Notice of Enforcement Discretion (NOED).

p The significance of CMS inoperability for less than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> beyond TS 3.0.3 and 3.8.1.1 requirements has been evaluated and found not to be of potential detriment to

'he public health and safety. Thus, therc is no safety consequence associated with the request to extend the allowable time to complete required repairs.

NMPC has evaluated this request using the criteria set forth in 10CFR50.92, and determined that it does not involve a significant hazards consideration nor an unreviewed safety question.

Operation of NMP2 in accordance with the enforcement discretion will not involve

r. significant increase in the probability or consequences of an accident previously evaluated.

The function of the reactor coolant system leakage detection systems specified in TS 3.4.3.1 is to monitor and detect leakage from the reactor coolant pressure boundary so that appropria:e actions can be taken before the integnty of the reactor coolant pressuie boundary is impaired. In the plant accident analysis, no credit for mitigation of an accident is taken for the reactor coolant system leakal ;etection systems. Per TS 3.4.3.1, leakage can be detected inside the drywell via: drywell floor and equipment drain tank fill rete changes, gaseous adioactivity levels, and particulate radioactivity levels. The drywell floor and equipment drain tank fill rate monitoring systems are operable and capable of quantifying leakage. Grab samples for gaseous or particulate activity will be taken as a backup to the normal sampling process. The proposed enforcement discr: tion does not alter any accident initiators or precursors. Also, the primary contamment equipment and floor drain monitors will be monitored every 4 laurs (versus the TS required 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />) during the period of enforcement discieticn.

With these diverse methods of monitoring reactor coolant system leakage within primary containment, NMPC is confident that unacceptable leakage rates from the reactor coolant system will be detected in a timely manner and appropriate actions taken to shut the unit down and depressurize the reactor coolant system. Therefore, the proposed enforcement discretion will r.ot increase the probability or consequences of a previously evaluated accident.

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Operation of NMP2 in acccrdans ' with the enforcement discretion will not create the possibility of a new or different kind of accident from any accident previously evaluated.

1-The function of the reactor coolant system leakage detection systems is to monitor and detect leakage from the reactor cc,olant pressure boundary so that approp-iate actions ccn be taken before the integrity of the reactor coolant pressure boundary is impaired.

The use of grab sampics is an acceptable alternative and is consistent with the ITS. No changes to the design or function of the leakage detection systems are being made. The granting of this enforcement discretion will not cause any systems to operate in an unanalyzed condition and will allow the completion of necessary repairs. Therefore, the proposed enforcement discretion will not create the possibility of a new or different kind of accident from any accident previously evaluated.

Operation of NMI 2 in accordance with the proposed enforcement discretion will not involve a significant reduction in a marg!n of safety.

The gaseous and particulate radioacti"if v monitoring systems are intended to provide hakage detection. Obtaining grab enes every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> provides comparable information. The use of grab sar. pb c no acceptable alternative and is censistent with the ITS. The drywell floor and ep;vr.ent drain tank fill rate monitoring systems remain capable of quantifying leaw,. Therefore, adequate leakage detection is still available and the proposed enforcement discretion does not involve a significant reduction in a margin of safety.

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The basis fer the licensee's conclusion that the noncompilance will not involve adverse consequences to the environment.

The enforcement discretion involves the NMP2 CMS which monitors primary containment conditions. The requested enforcement discretion does not involve an increase in the amounts or types of any effluents that may be released offsite nor an increase in individuc.1 or cumulative occupational radiation exposure. Also, the requested enforcement discretion does not physically modify the plant, increase the plant's licensed power level or involve irreversible environmental consequences.

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Any proposed compensatory measures.

Grab samples of the containment atmosphere will be obtained and analyzed eve y 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> to determine primary containment airbonne gaseous or particulate radioactivity.

This action is consistent with the ITS required actions on a loss of primary containment airborne gaseous and airborne particulate radioactivity systems. Also, the primary watzinment equipment and floor drain monitors will be monitored every 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> 4

(versus the TS required 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />) during the period of enforcement discretion. In.

addition, NMPC has verified the Division II systems required to meet TS 3.8.1.1

' Action e, except CMS, are operable.

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The justification for the duration of the noncompliance.

TS 3.4.3.1 requires that the primary containment airborne particulate and gaseous radioactivity monitors be operable. If both monitoring systems are inoperable, entry into TS 3.0.3 is required.- TS 3.0.3 requires initiating actions within I hour, placing the unit in Startup within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, Hot Shutdown within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and Cold Shutdown within the subsequent 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. Division I and II CMS both became inoperable at 0441 hours0.0051 days <br />0.123 hours <br />7.291667e-4 weeks <br />1.678005e-4 months <br /> on January 7,1998. Accordingly, NMP2 would have been required to be in Startup in accordance with TS 3.0.3 at 1141 nours on January 7, 1998.

TS 3.8.1.1 Action e, requires that with the Division I or II EDG inoperable, verify within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> that all required redundant systems, subsystems, trains, components, and devices that depend on the remaining operable diesel generator as a source of emergency power are also operable; otherwise, either declare inoperable the redundant systems, subsystems, trains, components and devices served by the inoperable diesel

- generator and take the Action required by the associated specification (s) for both divisional systems, subsystems, trains, components or devices inoperable or be in at least Hot Shutdown within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and in Cold Shutdown within the follewing 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. Once the Division II CMS system became inoperable at 0441 hcms on January 7,1998, entry into the shutdown portion of TS 3.8.1.1 Action e was required. This would require the unit be in Hot Shutdown by 1641 hours0.019 days <br />0.456 hours <br />0.00271 weeks <br />6.244005e-4 months <br /> on January 7, 1998.

NMPC requests enforcement discretion from these Specifications until 0900 hours0.0104 days <br />0.25 hours <br />0.00149 weeks <br />3.4245e-4 months <br /> on January 8,1998, to make the required equipment repairs and perform required system testing in an orderly manner.

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A statement that the request has been approved by the facility organization that normally reviews safety issues.

This request for enforcement discretion was reviewed and approved by the NMP2 Station Operations Review Committee (SORC) on January 7,1998.

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The request must specifically address how one of the NOED criteria for appropriate plant conditions specified in Section B is satisfied.

NMP2 is cur ently operating. Section B of Part 9900, criteria 1, states that for an operating plant, the enforcement discretion is intended to (a) avoid undesirable transients as a result of forcing compliance with the license condition and, thus, minimize potential safety consequences and operational risks or (b) eliminate testing, inspection, or system realignment that is inappropriate for the particular plant conditions. This enforcement dig:retion meets criteria 1(a) in that entry into TS 3.0.3 and 3.8.1.1 Action e would require a plant shutdown prior to being able to return the subject equipment to an operable status. NMPC believes there is less risk in continued operation than in forcing an unnecessary plant challenge by taking the plant to Shutdown to comply with the requirements of TS 3.0.3 and 3.8.1.1 Action e.

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If a follow-up license amendment is required, the NOED request must include marked up Technical Specification pages showing the proposed Technical Specification changes. The actual license amendment request must follow within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />.

No follow-up license amendment is required as part of this enforcement discretion.

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A statement that prior adoption of approved line item improvements to the Technical Specifications or the ITS would not have obviated the need for the NOED request.

NMPC is currently in the process of converting to ITS with our application scheduled to be submitted in early to mid-1998. ITS would have obviated the need for this enforcement discretion.

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Any other information the NRC staff deems necessary before making a decision to exercise enforcement discretion.

NMPC knows of no additionalinformation that is necessary for processing of this request.

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