Text

Discusses Requesting NRC Exercise Discretion Not to Enforce Compliance W/Actions Required in TS 3.8.1.1 Action B for Plant.Noed Granted Since Action Involved Minimal or No Safety Impact
	ML20199H913
Person / Time
Site:	Summer
Issue date:	11/17/1997
From:	Reyes L; NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:	Gabe Taylor; SOUTH CAROLINA ELECTRIC & GAS CO.
References
	NOED-97-2-003, NOED-97-2-3, NUDOCS 9711260258
	Download: ML20199H913 (4)
	v • d • e

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November 17, 1997 N0E0 NO. 97 2 003 South Carolina Electric & Gas Company ATTN:

Mr. Gary J. Taylor Vice President. Nuclear Operations Virgil C. Summer Nuclear Station P. O. Box 88 Jenkinsville. SC 29065

SUBJECT:

NOTICE OF ENIORCEMENT DISCRETION FOR SOUTH CAROLINA ELECTRIC AND GAS COMPANY REGARDING V. C. SUMMER

Dear Mr. Taylor:

By enclosed letter dated November 14. 1997. you requested that the Nuclear Regulatory Commit,sion (NRC) exercise discretion not to enforce compliance with the actions reavired in rechnical Specification (TS) 3.8.1.1 Action b.

This TS requires that with one Emergency Diesel Generator (EOG) inoperable, you take the foTlowing action with regard to your V. C. Summer nuclear unit:

" Restore the diest1 generator to operable status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within the following 30 hour3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .c.". Your letter documented information previously discussed with the NRC In telephone conversations on November 13 at 4:40 p.m. and 6:00 p.m.. You stated that on November 14. 1997, at 4:00 a.m. the plant would not be in compliance with 15 3.8.1.1 Action b and therefore, shutdown of the plant would be required. The TS action statement was entered at 4:00 a.m. on November 11. 1997.

You requested that a Notice of Enforcement Discretion (NOED) be issued pursuant to the NRC's pol'cy regarding exercise of discretion for an operating facility, set out in Section VII.c. of the " General Statement of Policy and Procedures for NRC Enforcemat Actions" (Enforcement Policy).

NUREG 1600, and be offective for 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months from 4:00 a m. to 4:00 p.m. on November 14.-1997.

'The condition which necessitated the request for discretion was a result of

)roblems encountered during the planned, monthly surveillance test of the 'A' DG, Specifically load oscillation with intermittent spikes of approximately 2400 to 500 kilowatt (Kw) above and below the nominal full load rating were observed.

Your-cnrrective maintenance involved replacement of the electrical control unit (EGA) and the hydraulic actuator (EGB) of the Woodward governor.

-Later bench testing of the electronic control unit exhibited spiking which you.have preliminarily determined to be the cause-of the load oscillations on the EDG, You stated that the control unit would be returned to the vendor to

' determine the root cause of the failure.

You requested a one-time extension Jof.the allowed outage time for the 'A' EDG from 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months , which is allowed in TS 3.8.1.1 Action b. to a total of 84 hours9.722222e-4 days 0.0233 hours 1.388889e-4 weeks 3.1962e-5 months .

During the telephone

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SCE&G 2

conversations on November 13, 1997. you stateu that the maintenance repairs to replace the governor components had been completed and the extension was needed to perform post-maintenance testing.

In requesting the N0ED your safety rationale for extension of the allowed outage time was: 1) the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety previously evaluated in the safety analysis report does not increase: 2) a single train of emergency safeguards equipment is adequate to mitigate the consequences of any previously analyzed accidert: 3) new accident precursors or limiting single failures are not created: and 4) the margin of safety as defined in the basis for any TS are not reduced.

In addition, you stated that a Probabilistic Risk Assessment (PRA) evaluation was conducted on the proposed 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months extension of the TS allowed outage time.

This evaluation, which utilized your plant PRA model, indicated that only a small change in the core damage frequency (CDF) would occur as a result of the increased outage time for the 'A'

EDG, As compen.;atory measures, the actions you committed to take included: no changes in reactor power from the current 73% power level would be made until the A' EDG was returned to service (this would not preclude a reduction in power to comply with TS requirements): no additional safety related equipment would be removed from service for maintenance or testing: nuclear instrumentation (NI) calibrations would not be performed during the 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months extension: and switchyard activities that could cause any unstable offsite or onsite power conditions would not be scheduled.

In addition, you stated that the 'B' EDG was successfully tested on November ll, 1997, as required by TS 3.8.1.1 (b) 1.

The staff has reviewed the above safety rationale regarding a one-time extension to the allowed outage time and the results of your PRA evaluation.

This safety rationale and your compensatory measures provide the ap)ropriate justification to support a conclusion that enforcement discretion s1ould be given to avoid undesirable transients as a result of forcing compliance with the TS, and thus would minimize potential safety consequences and operational risks.

On the basis of the staff's evaluation of your request, including the compensatory measures described above, the staff has concluded that an N0ED is warranted because we are satisfied that this action involves tinimal or no 9

safety impact and has no adverse radiological impact on public health and

safety, Therefore, it is our intention to exercise discretion not to enforce compliance with TS 3.8.1.1 Action b for the period from 4:00 a.m. on November

14. 1997, to 4:00 p.m. on November 14. 1997, If the 'A' EDG was returned to operable status before the expiration of this discretion, the discretion will be terminated at the time the 'A' EDG was returned to operable status.

This 4

letter documents our telephone conversation at 6:45 p.m. on November 13, 1997.

-when we orally granted this N0ED.

However, as stated in the Enforcement Policy, action will normally be taken, to the extent that violations were involved, for the root cause that led to the noncompliance for which this N0ED was necessary.

SCE&G 3

We are issuing this letter to confirm our verbal authorization. although the condition which caused the need for this N0ED (completion of post-maintenance testing on 'A' EDG) was completed and the EDG declared operable prior to 4:00 a.m. on Novembe* 14. 1997.

Sincerely.

Orig signed by Bruce Mallett for Luis A. Reyes Regional Administrator Docket No.: 50 395 License No.: NPF-12

Enclosure:

SCE&G letter dated November 14. 1997 cc w/ encl:

R. J. White Nuclear Coordinator (Mail Code 802)

S.C. Public Service Authority c/o Virgil C. Sunmer Nuclear Station P. O. Box 88 Jenkinsville. SC 29065 J. B. Knotts, Jr.. Esq.

.Winston and Strawn 1400 L Street. NW Washington. D. C.

20005 3502 Chairman Fairfield County Council P. O. Drawer 60 Winnsboro, SC 29180 Director Radioactive Waste Management Bureau of Solid and Hazardous Waste Management S. C. Department of Health and Environmental Control 2600 Bull Street Columbia. SC 29201 cc_w/ encl: Continued see page'4

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'cc w/ encl:--Continued

'R; M.=fowlkes. Manager'.

Operations 1 (Mail; Code 303)

South Carolina Electric & Gas Company.

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-Virgil =C. Summer Nuclear Station P. 6. Box 88 -~-

--Jenkinsville; SC 29065 April Rice. Manager.

Nuclear Licensing & Operating Ex3erience

'(Mail-Code 830)-

5 Sout1 Carolina Elect-ic & Gas Company

' Virgil C.. Summer Nuclear Station P. 0. Box 88 5 kinsville. SC -29065 i

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.NRC Resident Inspector U.S.-Nuclear Regulatory Commission W

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sn== m November 14,1997 BC-97-0236 Mr. Luis A. Reyes Regional Administrator U. S. Nuclear Regulatory Commission Region 11 Atlanta Federal Center 61 Forsyth St., SW, Suite 24TE,b Atlanta, GA 30303

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Attention:

Mr. Luis A. Reyes James E. Lyons, Project Dirsetor Gentlemen:

Subject:

VIRGIL C, SUMMER NUCLEAR STAT;ON DOCKET NO 50/395 OPERATING LICENSE NO. NPF-12 t

REQUEST FOR NOTICE OF ENFORCEMENT DISCRETION ON g'-

TECHNICAL SPECIFICATION 3.8.1.1.b e

South Carolina Electric & Cas Company (SCE&G) requests that the NRC exercise discretion not to enforce compliance with the actions required in Technical Specification (TS) 3.8.1.1.b.

Per our telephone conversation on November 13,1997, at 1640 hours0.019 days 0.456 hours 0.00271 weeks 6.2402e-4 months , we informed you that on November 14,1997, at 0400 hours0.00463 days 0.111 hours 6.613757e-4 weeks 1.522e-4 months , that Virgil C. Summer Nuclear Station (VCSNS) Unit 1 would not be in compliance with Technical Specification 3.8.1.1.b.

which states that "two separate and independent Emergency Diesel Generators (EDG)...shall be OPERABLE" The AOT (Allowed outage time), entered on Novemb2r 11,1997 at 0400 hours0.00463 days 0.111 hours 6.613757e-4 weeks 1.522e-4 months states that 'with one EDG of 3.8.1.1.b inoperable:.. 4. Restore the EDG to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months or be in HOT STANDBY within the next f Soum and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months ."

Acocidingly, VCENS requests that the NRC not enforce compliance to the ACT for an additional 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months beyond its expiration of November 14,1997, at 0400 hours0.00463 days 0.111 hours 6.613757e-4 weeks 1.522e-4 months , to an expiration time of November 14,1997, at 1600 hours0.0185 days 0.444 hours 0.00265 weeks 6.088e-4 months .

Per the guidance given in NRC Administrative Letter 95-05, dated November 07,1995, ths Attachment provides the information requested for your review:

NUCLEAR EXCELLENCE. SUMMER TRADITION!

Ericiosu.e fh O 9)*{-

MON,NOV-17-9711i43AN SUttER 8033455837 P. 03 Reg 12tial Administrator RC 97-0236 MSP 97 0031 Page 2 of 2 Should you have any questions, please call Michael J. Zaccone at (903) 345-4328.

Very truly yours, I

b M 0:rr Gary J. Taylor MJZ/GJT Attachment original to' Document Control Desk c:

J. L Skolds R. R. Manc. (w/o Attachment)

W. F. Conway R. J. Wh'te A. R. Johnson J. B. Knotts, Jr NRC Resident inspector NSRC.

S. A. Byrne DMS (RC-97 0236)

R. J. Wasolus RTS (MSP 97 0031)

Paulette Ledbetter File (818.26)

Gene >al Managers STATE OF SOUTH CAROLINA TO WIT :

COUNTY OF FAIRFiELD I hereby certify that on the

/V day of As*dsa912, before me, the subscriber, aN Public of the State of South Carohna personal,ly appeared Stephen A. Byrne, being sworn. and states that he has signature authority for the / ice President, Nuclear rations of the South Carolina Electric & Gas Company, a corporation of the State of South Carolina, tt'at he provides the foregoing response for the purposes tharoin set forth, that the statements made are true and correct to the best of his kncr.,iedge, information, and belief, and that he was authorized to provide the response on behalf of said Corporation.

MAb WITNESS my Hand and isotarial Seal 41otary Public

.Th / 3" too f My Commission Expires Date

NON, NOV-17-9711:44M SUttfR 8033455837

.04

' Attachment to Regional Administrator t -

RC 97-D236 MSP 97-0031 Pa0e 1 of 7 REQUEST FOR ENFORCEMENT DISCRETION REVIEW ITEMS

1. The TS or other license condition that will be violated.

TS 3.8.1.1.b. Specifically, the 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months AOT for "A" EDG would expire on November 14,1997, at 0400 houm. This request would allow the ACTION statement to be extended until November 14,1997, at 1600 hours0.0185 days 0.444 hours 0.00265 weeks 6.088e-4 months .

2. The circumstances surrounding the situation, including root causes, the nued for prompt action and identification of any relevant historical events.

On November 11, at 0400, the *A" EDG was declared inoperable after load oscillations occurred during performance of the monthly surveillance test. The EDG was operating at it's nominal full load rating (4250 kW) when intermittent load spikes of approximately 400 to 500 kW above and below this nominal loading were observed.

The load spikes were observed on both the local and control room meters and were also evident by fuel rack movement on the engine. Action was immediately initiated to determine lf these oscillations were due to instability on the EDG or the grid. No perturbations were observed on the grid by either VCSNS personnel or the load dispatcher.

After continued operation these oscillulons steadieel out and disappeared, but were again observed by arratic fuel rack movement after the engine was unloaded prior to it's shutdown. Following shift tumover, a detailed plan was developed, instrumentation was installed and troubleshooting initiated. However, no oscillatior,s were observed during this troublesnooting effort.

Based on plant and industry experience, it was determined that this condition was most probably due to a malfunction in either the electronic control unit (EGA) or the hydraulic actuator (EGB) of the Weodward governor. Since maintenance had been performed on the hydraulic actuator during the recent refueling outage, it was believed that some debris may have been present in the actuator oil. The hydraulic actuator oil was replaced, and a maintenance run was performed satisfactorily. The survelliance test was age'n performed on nightshift and the oscillations reappeared after the EDG hcd oparated satisfactorily for about half of the test duration. An additional troubleshooting plan was developed and subsequently approved by the govemor t

manufacturer (Woodward) to attempt to isolate the problem to the electronic control or hydraulic units.' A gravemor service representative was also dispatched for assistance.

The troubleshooting plan was implemented on day shift on 11/12/97, but only one smallet spike was observed during loading. At this time since the problem had still not

MON,L NOV-17-9711:45AM SultB

803 345 5837 P.05 Attachment to Regional Administ stor RC-97-0236 MSP 97-0031 I

Page 2 of 7 been isolated, it was deoided to replaos both the electronic control and hydraulle units.

It was believed that the problem was most probably due to a malfunction in the electronic control unit, but it was conservatively decided to replace both units. Thes.

units were replaced on n@ht sh:ft and setup oontinued into dayshift on 11/13/97.

Approximately 8 or 10 starts and shutdowns of the'EDG followed by govemor ad,iustments were neccesary to perform the setup. The surveillance test was then repeated, but a slightly longer govemor recovery time occurred which caused a slower than required ten second start time. This resulted in the surveillance test being stopped and an additional adjustment made to the governor hydraulic actuator (EGB unit). Several additional start attempts and runs were made to assure that the govemor adjustments were complete. In parallel with this effor', the testing necessary to retum the diesel to operability was being reviewed. It was determined that additional testing beyond the normal surveillance testing would be necessary to restore diesel opstability, lhis additional testing was necessary to assure that the governor operation and response would bre satisfactory under normal and accident cendttlons 3

and that all of the necessary circuitry would be exe chsed, i

l Attempts to determine the root cause of the EDG load oscillations were i

conducted on a parallel path with the govemor replacement activities. The old eisctronic control unit was taken to the shop and bench tested. No inputs other than power were applied, yet outputs indicating some spiking were observed. These spikes have been preliminarily determined to be the cause of the load oscillations, however, this unit will be returned to Woodward for their dstormination of the failure.

Additionally, the new electric control unit (EGA) was subjected to a static bench test prior to installation, with satisfactory results. VCSNS is confident that the problems wit'i 4

the "A* EDG have been corrected.

The remaining adjustments and rotests required to declare '

A" EDG OPERABLE willlikely exceed the remaining time of the AOT, which expires on November 14,1997, at 0400 hours0.00463 days 0.111 hours 6.613757e-4 weeks 1.522e-4 months . The rotests consist of maintenance runs necessary to iteratively set up the electric and hydraulic govemors, an operational run, a load rejection test, a variable loadir.g test, and a protective features test. The completion of the governor adjustments and the protective features test are considered i

the most limiting in terms of time. The governor adjustments must be completed prior to running any other testing. Additionally, the protection features procedures need to be developed, approved and carried out prior to exooeding the AOT.

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MW, NOV-17-97 11:46AM SVitER 8033455837 P. 06 Attachment to Regional Administratsr 1;O-97-0236 MSP 97-0031

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3. '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 include at least a qualitative dak assessment derived from the licensee's Probabilistic Misk Analysis (PRA)

This request is made based on avoiding an undesirable transient as a result of torood compliance with the license condition, and, thus minimize potential safety consequences and operational risks involved in performing a plant shutdown. A PRA evaluation was conducted on the proposed extension of the TS 3.8.1.1.b AOT by 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . The PRA resulted in a change in CDF of 4.42 E-7, which is a very small increase and below the allowable increase presented in ti.e ACRS committee meeting of November 6,1997. This change is determined to be of little safety significanoe by plant staff.

The potential consequences of performing a plant shutdown, however, is considered to be both an unnecessary risk and challenge to the plant under these circumstances. ' The problems have been corrected on the "A" EDO, yet due to the indeterminate number of retest adjustments and constraints, there may not be sufficient time remaining in the AOT to conduct thoroug's and conservative rsteste, prbr to subjecting the plant to the additional risk of performing a forced plant shutdown. This risk is consioered to be larger than the proposed action, which plant staff feels will be merely verifying the validity of our maintenance actions. We feel the "A" EDG could now function to provide its design basis requirements, but also know that complete, thorough and conservative rotests must be completed prior to declaring the "A" EDG OPERABLE.

4. The basis for the licensee's conclusion that the noncompliance will not be of potential detriment to the public's health and safety and that neither an unreviewed safety ques'Jon nor a significant hazard consideration is involved.

Based on the following assessment. VCSNS has determined that the proposed request does not represent an unreviewed safety question as delineated by 10 CFR 50.59. Additionally, based on this assessment, VCSNS has determined that the proposed request poses no sign @ ant hazard as delineated by 10 CFR 50.92.

SAFETY IMPACT AND POTENTIAL CONSEQUENCES INCLUDING DETERMir4ATION OF NO SIGNIFICANT HAZARDS CONSIDERATION Continued operation during the extended allowed outage time of the "A" EDG does not increase the probability of occurrence or the consequences of an accident or maifunction of equipment important to safety previously evaluated in the safety analysis

MON, NOV-17-9711M6AM SUttER 8033455837 P. W7 --

Attachmentto Regional Administrator

' RC 97-0236 MSP g7-0031 Page 4 of 7 report. The inoperability of an EDG does not affect the probability of any accident' previously analyzed. During the extended allowed outage time for the A' EDG, the

- remaining train of emergency power (1DB emergency bus) and emergency safeguards

- equipment will remain operable to mitigate the consequences of any previously analyzed socident. A single train of emergency safeguards equipment is adequate to mitigate the consequences of any previously analyzed accident. Furthermore, compensatory measures will ensure power is available to the 1 DA emergency bus in the event of an mooident or transient which requires emergency powering of the 1DA bus.

The proposed extension of the TS AOT does not create the possibility of an

. accident or matanction of a different type than any evaluated previously in the safety analysis report. The extended AOT of the "A" EDG does not create any new accident precursors, or limiting single failures. The FSAR accidents are analyzed asuming that the EDG is the worst single failure. No new initiators result from the change.

Therefore,it is concluded that no new or different kind of accident from any previously evaluated has been created by the _ extended AOT for the T EDO, The extended allowed outage time of ttie "A" EDG doe not result in a reduction in margin of safety as defined in the basis for any Technical Spoolfications. The compensatory measures provide additional assuranoe that power will be available for the 1DA emergency bus in the event of an socident or transient which requires emergency powering of the 1DA bus.

The margin of safety has been determined to be insignificantly changed by the I

application of this request. A PRA evaluation was conducted on the proposed extension of the TS 3.8.1.1.b AOT by 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . The PRA resutted in a change in CDF of 4.42 E-7, which represents a very small increaw in margin of safety and remains below the allowable increase presented in the ACRS committee meeting of November -

6,1997.

5. The brsis for the licensee's conclusion that ttu noncompliance will not involve adverse consequences to the environment.

e 8 Environmental Assessment This proposed request has been evaluated against criteria for and identification of licensing and regulatory actions requiring environmental assessment in accordance with 10 CFR 51.21. It has been determined that the proposed change would meet the criteria for categorical exciusion as provided for under 10 CFR 51.22(c)(9). The following is a discussion of how the proposed request would meet the critoria for r

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NN, NOV-17-97 ll:47AM SUttB 8033455837 P.08-Attachmentto Regional Administrator RC-97-0236 MSP 97-0031 PaGe 5 of 7 ostegorical exclusion as this enforcement discretion will not alter any previoub;y approved release limits, but only add an additional 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months to the AOT for "N L Although the proposed request involvs s exercise of enforcement discretio respect to me ACTION ete6ement for 3.8.1.1.0 (b.4.), vice an amendment to the lic pursuant to part 50, it is consistent with this regulation in tt,at; the proposed requast involves No Significance Hazards Consideration (refer to (i) -

the No Significance Hazards Consideration Determination section of this request);

. there are no significant changes in the types or significant increase in the (ii) amounts of any offluents that may be released offsite since the proposed request affects neither the generation of any radioactive affluents nor any of the permitted release paths; and (iii) there is no significant increase in Individual or cumulative oocupational radiation exposure.

Accordingly, VCSNS determined that the proposed request meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Based on the afurementioned and consistent with 10 CFR 51.22 (b), no environmental assessment or environmental impact statement need be prepared in connection with issuanoe of this enforooment discretion.

6. Any proposec compensatory measure (s).

During the extended AOT petiod of 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months from November 14,1997, at 0400

- hours or until the action statement is exited, VCSNS will not conduct power changes, l

allow any switchyard work, remove any additional safety related equipment from service, or conduct any instrument calibrations impacting safeguards equipment.

Additionail), an operability test has been successfully conducted on the "B" train EDG.

7. The justification for the duration of the noncomp'iance.

l The amount of time wa, estimated based on an estimate of the ramaining sequence of adjustments and rotests required to declare the "A" EDG OPERABLE.

The retests consist of maintenance runs necessary to iteratively set up the electric and hydraulic governors, an operational run, a load rejection test, a variable loading test, and a protective features test. The completion of the governor adjustments and the protective features test are considered the most limiting in terms of time. -The govemor adjustments must be completed prior to running any othe-testing. Additionally, the i

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Attachmentto Regional Administrator

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RC 97 0236 -

MSP 97-0031 -

- Pace 6 of 7 protection features procedures need to be developed,' approved and carried out prior to exceeding the AOT.

Each adjustment and retest takes a minimum of 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months . The operational and variable loading test duration is estimated at 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months . The load rejection and protective

. features test is cdmated to take approximately 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months (8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months to prepare and approve the procouure and 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months to brief and conduct the test). Maint) nance, and Systems Engineering determined that this would require, at most, an additional 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months past the AOT to complete.

A PRA evaluation was conducted on the proposed extension of the TS 3.8.1.1.b i

AOT by 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . The PRA resulted in a change in CDF of 4.42 E-7, which is a very small increase and below the allowable increase presented in the ACRS committee meeting of November 6,1997.

8. A statement that the request has been approved by the fdity organization that normally reviews safety issues (Plant Onsite Review Committee, or its equivalent).

F The proposed action to request enforcement discretion along w% the plant specific conditions requiring the need for the request were approved by the Plant safety Review Commhtee (PSRC) on November 13,1997, at 1600 hours0.0185 days 0.444 hours 0.00265 weeks 6.088e-4 months . The PSRC made the determination that thoto were neither unreviewed safety questions nor

- significant hazards considerations.

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

VCSNS is currenti. :n Mode 1, operating at 73% power. The applicable NOED criteria for this condition is :

"1. For an operating plant, the NOED is irf.orded to (a) avoid undesirable transients as a result of forcing compliance with the 16ense condition, p

-and, thus, minimize potential safety consequences and operational risks or'(b) eliminate testing, inspection, or system real'gnment that is inappropriate for the particular plant conditions."

As stated above, this request is made based on avoiding an undesirable 1 transient as a mault of forced compliance with the license condition, and, thus minimize potential safety consoquences and operational risks involved in performing a plant shutdown. The potential consequences of performing a plant shutdown is considered w

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i M, NOV-17-97 11:47At1

' SUttER 8033455837

p. 88 Attachmentto Regional Administrator

- RC-97-0236 ~

l MSP 97-0031 Page 5 of 7 ostegorical exclusion as this enforooment discretion will not alter any previousiy

- approved release limits, but only add an additional 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months to the AOT for "A" Although the proposed request involves exercise of enforooment discretion wit respect to the ACTION statement for 3.8.1.1.b (b.4.), vice an amendment to the lice pursuant to part 50, it is consistent with this regula', ion in that; the proposed request involves No Significance Hazards Consideration (refer to (i) the No Significanoo Hazards Consideration Determination section of this request);

there are no significant changes in the types or significant increase in the (ii) amounts of any effluents that may be released offsite sino m proposed request affects rWther the generation of any radioactive siiiuents nor any of the permitted release paths; and (iii) there is no significant increase in individual or cumulatNe oooupational radiation expocure.

Accordingly, VCSNS determined that the proposed request meets the eligibility I

criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Based on the aforementioned and consistent with 10 CFR 51.22 (b), no environmental assessment or environmemal impact statement need be prepared in connection with issuance of this enforcement discretion.

E. Any proposed compensatory measure (s).

During the extended AOT period of 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months from November 14,1997, at 0400 hours0.00463 days 0.111 hours 6.613757e-4 weeks 1.522e-4 months or until the action statement is exited, VCSNS will not conduct power changes, n

allow any switchyard work, remove any additional safety related equipment from servloe, or conduct any instrument calibrations impacting safeguards equipment, Additionally, an operability test has bean successfully conducted on the "B" train EDG.

7. The justification for the duration of the noncompliance.

Tha amount of time was estimated based on an estimate of me remaining sequence of adjustments and rotests required to deare the "A" EDG OPERABLE.

The retesta consist of maintenance runs necessary to iteratively set up the electric and hydrhulic governors, an operational run,' a load rejection test, a variable loading test, and a protective features test. The completion of the go"ernor adjustments and the protective features t.mt are considated the most lim t!ng in terms of time. The govemor adjustments must be completed prior to running any other testing. Additionally, the

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mN, NOV 17-9711:48fti-SUttER 8033455837 P. 09 Attachms,nito Regional' Administrator RC 97-0236 MSP 97-0031 l-Page 7 of 7 I

to be both an unnecessary risk and challenge to the plant under the otroumstances for -

which the request is made. The problems have been corrected on the W EDO, yet due to unforeseen rotest adjustments and constraints, there may not be sufficient time remaining in the AOT m conduct thorough and conse:vative retects, pilor to subjecting the plant to the additionst risk of performing a forood plant shutdo*vn. This risk is ensidered to be larger than the proposed action, which plant staff feels will be merely_

verifying the validity of our maintenance actions. We feel the W EDG oould now function to provide its design basis requirements, but also know that complete, thorough and conservative rotests must te completed prior to doolaring the "A" EDG OPERABLE.

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

VCtsNS proposes no license amendment. This item is not applicable.

11. A statementthat prior adoption of approved line-hom improvements to the TS or i the iTS would not have obviated tha need for the NOED request.

The 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months AOT given in TS 3.8.1.1, is also found it. the ITS. This AOT is not 1

included in the approved line-item improvements to the TS. Therefore, prior adoption of approved line-hem improvements to the TS of the ITS would not have obviated the need for the NOED request utlitzed in this request -

12, Any other information the NRC staff doen.s necessary before making a decision to exerdse enforcement discretion.

None.

TOML P.09

...

ML20199H913

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ML20199H913

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