ML20205J083

Requests Enforcement Discretion from Requirements of PBAPS, Units 2 & 3 Ts.Enforcement Discretion Pursued to Avoid Unneccessary Plant Transient Which Would Result from Compliance with TS

ML20205J083
Person / Time
Site:	Peach Bottom
Issue date:	03/26/1999
From:	Geoffrey Edwards PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20205J057	List: ML20205J053 ML20205J083
References
NUDOCS 9904090163
Download: ML20205J083 (7)

Text

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PECO NUCLEAR A Unit of PECO Energy nm e. co--

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March 26,1999 Docket No. 50-277 50-278 License No. DPR-44 DPR-56

. U. S. Nuclear Regulatory Commission Attn: Document Control Desk )

Washington, DC 20555

SUBJECT:

Peach Bottom Atomic Power Station, Unit UM53' 23 Request for Enforcement Discretion Conceming an Inoperable Diesel Generator

Dear Sir / Madam:

As discussed with the NRC on March 26,1999. PECO Ene.rgy Company he requests Enforcement Discretion (ED) from the recuirements of Peach Bottom Atomic Power Station (PBAPS), Units 2 and 3 Tec1nical Specifications (TS). l This Enforcement Discretion is being pursued to avoid an unnecessary plant transient l The reque(i.e., a plant shutdown) whicl1 would result from compliance with tI sted relief is non-recurring and of short duration, '

In accordance with the guidance contained in NRC Administrative Letter 95-05, Revision 1, " Revisions to Staff Guidance for implementing NRC Policy on i Noticec of Enforcement Discretion," and Part 9900 of the NRC Inspection Manua'. ie following information is provided:

~1)

The TS or other license conditions that will be violated.

Limiting Condition for Operation 3.8.1.b ("AC Sources - Operating") for the Peach Bottom Atomic Power Station (PBAPS , Units 2 and 3 Technical Specifications requires that four diesel genera) tors be capabl the onsite Class 1 E AC electrical power distribution system while in Modes 1,2, and 3. As discussed in Condition B, with one diesel generator inoperable Required Action 8.5 requires that the diesel generator be restored to operable status within a Completion Time of 14 days from the discovery to meet 3.8.1.b. Otherwise, with this Condition not met within the specified Completion Time, Condition G requires that the Units must be in Mode 3 in 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and Mode 4 within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.

This Enforcement Discretion (ED) requests a one-time. 3 day extension, from Required Action B.5 which requires that the one inoperable diesel generator be restored to an operable status within the Completion Time of 14 days. i 9904090163 990401 L PDR ADOCK 05000277 P PM

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March 26,1999 Page 2 I diesel generator, a 3 day extension is requested i

remaining testing associated with the diesel generator outage cur progress at PBAPS, Units 2 and 3. This extension is necessary in order  !

to avoid an undesirable transient resulting from the shutdown of both Unns.

2)

The circumstances surroundino the situation. includino ao

! causes. the need for oromot action and identification of any relevant historical events.

! No#

! On March 14,1999, at 1AWhours, an outage to perform a 24 month planned to occur over a 7 day period working 2 ,

I actual work was planned to occur over a 5 day work window, with an additional day for testing, and an additional day for unplanned contingencies. As a part of this diesel generator outage, the govemor an

! the Jacket water bypass gaskets were to be replaced. This is the first tim that the gaskets were replaced in the life of the diesel. Previously, a was identified in a gasket in the Jacket water system, in order to preven future Jacket water leaks, it was considered a prudent action to repla the gaskets. This evolution involved the replacement of 48 gaskets. The gaskets were replaced in-kind, which one would expect would be an began on Wednesday, March 17,1999. appropriate, prudent test, a leak was identified in one gasket on Saturday, March This gasket was replaced. During the first diesel run on Sunday. Marc 21,1999, a different gasket failed. At that time it was determined that all 48 gaskets would be replaced utilizing a different installation method. All gaskets were replaced.

During the second test run on Tuesday, March 23,1999 a different

/ gasket failed. All gaskets were replaced again, however, with a different gasket material and sealant. This activity was performed in accordance ith an approved Engineering evaluation.

pp,f The gasket failures were the result of the gaskets slipping out of their connections. The root cause for the failure of the gaskets has been attributed to the gasket material which could not adequately seal the being used,In addition to the new gasket material, a permatex sealant is surfaces.

'q*@ Due to the unanticipated time necessary to correct the gasket failures, an

% additional 3 days is requested in order to complete the remaining diesel consists of govemor tuning, corrgenerator testing associated with hour fast start fullload run test, a'd a fullload reject test..aion of gov L

March 26,1999 Page 3 3)

The safety basis for the reauest. includino an evaluation of_the safety signJtcance and ootential consecuences of the orooosed course of actio

_This evaluation should include at least a cualitative risk ass derived from the licensee's PRA.

V *y in assessing the safety significance of the requested ED, two perspec D. rwere consic'ered. The first perspective was to compa

@ shutdown. In this comparison, pursuing ED is preferred due to the g increased risk associated with placing the Units through a shutdown and s

creating the possibility of a disturbance on the offsite sources due to loss of generation from the PBAPS units.

The second perspective considers the actual safety conse associated with the proposed Completion Time extension.quences These consequences are considered minimai in that the extension in the Completion Time has no impact on the capability of the remaining dies generators and offsite sources to perform their required safety functions.

The level of acceptable risk associated with the E3 diesel generatorin the of 3 days. However, the additional 3 day duration rep calculated risk increase. The increase represents a negligible contribution to the total yearly risk and is considered non-risk significant using the acceptance guidelines for Core Damage Frequency (CDF) and the Large Early Release Frequency (LERF) from Regulatory Guide 1.174.

4)

Ihe basis for the licensee's conclusion that the noncomolianc pf ootential detriment to the oublic health and safety and that no sianificant hn7ard consideration is involved.

The proposed ED will not be of potential detriment to the public health and safety, and does not involve a Significant Hazards Consideration based on the following discussion:

1. The oronosed chanoes do not involve a sionificant increase i probability or consecuences of an accident oreviousiv evaluated because '

the probability of a Loss of Offsite Power LOOP day extension of the Completion Time for(the one) is independent of the 3 diesel generator, and the requested extension does not introduce any failure mechanisms to the previously considered LOOP. The consequences of an accident are independent of the Completion Times Time does not effect the consequence. The increase in the Completion s because the LOOP analysis considers that one diesel generator is out-of-service. The Peach Bottom standby AC power system is designed with sufficient redunJancy such that one diesel generator may be removed from service for testing, inspection, or repairs in the time provided in the current Technical Specifications. The remaining three diesel generators are still capable of carrying sufficient loads to mitigate the coriseguences of an accident and offsite source is fully capable of supplying the pow l o

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• March 26,1999 Page 4 mitigate an accident. Currently, the plant has three fully capable offsite lines (No. 2 startup source, No. 3 startup source, and the 343 startup source capable of supplying the power requirements to mitigate an acciden)t. During the 3 day extension, written dire limit planned on-site and offsite maintenance which would affect the availability of the offsh sources. Therefore, the probability or increased by the additional time requested. consequences of

2. The orooosed chsnoes do not create the possibility of a new or different kind of amident tmm any oreviousiv evaluated because the requested change is extendq a Completion Time, and this in and of itself does not create the possibility cf a new or different kind of accident.

Extending the Completion Time does not introduce any new accident initiator,

3. The oronosed chances do not involve a sianificant reduc 3on in maroin of safety. because the PBAPS, Units 2 and 3 standby AC system is designed with suificient redundancy such that one diesel generator be removed from service for testing, inspection or repairs with the remaining three diesel generators capable of carrying sufficient loads to satisfy the Updated Final Safety Analysis Report requirements for shutdown of both Units.

Written direction on planned maintenance will improve the likelihood that the three offsite lines will be available during the extended diesel outage period. There is no planned maintenance on the Conowingo Tie-Line (SBO)line during the extended Completion Time. Considering this fact, as well as the decrease in likelihood of a LOOP event, a 3 day extension to the Completion Time does not involve a significant reduction in a margin of safety.

5)

The basis for the licensee's conclusion that the noncomoliance wil involve adverse consecuences to the environment.

The proposed Enforcement Discretion will not have any adverse environmental impact since the Enforcement Discretion will not result in any increase in the amount or result in any change in the type of effluent which may be released offsite. The remaining diesel generators and offsite power sources will continue to peiform their intended safety functions and ensure safe plant shutdown if necessary.

6) Any orooosed compensatorv measure (st hg . As required by plant Technical Specifications (Required Action B.1), with 8 one diesel generator inoperable, verification is performed to ensure d' correct breaker alignment, required equipment available, and indicated power is available for the Conowingo Tie-Une. This verification is performed every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. Currently, the plant has three fully capable offsite lines (No. 2 startup source, No. 3 startup source, and the 343 l 1

M:rch 26,1999 Page 5 i 1

startup an source) accident. Durin capable of supplying the power requirements to m to limit planned on g the 3 day extension, written direction will oe in place availability of the offsite lines. site and offsite maintenance which would

- 7)

The iustification for the duration of the r:oncomoliance.

@ As a result of gasket failures which occurred during the testing of the E diesel generator, a 3 day extension P requested to complete the dp.remaining testing associated with a diesel generator ou 3rogress at PBAPS, Units 2 and 3. This extension is necessary in order

& "o avoid an undesirable transient resulting from the shutdown of both Units.

8)

A statement that the reauest has bp_en sooroved bv the facility l oraanization that normally reviews safety issues (Plant Onsite Review p,_ommittee. or its eouivalentt The Plant Operations Review Committee has approved this request fo Enforcement Discretion.

9)

The reauest must specifically address which of the NOED criteria for acorooriate olant conditions specified in Section B is satisfied and how it is soecified. {

i The plant conditions associated with this request satisfy Part 9900 Criterion B.1

'a), " avoid uMesirable transients as a result of forcing compliancidith the license condition and, thus, minimizing potential safety consequences and operating risks," in that this request avoids a shutdown of both Units.

Limiting Condition for Operation 3.8.1.b requires that four diesel generators be capable of supplying the onsite Class 1E AC electrical power distribution system while in Modes 1,2, arid 3. As discussed in Condition B, with one diesel generator inoperable, Required Action B.5 requires that the diesel generator be restored to operable status within a Completion Time of 14 days from the discovery to meet 3.8.1.b.

Otherwise, with this Condition not met within the specified Completion Time, Condition G requires that the Units must be in Mode 3 in 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> '

and Mode 4 within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. As discussed previously, pursuing ED is preferred due to the increased risk associated with placing the Units through a shutdown and creating the possibility of a disturbance on the offsite sourcas due to loss of generation from the PBAPS units.

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, March 26,1999 Page 6 10)

If a follow-uo license amendment is reouired the NOED reauest m include marked-uo TS oaoes showino the orooosed TS chances commitment hours. to submit the actual license amendment reauest within 4)

I This request is for a 3 day extension in the Completion Time, in Accordance with the guidance of Part 9900 of the NRC Inspection Manual, no license amendment is necessary, 11)

For NOEDs involvino severe weather or other natural events. the licentec's reauest must be sufficientiv deta!!ed for the staff to evalu likelihood that the event could affect the olant. the capability of the unimate heat sink. on-site and off-site emeroency orecaredness status.

access to and from the olant, acceptability of any increased radiolooical risk to the oublic and the overall oublic benefit.

This naturalEnforcement events. Discretion does not involve severe weather or oth I

Ve ruly yours,

,,[ h h  ?

D Edwards Director- Licensing ce; H. J. Miller, Administrator, Region 1. USNRC I

A. C. McMurtray, USNRC Senior Resident inspector, PBAPS i

03/26/99 FRI 14:40 FAI 610 640 6773 DIR. LICENSING 001 PECO Nuclear Memorandum i

l FACSIMILE TRANSMITTAL SHEET DATE: M 9h TOTAL No. OF PAGES:

TO: ,

.bdb FAX: b /O- 3 37-83 Y h l

FROM: D, hh PHONE:

FAX: 610-640-6773 l

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@ i Any questions with the transmittal of this fax please contact (610) 640. C176

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