ML20209D852

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Responds to Util 990706 Request That NRC Exercise Discretion Not to Enforce Compliance with Actions Required by TS 3.7.2, Auxiliary Electrical Sys. NOED Warranted & Approval Granted for Extension of Allowed Outage Time to 14 Days
ML20209D852
Person / Time
Site: Arkansas Nuclear 
Issue date: 07/07/1999
From: Merschoff E
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To: Hutchinson C
ENTERGY OPERATIONS, INC.
References
NUDOCS 9907140054
Download: ML20209D852 (5)


Text

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/ "49 UNITED STATES y

t NUCLEAR REGULATORY COMMISSION f

REGloN IV 1

l 611 RYAN PLAZA DRIVE, sulTE 400 ARLINGTON, TEXAS 760118064 y,,,

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l JUL - 7 1999 I

C. Randy Hutchinson, Vice President l

Operations l

Arkansas Nuclear One l

Entergy Operations, Inc.

1448 S.R. 333 Russellville, Arkansas 72801-0967

SUBJECT:

NOUCE OF ENFORCEMENT DISCRETION FOR ENTERGY OPERATIONS I

REGARDING ARKANSAS NUCLEAR ONE, UNIT 1, NOED NO 99-4-001

Dear Mr. Hutchinson:

By letter dated July 6,1999, Mr. J. Vandergrift of your office requested that the NRC exercise discretion not to enforce compliance with the actions required by Technical Specification j

(TS) 3.7.2, " Auxiliary Electrical Systems." Specifically, your staff requested approval of an extension of the allowed outage time spectiied in TS 3.7.2.C from 7 days to 14 days to compte's repair and testing of Ernergency Diesel Generttor (EDG) 2. Your staff's request for a Notice of Enforcement Discretion (NOED) was rc@wed by the NRC staff, in accordance with the NRC's policy regarding exercise of discretion for an operating facility, set out in Section Vll.c, of the " General Statement of Polby and Procedures for NRC Enforcement Actions," NUREG-1600.

Your July 6,1999, letter documented information discussed with the NRC in a telephone conversation cn July 5,1999. Participants in this phone call included Ellis Merschoff, Regional Administrotor, Region IV, and members of his staff; Stuart Richards, Director, Project Directorate IV, Division of Licensing Project Management, Office of Nuclear Reactor Regulation (NRR), and members of the URR staff; Craig Anderson, General Manager Plant Operations, Arkansas Nuclear One, and members of his staff. During that telephone conversation,it was stated that EDG 2 was removed from service at 10:37 p.m. (CDT) on June 28,1999, to perform previously scheduled maintenance activities. Following the July 1 postmaintenance testing conducted after the completion of these maintenance activities, a significant degradation in lubricating oil pressure was identified. Dadng subsequent inspection of the EDG, failed components associated with an engine idler gear were identified. It was stated that the failure i

of these components resulted in the observed degradation in lubricating oil pressure. Your staff i

determined that repairs to EDG 2 could not be completed within the 7-day allowed outage time provided in TS 3.7.2.0 and, therefore, you requested an extension to the allowed outage time i

of 7 days to facilitate completing the repfr and testing of EDG 2. Without an extension, the 7-day allowed outage time would expire at 10:37 p.m. (CDT) on July 5,1999, and a plant shutdown would be required.

The safety basis for the request for enforcement discretion was that increasing the allowed

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outage tin'e for EDG 2 for an additional 7 days resulted in a minimal increase in core damage frequency. The request also stated that shutting the plant down to repair the EDG would result in an increase in expected risk that would be greater than that of the 7-day extension of power operation. Compensatory measures proposed by your staff for the duration of the NOED and l

9907140054 990707 PDR ADOCK 05000313 i

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- Entergy Operations, Inc. considered in the NRC staff's evaluation included: (1) verifying the availability of off-site power i

sources and the alternate ac diesel generator once per shift, (2) prohibiting discretionary maintenance in the switchyard, (3) contacting the system dispatcher once per shift to communicate the status of the EDG and the power needs of the plant, (4) dispatching an operator to the alternate ac diesel generator for local operation in the event that a tornado or thunderstorm warning is issued for the local area, (5) posting and controlling the alternate ac -

diesel generator, the operable EDG, Startup Transformers 1 and 2, and the steam-driven emergency feedwater pump as " Protected Equipment," (6) on-shift operations crews discussing and reviewing appropriate normal and emergency operating procedures upon, or prior to, assuming watch for the first time while the enforcement discretion is in effect and following any period of scheduled days off, (7) briefing Unit 2 operations personnel on the Unit 1 EDG activities, including the compensatory measures and the importance of promptly starting and aligning the alternate ac diesel generator if needed, and (8) suspending maintenance and testing that affects reliability of the Unit 1 train associated with the operable EDG during the requested extension period.-

I

On the basis of the NRC staff's evaluation of your request, including the compensatory 1

measures described above, the NRC staff has concluded that an NOED is warranted because we are clearly satisfied that this action involves minimal or no safety impact and has no adverse radiological impact on public health and safety. Additionally, we determined that the request satisfied the NRC's policy for enforcement discretion. Therefore, it is our intention to exercise discretion not to enforce compliance with Technical Specification 3.7.2 by granting approval of an extension of the allowed outage time specified in TS 3.7.2.C from 7 days to 14 days to

. complete repair and testing of EDG 2.

This letter documents our telephone conversation on July 5,1999, at 9:50 a.m. (CDT) when we

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orally issued this NOED. This enforcement discretion expires at 10:37 p.m. (CDT) on July 12, 1999, or upon returning EDG 2 to an operable status, whichever occurs first. Your staff stated'

' that following completion of repairs to EDG 2, during postmaintenance testing of the EDG, a stable tubricating oil pressure of greater than 60 psi would be considered an indication that the repairs were effective and that the engine is fully operable, if you discover during this period that the cause of the EDG failure has not been corrected and additional troubleshooting is required to determine the cause, you will immediately inform the NRC. Should this occur, the NRC will reevaluate the appropriateness of the enforcement discretion.

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 NOED was necessary. This determination will be made during the planned NRC inspection.

Sincerely,

/

Ellis W. Merse f

Regional Administrator Docket No.: 50-313

- License No.: DPR l

Entergy Operations, Inc. cc:

' Executive Vice President

& Chief Operating Officer Entergy Operations, Inc.

- P.O. Box 31995

. Jackson, Mississippi 39286-1995 Vice President Operations Support Entergy Operations, Inc.

P.O. Box 31995 Jackson, Mississippi 39286 Manager, Washington Nuclear Operations ABB Combustion Engineering Nuclear Power 12300 Twinbrook Parkway, Suite 330

' Rockvitte, Maryland 20852 County Judge of Pope County Pope County Courthouse Russellville, Arkansas 72801 Winston & Strawn 1400 L Street, N.W.

Washington, D.C. 20005-3502 David D. Snellings, Jr., Director Division of Radiation Control and

- Emergency Management Arkansas Department of Health

- 4815 West Markham Street, Mail Slot 30 Little Rock, Arkansas 72205-3867

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Manager Rockville Nuclear Licensing s

- Framatome Technologies 1700 Rockville Pike, Suite 525 Rockville, Maryland 20852

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