ML20216B132

Application for Amend to License NPF-89,requesting Enforcement Discretion to Allow Plant to Continue to Operate W/O Having Performed Portions of Listed SRs

ML20216B132
Person / Time
Site:	Comanche Peak
Issue date:	04/06/1998
From:	Terry C, Walker R TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20216B138	List: ML20216B132 ML20216B147
References
RTR-NUREG-1600 TXX-98100, NUDOCS 9804130377
Download: ML20216B132 (24)

Text

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Log # TXX 98100 File # 10010 1UELECT IC' Roger D. Walker Apri1 6, 1998 Regulawry Afaars Manager U. S Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555

SUBJECT:

COMANCHE PEAK STEAM ELECTRIC STATION (CPSES) - UNIT 2 DOCKET NUMBER 50 446 ENFORCEMENT DISCRETION FOR A.C. SOURCES, OPERATING REF: 1. NUREG 1600 " General Statement of Policy and Procedures for NRC Enforcement Actions," dated June 1995

2. NRC Inspection Manual, Part 9900, " Operations -

Enforcement Discretion," dated November 2, 1995

3. TU Electric letter, logged TXX 98091, from C. L. Terry to the NRC dated March 24, 1998 l

l l 4. TU Electric letter, logged TXX 98095, from C. L. Terry

! to the NRC dated March 26, 1998 In reference 3 and as supplemented in reference 4. Texas Utilities Electric Company (TV Electric) requested enforcement discretion. In accordance with the guidance provided by reference 1. TV Electric requested that the Nuclear Regulatory Commission (NRC) exercise enforcement discretion to allow CPSES Unit 2 to continue to operate without having performed portions of Surveillance Requirements (SRs) 4.8.1.1.2f.4)a) . 4.8.1.1.2f.4)b), 4.8.1.1.2f.6)a), 4.8.1.1.2f.6)b) and 4.8.1.1.2f.6)c). TV Electric requested that the NRC exercise discretion to not enforce the applicable Technical Specification (TS) ACTION g requirements for an additional 14 days beyond the allowable 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period )

already allowed per SR 4.0.3 for the missed surveillances. In a \

l conference call between the NRC staff and TV Electric on March 25, 1998, at 2:25 p.m. CST, the NRC granted regional enforcement discretion as requested. ,

During'the additional 14 days allowed by the enforcement discretion. TV Electric's intent, as stated in reference 3, was to " assess which devices have not been fully tested. Identification of each device requires a ,

thorough engineering review and analyses of the ability to safely test a those devices which have not previously been tested. Further analyses of the detailed function and safety significance of each device which cannot l

9804130377 980406 PDR ADOCK 05000446 P PDR P. O. Box 1002 Glen Rose, Texas 76043 4

TXX 98100 Page 2 of 18 be tested in the current plant configuration is also needed. By the end of the requested time. TU Electric will have determined the subsequent corrective actions that are necessary." TO Electric has completed the above mentioned review and analyses. TU Electric has determined that the safest course of action is to request NRR enforcement discretion to allow noncompliance with the applicable action statements for which a license amendment will be processed to make a temporary change to the CPSES Technical Spwifications for Unit 2.

In accordance with the guidance provided by reference 1. TV Electric requests that the Nuclear Regulatory Commission (NRC) exercise enforcement discretion to allow CPSES Unit 2 to continue to operate without having performed portions of the SRs. Without the requested enforcement discretion, compliance with CPSES LC0 (Limiting Condition for Operation)  !

3.8.1.1 will require that CPSES Unit 2 shutdown for performance of the l SRs, and proceed to Mode 5 per the ACTION REQUIREMENTS. l I

The referenced section of the NRC Inspection Manual (reference 2) provides j guidance on the information to be included in a request for enforcement discretion. The sections below are arranged to correspond to that  !

guidance. j

1. REQUIREMENT / REQUEST:

SR 4.8.1.1.2f requires, in part, that certain A.C. electrical sources be demonstrated OPERABLE by performir.g the SR at least once per 18 months.

Failure to perform the surveillance within the 18 month frequency plus extensions allowed per SR 4.0.2, results in failure to perform a SR. In accordance with SR 4.0.3, this failure to perform the SR constitutes a noncompliance with the OPERABILITY requirements for the LCO.

! With resnect to SRs 4.8.1.1.2f.4 and 4.8.1.1.2f.6. TU Electric identified in reference 3, portions of these surveillances which may not have been previously demonstrated as acceptable. These portions " include (a) certain sequencer generated operator and automatic lockouts which ensure non-1E equipment separates from the A.C. busses, actuate equipment and preclude equipment from attempting to load inappropriately onto the vital A.C. busses: (b) unambiguous confirmation that diesel generator trips are bypassed on an emergency start due to multiple contacts ir; aries: (c)

! verificaticas that motor control center (HCC) load seal-in contacts open j upon bus deenergization thereby ensuring that equipment that was previously operating does nct attempt to reload inappropriately onto the bus and (d) 480 V undervoltage relays load shed the emergency fill fire pump."

TU Electric has completed the review and analyses of these identified testing omissions. The analyses results are presented in Attachments 1, 2, 3. 4 and 5. Those devices listed in Attachments 1, 2 and 3 have been identified as requiring surveillance testing which has not yet been accomplished. As shown in Attachments 1, 2 and 3, some of the testing may be acceptably performed during MODE 1 operation, while other testing

TXX 98100

- Page 3 of 18 should not be performed until the plant is in a shutdown condition. It is not currently anticipated that any of the testing omissions for CPSES Unit 2 will be resolved prior to the expiration of the existing N0ED on April 8, 1998, at 2:35 p.m. CST (3:35 p.m. CDST). At such time, SR 4.0.3 will require that the associated diesel generators be declared inoperable and immediate compliance with the appropriate ACTION statementr be exercised.

TU Electric requests that the NRC exercise enforcement discretion to not  ;

enforce LC0 3.8.1.1 ACTION statements for CPSES Unit 2. Specifically, LC0 3.8.1.1 ACTIONS b, c, d and f apply. TU Electric's review of the affected circuits has not revealed a method of testing some of these circuits during H0DE 1, POWER OPERATION, without exposing Unit 2 to what TU Electric feels is undue risk.and the remaining portions cannot reasonably be completed prior to the expiration of the enforcement discretion granted on March 25, 1998. As such, CPSES desires enforcement discretion not to enforce compliance with the aforementioned ACTION statements with respect to the inoperabilities generated directly from non performance of the prescribed surveillances. This request does not encompass the inoperability of the diesel generators for any reason other than the identified testing omissions.

2. CIRCUMSTANCES:

During the process of conducting reviews in accordance with U.S. NRC Generic Letter 96 01, CPSES discovered that certain lockouts, various seal-in contacts, diesel generator trip bypass circuits and the l undervoltage shedding feature of the emergency fill fire pump were not l

verified to perform thc" required functions or were not unambiguously l verified under the current testing methodology. Therefore, complete  !

testing in accordance with SR 4.8.1.1.2f has not been performed, as identified in Attachments 1, 2 and 3. CPSES anticipates that the outcome of the surveillance testing will be confirmation of OPERABILITY as there j is no known reason to suspect that problems with the circuitry exist.

l These omissions in the surveillance program at CPSES have been present since the time of initial license and were identified on March 24, 1998, at 2:35 p.m. CST. As the omissions constitute a failure to perform a SR within the surveillance frequencu plus allowable extension in accordance l with SR 4.0.2 and performance of the SRs within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> (from March 24, l 1998, at 2:35 p.m. CST) was not achievable, enforcement discretion was requested per reference 3 and granted by the NRC on March P.5, 1998, at 2:25 p.m. CST. This enforcement discretion expires on April 8, 1998, at 2:35 p.m. CST (3:35 p.m. CDST). Upon expiration of the enforcement '

discretion, CPSES Unit 2 will be required to immediately invoke the ACTIONS of LC0 3.8.1.1. LCO 3.8.1.1 ACTION f would be the most time liaiting. ACTION f states in part, "With two of the above required diesel generators inoperable. . . . restore at least one of the inoperable diesel generators to OPERABLE status within 2 hour:; or be in at least HOT STANDBY

! within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 p hours." In addition, once in Mode 5, LC0 3.8.1.2, ACTION a will require that, in part, the reactor coolant system (RCS) be depressurized and vented. This will result in an inadequate crud burst cleanup, the

TXX 98100 Page 4 of 18 stopping of all reactor coolant pumps, the taking of the RCS solid for a period of time, and the rapid cooling down of the pressurizer: all within the time constraints of the technical specifications.

TU Electric is nearing completion of the reviews required to comply with the actions identified in Generic Letter 96 01. This enforcement discretion request and the associated license amendment request will complete the currently identified corrective actions for CPSES with the exception of the testing which will be performed at power and the testing deferred until the next outage of sufficient dt;ation. Appropriate correspondence in accordance with Generic Letter 96 01, will be forthcoming upon completion. A determination of root cause for the events which necessitated this enforcement discretion will be evaluated and reported as required in the ensuing Licensee Event Report required per 10CFR50.73.

3. SAFETY SIGNIFICANCE AND POTENTIAL CONSEQUENCES:

The safety basis for this request is commensurate with the safety functions and significance of the components that have not been tested per the relevant SR. The safety functions and significance of those components varies as denoted in Attachments 1. 2, and 3. As such, the following discussion is broken down by the classifications and categories depicted within Attachments 1, 2 and 3. Those components listed in Attachments 4 and 5 do not require discretion as noted by the Category 1 designation.

The conditions discussed individually below have all existed since initial issuance of a CPSES Unit 2 operatiag license. When a surveillance is identified which has not been performed within the prescribed time period, the Technical Specifications allow the ACTION requirements to be delayed up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> (provided the allowed outage time for the ACTION requirements is less than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />) for the performance of the surveillance in accordance with Surveillance Requirement 4.0.3. In NUREG-1431, this allowance is contained within SR 3.0.3. As stated in the BASES to SR 3.0.3 of NUREG 1431 Rev. 1 "the basis for this delay period includes consideration of unit conditions, adequate planning, availability of personnel, the time required to perform the Surveillance, the safety significance of the delay in completing the required Surveillance, and the recognition that the most probable result of any particular Surveillance being performed is the verification of conformance with the requirements."

Consistent with this position TV Electric believes that performance of the SR will most probably demonstrate OPERABILITY. In addition to this general position concerning all of the testing omissions, case specific

, discussions are presented.

a) Attachment 1 lists automatic lockouts and some operator lockouts I (Items 2, 3, 4, 6 and 6) which block undesired automatic actions, which stop and start equipment, which actuate auxiliary relays, and which require testing. TV Electric's review of these lockouts has t

V l .

l TXX 98100 Page 5 of 18 not revealed a method of testing these lockouts in totality during l MODE 1. POWER OPERATION. without exposing Unit 2 to what TU Electric i feels is undue risk. TU Electric intends to demonstrate the

functionality of the relays which actuate these contacts prior to I

the completion of the current enforcement discretion. Functional verification that all relay contacts have repositioned will not be

! demonstrated by this date, however each relay will have been shown l to have actuated by a positive verification methodology. TU l Electric is confident that the relays can be safely tested but, due to the setup required to actuate, monitor, and verify the individual contacts, TV Electric is not prepared to say that the contact testing can be done safely at power. In addition, contacts involved with Train A common busses are listed on Attachment 1 (Item 7).

These busses have loads which are affected by auxiliary lockout -

relays scoped with Unit 1 Train A. The Unit 2 relays that affect these busses are category 2 and are included in items 2, 3, 4, and

5. The Unit 1 auxiliary relays will be tested during 1RF06 (and are therefore noted as category 5).

The safety functions of the lockouts are listed in Attachment 1 by groupings. These contacts are relied upon to ensure that perturbations in the diesel generator starting and loading sequence are avoided. Failure of the lockouts which block the auto start of l

equipment would allow loads to attach inaparopriately to the A.C.

bus potentially rendering the bus unavaila)1e as the power source for the necessary equipment to support reaching and/or maintaining l

safe shutdown following an event. Failure of the lockouts which start and/or stop equipment could result in equipment not being available as assumed in an accident analysis or could result in excessive load on the DG at some point in its loading sequence.

TU Electric believes that the operability of these lockout contacts will be confirmed when the contacts are tested. The basec. for this belief (in addition to that presented ga:arically in the bases for LCO 3.0.3) are as follows:

l 1. The lockout relays are identical to the load block relays which

have been routinely tested over the life of CPSES units 1 and 2.

During the course of over 8 years of operation and testing, none of these relays have failed to perform their function.

i l- 2. The CPSES Unit 1 Train B lockout relays and contacts. which are 1 l essentially identical to the lockout relays on Unit 2, have been l tested during the current Unit I refueling outage. As expected,

! no failures were identified and surveillance testing served as confirmation of OPERABILITY.

Testing of the Unit 1 Train A lockout relays and contacts is scheduled to be completed by April 17, 1998, as part of the ongoing Unit I refueling outage.

3. Prior to the expiration of the current enforcement discretion,

TXX 98100 Page 6 of 18 each lockout relay will be demonstrated to actuate by positive verification.

4. Pre operational testing in 1992 verified that the relays and contacts of concern operated as designed.' Therefore, if the relay actuates when tested per 3 above reasonable assurance exists that the contacts will reposition correctly.

5. The sequencer relay coils are continuously monitored on-line for continuity. If continuity were lost. the sequencer trouble alarm would alert the operators to take action.

6. The diesel generator has repeatedly demonstrated the capability to start and load satisfactorily without problems introduced by malfunctions of either the relays or their associated contacts.

These previous tests add additional evidence that the i confirmatian of OPERABILITY is highly probable. Although this I testing has not provided unambiguous confirmation that the I contacts currently perform their required functions it is most

!. likely that the circuits have responded appropriately during the previous integrated tests.

The course of action proposed by TV Electric is that the NRC

! exercise enforcement discretion to allow CPSES Unit 2 to continue to

! operate while a temporary technical specification change is processed. The change would in turn allow the unit to continue to operate until an outage of sufficient duration to perform the surveillance testing required. The potential safe';y consequences resulting from a shutdown of Unit 2 (as would be required if the requested enforcement discretion is not granted). thereby resulting in both of CPSES units being in a shutdown condition, are clearly higher than allowing Unit 2 to continue to operate without these lockout contacts (for which there is a high level of confidence that they will function as designed) being unambiguously tested.

Because the Unit 1 lockout contacts on the Train A common busses will be tested as part of 1RF06 the technical specification change will not need to include these Unit 1 contacts.

b) Attachment 1 lists lockouts (Items 1 and 3) which block undesired manual actions and which require testing. TU Electric's review of these lockouts has not revealed a method of testing these lockouts in totality during MODE 1. POWER OPERATION. without exposing Unit 2 to what TU Electric feels is undue risk. TV Electric intends to demonstrate the functionality of the relays which actuate these contacts prior to.the completion of the current enforcement discretion. Functional verification that all relay contacts have repositioned will not be demonstrated by this date, however each relay will-have been shown to have actuated by a positive verification methodology. TU Electric is confident that the relays can be safely tested but, due to the setup required to actuate.

monitor, and verify the individual contacts. is not prepared to say that the contact testing can be done safely at powec. In addition.

TXX 98100 Page 7 of 18 some Train A common busses are listed on Attachment 1 (Item 7).

These busses have loads which are affected by lockout relays from Unit 1 Train A. The Unit 2 relays that affect these busses are category 2 and are included in items 1, 2 and 5. The Unit I relay will be tested during 1RF06 (and are therefore noted as category 5).

The safety functions of the lockouts are listed in Attachment 1 by groupings. These contacts are relied upon to ensure that perturbations in the diesel generator starting and loading sequence by operator action are avoided. Failure of the lockouts would allow loads to be attached inappropriately to the A.C. bus potentially rendering the bus unavailable as the power source for the necessary equipment to support reaching and/or maintaining safe shutdown following an event.

1 TU Electric believes that the operability of these lockout contacts will be confirmed when the contacts are tested. The bases for this i belief (in addition to that presented generically in the bases for i LCO 3.0.3) are as follows:

1. The lockout relays are identical to the load block relays which have been routinely tested over the life of CPSES units 1 and 2.

During the course of over 8 years of operation and testing, none of these relays have failed to perform their function.

2. The CPSES Unit 1 Train B lockout relays and contacts, which are essentially identical to the lockout relays on Unit 2, have been tested during the current Unit 1' refueling outage. As expected, no failures were identified and surveillance testing served as confirmation of OPERABILITY.

Testing of the Unit 1 Train A lockout relays and contacts is scheduled to be completed by April 17, 1998, as part of the ongoing Unit I refueling outage.

3. Prior to the expiration of the current enforcement discretion, each lockout relay will be demonstrated to actuate by positive  ;

verification.

4. Pre operational testing in 1992 verified that the relays and contacts of concern operated as designed when tested per 3 above.

Therefore, if the relay actuates, reasonable assurance exists that the contacts reposition will correctly.

5. The sequencer relay coils are continuously monitored on line for continuity. If continuity were lost, the sequencer trouble alarm would alert the operators to take action.

6. The diesel generator has repeatedly demonstrated the capability to start and load satisfactorily without problems introduced by malfunctions of either the relays or their associated contacts.

These previous tests add additional evidence that the

TXX 98100 Page 8 of 18 confirmation of OPERABILITY is highly probable. Although this testing has not provided unambiguous confirmation that the contacts currently perform their required functions, it is most likely that the circuits have responded appropriately during the previous integrated tests.

7. .The manual actions which these lockout contacts are designed to block are very unlikely to occur. The period of time in which the. blocks are needed is very short (110 seconds or less). Both the operating procedures and operator training include aspects which decrease tte chances that the undesirable manual actions would ever occur (See section 6 on compensatory actions for a more in depth c hcussion).

The course of action proposed by TU Electric is that the NRC exercise enforcement discretion to allow CPSES Unit 2 to continue to operate while a temporary technical _ specification change is processed. The change would in turn allow the unit to continue to operate until an outage of sufficient duration to perform the surveillance testing required. The potential safety consequences resulting from a shutdown of Unit 2 (as would be required if the requested enforcement discretion is not granted), thereby resulting f in both of CPSES units being in a shutdown condition, are clearly i higher than allowing Unit 2 to continue to operate without these l lockout contacts (for which there is a high level of confidence that they will function as designed) being tested. In addition, the compensatory measures, as listed in Section 6 of this letter, directly address these lockouts. Because the Unit 1 lockcut contacts on the Train A common busses will be tested as part of IRF06, the technical specification change will not need to include these Unit 1 contacts.

c) Attachment 2 (Items 1 and 2) lists those seal-in contacts on CPSES Unit 2 that perform a load shed function as described within the FSAR which have not previously been unamt,iguously tested. Those contacts listed in Attachment 2, may be tested during H0DE 1. POWER OPERATION, and are noted as Category 2. For this category, the purpose of the enforcement discretion is to allow the continued operation of Unit 2 while TU Electric performs at power testing to demonstrate the functionality of the contacts and while a technical specification change is processed to allow the crediting of at power l testing for the "during shutdown" SRs. The at power testing is i scheduled to be completed by April 16, 1998. Also included on Attachment 3 are the seal in contacts for the Train A common busses.

These contacts are category 5 for these common busses and may be transferred to Unit 1 and tested during shutdown as part of the ,

ongoing refueling outage for Unit 1 (1RF06). )

The safety function of the seal in contacts is to ensure that the indicated equipment does not inappropriately load onto the A.C. bus powered by an operating diesel gr.crator These contacts are relied upon to ensure that the unnecessary equip.7ent loads do not cause '

TXX 98100

- Page 9 of 18 perturbations in the diesel generator starting and loading sequence.

Failure of the seal in contacts in such a manner as to allow the loads to attach inappropriately to the bus could render the A.C. bus unavailable as the power source for the necessary equipment to support reaching and/or maintaining safe shutdown following an event. However, these loads are relatively small in comparison to the allowable diesel generator loading. Therefore, based on a qualitative assessment, a combination of failures would be necessary to render the diesel generator incapable of performing its function.

The diesel generator has repeatedly demonstrated the capability to q start and load satisfactorily. These previous tests add additional evidence that confirmation of OPERABILITY is probable. Although this testing has not provided unambiguous confirmation that the contacts currently perform their required functions, it is most likely that the contacts have responded appropriately during the previous integrated tests. For the seal in contects, the relays are operated periodically in normal operation and/or surveillance testing and the functionality of only one or more contacts may not have been verified. As such, the current plant configuration is acceptable for continued operation until such time as the SR can be completed for these contacts.

TU Electric is requesting additional time to perform these tests based on a qualitative assessment that the potential consequences of l invoking the ACTION statements exceeds the potential consequences of l continuing in the present configuration for additional time in order to confirm OPERABILITY. TV Electric believes that the crediting of these segments of the integrative tests are both acceptable and noropriate during POWER OPERATIONS.

The course of action proposed by TU Electric is that the NRC exercise enforcement discretion to allow CPSES Unit 2 to continue to operate while a temporary technical specification change is processed. The change would in turn allow the unit to continue to operate (contingent upon completion of at power testing that demonstrates the functionality of the associated contacts) by crediting the at power test to satisfy '.he during shutdown i

surveillance requirements. The potential safety consequences resulting from a shutdown of Unit 2 (as would be required if the requested enforcement discretion is not granted), thereby resulting in both of CPSES units being in a shutdown condition, are clearly higher than allowing Unit 2 to continue to operate without these seal-in contacts (for which there is a high level of confidence that they will function as designed) being unambiguously tested for a short period of time and then crediting at power tests to demonstrate operability. Because the seal in contacts on the Train A common busses will be tested as part of 1RF06, the technical specification change will not need to include these contacts.

d) Attachment 2 (Item 3) lists the contacts on CPSES Unit 2 that .

perform a load shed function for the instrument air compressors. l 1

l i

1

l TXX-98100 Page 10 of 18 These contacts may be tested during MODE 1. POWER OPERATION, and are noted as Category 2. For this category, the purpose of the enforcement discretion is to allow the continued operation of Unit 2 while TU Electric performs at power testing to demonstrate the  !

functionality of the contact and while a technical specification change is processed to allow the crediting of at power testing for the "during shutdown" SRs. The at power testing is scheduled to be j completed by April 16, 1998. '

The safety function of the contacts is to ensure the instrument air compressors are load shed from the A.C. bus prior to being powered by an operating diesel generator. These contacts are relied upon to ensure that the instrument air compressor loads do not cause perturbations in the diesel generator starting and loading sequences. Failure of a contact in such a manner as to allow the load to attach inappropriately to the bus could render the A.C. bus unavailable as the power source for the necessary equipment to support reaching and/or maintaining safe shutdown following an event. However, this single load is relatively small in comparison to the allowable diesel generator leading. Therefore, based on a qualitative assessment, a combination of failures would be necessary to render the diesel generator incapable of performing its function.

The diesel generator has repeatedly demonstrated the capability to start and load satisfactorily. These previous tests add additional evidence that confirmation of OPERABILITY is probable. Although this testing has not provided unambiguous confirmation that the contacts currently perform their required functions, it is most likely that the contacts have responded appropriately during the previous integrated tests. As such, the current plant configuration is acceptable for continued operation until such time as the SR can be completed for this contact.

TV Electric is requesting additional time to perform these tests ,

based on a qualitative assessment that the potential consequences of '

invoking the ACTION statetents exceeds the potential consequences of continuing in the present configuration for additional time in order l to confirm OPERABILITY. TV Electric believes that the crediting of I

these segments of the integrative tests are both acceptable and ,

appropriate during POWER OPERATIONS. l l

The course of action proposed by TV Electric is that the NRC  !

exercise enforcement discretion to allow CPSES Unit 2 to continue to i operate while a temporary technical specification change is l processed. The change would in turn allow the unit to continue to '

operate (contingent upon completion of at power testing that demonstrates the functionality of the associated contact) by crediting the at power test to satisfy the during shutdown surveillance requirements. The potential safety consequences resulting from a shutdown of Unit 2 (as would be required if the requested enforcement discretion is not granted), thereby resulting in both of CPSES units being in a shutdown condition, are clearly j

TXX 98100 Page 11 of 18 higher than allowing Unit 2 to continue to operate without these seal in contacts (for which there is a high level of confidence that they will function as designed) being unambiguously tested for a short period of time and then crediting the at power test to demonstrate operability.

e) Attachment 3 list contacts on CPSES Unit 2 that perform the function of ensuring that non emergency diesel generator trips do not result in the trip of a diesel generator operating in the emergency mode.

These contacts may be tested during MODE 1 POWER OPERATION, and are noted as Category 2. For this category, the purpose of the enforcement discretion is to allow the continued operation of Unit 2 while TV Electric performs at power testing to demonstrate the functionality of the contacts and while a technical specification change is processed to allow the crediting of at power testing for the "during shutdown" SRs. The at power testing is scheduled to be completed by April 16, 1998.

The safety function of the contacts is to ensure that the engine overspeed and generator differential are the only diesel generator ,

faults that would actually result in the tripping of a diesel generator during an emergency start. Failure of these contacts could result in the diesel generator tripping on a non-emergency diesel generator trip signal if such a signal was present coincident i with the failure.

Under the worst case scenario of these contacts, the diesel generator would trip from a valid non emergency trip signal. The Emergency Response Guidelines currently provide onerator recovery instructions for this scenario.

TU Electric is requesting additional time to perform these tests based on a qualitative assessment that the potential consequences of ,

invoking the ACTION statements exceeds the potential consequences of '

continuing in the present configuration for additional time in order to confirm OPERABILITY. TV Electric believes that the crediting of these segments of the integrative tests are both acceptable and appropriate during POWER OPERATIONS.

The course of action proposed by TU Electric is that the NRC exercise enforcement discretion to allow CPSES Unit 2 to continue to operate while a temporary technical specification change is processed. The change would in turn allow the unit to continue to operate (contingent upon completion of at power testing that demonstrates the functionality of the associated contacts) by crediting the at power test to satisfy the during shutdown surveillance requirements. The potential safety consequences resulting from a shutdown of Unit 2 (as would be required if the requested enforcement discretion is not granted), thereby resulting in both of CPSES units being in a shutdown condition, are clearly higher than allowing Unit 2 to continue to operate without these bypass contacts (for which there is a high level of confidence that

TXX 98100 Page 12 of 18 they will function as designed) being unambiguously tested for a short period of time and then crediting at power tests to demonstrate operability.

A plant specific evaluation was performed to estimate the potential impact of the deferral of Unit 2 TS requirement testing on overall plant risk.

This evaluation was done using the CPSES IPE model. The result of this evaluation demonstrates that the total core damage frequency (CDF) could increase by less than 2 percentage should these tests be deferred to the next Unit 2 refueling outage. This increase is considered to be insignificant. In addition, the industry guidelines consider an increase in CDF up to 13% to be quite acceptable for a temporary plant change / plant alteration.

The PRA evaluation takes credit for the operator action to manually remove non essential loads from the diesel generators following a loss of off- ,

site power initiating event should any of the relay contacts fail to load i shed as required. A list of the loads that can be shed has been provided to the operators by a shift order. Furthermore, this evaluation conservatively assumes that any failure of any single relay contact to function will result in the failure of the associated diesel generator to start and run due to potential overloading of diesels. In reality, single failures that result in a 480 volt load inappropriately loaded on the DG are not expected to have any adverse impact. 1 Although not part of the request for enforcement discretion, the course of action planned by TU Electric includes some at power testing to verify the l functionality of some of the relays and contacts listed and discussed '

above. The operating and testing procedures that will be used to perform this at power testing are designed to minimize any adverse impact on safety. As part of the procedure development, the procedure writers and reviewers consider the conditions required to perform the test, the actions that will occur when the test is run and the potential adverse events that could occur, For this testing, where a defined set of relays and contacts are being operated, the pretest conditions are essentially normal operating conditions. If a relay or contact fails to operate, there is no adverse impact as the plant remains in the normal lineup.

When the contacts do operate, there will be cases that equipment will operate which either do not need to be operating or should not be  !

operating. If the equipment does not need to operate, the procedure will

, have the operator shut the equipment down. If the equipment should not operate, the procedure will include actions to inhibit that operation  !

(e.g., racking out the breaker or using pull to lock). In some cases, such action may require the unit to enter an action statement as equipment required to be operable by a technical specification LC0 must be taken out of service. The potential impact is also minimized by testing only one train at a time. When the testing is complete. equipment is returned to its normal operating condition. As can be seen, this at power testing is performed in a such manner that there is no significant impact on safety,  ;

even if the equipment fails to function as designed.

TXX 98100 Page 13 of 18

4. UNREVIEWED SAFETY OUESTION / NO SIGNIFICANT HAZARDS CONSIDERATION:

TU Electric has considered the criteria for assessing the potential of creating an unreviewed safety question or a significant hazards consideration with the exercising of enforcement discretion. In evaluating if discretion in enforcement constitutes a significant hazard consideration the criteria of 10CFR50.92(c) is discussed below:

1. Do the proposed changes involve a significant increase in the l probability or consequences of an accident previously evaluated? '

The propcsed change is to delay performance of the surveillance testing of specific devices as previously described and listed in Attachments 1, 2 and 3. Delaying performance of these tests until such time as appropriate does not increase the probability of an accident. The failure of any of these devices would not create an accident: therefore the probability of an accident previously evaluated is not increased.

No plant equipment is adversely affected by not performing these surveillance tests. The consequences of an accident, as analyzed in the FSAR. does not increase from not having performed the testing.

Based on the statements above and the expectation that the deferred testing will confirm OPERABILITY, this change poses no increase in the consequences of a previously evaluated accident.

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2. Do the proposed changes create the possibility of a new or different kind of accident from any accident previously evaluated?

Delaying performance of the tests is an administrative action and does not have the potential to create a new or different kind of accident from any previously evaluated. The systems will continue to respond in the same manner as they currently do.

3. Do the proposed changes involve a significant reduction in a margin of safety?

Delaying the performance of those portions of the surveillance testing necessary to demonstrate the lockouts and seal in circuitry, does not significantly reduce a margin of safety. Although untested, the circuitry is expected to perform its design functions.

TU Electric has performed a safety evaluation, and has determined, in j accordance with 10CFR50.59 that an unreviewed safety question does not exist. The following is a summary of the basis for that conclusion.

Granting the enforcement discreticn allows Unit 2 to continue to operate while a temporary technical specification change is processed which defers the testing until an appropriate time when the missed surveillances may be

, performed and allows TV Electric to use at power testing to satisfy shutdown surveillance requirements. Delaying the performance of these surveillance requirements will not cause an accident, will not cause equipment to malfunction and will not alter the course of an accident: as  !

1 TXX 98100

- Page 14 of 18 such, the enforcement discretion has no discernable impact on the probability or consequences of an accident or malfunction of equipment important to safety previously evaluated in the safety analysis report.

Similarly, not performing an action does not create the possibility of a new type of accident or equipment malfunction. Not performing actions means that the margin of safety that presently exists will remain essentially unchanged. Based on the logic summarized above, the granting of the requested enforcement discretion does not create an unreviewed j

safety question per 10 CFR 50.59.

)

In summary, using 10CFR50.59 and 10CFR50.92, TV Electric has determined that delaying performance of the necessary testing does not constitute an unreviewed safety question or a significant hazard consideration. ,

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5. ENVIRONMENTAL CONSEQUENCES:

The request only involves the delay in performance of testing within the plant. These activities and their potential consequences cre limited to the plant and will not result in any unplanned releases that could impact the environment.

6. COMPENSATORY ACTIONS:

The following compensatory measures will be implemented: l Although noi. specifically compensatory actions, CPSES procedures for dealing with safety injection actuations with and without loss of offsite j

)ower, and blackout sequencer actuations on loss of power to either or

)oth safeguards busses provide instructions to the operators on verifying  ;

proper load shedding and load sequencing and actions to be taken should l improper or incomplete load shedding / sequencing occur. '

E0P 0.0, " Reactor Trip or Safety Injection," at step 4 contains a Coution j statement which states. "If during performance of this procedure the SI j sequencer fails to complete its sequence. Attachment 3 may be used to l ensure proper equipment operation for major equipment." Attachment 3 is a  !

listing of the major components sequenced on and the sequence in which j l they are expected to start along with the sequence times and approximate

load imposed. Entry into attachment 3 would occur if, during steps 5 and j i beyond in E0P 0.0, operators identified loads expected to be running which  !

j were not. Attachment 3 enables them to confirm loads that should be  !

running and the amount of time after receipt of a SI signal after which the loads should be run.11ng. This, in turn, provides confidence that loads would be started, but not preemptively following a SI with a sequencer malfunction. Further the rule.S of usage for E0P 0.0 do not permit operators to act unilaterally in starting equipment. Permission must first be obtained from the Unit Supervisor for all major sequenced components. Given the time to implement individual steps of E0P 0.0, it is extremel/ unlikely that any components would be started preemptively.

These actir s are periodically reinforced through classroom and simulat or

TXX 98100

- Page 15 of 18 training as part of licensed operator requalification.

Step 18 of E0P 0.0 requires verification of proper SI alignment. This is accomplished by verifying the status of SI components through the use of status lights on the main control board backed up by an attachment which lists the individual components and verifying the status of bus and MCC load shedding again by status lights on the main control board backed up by an attachment which lists the individual components required to be load shed. The " Response Not Obtained" instructions require manual actuation / realignment of components as necessary to achieve acceptable status. Implementation of these actions requires Unit Supervisor concurrence. These actions are also periodically reinforced through classroom and simulator training as part of licensed operator requalification.

Section 8.0 of Abnormal Operating Procedure ABN 602. " Plant Recovery From a Blackout Sequencer Signal" specifies operator actions in response to a blackout sequencer actuation. It is entered upon a voltage loss of either or both of the safeguards busses. After assuring that auxiliary feedwater is running to provide a heat sink if needed, the procedure, at step 3. has the operators check to see if the operator lockouts are reset.

It also directs the operators to reset the blackout sequencer which resets the automatic lockout features permitting equipment to auto start as designed in response to process signals. To this point, no equipment starts are directed other than auxiliary feedwater which should have already started. A Caution statement between steps 3 and 4 states. "DG load should be maintained less than 7 MW during steady state conditions and shall be r.aintained less than 7.7 MW during transient conditions."

This caution alerts the operators that if equipment which should have been load shed has not been and is resulting in excessive diesel generator load, that load should be reduced by shedding unnecessary loads. An attachment to the procedure identifies loads which should be sequenced on by the sequencer, alerting the operators to loads which are necessary.

Taken collectively, this information has the operator check for sequencer status and diesel generator loading, and provides guidance to assure continued availability of power. These actions are periodically reinforced through classroom and simulator training as part of licensed )

operator requalification.

]I Collectively, the guidance in E0P 0.0 and ABN-602 and the periodic ]

training conducted as part of licensed operator requalification provide a j high level of confidence that the operators will detect malfunctions ia  !

the operation of the sequencers or load shedding in a timely manner, and i l will take actions to accommodate those malfunctions in a fashion that will i assure the continued availability of power to equipment needed to achieve and maintain safe shutdown. In addition, the operating procedures and licensed operator requalification prn;ide a high level of confidence that the operators will not attempt to start loads on the diesel generator during the first 110 seconds of loading following an emergency start.

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TXX 98100 Page 15 of 18

7. DURATION:

The requested duration is based upon the time required for the NRC to process a proposed change to the technical specifications. The requested duration is to commence upon approval of this enforcement discretion request and to expire upon disposition of the proposed license amendment.

8. SORC REVIEW:

This activity has been reviewed and approved by the Station Operations Review Committee (50RC).

9. CRITERIA FOR EXERCISING ENFORCEMENT DISCRETION:

Reference 2. section B item 1 provides the criteria for exercising enforcement discretion for an operating plant as follows:

For an operating plant, the N0ED 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 risk or (b) eliminate testing, inspection, or system realignment that is inappropriate for the particular plant conditions.

This criteria reflects the NRC's policy as provided in reference 1.

Initiating a Unit 2 shutdown to comply sith the subject Technical Specifications would subject CPSES to an undesirable transient which poses greater safety consequences than delaying performance of the surveillance testing segments until the next extended outage. Of immediate concern would be the potential disruptions i.o the A.C. distribution circuits providing for shutdown cooling for CPSES Unit 1.

10. PROPOSED TECH'NICAL SPECIFICATION CHANGES:

! A separate license amendment request (LAR) will be submitted under a different letter. This LAR will request a one time exception to not perform the portions of the surveillances related to this enforcement discretion request and to allow crediting performance of portions of the surveillances during power operation. The LAR will be submitted by April

10. 1998. The attached pages reflect the manner in which TV Electric currently intends to propose that the technical specifications be revised.

11. APPROVED LINE ITEM IMPROVEMENTS:

Prior adoption of approved line item improvements to the Technical Specifications or the improved Standard Technical Specifications would not  !

have obviated the need for this enforcement discretion request.

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TXX 98100 Page 17 of 18

12. ADDITIONAL INFORMATION REQUESTED BY THE NRC STAFF:

The NRC staff has requested no additional information.

CONCLUSION:

TV Electric requests the NRC grant the requested enforcement discretion to not enforce the ACTIONS of LC0 3.8.1.1 for CPSES Unit 2 (specifically, LC0

'3.8.1.1 ACTIONS b, c, d and f).

If during performance of testing activities on either CPSES Units 1 or 2, or during any additional engineering analyses, TU Electric determines that the circumstances which support the granting of the enforcement discretion have changed. TU Electric will notify the NRC. In particular, if any of the required features fail to exhibit operability during any of the testing which is to be completed prior to April 16, 1998. TU Electric will I notify the NRC. Further, if any of the assumptions which serve as a bas,is )

of the Unreviewed Safety Question evaluation is determined to be invalid.

TV Electric will notify the NRC. If TU Electric determines that a component will not pass its required surveillance test TU Electric will declare the impacted equipment inoperable and will perform the required ACTION requirements while correcting the deficiency. The NRC will be informed of our determination and our actions. In this example, the J

enforcement discretion would continue to apply to the other components for which surveillance requirements were missed. TU Electric intends to notify the NRC of such changes in circumstances by informing a CPSES resident inspector. It is understood that any such change in I circumstances may lead to additional discussions and, potentially, action l by either TU Electric or the NRC staff regarding the granted enforcement '

discretion.

A response is requested by 10:00 a.m. CDST on April 8, 1998.

This communication contains the following commitments which will be l completed as noted:

CDF Number Commitment l TU Electric intends to demonstrate the functionality of l the lockout and auxiliary relays (but not necessarily all contacts) which actuate the contacts-listed in attachment 1 to TXX 98100 prior to the completion of the current enforcement discretion (April 8, 1998, at 3:35PM COST).

The category 2 features (see attachments to TXX 98100) will be tested by April 16, 1998.

An LAR will be submitted which requests a one time exception to not perform the portions of the

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I TXX 98100 Page 18 of 18

-surveillances related to the enforcement discretion requested by TXX 98100 and to allow crediting

, performance of portions of.the surveillances during power operation. The LAR will be. submitted by April 10, 1998.

Lockout contacts which perform an SI separation function will be tested in the same time frame as the lockout relay and contacts which are tested per a Surveillance Requirement.

(

t Sincerely, e

• C. L. Terry l

By: m bW Rogef'D. Walker )

Regulatory Affairs Manager DRW/gp Attachments c Mr. E. W. Merschoff RIV Mr. T. J. Polich, NRR i Mr. J. I. Tapia. RIV CPSES Resident Inspectors i

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Attachment 1 to TXX 98100 Page l'of 1 LOCK 0UT CONTACTS REQUIRING TESTING Item g Classification Train f Cat Test in Affected Equipment 1-c t m cks A and B 61 3 No See attachment 6 l n 0 Blocks 2

t A and B 23 3 No See attachment 6 Lockout - Blocks 3 manual and auto A and B 24 3 No See attachment 6 starts l Lockout - Starts  !

i 4 and/or stops A and B 17 3 No See attachment 6 equipment 5

Lockout Actuates A and B 12 3 No See items 1, 2, 3 and an auxiliary relay 4 Automatic Lockout -

6 Bypass / block DG A and B 4 2 No DG Output Breaker interlock / trip Lockout - Functions in common circuits Unit 1 Train A lockout 7 and will be tested A 27* 5 NA relays only by Unit l' testing during 1RF06

• 27 of 54 contacts have beer, tested in Unit 1 Train B I 1

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m Number reflects the number of contacts l in Category 1 - Testing is not required l Category 2 - Testing may be performed at power  !

.- Category 3 - Testing not to be performed at power, however relay functionality ,

I either has been demonstrated or will be demonstrated prior to the j end of the current enforcement discretion.  :

Category 4 - Testing not to be performed at power, and relay functionality has i

'not been and will not be demonstrated prior to the next extended  !

outage Category 5 - Testing to be performed during 1RF06

Attachment 2 to TXX 98100 Page 1 of 1-SEAL IN CONTACTS REQUIRING TESTING Ites g Classification Train f Cat Te H0DE 1

" Affected Equipment DG Lube Oil Heater DG Jacket Water Heater RHR Pump Room Fan Cooler Containment Spray Pump Room Fan Coolers SI Pump Room Fan Load Shed NOT C

1 Verified _during A 10 2 Yes go r rive AFW Pump Normal Operations Room Fan Cooler CCW Pump Room Fan Cooler Positive Displacement Charging Pump Room Fan Cooler DG Generator Space Htr DG Lube Oil Heater DG Jacket-Water Heater RHR Pump Room-Fan

~ Cooler Containment Spray Pump l Load Shed -'NOT Room Fan Coolers-l 2 Verified during B 9 2 Yes SI Pump Room Fan l: Normal Operations Cooler

( Hotor Drive AFW Pump

! Room Fan Cooler CCW Pump Room Fan Cooler DG Generator Space Htr Load Shed. NOT Instrument Air 3 Verified during A and B 2 2 Yes Compressors Normal Operations Control Room AC Units Load Shed NOT 4 Verified during Normal Operations A 9 5 NA 1 { hfs

, Spent Fuel Pool Pumps i

m Number reflects the number of contacts m Category 1 - Testing is not required Category 2 - Testing may be performed at power Category 3 - Testing not to be performed at power, however relay functionality either has been demonstrated or will be demonstrated prior to the end of the current enforcement discretion.

Category 4 - Testing not to be performed at power, and relay functionality has not been and will not be demonstrated prior to the next extended outage-

. Category 5 - Testing -to be performed during 1RF06 -

-Attachment 3 to TXX 98100 Page 1 of 1 VARIOUS CONTACTS REQUIRING TESTING Ites Classification Train I Cat Test in Affected Equipment y , ,

1 DG Trip Bypass A and B 3 2 Yes

{'r cy trips i

n> Number reflects the number of contacts m Category 1 - Testing is not required Category 2 - Testing may be performed at power Category 3 - Testing not to be performed at power, however relay functionality either.has been demonstrated or will be demonstrated prior to the end of the current enforcement discretion.

Category 4 - Testing not to be performed at power, and relay functionality has not-been and will not be demonstrated prior to the next extended outage Category 5 - Testing to be performed during 1RF06

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Attachment 4 to TXX 98100 l Page 1 of 1 )

)

i LOCK 0UTS NOT REQUIRING TESTING l

Item T $t "

Classification Train H0DE 1 Affected Equipment Lockouts Provide A and B 1 43 1- N/A N/A SI separation i

Lockouts -

2 Blocks / Enables A and B 15 1 N/A N/A alarm 3 A and B 12 1 N/A N/A [

ant Contact

• To be tested (not a Surveillance Requirement) to demonstrate functionality in the same time frame as the lockout relays and contacts.

l m Number reflects the number of contacts m Category 1 - Testing is not required Category 2 - Testing may be performed at power Category 3 - Testing not to be performed at power, however relay functionality C'ther has been demonstrated or will be demonstrated prior to the end of the current enforcement discretion.

Category 4 - Testing not to be performed at power, and relay functionality has not been and will not be demonstrated prior to the next extended outage

{

Category 5 - Testing to be performed during 1RF06

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Attachment 5 to TXX 98100 Page 1 of 1 SEAL IN CONTACTS NOT REQUIRING TESTING Iten Te "

p Classification Train [, H00E 1 Affected Equipment Contacts which were identified as not 1 performing a load shed A 40 1. N/A N/A function due to load restarting.

Contacts which were identified as not 2 performing a load shed B 42 1 N/A N/A function due to load restarting.

.\

Perform Load Shed i 3 Function Verified by A 16 1 N/A N/A normal operations Perform Load Shed 4 Function - Verified by B 15 1 N/A N/A normal operations Motor Operated Valve

( or Damper which would l- require operator

! action'or signal to 5 A 60 1 N/A N/A l l- induce load. These ,

loads are accounted for within DG loading i calculations.

Motor Operated Valve or Damper which would require operator action cr signal t 6 B 68 1 N/A N/A induce load. These loads are acccunted for within DG loading calculations.

m Number reflects the number of contacts i

m Category 1 . Testing is not required Category 2 e Testing may be performed at power Category 3 - Testing not to be performed at power, however relay functionality either has been demonstrated or will be demonstrated prior to the end of the current enforcement discretion.

Category 4 - Testing not to be performed at power and relay functionality has not been and will not be demonstrated prior to the next extended ,

outage .

l Category 5 -. Testing to be performed during 1RF06

Attach::nt 6 to TXX 98100 Page 1 of 2 Lockout Relay Functions Loads with a block of automatic or manual start:

Chilled Water Recirc Pumps CCW Pumps AFW Pumps SSW Pumps Pressurizer Heaters Vent Chiller Water Recirculation Pump Spent Fuel Pool Cooling Pumps Control Room AC Units Reactor Makeup Water Pumps DG-Air Compressors UPS HVAC Unit Fans Safety Chillers DG Jacket Water Pumps DG Aux Lube Oil Pumps DG Prelube Pumps Instrument Air Compressors Containment Spray Pumps SI Pumps RHR Pumps CCP Pumps Containment Recirc Fans

-Chilled Water Recirc Pumps PD Pump

Aux Bldg Equip Rm Exh Fans l Plant Vent Exh Fans Loads with an automatic start and/or ston

,

l TDAFW Pump Vent Chilled Water Pumps Rad Monitors DG Emergency Start Spent Fuel Pool Pumps Safety Chillers 1 Reactor Makeup Water Pumps 1

1