ML20216G893
| ML20216G893 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 03/12/1998 |
| From: | Terry C, Walker R TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| TXX-98077, NUDOCS 9803200127 | |
| Download: ML20216G893 (6) | |
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=M Log # TXX 98077
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File # 10010 geg,y$g&ff 1UELECTRIC c.u wny-senior vice ere,w,n, March 12, 1998
& PrincipalNuclear Oficer U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555
SUBJECT:
COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)
UNITS 1 AND 2 DOCKET NUMBERS 50 445 AND 50 446 ENFORCEMENT DISCRETION FOR APPLICABILITY, SURVEILLANCE REQUIREMENTS 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 98066 from C. L. Terry to NRC dated March 9, 1998 4.
NRC Letter from John N. Hannon to C. Lance Terry dated February 28, 1998 Gentlemen:
In accordan':e with the guidance provided by reference 1 Texas Utilities Electric Ccmpany (TV Electric) requests that the Nuclear Regulatory Commissi c (NRC) exercise enforcement discretion to allow CPSES Units 1 and 2 to remain in MODE 1. POWER OPERATION, in accordance with the guidance of Surveillance Requirement (SR) 4.0.3 for an additional 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> beyond the 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> allowable. Without the requested enforcement discretion, compliance with CPSES SR 4.0.3 would require that
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4.8.1.1.2f.4)a) and 4.8.1.1.2f.6)a) be performed within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> following identification that the SR was incomplete or perform the applicable ACTIONS.
Compliance without enforcement discretion may require that TU Electric attempt to construct and perform the SR testing in a time frame inconsistent with nuclear safety significance if it is determined that testing of the surveillance segments at power is the most conservative action.
The referenced section of the NRC Inspection Manual (reference 2) provides guidance on the information to be included in a request for enforcement discretion.
TU Electric believes the enforcement discretion being requested is consistent with the criteria for regional enforcement i
discretion as described in reference 2.
The sections below are arranged g
3-9 to corres n to that guidance.
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TXX 98077 Page 2 of 6
- 1. REQUIREMENT /RE0 VEST:
Surveillance Requirement 4.0.3 states, in part, that "the time limits of the ACTION requirements are applicable at the time it is identified that a Surveillance Requirement has not been performed. The ACTION requirements may be delayed for up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to permit the completion of the surveillance when the allowable outage time limits of the ACTION requirements are less than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />."
With respect to Surveillance Requirement 4.0.3. TU Electric requests that the NRC exercise discretion to not enforce the ACTION requirements for an additional 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> beyond the allowable 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period. TU Electric believes that the additional 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> are necessary to allow for preparation and performance of test instructions and the administrative processing of appropriate Enforcement Discretion and License Amendment Requests necessary to complete the SR testing in a manner consistent wa the nuclear safety significance of the omission (s).
- 2. CIRCUMSTANCES:
During the process of conducting reviews in accordance with U.S. NRC Generic Letter 96-01, CPSES discovered that positive confirmation of the undervoltage contacts in the 480 V Motor Control Center (HCC) load shedding scheme cannot be established.
Surveillance testing has been accomplished that confirms that MCCs load shed (with the exception of XEB4 3 on Unit 2, see Reference 3) but a parallel circuit path to the undervoltage contacts exists. This alternate path is activated by the Emergency Diesel Generator Output Breaker closure and occurs shortly following the undervoltage trip path. This omission in the surveillance program at CPSES has been present since the time of initial license and was identified on March 12, 1998 at 5:18 pm CST. As the omission constitutes the failure to perform a Surveillance Requirement within the surveillance frequency plus allowable extension in accordance with SR 4.0.2, 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> from March 12. 1998 at 5:18 pm CST is allowed to perform the SR in accordance with SR 4.0.3.
TV Electric believes that performance of the omitted portions of 4.8.1.1.2f.4)a) and 4.8.1.1.2f.6)a), during POWER OPERATIONS is acceptable.
However in TU Electric's pursuit of safe operation, additional time for test preparation and performance beyond the 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> is deemad necessary.
From previous discussions with the NRC, TU Electric believes that this request is commensurate with the NRC's expectations for safe power plant operation and conservative decision making. A determination of root cause will be evaluated and reported as required in the ensuing Licensee Event Report required per 10CFR50.73.
- 3. SAFETY SIGNIFICANCE AND POTENTIAL CONSEQUENCES:
The condition has existed since the time of initial license for both units. 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 I
TXX 98077 Page 3 of 6 the' Surve'111ance, the safety significance of the delay in the 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." Commensurate with this position TV Electric believes that performance of the SR will most probably demonstrate OPERABILITY. However, as opposed to the generic 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> i
allowance, TU Electric believes that additional time is necessary for adequate planning of tests which have not previously been written and performed.
TV Electric is reviewing the required testing and believes that acceptable j
tests, with respect to nuclear safety, to satisfy 4.8.1.1.2f.4)a) and 1
4.8.1.1.2f.6)a), can be performed during POWER OPERATIONS with no adverse I
effect.
TU Electric is requesting an additional 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to allow for preparation and performance of the SRs in a controlled and safe manner.
The potential consequences of performing these SRs without sufficient review exceeds the potential consequences of operation continuing for an additional 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> in the present condition. This assessment is based on the most probable result of surveillance performance, that OPERABILITY is confirmed.
In contrast, an inadequate surveillance could pose additional i
consequences.
Further, a qualitative risk assessment based on the CPSES PRA concluded that the granting of the requested enforcement discretion j
will not have an adverse impact on risk for either CPSES Unit 1 or Unit 2.
- 4. UNREVIEWED SAFETY OUESTION / NO SIGNIFICANT HAZARDS CONSIDERATION:
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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 the criteria of 10CFR50.92(c) is discussed below:
1.
Do the proposed changes involve a significant increase in the probability or consequences of an accident previously evaluated?
The plant will be maintained in the existing condition for the a period of time to allow surveillance testing. The extension of this allowable time only provides for additional assurance that the testing is performed in a safe manner. As the plant would respond in the same manner during the additional 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> as in the first 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> no additional consequences are credible. The probability of an accident remains fixed whether the SR is current or not.
Therefore no increase in the probability of a previously evaluated accident exist.
The proposed change of allowing an additional 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to the 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> already allowed per SR 4.0.3 does not constitute an increase in the probability or consequences of an accident prev 1ously evaluated.
TXX 98077 Page 4 of 6 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 SRs until such time as an acceptable test can be prepared does not create the potential for any accidents.
In contrast, the additional preparation time potentially decreases the possibility of the creation of a new or different kind of accident by allowing adequate preparation and review.
3.
Lo the proposed changes involve a significant reduction in a margin of safety?
The margin of safety inherent in the first 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> delay is predicated on the assumption that the most probable result of surveillance testing is the demonstration of OPERABILITY.
- Likewise, the same assumption is inherent within the additional 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.
Although the time period is extended, no significant reduction within a margin of safety is experienced as the most probable result of the delay is that the equipment is OPERABLE. As for the-potential that the equipment is demonstrated inoperable and
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incapable of performing its safety function, the additional 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> which the equipment could be inoperable does not result in a further reduction in a margin of safety as the condition already exist during the first 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
i TU Electric has performed a safety evaluation, and has determined, in accordance with 10CFR50.59 that extending the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> allowance of SR 4.0.3 to 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> for performance of 4.8.1.1.2f.4)a) and 4.8.1.1.2f.6)a) does not constitute an unreviewed safety question.
In summary, using 10CFR50.59 and 10CFR50.92, TV Electric has determined that extending the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> allowance of SR 4.0.3 to 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> does not constitute an unreviewed safety question or a significant hazard.
- 5. ENVIRONMENTAL CONSEQUENCES:
The request only involves the delay in performance of testing within the plant. These activities and their potential consequences are limited to the plant and will not result in any unplanned releases that could impact the ensironment.
- 6. COMPENSATORY ACTIONS;,
Performance of the required testing will be conducted in a safe and controlled manner at the first opportunity. TU Electric will not intentionally delay conducting the testing in order to utilize the additional time allowance.
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j TXX 98077 Page 5 of 6
- 7. DURATION:
1 The requested duration of this enforcement discretion is a maximum of 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br />.
The enforcement discretion will expire at 5:18 pm CST on March 16, 1998.
- 8. 50RC REVIEW:
This activity has been reviewed and approved by the Station Operations Review Committee (SORC).
- 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.
i This criteria reflects the NRC's policy as provided in reference 1.
Preparation and performance of the testing within the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> allowance has the potential to create inappropriate system realignment and possibly induce a plant transient that could have otherwise been avoided with adequate test preparation.
- 10. PROPOSED TECHNICAL SPECIFICATION CHANGES:
The requested enforcement discretion is temporary for a maximum period of 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> and nonrecurring. An amendment to the technical specifications is not required.
- 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.
- 12. ADDITIONAL INFORMATION REQUESTED BY THE NRC STAFF:
The NRC staff has requested no additional information.
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TXX-98077 Page 6 of 6 CONCLUS[0N:
TV Electric requests the NRC grant the requested enforcement discretion to allow CPSES to extend the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> allowance of SR 4.0.3 to 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> in order for the preparation and performance of test instructions that will satisfy the omitted portions of 4.8.1.1.2f.4)a) and 4.8.1.1.2f.6)a).
If there is a significant change in the circumstances associatod with this exercising of enforcement discretion, TV Electric will notify the NRC. A response is requested by 10:00 am on March 13, 1998.
Sincerely,
- d. k, C. L. Terry By:
0901 Roge PD. Walker Regulatory Affairs Manager JDS/gp c - Mr. E. W. Herschoff. Region IV Mr. T. J. Polich. NRR Hr. J. I. Tapia, Region IV CPSES Resident Inspectors i
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