ML20217F919
| ML20217F919 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 03/24/1998 |
| From: | Terry C, Walker R TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| RTR-NUREG-1600 GL-96-01, GL-96-1, TXX-98091, NUDOCS 9804010276 | |
| Download: ML20217F919 (7) | |
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Log # TXX 98091 Z
Z File # 10010 7UELECTR/C 916 (3/4.0)
Ref. # NUREG-1600 C. Lance Thrry senior vice Presiden:
March 24, 1998
& PrincipalNuclear Officer 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
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ENFORCEMENT DISCRETION FOR APPLICABILITY, SURVEILLANCE I
REQUIREMENTS REF:
1.
NUREG 1600, " General Statement of Policy and Procedures for NRC Enforcement Actions." dated June 1995 I
2.
NRC Inspection Manual. Part 9900. " Operations - Enforcement Discretion," dated November 2, 1995 1
Gentlemen:
j In accordance with the guidance provided by reference 1, Texas Utilities Electric Company (TV Electric) requests that the Nuclear Regulatory Commission (NRC) exercise enforcement discretion to allow CPSES Unit 2 to continue to operate and to allow the refueling outage activities for CPSES Unit 1 to continue without having performed portions of Surveillance j
Requirements (SR) 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), 4.8.1.1.2f.6)c) and 4.8.1.2.
Without the requested enforcement discretion, compliance with CPSES LC0 3.8.1.1 and LC0 3.8.1.2 would require a reactor shutdown for Unit 2 and significant disruption in the in progress Unit 1 refueling outage.
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 discretion as described in reference 2.
The sections below are arranged to correspond to that guidance.
- 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
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requirements are less than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />."
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COMANCllE PEAK STEAM El ECTRIC STATION
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'. t i. L 2. Y P.O. Box 1002 Glen Rose, Texas 76043 1002 O
,9804010276 980324" T' DR ADOCK 05000445!
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l TXX 98091 Page.2 of 7 With respect to Surveillance Requirements 4.8.1.1.2f.4, 4.8.1.1.2f.6 and
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corresponding SRs in 4.8.1.2. TU Electric has identified portions of these q
surveillances which have not previously been demonstrated as accepthble.
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 in series: (c) verifications that motor control center (mcc) load seal-in contacts open upon bus deenergization thereby ensuring 3
that equipment that was previously operating does not attempt to reload inappropriately onto the bus and (d) 480 V undervoltage relays load shed the emergency fill fire pump.
As a result of the testing omissions in SR 4.8.1.1.2f and SR 4.8.1.2, TU Electric requests that the NRC exercise discretion to not enforce the ACTION requirements for an additional 14 days beyond the ellowable 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.
TU Electric believes that the additional time is necessary to allow for adequate engineering review in order 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 those devices which have not previously been tested.
Further analyses of the detailed function and safety significance of each device which can not be tested in the current plant configuration is also needed. By the end of the requested time, TV Electric will have determined the subsequent corrective actions that are necessary.
- 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 underve;tage shedding of the emergency fill fire pump are not positively verified to perform their required functions. Therefore, complete testing in accorriance with Surveillance Requirements 4.8.1.1.2f and 4.8.1.2 has not been performed. CPSES anticipates that the outcome of the surveillance testing will be confirmation of OPERABILITY as there is no known reason to suspect that problems with the circuitry exist. This omission in the surveillance program at CPSES has been present since the time of initial license and was identified on March 24, 1998, at 02:30 p.m. CST.
As the omission constitutes the failure to perform a Surveillance Requirement within the surveillance frequency plus allowable extension in accordance with Surveillance Requirement 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 24, 1998, at 02:30 p.m. CST) is allowed per Surveillance Requirement 4.0.3 to perform the Surveillance Requirement, during which time the ACTION requirements may be delayed. However. TV Electric does not anticipate that sufficient time exists to fully identify all the devices that are required by the Technical Specifications and have not been fully tested.
If the NRC chooses not to exercise enforcement discretion, TV Electric will comply with the applicable ACTION statements.
A determination of root cause will be evaluated and reported as required in the ensuing Licensee Event Report required per 10CFR50.73.
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- 3. SAFETY SIGNIFICANCE-AND POTENTIAL CONSEQUENCES:
i The safety functions of the lockouts, bypasses, undervoltage relay load shedding'and seal in contacts are to ensure unnecessary equipment does not l
inappropriately load onto the A.C. bus, that equipment load sheds, and L
that the diesel generator does not trip from a non essential trip signal.
l These devices are intended to ensure that the unnecessary equipment' l'
' loads do not cause perturbations in the' diesel starting and loading sequence.
Failure of the affected equipment to properly sequence loads onto 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.
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The condition has existed since the time of initial license issuance for both units. When a surveillance is identified which has not been performed within the prescribed time period, the Technical Specifications allow 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 )eriod includes consideration of unit conditions, adequate planning, availa)ility of personnel, the time required to perform the Surveillance, 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 is confident that performance of the SR will confirm OPERABILITY. The fact that the diesel generator has satisfactorily demonstrated the capability to start and load during integrated testing is additional evidence that the confirmation of OPERABILITY is most probable.
For the seal-in circuits, the relays are typically operated periodically in normal operation or surveillance j
testing and the functionality of only one or more contacts may not have l
been verified.
Diesel generator trips have been verified to be bypassed, but because of multiple contacts, it is not clear that each contact functioned as required. The undervoltage relays that shed the emergency fill fire pump have been demonstrated and the functionality of the single contact and component have not been verified. Although, absolute confirmation can not be demonstrated that the circuits have performed their required functions, it is most likely that the circuits have responded appropriately during the previous integrated tests and system actuations. As such, the current plant configuration is acceptable for continued operation and for continuation of the in progress refueling outage. 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 /> allowance. TU Electric
. believes that additional time is necessary to allow for adequate
, engineering review in order to assess which sequencer automatic lockouts, operator lockouts, bypasses, undervoltage relays and seal in contacts have not been fully tested.
Identification of each requires a thorough engineering review.'
Analyses of the ability to safely test those
~ circuits which have not previously been. tested is also necessary.
Further analyses of the detailed function and safety significance of each circuit 1
which can not be tested in the current plant configuration is also needed.
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-TV Electric is requesting additional time to perform these assessments.
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TXX 98091 Pages 4 of 7 The potential consequences of invoking the ACTION statements exceeds the potential consequences of continuing in the present configurations for additional time. This assessment is based on the most probable result of surveillance performance, that being that OPERABILITY is confirmed.
i Further, a qualitative risk assessment based on the CPSES PRA concluded j
that the granting of the requested enforcement discretion will not have an
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adverse impact on risk for either CPSES Unit 1 or Unit 2.
- 4. UNREVIEWED SAFETY OUESTION / NO SIGNIFICANT HAZARDS CONSIDERATION:
i 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 tha probability or consequences of an accident previously evaluated?
The proposed change is to delay performance of the surveillance testing of specific lockouts, trip bypass circuits, undervoltage relay shedding of the emergency fill fire pump and seal in contacts.
Delaying performance of these tests until such time as appropriate does not increase the probability of an accident.
No plant equipment is affected by not performing manipulations within the plant.
The consequences of an accident also does not increase from i
not having performed the testing. As the plant would respond in the i
same manner during the additional time 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 additional time 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 previously evaluated.
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 requirement and does not have the potential to create a new or different kind of accident from any previously evaluated. The system will continue to respond in the same nanner as it currently does.
3.
Do 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 time for these specific circuits.
Although the time period is extended. no significant reduction in a margin of safety is experienced as the t
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l TXX 98091-Page.5 of 7 l
most 3robable result of the delayed testing is that the equipment will se demonstrated OPERABLE.
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 15 days for a detailed assessment of Surveillance Requirements 4.8.1.1.2f.4)a) 4.8.1.1.2f.4)b), 4.5.1.1.2f.6)a). 4.8.1.1.2f.6)b),
4.8.1.1.2f.6)c) and 4.8.1.2 does not constitute an unreviewed safety question.
In summary, using 10CFR50.59 and 10CFR50.92 TU 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 15 days 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 environment.
- 6. COMPENSATORY ACTIONS:
No compensatory actions are planned at this time.
- 7. DURATION:
The requested duration of this enforconent discretion is 14 additional days beyond the initial 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> allowance. The enforcement discretion will expire at 02:30 pm CST on April 8, 1998.
- 8. SORC 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.
This criteria reflects the NRC's policy as provided in reference 1.
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-1 Initiating a Unit 2 shutdown to comply with the subject Technical Specifications would subject CPSES to an undesirable transient which poses
. greater safety consequences than delaying performance of the surveillance testing segments.
Reference 2, section B item 2 provides the criteria for exercising enforcement discretion for a shutdown plant as follows:
For plants in a. shutdown condition, the NOED is intended to reduce shutdown risk by avoiding testing, inspection, or system realignment thatLis inappropriate for the particular plant conditions, in that it.does not provide an overall safety benefit, or say, in fact, be detrimental to safety in the particular plant condition.
This criteria reflects the NRC's policy as provided in reference 1.
Rescheduling activities within the in progress Unit i refueling outage, has the potential to increase risk from inappropriate system realignments occurring as the result of improper planning. Outage planning has.been ongoing for months and to significantly reschedule while in progress has an increased potential for errors.
- 10. PROPOSED TECHNICAL SPECIFICATION CHANGES:
The. requested enforcement discretion is temporary for a maximum period of J
15 days 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 for Unit 2.
'The surveillance testing related to this request is no longer applicable
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in H0 DES 5 and 6 under the improved Technical Specification submitted to the NRC on May 15, 1997. Thus no discretion would be necessary for Unit 1 had the improved Technical Specifications submittal been approved.
12.. ADDITIONAL INFORMATION REQUESTED BY THE NRC STAFF:
The NRC staff has requested no additional information.
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, Page.7 of 7 CONCLUSION:
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 15 days in order to perform a detailed assessment of Surveillance Requirements 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).
4.8.1.1.2f.6)c) and 4.8.1.2.
If there is a significant change in the circumstances associated with this exercising of enforcement discretion.
TV Electric will notify the NRC. A response is requested by 10:00 am on March 25, 1998.
Sincerely.
- 0. $. g C. L. Terry By: @
Roger D. Walker Regulatory Affairs Manager RTB/rb c
Mr. E. W. Herschoff. Region IV Mr. T. J. Polich NRR Mr. J. I. Tapia. Region IV CPSES Resident Inspectors t-