ML20217F949

Documents Basis of Verbal Request for Enforcement Discretion to TS 4.8.2.1d & Requests Written Confirmation of Enforcement Discretion That Was Granted

ML20217F949
Person / Time
Site:	Nine Mile Point
Issue date:	04/18/1998
From:	Mueller J NIAGARA MOHAWK POWER CORP.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20217F892	List: ML20217F888 ML20217F949
References
NMP2L-1771, NUDOCS 9804280319
Download: ML20217F949 (8)

Text

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John H.MusNer 4emormePedfuseW onw. iets)>sen CeufMstercAner Fat m6)*S1321 eenk :

.amm April 18,1998 NMP2L 1771 U. S. Nuclear Regulatory Commission Attn: Documcht ControlDesk Washington, DC 20$55 RE:

Nine Mile Point Unit 2

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Docket No. 50-410 NPF-69

Subject:

Seguestfor Enforcement Discretion to Dcluded Syn :ification Surveillance Requirement 4.8.2.1d i

Gentlemen:

On April 17,1998, following discussions with the NRC Staff, NineMile Point Unit 2 (NMP2) was granted enforcement diW an with respect to Ts'ehnica Specification US) i 4.8.2.1d.. The enforemant discrenon became effective at 1845 hourt on April 17,1998, and expires at NMP2's next entry into Coki Shutdown but no later than hmy3,1998. The purpose of this letter is to document the basis of tho verba1 re 1 to request written confirmation of phe enforcement discretion thai'was granfe8. quest an NMP2 TS Umiting Conditions for Opention (LCO) 3.8.2.la require i that the Division. IDC electrical power source, consisting of a 125-volt battery and one 125-"olt full capacity charger, be operable. SurveiDance Requirement (SR) 4.8.2.ld requires that at least once per 18 months, during shutdown, battery capacity is determined to be adequate by performance of a battery service test. This service test can either demonstrate that the DivisionIbanery capacity is adequate to supply and maintain in operable status all of th > actualemergency loads for two hours, or that the battery capacity is adequate to supply a duna myload of a specified

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profile whila maintaining a battery terminal voltage of greater than or equal to 105 volts. With the battery and/or a charger of the Division I DC electrical power soulces inoperable, TS 3.8.2.1, Action & requires that the inoperable division DC power sonoe be returned to operable status within two hours or be in Hot Shutdown within the nea t 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and in Cold Shutdown within the following 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

On April 17,1998 at 1407 hours0.0163 days <br />0.391 hours <br />0.00233 weeks <br />5.353635e-4 months <br />, Niagara Mohawk Power Corporatio t (NMPC) discovered that SR.4.8.2.1d had not been met. Accordingly, Action a was entere I. To preclude the plant shutdown required by Action a, NMPC requested discretionary enforci ment from the requirements to perform SR 4.8.2.I4 unti1 NMP2's next entry into Co d Shutdown, but no Inter than May 3,1998. By May 3,1998, NMP2 will shur,down to bgin Refueling Outage 6.

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Page 2 NMPC believes thereis less risk in continued operation than in forciog an unnecessary plant ciudlenge by taking the plant to Shutdown to comply with the require acnts of TS 3.8.2.1, Action a. Attachment 1 provides NMPC's response to the 12 criteria identified in NRC Inspection Manua19900, which provides the a$)topriate jdstification for this request for enforcement discretion,

'Ihis request for enforcement discretion has been reviewed and apprcr ni by the NMP2 Station Operations Review Commh. tee (SORC).

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Very tmly yours, hf

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ohn H. Mueller Chief Nuclear Officc r JHM/IMT/hnc Attaclunent xc:

Mr. H. J. Miller, Regional Administrator, Region I Mr. S. S. Bajwa, Director, Project Directorate I-1, NRR Mr. B. S. Norris, Senior Resident 1nspgptor Mr. D. S. Hood, Senior Project Manager, NRR Records Management l

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ATTACHMENT 1 i

REGunfi FOR ENFORfTMFNT DISCRE1 inn 1.

The Taehair=1 Sydftemh or other ifcense conditions thal wiJ1 be violated.

Nine Mile Point Unit 2 (NMP2) Technical Spa ificW (TS) Jmiting Conditions for Operation 640) 3.8.2.la requires that the Division I DC cles tricalpower source, consisting of a 125-volt battery and one 125-volt full capacity :harger be operable.

Survaillam Requirement (SR) 4.8.2.1d requires that at least < ace per 18 months, during shutdown, battery capacity is determined to be adequanbyperformanceof a battery service test. This service test can either demonstrate 12 at the Division Ibat1ery capacity is adequate to supply and maintain in operable status ullof the actual emergency loads for two hours, or that the battery capacity is Mequate to supply a dummy load of a spdMed profUc whUs maintaining a battery trminalvoltage of greater than or cqual to 105 volts. With the battery and/or a ciargerof theDivision1 DC electrical power source inoperable, TS 3.8.2.1, Action a 2 : quires that the inoperable division DC power sources be returned to operable status within two hours or be in Hot Shutdown within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and in Cold S nutdown within the following 24. hours.

On April 17,1998 at 1407 hours0.0163 days <br />0.391 hours <br />0.00233 weeks <br />5.353635e-4 months <br />, Niagara Mohawk Power Ca poration (NMPC) discovered that SR 4.8.2.1d had not been met. Accordingly, don a was entered. To preclude the plant shutdown required by, Action s, NMPC regi ested discretionary enforcement from the requirernents to perform SR 4.8.2.2d un:i1NMP2's next entry into Cold Shutdown but no later than May 3,1998. By May 3,1998, NMP2 wi)1 shut down to begin Refueling Outage 6.

2.

The circumstances surrounding the situation, including roa t ceases, the need for prompt action, and identification of any relevant historical events.

SR 4.8.2.id requires the performance of a battery service test ' rvery 18 months during shutdown. SR 4.8.2.le requires that a performance discharge est be p ifermed every 60 months. SR 4.8.2.le also states that during this once every 60 month interval. the performance discharge test can be used in lieu of the battery se vice test (SR 4.8.2.1d).

As part of the development ofImproved Technical Specificalic is (ITS), it was discovered SR 4.8.2.1d had not becrt met. SWFady, the albwance to perform the performance discharge 1 cst in lieu of the battery service test wa 6 inappropriately applied more than once over a 60 month interval fer the Division I bad ery (i.e., the performance discharge test was in.ypeydately used in lieu of he battery service test for the previous two refueling outages (RPO4 and RPOS) whes testing the Division I battery).

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3.

The safety basis for the request, including an evaluation of the safety signincance and potential consequences of the proposed course of actia 1. This evaluation should include at least a qualitative risk assessment derived from the licensee's PRA.

The 125 VDC electrical power system e,onsi.tts of three inder *t Class 1E DC

• 1m+=1 power subsystems, Division I, Division d, and Divi ionHI. Each subsystem consists of a battery, two 100 percent batsr.ry chargers, and al) the associated control equipment and interconnecting cabling. The station DC clects,calpower system provides the AC emergency power system with controlpower and provides both motive and control power to selected safety related equipment. Duri ig normaloperation, the DC loads are powered from the battery charger with the battei les floating on the system. In the event of a of loss of normalpower to the batte y charger, the DC loads are auto =*tir*11y powered from the batteries.

NMPC has determined that the Division I DC System is capal le of performing its intended function and that this enforcement discretion is not ir consistent with protecting public health and safety. The basis for this determination is 11 e following:

The maximum duration of the enforcement discretion i i slightly over two weeks. The Division I battery will be declared inoperable upon entry into Cold Shutdown. The required battery service test will be p. Gnwed prfor to declaring the battery operable, The design of the battenes are well above the required performancelevels.

a SpaAfic211y, the Division I and Division II hatteries arn over-designed by approximately 40% and 60%, respectrvely.

Identica1 batteries used in the Division II DC System h ive successfully passed previous service tests. Therefore, the most likely outco ne of the Division I battery service last would be confirmation of its operat lity.

External resistance checks for both Division I and Divi rienIIbatteries have been acceptable.

The Division I and Division II hawh were replaced with the same model batteries having an improved post seal design in RPO3 and RFO4, respectively.

Battery service tests on the older batteries were success M showing that this size battery has the ability to handle the required loads. Al o, theimproved Division I and Division U battery post seal design has ulaimiW corrosima on connection points. Connection point corrosion could p pahally affect the results of abattery service test.

Previous performance & huge tests for both the Division Iand Division II batteries have been===*eful.

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I To determine the change in Core Damage Frequency (:DF), the PRA l

conservatively assumed that the battery will not functf( n at time zero if a fv11 or l

partaal loss of AC powu occurs. His results in a tem xyraIy or configuration-specific CDF of 2.17E 4/yr. Since the time period th: t the possible loss of baitcry function.will exist in the,,,two week p,eriod until phnt shutdown, the yearly CDF calet. lated by the PRA is adjusted to deter nine the Core Damage Probability (CDP) for this period. 'Ihis results in a CDP of 8.35Ee6 (2.17E-4*2/52). The CDP is based on the product of the risk rate (CDP) and the l

duration or portion of one year that the temporary con lition will exist (i.e., two weeks or 2/52).

On March 28,1998 at 1425 hours0.0165 days <br />0.396 hours <br />0.00236 weeks <br />5.422125e-4 months <br />, the offsite 115 Ky supply line (Line 5) to the Division I (and Division III) onsite chss 1E power dit ribution system tripped.

l As a result, the Division I diesel generator automaticaly started and re-energized the AC bus as required. A reactor building isola 00n occurred and both of the Division I and Division II Standby Gas Tri atment Systems were automatically started. There was a partia1 actuation oj the Division I Control Building Special Filter Train per design. The service aater non-essendal isolation valves auto closed and the Division Iload se< uencing circuitry auto started the Division I service wzfer pump. The Divisi m I Uninterruptible Power Supply (UPS) went on battery power maintaini ng power to the required UPS vital power distribution system.

This sequence of events verifies that the Division I ba' tery supplied power to the Division I diesel DC; fuel oil pvmp, field Dashing, oc tput breaker, the Division I UPS DC input, the Division Iload shedding and seg aencing and other required emergency Division I DC circuits. This furt ter vexifies that the Division I battery is capabic of adequately providing ; ower to those required critb1 systems that require emergency power to safel t shut down the plant and maintain it in a safe shutdown condition in conjunctica with a loss of off-site power event.

4 The basis for the licensee's conclusion that the noncon2plinnee will not be of potential detriment to the public bealth and safety and th it neither an unreviewed safety question nor a signiricant hazard consideration is is.volved.

NMPC has evaluated the missed surveillance event and has c mcluded that there is no significant hazards consideration involved with the requested tiotice of Enforcement Discretion (NOED). The sigtnficance of not performing SR t 8.2.id has been found not to be of potential detriment to Ole public health and safety based upon the evaluation provided in Item 3, which concludes that the Divi! ion I battery is capable of performmg its safety fonction, Thus, there is no safety corm quence associated with the regoest for enforcement discredon.

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NMPC has evaluated this request using the criteria set forth is 10CFR50.92, and determined that it does not involve a significant hazards consi,leration nor an unreviewed safety question.

Operation of NMP2 in accordance with the enforcement d scretion will not involve a significant increase in the probabig or consequences of an accident previously evaluated.

The NMP2 Division I batteries are not a 1 initiating event in a iy accident or transient.

Therefore, operation of NMP2 in accordance with the enforet ment discretion will not involve a significant increase in the probability of an accident previously evaluated.

The Division H and Division m batteries are operable and all appropriate surveillances are satisfied, indicating the systems' capability of performing their safety function.

Based upon the evaluation previously provided inItem 3, N1W PC bas concluded that the Division I battery is capable of performing its safety function during a design basis accident. Therefore, the enfes.ese discretion will not invc ve a significant increase id tbc consequences of an accident previously evaluated, Operation of NMP2 in accordance with the enforc=ent d kretion will not create the possibility of a new or diffe.snt kind of accident from any accident previously eralnated.

Based upon the performance of surveillance requirements to 4 ate, during a design basis scridmt, the Division H and Division m battedes will contin ne to perform their safety fonctions of providing the n==_y voltage and current to sa iety-related loads. The Division I battery will be fully functional and alsopapable of supporting its safety-related loads. There are no configuranon. changes to plant eq dpment and the plant is not operalad in a manner differently than previously analyzed Accordingly, the enforcement discretiorrwill not create thepossibility of a new or different kind of accident from any accident previously evaluated.

Operation of NMP2 in accordance with the proposed enfo reement discretion will not involve a "- # reductionin a margin of safety.

Tbs Division II and Division m banenes are fully operable a id all appropriate surveiUances are satis 6ad, indicating the systems' capability a f performing their safety function. Based upon the ev=tamia_n previously provided in I em 3, NMPC has concluded that the Division I battery is capable of performing its safety function during a design basis accident. Accordingly, the proposed enforcem ent discretion will not involve a signincant ~Metian in a margin of safety.

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mee win not involve The basis for the licensee's conclusion that the noncompli l

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adverse consequences to the environment, ttery. The requested The enforcement discretion involves the NMP2 Division I bs iounts or types of any enforcement discretion does not involve an increase in the as idualor cumulative a

effluents that thay be ret **wl offsite ner an increase in indis uncet discretion does not occupahonai r* Man exposure. Also, the requested enfore verlevelor involve physically modify the plant, increase the plant's licensed po'

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irreversible environment =1 consequences.

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" gy measures.

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Amy proposed c.

es operable during the NMPC will maintain the Division U and Division III batter beDivisionIbattcTy willbe enforcement discretion period. Also, resistance checks on i

> were completed on performed every 7 days during this period. The initial test April 18,1998.

i The. justification for the duration of the noncompliance 7.

l until NMP2's next entry into NMPC requests enforcement discreaan from TS 4.8.2.Id

,1998, NMP2 will shut Cold Shutdown but no later than May 3,1998. By May 3 1

m, the DivisionIbattery is down to begin Refueling Outage 6. Once in Cold Shutdoa

and enforcement discretion no longer required to be operable to meet TS requirement willno longer be needed.

facility organizatien that A sta**=*=t that the request has been approved by th<

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normaHy reviews safety lesues, approved by the NMP2 Site

'Ihis request for enforcement discretion was reviewed aru OperationsReview Comuh (SORC).

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Is 90ED criteria for The request umst specifically address how one of the satisGed.

9 appropriate plant cM*'== specified in Section B is l

NMP2 is currently operating. Secdon B of Part 9900, Criteria 1, states tha

> (a) avoid undesirable l!

operating plant, the enforcement discredon is intended t ase condition and, thus, transients as a result of forcing compliance with the Jice risks or (b) eliminate testing, sninimin: potential safety consegucoces and operational inspechon, or system realignment that is inappropriate f or the particular plant conditions. "Dds enforcement discretion meets criteria.

.(a)in that entry into TS 3.8.2.1, Action a would require a plant shutdown tc perform the missed i

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survedhnce. NMPC beJieves there is less riskin continued ( peration thanin forcing f

an unnmsary plant challenge by taking the plant to Shutdom to comply with the to be in Shutdown to l

requirements of TS 3.8.2.1, Action a. The plant is required fu fuss SR 4.8.2.1d.

a 1

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Jr a foDow-up license amendment is required, the NOED request must include marked up Technical $pecification pages Aowing the prc posed Technical uestmust follow within Specification changes. The actual Heense amendment rey 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />.

No follow-up license amendment is required as part of this enforcement discretion.

l A statement that prior adoption of approved line item in provanents to the 11.

Technical Specifications or the ITS would not have obvis tad the need for the NOED request.

theITS would not have l

Adoption of approved line item improvements to the TSs of l

obviated the need for the NOED request in that the ITS requires the test that was missed.

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Any other information theNRC staff deems necessary bdare msMng a decision to excrcise enforcement discreflon.

NMPC knows of no additionalinformation thatis necessar for processing this Icquest.

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TOTAL P.09 l

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