ML20217P281
| ML20217P281 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 03/03/1998 |
| From: | Terry C, Walker R TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| TXX-98062, NUDOCS 9803100188 | |
| Download: ML20217P281 (6) | |
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Log # TXX 98062
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File # 10010 g,7_yyg&ff 1UELECTRIC i
s$.IrScN,isen, March 3, 1998
& PrincipalNuclear Oficer U. S. Nuclear Regulatory Commission j
Attn: Document Control Desk Washington, DC 20555 I
SUBJECT:
COMANCHE PEAK STEAM ELECTRIC STATION (CPSES) - UNITS 1 AND 2 DOCKET NUMBERS 50-445 AND 50 446 ENFORCEMENT DISCRETION FOR ENGINEERED SAFETY FEATURES ACTUATION SYSTEM INSTRUMENTATION REF:
1.
NUREG 1600, " General Statement cf Policy and Procedures for NRC Enforcement Actions." dated June 1995 2.
NRC Inspection Manual.. Part 9900, " Operations - Enforcement Discretion," dated November 2. 1995 Gentlemen:
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 Units 1 and 2 to remain in MODE 1, POWER OPERATION,~for the purpose of crediting the performance of Surveillance Requirement 4.3.2.1, for Table 4.3 2 Channel Functional Units 8d, 8e and 8f. Without the requested enforcement discretion, compliance with CPSES Technical Specification 4.3.2.1 would require a plant shutdown to MODE 5. COLD SHUTDOWN. in order to demonstrate the OPERABILITY of the closed contact from the 62-2 time delay relay.
m, Compliance without enforcement discretion would require that TU Electric
/
R shutdown both units and deliberately remove all offsite power.
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The referenced section of the NRC Inspection Manual (reference 2) provides g"
guidance on the information to be included in a request for enforcement g-discretion.
The sections below are arranged to correspond to that g"
guidance.
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- 1. REQUIREMENT /REOUEST:
1 Surveillance Requirement 4.3.2.1 requires, in part, that the TRIP ACTUATING DEVICE OPERATIONAL TEST (TAD 0T) for Channel Functional Units 8d, 8e and 8f: 6.9kV Degraded Voltage, 480V Degraced Voltage and 480V Low Grid Undervoltage, respectively, be performed "whenever the plant is in COLD SHUTDOWN for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or more and if... not performed in the previous 92 days".
Failure to perform the surveillance requirement within the allotted surveillance interval allowed per Surveillance Requirement 4.0.2,
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TXX 98062 Phge 2 of 6 would result in failure to perform a Surveillance Requirement.
In accordance with Surveillance Requirement 4.0.3, this failure to perform the Surveillance Requirement would constitute a noncompliance with the OPERABILITY requirements for the LCC.
Further, in accordance with Surveillance Requirement 4.0.3, the ACTION require =ents 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 completion of the surveilience 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 4.3.2.1, TU Electric requests that the requirement to perform the surveillance at COLD SHUTDOWN be waived in order to demonstrate the OPERABILITY of the closed contact from the 62 2 time delay relay, by allowing credit of testing conducted during POWER OPERATIONS.
Failure to perform the Surveillance Requirements during l
MODE 1, POWER OPERATIONS. would result in the inoperability declaration of both A.C. Offsite Power Sources for each unit in accordance with Table 3.3 2 Action Statement 23e.
This ACTION requires in part, that CPSES
" declare both Offsite Power Sources inoperable, take the Action-required by Specification 3.8.1.1, and open both offsite power breakers to the affected bus within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />."
i TU Electric requests that the NRC exercise enforcement discretion to not enforce compliance with the COLD SHUTDOWN portion of the Surveillance Requirement 4.3.2.1, Channel Functional Units 8d, 8e and 8f TAD 0Ts in i
l order that CPSES not be required to declare otherwise 0PERABLE Offsite Power Sources inoperable and comply with LCO Table 3.3 2 Action Statement 4
23e. Additionally, CPSES has already verified the continuity of the portion of the circuit which had not previously been tested. As such, CPSES considers the TAD 0Ts to be complete with the exception of literal l
compliance with the COLD SHUTDOWN requirement. Testing of differing magnitude would not be required at COLD SHUTDOWN conditions and would l
serve the came purpose as the testing already completed.
- 2. CIRCUMSTANCES:
During the process of conducting reviews in accordance with U.S. NRC Generic Letter 96-01, CPSES discovered that the closed contact from the 62 2 time delay relay has not been tested in accordance with the surveillance requirements of Technical Specification 4.3.2.1.
This omission in the surveillance program at CPSES has been present since the time of initial license and was identified on March 3,1998 at 10:10 a.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 3, 1998 10:10 a.m. CST is allowed per Surveillance Requirement 4.0.3 to perform the Surveillance Requirement.
TU Electric believes that crediting performance of a portion of Surveillance Requirement 4.3.2.1 Channel Functional Units 8d, 8e and 8f TAD 0Ts during POWER OPERATIONS as opposed to COLD SHUTDOWN is acceptable with respect to overall safety and does not constitute an unreviewed safety question as detailed in the following sections.
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TXX 98062 Plge 3 of 6 i
- 3. SAFETY SIGNIFICANCE AND POTENTIAL CONSEQUENCES:
The safety function of the closed contact from the 62-2 time delay relay is to maintain continuity for the purpose of actuation of the 480V degraded and low grid voltage circuits as well as the 6.9kV degraded voltage. These circuits are relied upon to ensure that the offsite circuit breakers are opened in order to allow the safety related diesel
-9enerators to load on a de-energized electrical bus, during offsite power perturbation events.
TU Electric has reviewed the required testing and has determined that an acceptable test for demonstrating the OPERABILITY. of the closed contact from the 62 2 time delay relay, can be performed during POWER OPERATIONS with no adverse effect to the A.C. electrical distribution system. TU Electric is aware that the preclusion from performing these surveillance tests at conditions other than shutdown is to avoid the potential for perturbations to the A.C. electrical distribution system and thereby result in a challenge to safety systems. The tests which would demonstrate the closed' contact from the 62 2 time delay relay, are a small segment of the complete TAD 0T. This segment comprises a continuity check across one contact and does not pose the potential for opening a breaker as would normally be the case during performance of the complete TADOT.
By performance of this testing, TU Electric has eliminated the potential for creating a perturbation to the A.C. electrical distribution system while the reactor is critical. The test, a continuity check, was successfully performed with no adverse system effects.
TU Electric believes that the crediting of this segment of the TAD 0T is both acceptable and appropriate during POWER OPERATIONS. The potential consequences resulting from a coincident shutdown of both units of CPSES and the possible perturbations induced into the A.C. grid are clearly higher than those of crediting this testing segment during POWER OPERATIONS. Therefore, the possible consequences of c.onducting a dual unit shutdown in order to demonstrate the OPERABILITY of the closed contact from the 62-2 time delay relay far exceeds the potential consequences cf crediting the testing segment in order to satisfy the Surveillance Requirement.
- 4. UNREVIEWED SAFETY OUESTION / NO SIGNICICANT HAZARDS CONSIDERATION:
TV 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?
Crediting performance of the portion of surveillance testing necessary to demonstrate the OPERABILITY of the closed contact from the 62 2 time delay relay, will not increase the probability or i
TXX 98062 Pnge 4 of 6 consequences of an accident previously evaluated. The conclusion
-has been reached that the probability of initiating a perturbation in the A.C. electrical distribution system is not created via the crediting of the tests. As the testing was only conducted on one channel per unit at a given time, no increase in consequences, other than those previously postulated. is considered credible.
2.
Do the proposed changes create the possibility of a new or.different kind of accident from any accident previously evaluated?
Perturlvtions in the A.C. electrica1 distribution system have been fully considered within the Final S'afety Analysis Report.
No new or-different kind of perturbation or accident is deemed credible from crediting the performance of the tasting.
3.
Do the proposed changes involve a significant reduction in a margin of safety?
Crediting the required testing does not create any new failure scenarios or A.C. electrical distribution perturbations, no associated margin is expected to be reduced.
As r,uch, no reduction in any margin of safety is anticipated.
TV Electric has performed a safety evaluation, and has determined, in accordance with 10CFR50.59 that crediting the performance of the segment of testing necessary to de~onstrate the OPERABILITY of the closed contact from the 62-2 time delay cay does not constitute an unreviewed safety question.
In summary, using 10CFR50.59 and 10CFR50.92, TU Electric has determined that crediting the necessary testing does not constitute an unreviewed safety question or a significant hazard.
- 5. ENVIRONMENTAL CONSEQUENCES:
The request only involves the crediting of performance of testir.g 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:
Perfcreance of the required testing was conducted on only one channel per unit at any given time. Although not necessary, this action precludes a common occurrence to Loth channels per bus. This compensatory measure was in place during the conduct of the tests.
TXX 98062 Page 5 of 6
- 7. DURATION:
The requested duration of this enforcement discretion is 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to allow for a one time credit for performance on each train within the allotted time of Surveillance Requirement 4.0.3.
The enforcement discretion will expire at March 4, 1998 at 10:10 a.m. CST.
- 8. SORC REVIEW:
This activity has been reviewed and approved by the Station Operations Review Committee (SORC).
- 9. CRITERIA FOR EXERCISING ENFORCEMENT DISCRETION:
j 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 two unit shutdown to comply with the subject technical specification would subject CPSES to an undesirable transient which poses greater safety consequences than crediting performance of the already completed surveillance requirement segment during POWER OPERATION.
- 10. PROPOSED TECHNICAL SPECIFICATION CHANGES:
The requestod enforcement discretion is temporary for a period of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and nonrectrring. 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.
considering the CPSES plant design.
- 12. ADDITIONAL INFORMATION REQUESTED BY THE NRC STAFF:
l The NRC staff has requested no additional information.
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TXX-98062 Page 6 of 6 CONCLUSION:
TU Electric requests the NRC grant the requested enforcement discretion to allow CPSES to credit the performance of Surveillance Requirement 4.3.2.1, for Table 4.3 2 Channel Functional Units 8d, 8e and 8f., for the closed contact from the 62-2 time delay relay during POWER OPERATIONS.
If there is a significant change in the circumstances associated with this exercising of enforcement discretion, TU Electric will notify the NRC. A response is requested by March 3, 1998 at 6:00 p.m. CST.
Sincerely,
- 8. f. Wuup C. L. Terry k
By:
<N RogeV D. Walker Regulatory Affairs Manager RTB/rb c
Mr. E. W. Merschoff, RIV Mr. T. J. Polich, NRR Mr. J. I. Tapia, RIV CPSES Resident Inspectors j
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