ML20249B159
| ML20249B159 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 05/05/1998 |
| From: | Merschoff E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Cottle W HOUSTON LIGHTING & POWER CO. |
| References | |
| 98-4-006, 98-4-6, NUDOCS 9806220122 | |
| Download: ML20249B159 (6) | |
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NUCLEAR REGULATORY COMMISSION g
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MAY - 51998 William T. Cottle, President and Chief Executive Officer STP Nuclear Operating Company P.O. Box 289 Wadsworth, Texas 77483
SUBJECT:
NOTICE OF ENFORCEMENT DISCRETION FOR STP NUCLEAR OPERATING COMPANY REGARDING SOUTH TEXAS PROJECT, UNIT 1, NOED NO. 98-4-006
Dear Mr. Cottle:
By letter dated May 1,1998, you requested that the NRC exercise discretion not to enforce compliance with the actions required by Technical Specification 3.0.3, because repairs to a failed Unit 1, fuel handling building exhaust booster Fan 118 required you to temporarily render all three trains of the fuel handling building exhaust systems inoperable. Your request for a Notice of Enforcement Discretion (NOED) was reviewed by the staff in accordance with the NRC's policy regarding exercise of discretion for an operating facility, set out in Section Vll.c, of the General Statement of Policy and Procedures for NRC Enforcement Actions," NUREG-1600.
Specifically, you requested discretion to not enforce Technical Specification 3.0.3 as it applied to the requirements of Technical Specifications 3.7.8(b)," Fuel Handling Building Exhaust Air System," and 3.3.2, " Engineered Safety Features Actuation System Instrumentation," which requires that three independent Fuel Handling Building Exhaust Booster Fans, three
= independent Fuel Handling Building Main Exhaust Fans, and certain instrumentation be operable. Your May 1,1998, letter and its supplement dated May 4,1998, documented information discussed with the NRC in a telephone conversation on May 1,1998. During that telephone conversation, you stated that, in order to facilitate repairs to failed exhaust booster
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Fan 11B, that shared a common supply plenum and a common exhaust plenum with the
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remaining trains, you would have to disable the fuel handling building exhaust air system to maintain adequate personnel safety while installing and removing a temporary modification.
Once installed, the temporary modification allowed the remaining portion of the fuel handling building ~ exhaust air system to operate while the exhaust booster Fan 118 motor was being replaced. However, to facilitate this approach, the NRC would need to exercise discretion not to l
- enforce compliance with the actions re-quired by Technical Specification 3.0.3, for a maximum period of 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> to install the temporary modification and a maximum period of 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> to remove the temporary modification.
l The safety basis for the staff's exercise of discretion was to avoid an undesirable plant transient as a result of forcing compliance with the license condition for which no compensatory benefit to public health and safety existed. Compensatory measures proposed by you for the duration of the NOED and considered in the staff's evaluation included: (1) stopping the movement of any loads over the spent fuel pool, (2) stopping any movement of irradiated fuel assemblies, (3)
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STP Nuclear Operating Company e stopping all activities which could potentially affect spent fuel pool level or cooling, and (4) developing work instructions, a pre-job briefing, and training to restore the fuel handling building exhaust system within 16 minutes of any identified reactor coolant system leak or reactor trip. These compensatory measures were determined to be sufficient to prevent any increase in either onsite and offsite dose consequences following a postulated fuel handling or loss of coolant accident and, as such, the proposed NOED did not involve an unreviewed safety question.-
On the basis of the staff's evaluation of your request, including the compensatory measures described above, the staff has concluded that an NOED is warranted because we are clearly satisfied that this action involves minimal or no safety impact and has no adverse radiological impact on public health and safety. Additionally, we determined that your request satisfied the NRC's policy for enforcement discretion. Therefore, it is our intention to exercise discretion not to enforce compliance with Technical Specification 3.0.3 as it relates to Technical Specification 3.7.8(b) and 3.3.2 for a maximum of 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> to install and 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> to remove the temporary modification described above. This discretion is allowed to be used once during the seven day allowed outage time for the applicable Technical Specification discussed above. This letter documents our telephone conversation on May 1,1998, at 4:40 p.m. (CDT) when we orally issued this notice of enforcement discretion.
Accordingly, at 10:34 p.m. on May 1, you secured the fuel handling building exhaust system to install the temporary modification, and restored two trains to service after completing the installation at 2:22 a.m. on May 2. After completing the fan motor replacement, at 10:37 p.m. on May 2, you again secured the fuel handling building exhaust system to remove the temporary modification, and restored two trains to service after completing the removal at 2:24 a.m. on May 3. At 4:31 a.m. on May 4, all testing was complete on the new fan motor and you restored all three fuel handling building exhaust booster fans to an operable status.
It is the NRC's policy to not exercise discretion involving recurring problems, such as requests for the same reasons or some similarly avoidable situation. Because a similar failure of a Unit 2 fuel handling building exhaust booster fan motor which occurred in 1992 required the staff to exercise a temporary waiver of compliance, a significant number of questions were raised by the staff during the May 1 telephone conference. These questions were necessary in order for the staff to determine if circumstances warranted enforcement discretion considering our existing policy. During the May 1 telephone conference, the NRC requested that you document the additional information discussed on May 1 related to the actions taken to prevent recurrence of this problem by May 4. Your written response was received by the NRC on May 4 and it confirmed the May 1 discussions.
Your letters indicated that the symptoms of the two failures were different. In addition, you outlined corrective actions implemented by your staff following the 1992 failure. These corrective actions included increasing the frequency of vibration monitoring and periodic testing of fan motor insulation resistance (which you have since stopped because of limited insights gained on motor performance). Although responsive to the original failure, the corrective actions
. implemented following the 1992 failure did not prevent the need for you to again need discretion for a fuel handling building exhaust booster fan failure. Because circumstances were sufficiently L
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l STP Nuclear Operating Company different, the_ NRC concluded that it was appropriate to exercise discretion in this case.
However, the NRC recommends you ceek more through corrective actions for the problem of a L
booster fan failure for any reason as we are not likely to propose to exercise such discretion in the future.
In your May 4 letter, you committed to take the following actions: (1) perform a root cause evaluation of the 11B exhaust motor fan failure, (2) evaluate physical plant modifications that would enhance the ability to isolate the individual components or trains, (3) review the design -
basis for the three-train system to determine if adequate design margin can be maintained with -
one train inoperable, (4) review the applicable Technical Specifications to determine if there might be changes that would facilitate the ability to work on these components in the future, and' (5) review periodic and preventive maintenance to identify actions that could be taken to preclude failures. These commitments will be verified during an NRC inspection once they have been completed. As stated in the Enforcement Policy, action will normally be taken, to the extent that violations were involved, for the root cause that led to the noncompliance for which this NOED was necessary. ' This determhation will be made during the planned NRC inspection.
Sincerely, -
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./f Ellis W. Merscho Regional Admi istrator Docket Nos.: 50-498 50-499 License Nos.: NPF-76 NPF-80 cc:
Lawrence E. Martin, Vice President Nuclear Assurance & Licensing STP Nuclear Operating Company P.O. Box 289
' Wadsworth, Texas 77483 ~
? A. Ramirez/C. M. Canady
= City of Austin -
Electric Utility Department 721 Barton Springs Road Austin, Texas 78704
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' STP Nuclear Operating Company l, Mr. M. T. Hardt/Mr. W. C. Gunst City Public Service Board P.O. Box 1771 San Antonio, Texas 78296 D.' G. Tees /Ri L. Balcom
- Houston Lighting & Power Company
. P.O.- Box 1700 Houston, Texas 77251 Jon C: Wood 4
. Matthews & Branscomb
- One Alamo Centers 106 S. St. Mary's Street, Suite 700 San Antonio, Texas 78205-3692 Jack R. Newman, Esq.
Morgan, Lewis & Bockius 1800 M. Street, N.W..
- Washington, D.C.' 20036-5869 Mr. G. E. Vaughn/Mr. C. A. Johnson -
Central Power & Light Company P.O. Box 289 -
MailCode: N5012 Wadsworth, Texas 77483
!NPO Records Center 700 Galleria Parkway Atlanta, Georgia 30339-5957
- ' Bureau of Radiation Control i
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.- State of Texas 1100 West 49th Street i Austin Texas - 78756 -
1Mr. Jim Calloway -
Texas Public Utility Commission f William B. Travis Building 1701 North Congress Avenue P.O. Box.13326 i Austin, Texas 78701-3326:
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Project Engineer (DRP/A)
Branch Chief (DRP/TSS)
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