WO 08-0006, Request for Notice of Enforcement Discretion from Technical Specification 3.8.1, AC Sources - Operating.

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Request for Notice of Enforcement Discretion from Technical Specification 3.8.1, AC Sources - Operating.
ML080580313
Person / Time
Site: Wolf Creek Wolf Creek Nuclear Operating Corporation icon.png
Issue date: 02/15/2008
From: Matthew Sunseri
Wolf Creek
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
WO 08-0006
Download: ML080580313 (11)
v • d • e


Text

W#ILF CREEK 'NUCLEAR OPERATING CORPORATION Matthew W. Sunseri Vice President Operations and Plant Manager February 15, 2008 WO 08-0006 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555

Subject:

Docket No. 50-482: Request for Notice of Enforcement Discretion from Technical Specification 3.8.1, "AC Sources - Operating" Gentlemen, This letter confirms the results of the teleconference that was conducted between Wolf Creek Nuclear Operating Corporation (WCNOC) and NRC Staff representatives at 1830 hours0.0212 days <br />0.508 hours <br />0.00303 weeks <br />6.96315e-4 months <br /> on February 13, 2008 in which WCNOC requested the NRC to exercise enforcement discretion for the Wolf Creek Generating Station (WCGS), regarding the requirements of Technical Specification (TS) 3.8.1, "AC Sources - Operating." With the plant operating in MODE 1 at approximately 99% rated thermal power, the request was made in order to provide additional time to repair and test the "A" Centrifugal Charging Pump (CCP) room cooler (SGL12A) and restore the "A" CCP before a plant shutdown would have otherwise been required.

The events leading to WCNOC's request began when water was identified coming from the drip pan for the "A" CCP room cooler at 1420 hours0.0164 days <br />0.394 hours <br />0.00235 weeks <br />5.4031e-4 months <br /> Central Standard Time (CST) on February 13, 2008. At 1445 hours0.0167 days <br />0.401 hours <br />0.00239 weeks <br />5.498225e-4 months <br /> the room cooler was de-activated to identify the source of the water. At 1550 hours0.0179 days <br />0.431 hours <br />0.00256 weeks <br />5.89775e-4 months <br />, after the removal of the outer cover panel of the room cooler, a leak was identified on a room cooler H-bend assembly. The "A" CCP room cooler and "A" CCP were conservatively declared inoperable back at time 1420 hours0.0164 days <br />0.394 hours <br />0.00235 weeks <br />5.4031e-4 months <br />. TS 3.5.2, Condition A/Required Action A.1 was entered with a 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> Completion Time to restore the inoperable train ("A" CCP) to OPERABLE status. Additionally, Condition B/Required Action B.2 was entered with a Completion Time of 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> to declare the required feature(s) supported by the inoperable DG inoperable when its required redundant feature(s) is inoperable (i.e., 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> to declare the "B" CCP inoperable). On February 11, 2008, at 0502 hours0.00581 days <br />0.139 hours <br />8.300265e-4 weeks <br />1.91011e-4 months <br />, the "B" diesel generator (DG) had been declared inoperable for voluntary planned maintenance activities in accordance with TS 3.8.1, Required Action B.4.2.1 and B.4.2.2. Required Action B.4.2.2 specifies a Completion Time of 7 days to restore the DG to OPERABLE status. When the "A" CCP was declared inoperable, entry into TS 3.8.1 Condition B/Required Action B.2 was required as discussed in the TS Bases.

P.O. Box 411 / Burlington, KS 66839 / Phone: (620) 364-8831 An Equal Opportunity Employer M/F/HCNVET

WO 08-0006 Page 2 of 2 Enforcement discretion was sought to permit non-compliance with the Completion Time of Required Action B.2 of LCO 3.8.1, i.e., to permit additional time to complete repairs and restoration of the "A" CCP room cooler and restoration of the "A" CCP before a plant shutdown was required. An additional 15 hours1.736111e-4 days <br />0.00417 hours <br />2.480159e-5 weeks <br />5.7075e-6 months <br /> was requested to restore the "A" CCP room cooler and "A" CCP to OPERABLE status by 0920 hours0.0106 days <br />0.256 hours <br />0.00152 weeks <br />3.5006e-4 months <br /> on February 14, 2008, such that entry into MODE.

3 would not be required until 1620 hours0.0188 days <br />0.45 hours <br />0.00268 weeks <br />6.1641e-4 months <br /> on February 14, 2008. The requested additional time for restoring the "A" CCP room cooler and "A" CCP had been evaluated and shown to be less than the Regulatory Issue Summary 2005-01 risk metric criteria for incremental conditional core damage probability (ICCDP) and incremental. conditional large early release probability (ICLERP). Qualitative factors favoring the request, include avoiding transition to shutdown, repair, and transition to power operation, and a possible consequential loss of offsite power with only one OPERABLE DG. In addition, it had been determined that there was no net increase in radiological risk.

At 1950 hours0.0226 days <br />0.542 hours <br />0.00322 weeks <br />7.41975e-4 months <br /> CST on February 13, 2008, Tony Vegel, Deputy Director, Division Reactor Projects, Region IV, notified WCNOC that after NRC Region IV Office consideration of WCNOC's verbal request for enforcement discretion, and in consultation with the NRR technical staff, the request for a Notice of Enforcement Discretion (NOED) was approved.. The approval was effective and would begin at 1420 hours0.0164 days <br />0.394 hours <br />0.00235 weeks <br />5.4031e-4 months <br /> on February 14, 2008 for a total of 19 hours2.199074e-4 days <br />0.00528 hours <br />3.141534e-5 weeks <br />7.2295e-6 months <br />. WCNOC is required to submit a written request for the NOED within 2 working days of the NRC verbal approval.

Subsequently, at 0141 hours0.00163 days <br />0.0392 hours <br />2.331349e-4 weeks <br />5.36505e-5 months <br /> on February 14, 2008, the condition causing the need for this enforcement discretion was corrected resulting in exiting Required Action B.2 in TS 3.8.1 and from this NOED.

The Attachment provides the information documenting WCNOC's earlier verbal request for the NOED. If you have any questions concerning this matter, please, contact me at (620) 364-4008, or Mr. Richard D. Flannigan, Manager Regulatory Affairs at (620) 364-4117.

Sincerely, Matthew W. Sunseri MWS/rlt Attachment cc: E. E. Collins (NRC), w/a V. G. Gaddy (NRC), w/a B. K. Singal (NRC), w/a Senior Resident Inspector (NRC), w/a

Attachment to WO 08-0006 Page 1 of 9 Request for Notice of Enforcement Discretion from Technical Specification 3.8.1, "AC Sources 7 Operating"

1. The Technical Specification (TS) or other license conditions that will be violated.

Wolf Creek Nuclear Operating Corporation (WCNOC) specifically requests enforcement discretion from the requirements of Required Action B.2 of LCO 3.8.1, i.e., to permit additional time to complete repairs and restoration of the "A" CCP room cooler and restoration of the "A" CCP before a plant shutdown was required in accordance with LCO 3.0.3. TS 3.8.1, Required Action B.2 requires declaring inoperable required feature(s) supported by the inoperable diesel generator (DG) when its required redundant feature(s) is inoperable within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> from discovery of Condition B.

Enforcement discretion was sought such that it would allow up to an additional 15 hours1.736111e-4 days <br />0.00417 hours <br />2.480159e-5 weeks <br />5.7075e-6 months <br /> for restoring the "A" CCP room cooler and "A" CCP to OPERABLE status. In effect, it would allow delaying declaring the "B" CCP inoperable until 0920 hours0.0106 days <br />0.256 hours <br />0.00152 weeks <br />3.5006e-4 months <br /> Central Standard Time (CST) on February 14, 2008. Declaring the "B" CCP inoperable would result in entry into LCO 3.0.3 and initiation of a plant shutdown.

2. The circumstances surrounding the situation: including likely causes; the need for prompt action; action taken in attempt to avoid the need for an NOED; and identification of any relevant historical events.

At 1420 hours0.0164 days <br />0.394 hours <br />0.00235 weeks <br />5.4031e-4 months <br /> on February 13, 2008 water was identified coming from the drip pan for the "A" CCP room cooler. At 1445 hours0.0167 days <br />0.401 hours <br />0.00239 weeks <br />5.498225e-4 months <br /> the room cooler was de-activated to identify the source of the water. At 1550 hours0.0179 days <br />0.431 hours <br />0.00256 weeks <br />5.89775e-4 months <br />, after the removal of the outer cover panel of the room cooler, a leak was identified on a room cooler H-bend assembly. The "A" CCP room cooler and "A" CCP were conservatively declared inoperable back at time 1420 hours0.0164 days <br />0.394 hours <br />0.00235 weeks <br />5.4031e-4 months <br />. TS 3.5.2, Condition A/Required Action A.1 was entered with a 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> Completion Time to restore the inoperable train ("A" CCP) to OPERABLE status. Additionally, Condition B/Required Action B.2 was entered with a Completion Time of 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> to declare the required feature(s) supported by the inoperable DG inoperable when its required redundant feature(s) is inoperable (i.e., 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> to declare the "B" CCP inoperable). On February 11, 2008, at 0502 hours0.00581 days <br />0.139 hours <br />8.300265e-4 weeks <br />1.91011e-4 months <br />, the "B" DG had been declared inoperable for voluntary planned maintenance activities in accordance with TS 3.8.1, Required Action B.4.2.1 and B.4.2.2. Required Action B 4.2.2 specifies a Completion Time of 7 days to restore the DG to OPERABLE status. When the "A" CCP was declared inoperable, entry into TS 3.8.1 Condition B/Required Action B.2 was required as discussed in the TS Bases.

At 1820 hours0.0211 days <br />0.506 hours <br />0.00301 weeks <br />6.9251e-4 months <br /> on February 13, 2008, Control Room operators declared the "B" CCP inoperable, entered LCO 3.0.3, and initiated action within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> to place the unit in MODE 3. At the time of the approval of the request for Notice of Enforcement Discretion, the plant had reduced rated thermal power to approximately 90%.

During the request for enforcement discretion telecon in response to a question by the NRC, WCNOC indicated that there had been two previous repairs to the "A" CCP room cooler. A further review of maintenance history has identified three previous repairs. On October 9 and 10, 2003, a threaded hex nut replacement occurred. On December 12, 2004, an H-bend assembly and a threaded hex nut replacement occurred. On October 8, 2006, an o-ring replacement on an H-bend assembly occurred.

Attachment to WO 08-0006 Page 2 of 9

3. Information to show that the cause and proposed path to resolve the situation are understood, such that there is a high likelihood that planned actions to resolve the situation can be completed within the proposed NOED time frame.

At 1550 hours0.0179 days <br />0.431 hours <br />0.00256 weeks <br />5.89775e-4 months <br />, after the removal of the outer cover panel of the room cooler, a leak was identified on a room cooler H-bend assembly. Visual observation of the H-bend assembly identified that the leak was due to a through-wall flaw at the threaded hex nut. Figure 1 provides a diagram of the H-bend assembly and the location of the through-wall flaw. WCNOC has had previous experience with repairing leaks on the room cooler H-bend assembly as discussed in Section 2 above.

Initially it was believed that the most likely cause was due to long term maintenance activities associated with the connection. Upon removal of the H-bend assembly identified that the most likely cause of the leak was due to flow induced erosion. The "A" CCP room cooler remains scheduled for replacement in the upcoming refueling outage (March 2008).

Existing Tube at Row 42 Tube 4 Existing Tube at Row 43 Tube 4 WJ-2 -- - - - J-4 BJ-6 Item 5 5

Item 33 X .Item 4 BIJ-1 / BJ-5 BJ-3 Item 1 Room Cooler H-Bend Assembly

Attachment to WO 08-0006 Page 3 of 9

4. The safety basis for the request, including an evaluation of the safety significance and potential consequences of the proposed course of action.

Incremental Conditional Core Damage Probability (ICCDP) and Incremental Conditional Large Early Release Probability (ICLERP) Determination The WCGS zero maintenance Revision 4 Probabilistic Risk Assessment (PRA) model was used to quantify the impact on risk of extending the allowed outage time per this request. Core Damage Frequency (CDF), Large Early Release Frequency (LERF), Incremental Conditional Core Damage Probability (ICCDP), and Incremental Conditional Large Early Release Probability (ICLERP) factors are listed below.

The PRA model configuration consisted of the "A" train aligned for service, with the following three PRA structures, systems, and components (SSCs) non-functional:

  • "B" DG (KKJO1 B) in 7 day extended Completion Time
  • Steam dump valve to intermediate pressure condenser (ABUVO044)

Additionally, as a conservative consideration for risk evaluation, one Sharpe Station genset is considered non-functional. This plant configuration is referred to as Case 1.

The WCGS PRA model assumes a complete dependency of the CCP Room Cooler for successful operation of the CCP. Case 2 adds the non-functional "A" CCP (PBG05A) to the non-functional SSCs of Case 1.

CDF1 and LERF1 are defined as the CDF and LERF values reflecting the plant configuration of Case 1. CDF 2 and LERF 2 are defined as the CDF and LERF values reflecting the plant configuration of Case 2.

CDF/yr LERF/yr Case 1. "B" DG in extended Completion Time 4.02E-05 2.55E-06 Case 2. Add "A" CCP room cooler non-functional 4.58E-05 2.55E-06 The ICCDP and ICLERP were calculated using Equations 1 and 2 below.

Equation 1: ICCDP = (CDF 2 - CDF 1 ) x Duration in years Equation 2: ICLERP = (LERF 2 - LERF 1 ) x Duration in years The Duration in years is defined as the additional time for the plant to be in the emergent condition. While this request is for an additional 15 hours1.736111e-4 days <br />0.00417 hours <br />2.480159e-5 weeks <br />5.7075e-6 months <br /> (approximately 1.71 E-03 years), the ICCDP and ICLERP are calculated using a bounding 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> (approximately 2.74E-03 years).

ACDF = 4.58E 4.02E-05 = 5.60E-06 ICCDP = (4.58E 4.02E-05)*2.74E-03 = 1.53E-08 ICLERP = (2.55E 2.55E-06)*2.74E-03 = 0.0 The calculated value for ICCDP meets the Regulatory Issue Summary 2005-01, "Changes to Notice of Enforcement Discretion (NOED) Process and Staff Guidance," threshold of less than or equal to 5.OE-07, and ICLERP of less than or equal to 5.OE-08. The calculated ICCDP value

Attachment to WO 08-0006 Page 4 of 9 reported above does not account for various qualitative conservatisms in place including, but not limited to, the following:

  • Just-In-Time training of the operations staff on Top Operator Actions (see Operator Action Review discussion below)
  • "A" CCP in a functional status, but inoperable due to room cooler non-functional
  • CCP room volume communicates with the Safety Injection and Containment Spray pump rooms which have their own functional room coolers.

Dominant Risk Contributors Three initiating events account for the majority of the total conditional core damage contribution.

As expected, loss of offsite power (INIT-LSP) dominates all other initiating events. Small LOCA (INIT-SLO) and very small LOCA (INIT-VLO) are the next highest CDF contributors. LERF did not change from Case 1 to Case 2.

Case 1 CDF Case 2 CDF INIT-LSP 55.0% 59.7%

INIT-SLO 21.5% 19.5%

INIT-VLO 4.6% 4.1%

Sub-total 81.1% 83.3%

Important functional components from the Safety MonitorTM with consideration for the "B" DG unavailability are the Class 1E DC Bus SSCs (e.g., NK001, NK054, NK004), Startup Transformer, Essential Service Water (ESW) Train "A", Class 1 E Electrical Bus NB002, No. 7 Switchyard Transformer, "A" DG, and "A" Component Cooling Water (CCW) Train.

Compensatory Risk Manaaement Measures Compensatory risk management measures in place for the DG equipment outage serve to minimize challenges to the dominant CDF contributor of Loss of Offsite Power. These items include:

  • Avoidance of testing and maintenance impacting availability of the "A" train safety bus, including but not limited to, the ESW System, Motor Driven Auxiliary Feedwater Pump (MDAFP), Turbine Driven Auxiliary Feedwater Pump (TDAFP), Component Cooling Water (CCW) System, Residual Heat Removal (RHR) System, Air Conditioning Units, and all 125 Volt DC System (NK) Batteries and the associated DG to maximize the mitigative response to a Station Blackout Event (SBO)
  • Ensure no switchyard work is allowed. This includes XMR01, No. 4, 5, and 7 transformers.
  • Enhanced operator sensitivity to safety bus electrical power supply issues to recognize and respond expeditiously to an SBO or loss of offsite power event (e.g., posting of Protected Train signage)

" Continual monitoring by the grid operator regarding grid conditions to anticipate challenges to offsite power availability

" Availability of the Sharpe Station to mitigate an SBO and station operator just-in-time training

Attachment to WO 08-0006 Page 5 of 9 Operator Action Review Safety Monitor TM Case 2 cutsets were reviewed down to 5.OE-07 CDF for operator actions.

Two actions were identified and given to the Shift Manager for discussion with Control Room staff. The purpose was to refresh important actions that could emerge with additional postulated SSC failures given a plant initiating event.

The specific PRA Operator Actions discussed in the enforcement discretion teleconference:

1. OPA-RRI1. Align and start one CCP or safety injection pump following reactor coolant pump seal LOCA to restore Reactor Coolant System inventory (auxiliary feedwater or main feedwater available), and
2. OPA-RHR. Stop RHR pumps during a high pressure injection event.

Weather Forecast The National Weather Service forecast for the duration of the request for enforcement discretion is that temperatures will be in the mid-40's for highs and lower 30's for lows. The conditions are expected to be mostly clear. No severe weather or significant front is expected to be moving through the area for the duration of the requested enforcement discretion.

5. The justification for the duration of the non-compliance.

As discussed in the probabilistic risk assessment above, extending the Completion Time of TS 3.8.1, Required Action B.2 from 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> to 19 hours2.199074e-4 days <br />0.00528 hours <br />3.141534e-5 weeks <br />7.2295e-6 months <br /> results in less than the Regulatory Issue Summary 2005-01 risk metric criteria for ICCDP and ICLERP.

A total of 19 hours2.199074e-4 days <br />0.00528 hours <br />3.141534e-5 weeks <br />7.2295e-6 months <br />, from the entry into Required Action B.2 of TS 3.8.1 (1420 hours0.0164 days <br />0.394 hours <br />0.00235 weeks <br />5.4031e-4 months <br /> on February 13, 2008) will provide the necessary time to effect repairs of the "A" CCP room cooler and restore the cooler and "A" CCP to OPERABLE status.

Activities to prepare for and perform repairs to the "A" CCP room cooler are currently in progress and are being worked on a 24-hour schedule until completion. The following compensatory measures discussed in Section 4 above were being taken in conjunction with the "B" DG planned maintenance activities.

6. The condition and operational status of the plant (including safety-related equipment out of service or otherwise inoperable).

Currently, the plant is operating in MODE 1 at approximately 99% power with a Technical Specification required shutdown in progress. The current Plant Awareness Level is 2. Plant Awareness Level identifies the risk of performing work activities, by considering core damage frequency and commercially significant equipment.

The following list of safety-related components are currently inoperable or out of service:

KKJ01 B, Diesel Generator "B" SGL12A, CCP "A" Room Cooler PBG05A, CCP "A" (administratively inoperable per Technical Specifications)

PBG05B, CCP "B" (administratively inoperable per Technical Specifications)

Attachment to WO 08-0006 Page 6 of 9

7. The status and potential challenges to off-site and on-site power sources.

Currently, the plant is providing power to the offsite power grid and all offsite power sources and the "A" DG is OPERABLE. According to System Operations (Westar Energy Transmission Services), there are no abnormalities with the transmission system. Control Room staff are continuing to monitor off-site power. The required Sharpe Station gensets are available to mitigate an SBO.

8. The basis for the conclusion that the noncompliance will not be of potential detriment to the public health and safety.

The request for enforcement discretion is to allow an additional 15 hours1.736111e-4 days <br />0.00417 hours <br />2.480159e-5 weeks <br />5.7075e-6 months <br /> to TS 3.8.1, Required Action B.2, to effect repairs to the "A" CCP room cooler and restore the room cooler and "A" CCP. WCNOC has evaluated whether or not a significant hazards consideration is involved with the requested enforcement discretion by focusing on the three standards set forth in 10 CFR 50.92(c) as discussed below:

(i) Do the proposed changes involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No Overall protection system performance will remain within the bounds of the previously performed accident analyses since no hardware changes are proposed. The protection systems (Reactor Trip System and Engineered Safety Features Actuation System) will continue to function in a manner consistent with the plant design basis. This additional allowed time does not result in a condition where the design, material, and construction standards that were applicable prior to the change are altered.

The one-time extension of the Completion Time does not adversely affect accident initiators or precursors nor alter the design assumptions or the manner in which the plant is normally operated and maintained.

Therefore, the proposed request does not involve a significant increase in the probability or consequences of an accident previously evaluated.

(ii) Do the proposed changes create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No The one-time extension of the Completion Time does not result in a change in the manner in which the electrical distribution subsystems provide plant protection. The request for enforcement discretion does not introduce any changes or mechanisms that create the possibility of a new or different kind of accident. The change does not alter assumptions made in the safety analysis.

Therefore, the proposed request does not create a new or different kind of accident from any accident previously evaluated.

Attachment to WO 08-0006 Page 7 of 9 (iii) Do the proposed changes involve a significant reduction in a margin of safety?

Response: No The proposed change does not affect the acceptance criteria for any analyzed event nor is there a change to any Safety Analysis Limit (SAL). There will be no effect on the manner in which safety limits, limiting safety system settings, or limiting conditions for operation are determined nor will there be any effect on those plant systems necessary to assure the accomplishment of protection functions.

Therefore, the proposed changes do not involve a significant reduction in the margin of safety.

Based on the above evaluations, WCNOC concludes that the activities associated with the above described enforcement discretion request present no significant hazards consideration under the standards set forth in 10 CFR 50.92 and as such, would not be a potential detriment to the public health and safety.

9. The basis for the conclusion that the noncompliance will not involve adverse consequences to the environment.

WCNOC has determined that this request for enforcement discretion meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9) as specified below:

(i) Involves no significant hazards consideration.

As demonstrated in Section 8 above, this request does not involve any significant hazards consideration.

(ii) There is no significant change in the types of or significant increase in the amounts of any effluents that may be released offsite, The request does not involve a change to the facility or operating procedures that would cause an increase in the amounts of effluents or create new types of effluents.

(iii) There is no significant increase in individual or cumulative occupational radiation exposure.

The request would not adversely affect the operation of the reactor and would not affect any system that would affect occupational radiation exposure. The proposed request does not create additional exposure to utility personnel nor affect radiation levels that are present. The request will not result in any increase in individual or cumulative occupational radiation exposure.

Accordingly, the proposed change meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), an environmental assessment of the proposed change is not required.

Attachment to WO 08-0006 Page 8 of 9

10. A statement that the request has been approved by the facility organization that normally reviews safety issues (Plant Safety Review Committee).

The WOGS Plant Safety Review Committee convened at 1730 on February 13, 2008, and approved this request for enforcement discretion.

11. The request must specifically address which of the NOED criteria for appropriate plant conditions specified in Section B of Part 9900, "Operations - Notices of Enforcement Discretion," is satisfied and how it is satisfied This request is made under the criteria in Section B, Paragraph 2.1, Item l.a in Part 9900:

Technical Guidance, "Operations - Notices of Enforcement Discretion." This NOED criteria states:

1. For a plant in power operation, an NOED is intended to:
a. avoid unnecessary transients as a result of compliance with the license condition and, thus, minimize potential safety consequences and operational risks; or The type of NOED required per this request was identified to be a "regular" NOED, ii.e., one that does not involve severe weather or other natural phenomena. It involves a nonrecurring noncompliance as it only involves a single request for extending the period of time that an inoperable plant component must be restored to OPERABLE status as specified per the plant Technical Specifications. As such, it involves a plant condition whereby the plant would be returned to compliance with the plant operating license within a short period of time.

With WOGS currently in MODE 1 at approximately 99% power with a Technical Specification required shutdown in progress, this request is for an operating plant. The intent is to avoid an unnecessary plant shutdown, thereby avoiding the increased potential for a transient associated with plant shutdown, consistent with criterion 2.1.1 (a)above.

12. Unless otherwise agreed as discussed in Section B of Part 9900, a commitment is required that the written NOED request will be submitted within 2 working days and the follow-up amendment will be submitted within 4 working days of verbally granting the NOED.

This request for enforcement discretion is a one-time only extension of the Completion Time to complete restoration activities on the "A"CCP room cooler. As such, a follow-up license amendment is not required. WONOC committed to provide the written request for a NOED within 2 working days (i.e., by close of business on February 15, 2008). This submittal satisfies the commitment.

13. For a severe weather NOED request provide the following information:

The name, organization and telephone number of the official in the government or independent entity who made the emergency situation determination.

Details of the basis and nature of the emergency situation, including, but not limited to, its effect on:

Attachment to WO 08-0006 Page 9 of 9

i. on-site and off-site emergency preparedness ii. plant and site ingress and egress iii. off-site and on-site power sources iv. grid stability; and
v. actions taken to avert and/or alleviate the emergency situation (e.g.,

coordinating with other utilities and the load dispatcher organization for buying additional power or for cycling load, or shedding interruptible industrial or non-emergency loads).

Potential consequences of compliance with existing license requirements (e.g.,

plant trip, controlled shutdown).

The impact of the emergency situation on plant safety including the capability of the ultimate heat sink.

Potential adverse effects on public health and safety from enforcing compliance with specific license requirements during the emergency situation.

Not applicable.

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