ML20217B092

Discusses Notice of Enforcement Discretion Requested on 970905 by Utility Requesting NRC Exercise Discretion Not to Enforce Compliance W/Ts SR 4.8.1.1.2.g.2)c)2 & 4.8.1.1.2.g.3)d).Staff Concludes NOED Warranted

ML20217B092
Person / Time
Site:	Wolf Creek
Issue date:	09/12/1997
From:	Bateman W NRC (Affiliation Not Assigned)
To:	Maynard O WOLF CREEK NUCLEAR OPERATING CORP.
References
GL-96-01, GL-96-1, NOED-96-06-013, NOED-96-6-13, TAC-M99520, NUDOCS 9709230229
Download: ML20217B092 (4)

Text

i Sh MJ2.

!t p**C'%

j p \ UNITED STATES 1 , a NUCLEAR REGULATORY COMMISSION l

• WASHINSToN, D.C. SMAHeM i September 12, 1997 k***** .

i Mr. Otto L. Maynard j President and Chief Executive Officer j Wolf Creek Nuclear Operating Corporation Post Office Box 411 Burlington, Kansas 66839 '

]

I

SUBJECT:

NOTICE OF ENFORCEMENT DISCRETION FOR WOLF CREEK NUCLEAR OPERATING ,

CORPORATIONREGARDINGWOLFCREEKGENERATINGSTATION(N0E097-06-013) j (TACNO.M99520) f i

Dear Mr. Maynard:

j( By letter dated September 5,1997, Wolf Creek Nuclear Operating Corporation 1

(WCNOC)requestedthattheNRCexercisediscretionnottoenforcecompliance with Technical Specification (TS) Surveillance Requirements 4.8.1.1.2.g.2)c)2),

, and 4.8.1.1.2.g 4)d , " Emergency Diesel Generators." That t

4.8.1.1.2.g.3)d)d letter documente information previous)ly discussed with the NRC in a tel conversation on September 5, 1997, at 1300 Eastern Daylight Time. On

! September 4, 199/, at 1906 CDT, you determined that certain surveillance j at Wolf Creek had not requirements been met. TS A: fortion both emergency Statement diesel 3.8.1.1.f. generators applicable if (EDGs)two diesels are 4 inoperable, requires at least one EDG be returned to OPERABLE within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />.

l Because the surveillance requirements require the plant to be shutdown to

perform the surveillance T.S. 4.0.3, which allows 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> for the completion j of missed surveillances was entered. You stated that on September 5, 1997, at 1906 Central Daylight Time (CDT the plant would not be in com '

! Surveillance Requirements-4.8.1).1.2.g.2)c)2), 4.8.1.1.2.g.3)d)pliance, and with TS

4.8.1.1.2.g 4)d) and, therefore, the plant would be required to be shut down

in order to perform the surveillances. You requested that an NOED be issued i pursuant to 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 i Procedures for NRC Enforcement Actions," NUREG-1600, and that it be effective until an application for a licensee amendment to grant a one time exception to ,

the TSs as described below could be processed.

On September 4, 1997, as a result of reviews undertaken in response to Generic l

Letter 96-01, " Testing of Safety Related Logic Circuits," and information received from another plant, WCNOC detemined that existing surveillance tosting did not completely verify all of the above technical specification

! survei lance requirements. Specifically,-it was-discovered that certain relay 1 Q i contacts had not been tested during performance of Surveillance Procedure No. \

STS KJ-001A/8, 'Intefirated Diesel Generator Safeguards Actuation Test Train

! A/8." The contacts <n question are actuated by relays K1102, K4102 Kill 7,

! K4117, Kill 8 and K4118. The relay contacts provide a blocking i function for starting of the component cooling water (CCW),sential es/ time delay service i . water (ESW), and motor driven auxiliary feedwater (MDAFW) pumps. These pumps I can be started on signals from various sources.

! O 482 5 P 9 PDR i

• , ,4 NRC FIE CENTER COPY i

llllllllllll

Mr. Otto L., Haynard September 12, 1997 !

On a loss of offsite power, the CCW, ESW, and HDAFW pumps are shed from the safety busses and then loaded in sequence to the emergency diesel generators.

The contacts assure that no matter what the start demand is for the pumps, l they are not started out of sequence. The current TS re these circuits be accomplished with the plant shut down. quires that testing l The purpose of theof l N0E0 is to grant discretion to permit one-time testing of these contacts with I the plant in H0DE 1, and to permit t.n additional 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in which to perform the testing while an amendment allowing these changes is processed.

WCNOC's safety evaluation states that the load shedding and emergency load sequencing system will continue to perform in a manner consistent with the assumptions in the Updated Safety Analysis Report (USAR). The activit not affect any system or component setpoints or safety limit settings.yNo will new accident scenarios, transient precursors, failure mechanisms, or limiting single failures will be introduced. There will be no adverse effects or challenges imposed on any safety-related system as a result of this request.

During the testing the following compensatory actions were committed to be in I place: (1 WCHOC will follow its protected train philosophy and only one train will)be worked on at a time. (2) no work will be ongoing in the switchyard, and (3) System Operations will be notified to maintain maximum grid t,tability.

The staff has reviewed the licensee's request and justification for the issuance of a NOED and agrees that testing of the specific contacts should be conducted to provide assurance that load sequencing will function as designed.

The testing proposed to be done at power should not cause any perturbation to the electrical distribution systems that could challenge steady state operation or unit safety systems. This is consistent with HUREG-1600, which states that "... enforcement discretion is intended to minimize the potential safety consequences of unnecessary plant transients (shutdown) with the accompanying operational risks and impacts."

On the basis of the staff's evaluation of your request, including the compensatory measures described above, the staff has concluded that the notice of enforcement discretion is warranted. We are clearly satisfied that this action involves minimal or no safety impact and has no adverse impact on public health and safety. Therefore, it is our intention to exercise discretion not to enforce compliance with the shutdown requirements of TS Surveillance Requirements 4.8.1.1.2.g.2)c)2), 4.8.1.1.2.g.3)d), and 4.8.1.1.2.g.4)d) and permit one-time testing while the plant is in MODE 1.

Also, an additional 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> beyond the 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> permitted by Technical Specification 4.0.3, is granted in order to complete this testing. This agrees with your request for relief. This letter documents our telephone conversation on September 5, 1997, in which we orally issued this notice of enforcement discretion at 1300 EDT. The licensee has reported that the surveillance testing was completed for both EDGs at 1057 COT on September 6, 1997.

Mr. Otto L. Maynard September 12, 1997 However, 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 N0ED was necessary.

Sincerely.

Original Signed By William H. Bateman, Project Director Project Directorate IV-2 Division of Reactor Projects Ill/lV Office of Nuclear Reactor Regulation Docket No. 50-482 DISTRIBU1'10N:

Docket Ftles cc

See next page PUBLIC PDIV-2 Reading SCollins/FMiraglia l RZimmerman EGAl CCarpenter OGC ACRS WBateman JStone MKotzalas EPeyton JWermlel JCalvo NGilles PGwynn, Region IV KBrockman, Region IV N0ED(E-mail)

TOG (E-mail)

DOCUMENT NAME: WCM99520.N0E *See Previous Sheet for Concurrence

. T4' M OFC PDlyr7/flM PD)V 4 TNTS PDIV-2MA _ NRR:HICB* NRR:EELB*

NAME NkP MMahih EP M h hJWermiel JCalvo DATE 9/11/97 9/hJ97 9/12J97 9/9/97 9/9/97 0FC PDIVrR/O n /RLV1 1 NAME WBa NkNch$n h _c 9 DATE 9/}7/97 9/P2/9I i 0FFICIAL RECORD COPY

Mr. Otto L. Maynard September 12, 1997 CCt Jay Silberg, Esq. Chief Operating Officer Shaw, Pittman, Potts & Trc'vbridge Wolf Creek Nuclear Operating Corporation 2300 N Street, NW P. O. Box 411 Washington, D.C. 20037 }

Burlington, Kansas 66839 Regional Administrator, Region IV Supervisor Licensing U.S. Nuclear Regulatory Comission Wolf Creek Nuclear Operating Corporation 611 Ryan Plaza Drive, Suite 1000 P.O. Box 411 Arlington, Texas 76011 Burlington, Kansas 66839 Senior Resident inspector U.S. Nuclear Regulatory Comission l U.S. Nuclear Regulatory Comission Resident Inspectors Office i

' P. O. Box 311 8201 NRC Road Burlington, Kansas 66839 Steedman, Missourt 65077-1032 Chief Engineer Utilities Division l Kansas Corporation Comission 1500 SW Arrowhead Road Topeka, Kansas 66604-4027 Office of the Governor State of Kansas Topeka, Kansas 66612 -

Attorney General Judicial Center 301 S.W. 10th 2nd Floor Topeka, Kansas 66612 County Clerk Coffey County Courthouse Burlington, Kansas 66839 Vick L. Cooper, Chief Radiation Control Program Kansas Department of Health and Environment Bureau of Air and Radiation Forbes_ Field Building 283 Topeka, Kansas 66620