ML20148E089

Requests That NRC Exercise Discretion Not to Enforce Compliance W/Actions Required in TS 4.5.2.b.1 for Byron, Units 1 & 2 & Braidwood,Unit 2

ML20148E089
Person / Time
Site:	Byron, Braidwood
Issue date:	05/28/1997
From:	Capra R NRC (Affiliation Not Assigned)
To:	Johnson I COMMONWEALTH EDISON CO.
References
EA-97-264, EA-97-265, NOED-97-6-010, NOED-97-6-10, TAC-M98780, TAC-M98781, TAC-M98782, NUDOCS 9706020267
Download: ML20148E089 (5)

Text

a n,% b cch th 0 L O k UNITED STATES T6 g g NUCLEAR REGULATORY COMMISSION

, o  ! WASHINGTON. D.C. 20666-0001

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• • • • • May 28, 1997 EA 97-264: 97-265 i 1 Ms. Irene M. Johnson. Acting Manager I Nuclear Regulatory Services l Commonwealth Edison Company Executive Towers West III

, 1400 Opus Place. Suite 500 Downers Grove. IL 60515

SUBJECT:

NOTICE OF ENFORCEMENT DISCRETION FOR COMMONWEALTH EDISON COMPANY REGARDING BYRON UNITS 1 AND 2: AND BRAIDWOOD. UNIT 2 (TAC NOS.

M98781. M98782 AND M98780: NOED NO. 97-6-010)

Dear Ms. Johnson:

By letter dated May 23. 1997. Commonwealth Edison Company (Comed) requested that the NRC exercise discretion not to enforce compliance with the actions recuired in Technical Specification (TS) 4.5.2.b.1 for Byron. Units 1 and 2.

anc Braidwood. Unit 2. TS 4.5.2.b.1 recuires venting of the emergency core I cooling system (ECCS) pump casings and cischarge piping high points outside of containment at least once every 31 days. The letter documented information previously discussed with the NRC during several tele) hone conference calls on May 22 and 23, 1997. During discussions with the 4RC Comed became aware that their venting practices of ECCS pump casings and hihh points for the centrifugal charging (CV) pumps were not in literal compliance with TS 4.5.2.b.1. It was determined that this condition constituted a non-compliance with the surveillance requirements of TS 4.5.2.b.1. This determination was made at 7:00 p.m. CDT on May 22, 1997. Consequently, both trains of CV for each of the three units were declared inoperable and  ;

TS 3.0.3 was entered. In accordance with TS 4.0.3 the actions of TS 3.0.3 / i were delayed for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> for performance of the missed surveillance. TS I, l 3.0.3 requires that when a limiting condition for operation is not met, within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> action shall be initiated to ) lace the unit in a Mode in which the i specification does not apply. For tais particular case, the units would have had to be in hot standby within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, in hot shutdown within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, and in cold shutdown within the subsequent 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. Comed requested /

that a Notice of Enforcement Discretion (N0ED) be issued pursuant to the NRC's policy regarding exercise of discretion for an operating facility, set out in Section VII.c. of the " General Statement of Policy and Procedures for NRC Enforcement Actions" (Enforcement Policy). NUREG-1600, and be effective until the NRC could review and approve an exigent amendment to the TS. Although the same issue applied to Braidwood. Unit 1. that unit was in the process of restarting from its sixth refueling outage and Comed determined that the NOED criteria for a plant attempting to start up were not met.

In order to demonstrate operability of the ECCS subsystems, the TS require. in part: " venting the ECCS pump casings and discharge piping high points outside i 9706020267 970528 4 NRC BLE CENTER COPY PDR ADOCK 0500 P

l I. Johnson of containment. --- " at least once per 31 days. In discussions with the NRC on May 22, 1997 regarding a plugged pump vent line for the 2A safety injection pump at Byron. Unit 2. Comed became aware that their venting practices for CV pump casings and discharge piping high points were not in literal compliance with TS 4.5.2.b.i. Prior to these discussions. Comed considered themselves in compliance with the TS by crediting the dynamic venting action of the system in operation as meeting the recuirement to ensure that the ECCS piping is full of water. For the piping not cirectly in the-flowpath, gas accumulation was judged not to be credible due to the pressure inside the piping. The idle CV pump was considered to be self-venting due to the system design and piping configuration. During the May 22. 1997, discussions. Comed was informed that the discharge piping downstream of the standby CV pumps and the piping associated with the high point vent valves are not subject to system flow and are, therefore, not flushed or vented.

Although Comed considered all CV pumps to be operable at Byron. Units 1 and 2.

and Braidwood. Unit 2. it concluded that the plants were not in literal compliance with the TS and both trains of CV were declared inoperable at 7:00 p.m. CDT In support of the NOED request. Comed referenced information previously provided to the staff in support of License Amendment No. 47 for Byron and Amendment No. 36 for Braidwood. Comed stated that it had performed an engineering analysis and concluded that in the unlikely event of air voids l entering the discharge side of the ECCS pumps, the piping would be capable of

withstanding a water hammer event caused by the maximum credible air void in i the piping. Comed also stated that operational experience at Byron and Braidwood in performing ECCS venting surveillances had identified insignificant quantities of air in the pipes. Additionally. Comed undertook compensatory action on May 22 and 23, 1997.. by performing ultrasonic test (UT) inspections of the vulnerable areas in the CV system piping to verify that the piping is filled with water. The UT testing was conducted in accordance with a Comed approved procedure. Further. Comed committed to perform weekly UT inspections of the vulnerable areas in the CV system piping until the NRC l approves a license amendment to revise the TS.

The intent of TS 4.5.2.b.1 is to ensure that the piping is full of water.

Based on UT testing by Comed to verify that the piping is water-filled, the staff concluded that a N0ED is warranted in order to avoid undesirable l transients as a result of forcing compliance with the TS and, thus, minimize l potential safety consequences and operational risks. With respect to the l engineering analysis. the staff reaffirmed its conclusion stated in the Safety l Evaluation supporting Amendment No. 47 for Byron and Amendment No. 36 for i

Braidwood that, in general, the calculations and analytical methods used in determining the effects of water hammer for any system are uncertain in nature  ;

due to computer code limitations. Therefore, the staff did not consider the water hammer analysis in evaluating Comed's NOED request.

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On the basis of the NRC's evaluation of Comed's request, including the  ;

compensatory measures described above. the staff has concluded that a N0ED is

warranted because we are clearly satisfied that this action involves minimal

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1 or no safety impact, has satisfied Section B. Criterion 1(a), avoidance of undesirable plant transients, of the NRC Administrative Letter 95-05.

Revisions to Staff Guidance for Implementing NRC Policy on Notices of Enforcement Discretion, and has no adverse radiological' impact on public health and safety. Therefore, it is our intention to exercise discretion not to enforce compliance with TS 4.5.2.b.1 for the period from 7:00 p.m. CDT on

! May 23, 1997, until issuance of a license amendment. We have received Comed's request, dated May 24, 1997. for an exigent license amendment. This letter  !

-documents our tele) hone conference call on May 23. 1997, at 4:40 p.m. CDT when l we orally issued t1is notice of enforcement discretion. '

l However, as stated in the Enforcement Policy, action will normally be taken, i to the extent that violations were involved..for the root cause that led to l the noncompliance for which this NOED was necessary.  :

Sincerely.

/s/ .

Robert A. Capra. Director Project Directorate III-2

, Division of Reactor Projects - III/IV Office of Nuclear Reactor Regulation Docket Nos. STN 50-454. STN 50-455.

STN 50-457 cc: see next page DISTRIBUTION: Docket File PUBLIC PDIII-2 r/f S. Collins. 012G18 F. Miraglia. 012G18 R. Zimmerman 012G18 R. Capra G. Dick C. Carpenter. 013E4 C. Moore OGC. 015B18 C. Grimes. 013H15 M. Shuaibi . 08E23 ACRS. T2-E26 S. Bailey J. Lieberman. 07H5 R. Lanksbury. RIII J. Lyons. 08D1 G. Holahan, 08E2 G. Grant. RIIII- J. Goldberg. 015B18 R. Assa EMAIL J. Roe (JWR)

E. Adensam (EGA1)

NOED BBS (TGD)

• See previous concurrence l

l DOCUMENT NAME: G:\CMNTJR\ BRAID-BY\BB98781.LTR To receive a copy of hdocpment, indicate in the box: "C" = Copy without enclosures "E" = Copy with enclosures "N" = No copy

, PM:PD3-S E l. AAK -2 l CL DE l SRXB l D:DSSA l DRPR,*I,, l PD:PD3-2 l GDICK M// CR00Rf) BSHERON* JLYONS* GHOLAHAN* GGRANT1,_ RCAPRA 05416/97 \ 05/ M'97 05/28/97 05/27/97 05/28/97 05/2.7/97 (~ 05/z &/97 0F-ICIAL RECORD COPY

I. Johnson Byron /Braidwood Power Stations Commonwealth Edison Company cc: >

Mr. William P. Poirier, Director George L. Edgar Westinghouse Electric Corporation Morgan, Lewis and Bochius Energy Systems Business Unit 1800 M Street, N.W.

! Post Office Box 355, Bay 236 West Washington, DC 20036 l Pittsburgh, Pennsylvania 15230 l Attorney General Joseph Gallo 500 South Second Street

, Gallo & Ross Springfield, Illinois 62701 l 1250 Eye St., N.W.

l Suite 302 EIS Review Coordinator l Washington, DC 20005 U.S. Environmental Protection Agency 77 W. Jackson Blvd.

Michael I. Miller, Esquire Chicago,_ Illinois 60604-3590 Sidley and Austin One First National Plaza Illinois Department of Chicago, Illinois 60603 Nuclear Safety

, Office of Nuclear Facility Safety -

I Howard A. Learner 1035 Outer Park Drive Environmental law and Policy Springfield, Illinois 62704 Center of the Midwest l 203 North LaSalle Street Commonwealth Edison Company Suite 1390 Byron Station Manager i Chicago, Illinois 60601 4450 North German Church Road Byron, Illinois 61010 U.S. Nuclear Regulatory Commission

! Byron Resident Inspectors Office Kenneth Graesser, Site Vice President l

4448 North German Church Road Byron Station Byron, Illinois 61010-9750 Commonwealth Edison Station 4450 N. German Church Road Regional Administrator, Region III Byron, Illinois 61010 U.S. Nuclear Regulatory Commission 801 Warrenville Road U.S. Nuclear Regulatory Commission Lisle, Illinois 60532-4351 Braidwood Resident Inspectors Office Rural Route #1, Box 79 Ms. Lorraine Creek Braceville, Illinois 60407 Rt. 1, Box 182 Manteno, Illinois 60950 Mr. Ron Stephens Illinois Emergency Services Chairman, Ogle County Board and Disaster Agency Post Office Box 357 110 East Adams Street Oregon,-Illinois 61061 Springfield, Illinois 62706

, Mrs. Phillip B. Johnson Chairman l 1907 Stratford Lane Will County Board of Supervisors i Rockford, Illinois 61107 Will County Board Courthouse l Joliet, Illinois 60434 I

. - _ . - . . - . - - . . - - - - - - - - - - - . - - - .~. - . _ . -

l Commonwealth Edison Company Braidwood Station Manager Rt. 1, Box 84 Braceville, Illinois 60407 i

Ms. Bridget Little Rorem Appleseed Coordinator 117 North Linden Street Essex, Illinois 60935 Document Control Desk-Licensing  ;

Commonwealth Edison Company i

-1400 Opus Place, Suite 400  !

Downers Grove, Illinois 60515 Mr. H. G. Stanley Site _Vice President  !

Braidwood Station l Commonwealth Edison Company l RR 1, Box 84 i Braceville, IL 60407  ;

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