ML20078K512
| ML20078K512 | |
| Person / Time | |
|---|---|
| Site: | Oyster Creek |
| Issue date: | 01/21/1994 |
| From: | J. J. Barton GENERAL PUBLIC UTILITIES CORP. |
| To: | Martin T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML20078K505 | List: |
| References | |
| FOIA-94-167 NUDOCS 9502090274 | |
| Download: ML20078K512 (4) | |
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C321-94-2011 Mr. Thomas Martin, Administrator U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia PA 19406
Dear Sir:
Subject:
Oyster Creek Nuclear Generating Station Docket No. 50-219 Request for Enforcement Discretion - APRM l
This letter provides written documentation of our request to depart from the Oyster Creek Nuclear Generating Station Technical Specifications in accordance with the recent revisions to Section VII.C of the Enforcement Policy (10 CFR, Part 2, Appendix C) as we discussed orally on Friday, January 21, 1994.
The attached enclosure includes the required information to support our request for enforcement discretion when we will not perform the Average Range Power Monitor Scram Trip Surveillance in accordance with its specified frequency.
If any additional information or assistance is required, please contact Mr. Terry Sensue of my staff at (609)971-4680.
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This enclosure provices a oiscussion of the following nine items stated within 10 CFR Part 2 Appendix C. Enforcement Discretion, Section E:
Request for Enforcement Discretion.
1.
The TS or other license conditions that will be vio) &
0.C.N.G.S. TS 4.1, Protective Instrumentation Surveillance Requirements.
specifically, Item 11 from Table 4.1.1.
The Average Power Range Monitor (APRM) scram trips are to be tested and calibrated once per week.
We request that this week's test be delayed past its drop dead date.
2.
The circumstances surrounding the situationdncluding the need for Drompt action.
As a result of severe cold weather conditions, the Pennsylvania. New Jersey, and Maryland (PJM) electrical grid is experiencing difficulty in meeting electrical demands of its customers causing grid instabilities.
PJM has asked all generating stations to avoid loss of or reduced generation.
The weekly APRM scram trip surveillance is a high risk activity to perform that has the potential to cause a plant shutdown.
This surveillance is scheduled to be performed on Sunday: and has a drop date on Monday.
3.
Ihe safety basis for the reauest that enforc
- .t discretion be exercised.
includino an evaluation of the safety significance and notential consecuences of the proposed course of action.
The safety significance of this request is considered minimal for the following reasons:
Past surveillance data of the APRM trip system indicates the system a.
will perform its intended function, if called upon to do so.
Potential Consequences of the proposed course of action would be instrument drift.
However, a review of the last eight weeks of surveillance data exhibits no sufficient orif t trends associated with APRM setpoints.
b.
There is sufficient -redundancy should one or more of the APRM channels become inoperable. The logic for the APRM trips is one out of four twice with four APRM channels in each reactor protection system.
Currently, all eignt APRM cnannels are operable.
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C321-92-2011 Page 2 of '
Enclosure (Centinuec)
Other scram functions such as the reactor anticipatory scram and c.
reactor high pressure scram would cause a reactor shutdown should all the APRM channels fail to perform their intended function.
Additionally, no design basis accident analysis considers the APRM High Flux Scram in determining the consequences of the accioent.
The only design basis transient relying on the APRM scram function is a loss of feedwater heating. The consequences of this transient are less than nalf as severe as for a turbine trip without bypass valves, which is the limiting transient relative to the fuc.
cladding integrity safety Simit.
If the APRM scram function is n-considered in the analysis, a loss of feedwater heating is sti > '
less limiting than a turbine trip without bypass.
The Control Room operators would take manual control and scram the d.
reactor in accordance with approved station procedures when required.
4 Any proposed compensatory measure (s).
None.
5.
The iustification for the duration of the norK w 11ance.
OCNGS requests the APRM Scram Trip surveillance be delayed approximately one week or less until such time as the P]M electrical grid conditions return to normal in which the surveillance will be performed within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
This duration will avoid unnecessary plant transients and reduce operational risk to OCNGS while supporting the PJM electrical demand.
6.
The basis for the licensee's conclusion that the norvc---11ance will not be of notential detriment to the public health and safety and that a s_ionificant safety hazard is not involved.
The results of the safety basis discussion provided for question 3 aoova indicate that no significant safety hazard is involved.
Public health anc safety is enhanced by ensuring the stability of Oyster Creek's generating output to the PJM electrical grid.
7.
The basis for the licensee's conclusion that the noncewliance will not involve adverse consecuences to the environmenh The APRM system has no direct interface with the environment or monitom of environmental parameters.
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DRAFT C221-92-2311 Page 3 of 3 Enclosure (Continuea) 8.
A statement that the recuest has been approved by the facility oraanization that normally reviews safety issues (Plant Onsite Review Conusittee. or its eauivalent).
The Plant Review Group (PRG) held meeting #94-04 and approved engineering evaluation 0042-94 which provided the technical justification for this t
relief request.
9.
Any other information the NRC staff deems necessary before makinq a decision to exercise enforcement discretion.
None requested from the telephone conversation held on January 21, 1994 DRAFT
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(717) 948-8005 January 21, 1994 C311-94-2010 Mr. T. T. Martin Regional Administrator, Region 1 i
US Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406-1415
Dear Sir:
Three Mile Island Station Unit 1 TMI-1) j Dperating License No. DPR-Docket No. 50-289 Request for a Regional Temporary Waiver of Compliance I
On January 20,1994, at 11:00 a.m., GPU Nuclear orally requested a regional temporary waiver of compliance from the requirement to conduct the Control Rod Movement surveillance test.
At 12:55 p.m. on January 20, 1994, Ms. Michele Evans, TNI Senior Resident Inspector, informed Mr. Jack Wetmore, Manager, TMI Licensing,'that the request had been granted. This letter is a. followup to GPU Nuclear's oral request for a regional temporary waiver of' compliance.
The Control Rod Movement surveillance test is a requirement of TMI-1 Technical Specification 4.1.2 (Table 4.1-2). The current' due date for the surveillance is Thursday, January 20 1994 and the late date for the surveillance (the allowable surveillance frequency.of 14 days plus 255) will be Sunday, January 23, 1994.
GPU Nuclear requested a waiver of compliance be effective iiunediately until January 28, 1994. GPU Nuclear intends to perform the surveillance on or before January 28, 1994.
The temporary waiver of compliance was requested to minimize the possibility of a reactor power reduction or trip as a consequence of surveillance testing that is required to be performed during the extremely cold weather which the PJM grid is currently experiencing.
TMI-1 has previously experienced a reactor power reduction due to an inadvertent rod drop that occurred during the performance of the biweekly control rod movement surveillance that was the result of a faulty cable / stator electrical connection (December 12, 1991). Note: The inadvertent rod drop did not affect the ability of.the Control Rod Drive Mechanisms to perform their safety function.
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C311-94-2010 Page 2 The requested duration for the waiver of compliance will allow GPU Nuclear to postpone the performance of the Control Rod Movement surveillance testing until the extremely cold weather has abated and the PJM grid is restored to normal conditions (no voltage reductions or blackouts).
The t.ommcnwealth of Pennsylvania has declared a state of emergency in response to the current unprecedented extremely cold wather. The PJM grid is currently undergoing mandatory voltage reductions and rolling blackouts.
It is in the public interest to minimize all activities that could jeopardize current electrical production.
The safety significance of postponing the performance of the surveillance until January 28, 1994 is minimal.
The biweekly surveillance interval stated in current TMI-I Technical Specifications is very conservative when compared to the 92 day surveillance interval specified in NURfG 1430, Revised Standard Technical Specifications (RSTS) for BW Plants.
The intent of the surveillance is to ensure control rod movement, trippability and the reliability of the control rod mechanisms.
The control rod mechanism movement surveillance has been successfully performed in accordance with the surveillance interval since the plant returned to power after the 10 R outage. The reliability of the control rod mechanism can be assured during the period for which the temporary waiver of compliance has been requested by monitoring other available indicators of control rod performance that are obtained from other Technical Specification required surveillance activities and from plant instruuntation such as the asymmetric rod position indicator alare.
We note that RSTS for BW plants specifies a 92 day surveillance frequency for the performance of verifying control rod freedom of movement (SR 3.1.4.2, page 3.1-9) ver, sus the 14 day surveillance interval in the TMI-l Technical Specifications..The Bases for the RSTS 3.1.4.2 (page 3.1-26) states the bases for the 92 day surveillance interval takes into consideration other information available to the operator in the control room and the RSTS requirement for verification that individual control rod positions are within 6.55 of their group average be performed every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> with the reactor at power. Along this same line, TMI-1 Technical Specification 4.1-1.23,24 requires verification of control rod absolute / relative position comparison be performed on a shiftly (once every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />) surveillance laterval with the plant critical.
This requirement is implemented by GPU Nuclear via TMI-1 Surveillance Procedure 1301-1.
The requested temporary waiver of compliance does not involve a significant hazards consideration because:
1.
There is no significant increase in the probability or consequences of an accident previously evaluated because control rod mechanism operability is verifiable via other available information and Technical Specification required surveillance and because the specified duration of the temporary waiver of compliance is much less than the 92 day surveillance interval that would be allowed under NUREG 1430.
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C311-94-2010 Page 3 2.
It will not create the possibility of a new or different kind of accident from any accident previously evalurt:J. A one-time change in the frequency in the performance of ti.e control rod movement surveillance does not change plantsperations or have any impact on plant systems, structures or components, and 3.
It does not involve a significant reduction in a margin of safety.
The frequency of Technical Specification surveillance is not a specified margin of safety in TMI-1 Technical Specifications.
The temporary waiver of compliance will not involve irreversible environmental consequences because the extension of the surveillance interval has no impact on plant operations or plant affluents.
The TMI-1 Plant Review Group reviewed and approved the action to request a temporary waiver of compliance from the specified 14 day frequency requirement for the control rod movement surveillance on Wednesday, January 19, 1994.
GPU Nuclear appreciates the prompt NRC review and approval of the temporary waiver of compliance.
If you have any questions regardi this matter, please contact Mr. John Schork, TMI Licensing Engineer at (717) 8832.
Sincerely, T. G. Broughton Vice President h Director, TMI JSS/esf cc:
M. G. Evans - TMI Senior Resident Inspector R. W. Hernan
.Senter Pro, ject Manager Document Control. Desk
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