ML20134J861

Requests That NRC Exercise Discretion Not to Enforce Compliance W/Actions Required in SR 3.1.5.4 of TS 3.1.5, CEA Alignment for Plant,Unit 3

ML20134J861
Person / Time
Site:	San Onofre
Issue date:	02/10/1997
From:	Adensam E NRC (Affiliation Not Assigned)
To:	Ray H SOUTHERN CALIFORNIA EDISON CO.
References
NOED-97-06-002, NOED-97-6-2, TAC-M97870, NUDOCS 9702120372
Download: ML20134J861 (4)

Text

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j NUCLEAR REGULATORY COMMISSION wasninovow, o.c. sones.eooi February 10, 1997 i

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Mr. Harold B. Ray i

Executive Vice President i

Southern California Edison Company j

San Onofre Nuclear Generating Station P. O. Box 128 l

San Clemente, California 92674-0128 l

SUBJECT:

NOTICE OF ENFORCEMENT DISCRETION FOR SAN ONOFRE NUCLEAR GENERATING STATION, UNIT 3 (N0ED 97-06-002) (TAC NO. l197870) j

Dear Mr. Ray:

By letter dated February 6,1997, Southern California Edison (SCE or the licensee) requested the NRC exercise discretion not to enforce compliance with l

the actions required in Surveillance Requirement (SR) 3.1.5.4 of Technical i

Specification (TS) 3.1.5, "CEA Alignment," for San Onofre Nuclear Generating Station (SONGS), Unit 3.

The letter documented information previously i

discussed with the NRC in a telephone conversation on February 5, 1997, that 3

l began at 12:00 noon Eastern Standard Time (EST). During this telephone

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conversation, the licensee stated that the 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> allowed by SR 3.0.3 would expire at 8:06 pm EST on February 5, 1997, which would require the unit to l

begin shutting down in accordance with Action D of Limiting Condition for Operation (LCO) 3.1.5.

You requested that a Notice of Enforcement Discretion j

(NOED) be issued pursuant to the NRC's policy reaarding exercise of discretion for an operating facility, set out in Section VII.c, of the " General Statement i

of Policy and Procedures for NRC Enforcement Actions" (Enforcement Policy),

j HUREG-1600, and be effective for the period of time needed for the NRC to i

process a TS amendment on an exigent basis. This TS amendment would defer i

implementation of SR 3.1.5.4 to no later than the SONGS Unit 3. Cycle 9 i

refueling outage (currently scheduled to begin on April 12,1997). The i

licensee committed. in its letter dated February 7,1997, to test the reed switch position channels in accordance with SR 3.1.5.4 in the event of a i

planned or unplanned shutdown of Unit 3 before the refueling outage.

The need for this NOED request results from an administrative error in the implementation of the Technical Specification Improvement Program (TSIP) approved by the NRC and implemented by SCE on August 5, 1996. During the TSIP i

project, SCE personnel incorrectly believed that SR 3.1.5.4 was satisfied by a 2

surveillance conducted during the previous SONGS Unit 3 refueling outage.

SR i

3.1.5.4 states, " Perform a CHANNEL FUNCTIONAL TEST (CFT) of each reed switch 1

position transmitter channel," and the frequency of this SR is every 24 j

months. The previous surveillances performed on these channels consisted of i

simulating an input for each reed switch position transmitter into each control element assembly (CEA) calculator, and verifying the correct response Q of each CEA calculator.

In order to perform the current SR 3.1.5.4, each CEA y

has to be exercised over its entire length of movement.

It is not possible to j

perform this functional test with the unit in Mode 1.

Therefore, the licensee 0

9702120372 970210 E"

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i Mr. Harold B. Ray February 10, 1997 i

i requested relief from performing the CFTs needed to demonstrate compliance with SR 3.1.5.4 until the upcoming scheduled refueling outage. The licensee's safety rationale for this request is that the recent operational history and i

j inherent reliability of the Unit 3 reed switch position transmitters provide i

adequate assurance that the transmitters are operable and fully capable of performing their intended safety function The enforcement discretion would avoid an undesirable transient associated with an unnecessary plant shutdown i

and thus minimize potential safety consequences and operational risks associated with such action.

The staff evaluated the safety consequences of allowing Unit 3 to continue operation until its next refueling outage without compliance with SR 3.1.5.4 along with other mitigating information that is available, and compared this I

to the small, but measurable amount of risk associated with an unnecessary plant shutdown.

The staff concluded that the option that resulted in the minimum safety impact was the option of allowing the surveillances to be postponed until the upcoming refueling outage. During startup, normal operations, and shutdown activities involving CEA movement, the CEA calculators will sound an annunciator in the control room should a CEA deviate 3

from its subgroup position by more than 5 inches.

If appropriate, the CEA calculators will transmit penalty factors to the core protection calculators that will cause trip setpoints to be approached. When the CEAs are at the fully withdrawn position, the cross channel check performed shiftly provides

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assurance that there is no pair of reed switches failed in the closed position below the CEA position.

The reed switch position transmitter assemblies are considered highly reliable because the only active components are the magnetically actuated reed switches. The magnet attached to the CEA extension a

shaft closes two pairs of reed switches with all of the other reed switches normally open.

If a pair of reed switches were to stick in the closed position, the channel would not function properly and the failure would be detected by the cross channel check procedure discussed above. The licensee has stated that there have been no deviation alarms attributable to failures i

of the reed switch position enannels during Cycle 8 operation. The staff concludes that the combination of factors discussed above provides adequate assurance, for the limited period of time before the next refueling outage, that the reed switch position channels can perform their intended safety function. The staff agrees with the licensee that an unnecessary plant shutdown constitutes an undesirable transient involving a small amount of risk and, therefore, considers the option of requiring a shutdown specifically to perforia SR 3.1.5.4 to be unwarranted. Criterion 1 of Section B of the i

Enforcement Policy states in part that, "For an operating plant, the NOED is 1

intended to (a) avoid undesirable transients as a result of forcing compliance with the license condition and, thus, minimize potential safety consequences and operational risks...."

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j On the basis of the staff's evaluation of your request, 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 j

impact on public health and safety. Therefore, it is our intention to g

exercise discretion not to enforce compliance with LCO 3.1.5 for the period 4

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Mr. Harold B. Ray February 10, 1997 i

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from 8:06 pm EST February 5, 1997, until issuance of a license amendment.

The staff will process your TS amendment request received on February 7, 1997, to resolve this issue on an exigent' basis. This-letter documents our telephone conversation on February 5,1997, when we orally issued this notice of enforcement discretion.

.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 nocompliance for which this N0ED was necessary.

Sincerely, Original. Signed By Elinor G. Adensam, Deputy Director Division of. Reactor Projects III/IV Office of Nuclear Reactor Regulation Docket No. 50-362 cc:

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d Mr. Harold B. Ray February 10, 1997 cc:

i Mr. R. W. Krieger, Vice President Resident Inspector / San Onofre NPS Southern California Edison Company c/o U.S. Nuclear Regulatory Commission San Onofre Nuclear Generating Station Post Office Box 4329 P. O. Box 128 San Clemente, California 92674 San Clemente, California 92674-0128 Mayor Chairman, Board of Supervisors City of San Clemente County of San Diego 100 Avenida Presidio 1600 Pacific Highway, Room 335 San Clemente, California 92672 i

San Diego, California 92101 Alan R. Watts, Esq.

Woodruff, Spradlin & Smart 701 S. Parker St. No. 7000 Orange, California 92668-4702 Mr. Sherwin Harris i

Resource Project Manager Public Utilities Department City of Riverside 1

3900 Main Street 4

Riverside, California 92522 4

Dr. Harvey Collins, Chief Division of Drinking Water and Environmental Management Cal!fornia Department of Health Services P. 9. Box 942732 Sac ~ramento, California 94234-7320 Regional Administrator, Region IV U.S. Nuclear Regulatory Commission Harris Tower & Pavilion i

611 Ryan Plaza Drive, Suite 400 Arlington, Texas 76011-8064 d

3 Mr. Terry Winter Manager, Power Operations San Diego Gas & Electric Company l

P.O. Box 1831 San Diego, California 92112-4150 Mr. Steve Hsu i,

Radiologic Health Branch State Department of Health Services Post Office Box 942732 Sacramento, California 94234