NOED-01-4-002 - South Texas Project 1 (STP Nuclear Operating Company)

September 25, 2001

William T. Cottle, President and
Chief Executive Officer
STP Nuclear Operating Company
P.O. Box 289
Wadsworth, Texas 77483


Dear Mr. Cottle:

By letter dated September 23, 2001, STP Nuclear Operating Company (STPNOC) requested that the NRC exercise discretion not to enforce compliance with the actions required in Technical Specification (TS) 3.7.4, "Essential Cooling Water." That letter documented information previously discussed with the NRC in a telephone conversation on September 22, 2001, at 6:00 p.m. (all times are CDT). Participants in the telephone conversation held September 23, 2001, at 6:00 p.m. included Ellis Merschoff, Regional Administrator, RIV, and members of his staff; Stuart Richards, Director, Project Directorate IV, Division of Licensing Project Management, Office of Nuclear Reactor Regulation (NRR), and members of the NRR staff; and Russ Lovell, Acting General Plant Manager, and other members of his staff. During the conversation, your staff stated that at 2:00 a.m. on September 24, 2001, the plant would no longer be in compliance with the Action Statement of TS 3.7.4(1), which would require that with only two essential cooling water loops OPERABLE, restore at least three loops to OPERABLE status within 7 days or be in at least HOT STANDBY within the next 6 hours and in COLD SHUTDOWN within the following 30 hours. The Limiting Condition for Operation was entered at 2:00 a.m. on September 17, 2001, for the Train C Essential Cooling Water pump. STPNOC requested that a Notice of Enforcement Discretion (NOED) 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 for the period 2:00 a.m. on September 24, 2001 until 2:00 a.m. on September 29, 2001, a period of 5 days past the Limiting Condition for Operation completion time.

According to your staff, the Train C Essential Cooling Water pump experienced an unexpected loss of discharge pressure during postmaintenance testing at 9:06 p.m. on September 21, 2001, due to a seizure of the center shaft bearing from lack of cooling and lubrication water. The remaining completion time was insufficient for repair and testing of the pump. The degraded condition of the Essential Cooling Water pump had two potential outcomes: either maintain the plant at power for no more than an additional 5 days, which your staff determined would be adequate to complete repairs and testing, or proceed to COLD SHUTDOWN in accordance with the TS. The quantitative change in core damage probability associated with the Essential Cooling Water pump being out of service for an additional 5 days was compared to a qualitative assessment of risk associated with a plant shutdown to comply with TS 3.7.4. You stated that allowing the additional 5 days was preferable to the potential consequences associated with a plant shutdown, and that there was no increase in radiological risk.

In conjunction with this action, STPNOC initiated compensatory measures which included: functionality or operability of the remaining power sources and the remaining Essential Cooling Water loops have been verified; in the event of a loss of offsite power, Train C Engineered Safety Features (ESF) bus will be cross-connected to an alternate emergency power source by backfeeding through an ESF transformer to the emergency bus in accordance with station procedures; loading on the ESF bus is being restricted to the 480 VAC ESF load centers, one centrifugal charging pump and its associated cubicle cooler, two Class 1E battery chargers and the 25 KVA TMI inverter; in the event of a loss of offsite power, Operations personnel will be allowed to cross connect between the Essential Cooling Water trains; and surveillance and planned maintenance activities with the potential to cause a reactor/turbine trip or onsite power interruption in both units have been suspended. In addition to the hardware and procedural measures taken to compensate for the pump failure, actions have been implemented to further assure plant physical security, especially as it relates to the physical location of the Essential Cooling Water system.

NRC staff evaluated your request, which was reviewed and approved by your Plant Operations Review Committee and agreed that maintaining the plant stable at power for an additional 5 days was preferable to the potential for a plant transient that could occur during a plant shutdown. The NRC found no reason to challenge your statement that staying at power in this condition did not constitute an increase in radiological risk. The NRC agreed that your no significant hazards consideration was appropriate, your compensatory measures were appropriate, and your corrective actions were appropriate for the Train C Essential Cooling Water pump.

On the basis of the staff's evaluation of your request, including the compensatory measures described above, the staff has concluded that an NOED is warranted because we are clearly satisfied that this action involves no safety impact and has no adverse radiological impact on public health and safety or adverse consequences to the environment. Additionally, we determined that the request satisfied the NRC's policy for enforcement discretion. Therefore, it is our intention to exercise discretion not to enforce compliance with the required action of TS 3.7.4, for the period of time not to exceed from September 24, 2001, at 2:00 a.m. until September 29, 2001, at 2:00 a.m., or the time the Train C Essential Cooling Water pump is returned to an operable status. This letter documents our telephone conversation of September 23, 2001, at 6:00 p.m. when we orally issued this NOED.

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

  TPGwynn for
  Ellis W. Merschoff
Regional Administrator

Docket No: 50-498
License No: NPF-76

J. J. Sheppard, Vice President
Engineering & Technical Services
STP Nuclear Operating Company
P.O. Box 289
Wadsworth, Texas 77483

S. M. Head, Manager, Licensing
Nuclear Quality & Licensing Department
STP Nuclear Operating Company
P.O. Box 289, Mail Code: N5014
Wadsworth, Texas 77483

A. Ramirez/C. M. Canady
City of Austin
Electric Utility Department
721 Barton Springs Road
Austin, Texas 78704

M. T. Hardt/W. C. Gunst
City Public Service Board
P.O. Box 1771
San Antonio, Texas 78296

D. G. Tees/R. L. Balcom
Houston Lighting & Power Company
P.O. Box 1700
Houston, Texas 77251

Jon C. Wood
Matthews & Branscomb
112 E. Pecan, Suite 1100
San Antonio, Texas 78205

A. H. Gutterman, Esq.
Morgan, Lewis & Bockius
1800 M. Street, N.W.
Washington, D.C. 20036-5869

C. A. Johnson/R. P. Powers
AEP - Central Power and Light Company
P.O. Box 289, Mail Code: N5022
Wadsworth, Texas 77483

Records Center
700 Galleria Parkway
Atlanta, Georgia 30339-5957

Bureau of Radiation Control
State of Texas
1100 West 49th Street
Austin, Texas 78756

Jim Calloway
Public Utility Commission
William B. Travis Building
P.O. Box 13326
1701 North Congress Avenue
Austin, Texas 78701-3326

John L. Howard, Director
Environmental and Natural Resources Policy
Office of the Governor
P.O. Box 12428
Austin, Texas 78711-3189

Judge, Matagorda County
Matagorda County Courthouse
1700 Seventh Street
Bay City, Texas 77414

1. In addition to not being in compliance with TS 3.7.4, the licensee noted that non-compliance would cascade to TS's 3.5.2, 3.5.6,,, 3.7.3, 3.7.7, and All discussions and approvals include the Allowed Outage Times for all of these TS's.


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