IR 05000445/1997015
| ML20198N188 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 01/14/1998 |
| From: | Dyer J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Terry C TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| Shared Package | |
| ML20198N193 | List: |
| References | |
| 50-445-97-15, 50-446-97-15, NUDOCS 9801200289 | |
| Download: ML20198N188 (4) | |
Text
SUBJECT:
NRC INSPECTION REPORT 50-445/97-15; 50-446/9715
Dear Mr. Terry:
Thank you for your letters dated October 3,1997, and October 15,1997, in response to our letter and Notice of Violation dated August 5,1997. We have reviewed your reply to Violation A and find it responsive to the concems raised in our Notice of Violation. We will review the implementation of your corrective actions during a future inspection to determine that full compliance has been achieved and will be maintahed.
We have reviewed your denial of Violation B. In your denial, you referred to Technical Specification Basis 3/4.7.10 which states that the limitations on nominal area temperatures ensure that safety-related equipment will not be subjected to temperatures that would impact their environmental qualification temperatures. Exposure to temperatutes in excess of the maximum temperature for normal conditions for extended periods of time could reduce the qualified life or design life of that equipment. For normal areas in the safeguards building, which inc!udes the main steam and feedwater penetration areas, an analysis is required by Technical Specification 3/4.7.10 if the maximum temperature for normal conditions of 104'F is exceeded for more than 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />.
Subsequent to our inspection, you performed vn evaluation of data collected over a seven day period in which you concluded that the temoeratura indicator utilized to perform Technical Specification Surveillance Requirement 4./.10, deviated 11.1'F from the average of the bulk area temperature of the combined main steam /feedwater penetation area. Since the qualified life of some of the components in the mcin steam and feedwater penetration areas is based on a tomperature of 104'F, you determined that it was necessary to include a factor to account for the difference between the temperature indicator reading and the bulk area temperature. In your supplemental response letter, you committed to revise your surveillance procedures on or about October 31,1997, to alert the plant operators to consult engineering if the temperature reaches 103*F at the temperature indicator.
We have determined that Violation B, as written, did not occur. However, Operations Testing Manual Procedures OPT-102A, Revision 8, (Unit 1) and OPT 1028, Revision 2, (Unit 2),
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" Operations Shiftly Routine Tests," did not include appropriate quantitative acceptance criteria in that the tests did not account for the temperature offset you identified in your response.
k Therefore, this represents a violation of 10 CFR Part 50, Appendix B, Criterion V. The violation
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- TU Electric 2-is cited in the enclosed Notice of Violation. Accordingly, NRC Inspection Report 50-445/9715;
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50-446/9715, Notice of Violation B is withdrawn and superseded with the attachad Notice of Violation.
The NRC has concluded that information regarding the reason for the violation, corrective actions taken, plans to correct the violation and prevent recurrence is already adequately
addressed on the docket in your letters dated October 3 and 15,1997. Therefore, you are not i
required to respond to this letter unless the description therein does not accurately reflect your corrective actions or position. If you choose to provided additionallnformation, you should foll >w the instructions specified in the enclosed Notice of Violation.
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In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of this letter, its enclosure, and your response will be placed in the NRC Public Document Room.
Should you have any questions concoming thlu inspection, we will be pleased to discuss them with you.
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Sincerely,
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.l, l g, James E. Dyer Deputy Regional Administrator Docket Nos.: 50-445; 50-446 License Nos.: NPF-87; NPF-89 '
Enclosure: Notice of Violation cc w/ enclosure:
Mr. Roger D. Walker TU Electric Regulatory Affairs Manager P.O. Box 1002 Glen Roso, Texas 76043 Juanita Ellis President. CASE 1426 South Polk Street
' Dallas, Texas 75224
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TU Electric Bethesda Licensing 3 Metro Center, Suite 610
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Bethesda, Maryland 20814
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i TU Electric
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George L. Edgar, Esq.
Morgan, Lems & Booklus
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1800 M. Street, NW Washington, D.C. 20036-l i
G. R. Bynog, Program Manager /
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Chief inspecW -
Texas Department of Lloonsing & Regulation -
l Boiler Division l
P.O. Box 12157. Capitol Station Austin, Texas 78711
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' Honorable Dale McPherson
' County Judge P.O. Box 851 Gian Rose, Texas 76043 Texas Radiation Control Program Director 1100 West 4oth Street Austin, Texas 78756
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John Howard, Director Environmental and Natural Resources Policy Omos of the Govemor P.O. Box 12428 Austin, Texas 78711
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Tu iet.tne 4.
JAN I 41998 bec to DCD (IE01)
l bec distrib. by RIV-Regional Administrator Resident inspector (2)
DRP Director DRS-PSB
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Branch Chief (DRP/A)
MIS System Project Engineer (DRP/A)
RIV File Branch Chief (DRP/TSS)
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OFFICIAL RECOhr. ;opy
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