ML20207E929
| ML20207E929 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 06/02/1999 |
| From: | Richards R NRC (Affiliation Not Assigned) |
| To: | Terry C TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| References | |
| NOED-99-6-005, NOED-99-6-5, TAC-MA5524, TAC-MA5525, NUDOCS 9906070208 | |
| Download: ML20207E929 (4) | |
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UNITED STATES r
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NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. SegaMeet
. June 2, 1999
. Mr. C. Lance Tony -
iTU Electric.
Senior Vice President & Principal Nuclear Officer Attn: Regulatory Affairs Department P. O. Box 1002 -
Glen Rose, TX-76043 -
SUBJECT:
NOTICE OF ENFORCEMENT DISCRETION FOR TEXAS UTILITIES (TU)
ELECTRIC COMPANY REGARDING COMANCHE PEAK STEAM ELECTRIC STATION (CPSES), UNITS 1 AND 2 (TAC NOS. MA5524 AND MA5525,
' NOED NO. 99-06-05)
Dear Mr. Terry:
By letter dated May 26,1999, you requested that the U.S. Nuclear Regulatory Commission (NRC) exercise discretion not to enforce compliance with Technical Specification (TS) 4.8.2.1e, "D. C. [ Direct Current) Sources - Operating," with regard to the performance of a battery performance discharge test, in lieu of a battery service test, only once per 60-month period for
' CPSES, Unit 1, Battery BTIED2. Your letter documented information previously discussed with the NRC staff in a telephone conference on May 26,1999, at 3:45 p.m., Eastern Daylight Time (EDT). The principal NRC staff members who participated in that telephone conference
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- included Mr. J. Tapia, Chief, Reactor Projects, Branch A Region IV, Mr. A. Howell, Director, Division of Reactor Safety, Region IV, Mr. K. Brockman, Director, Division of Reactor Projects, Region IV, Mr. R. Gramm, Chief, Project Directorate IV, Section 1, Mr. D. Jaffe, Senior Project
. Manager, Project Directorate IV, Section 1, and Mr. D. Thatcher, Section Chief, Electrical and Instrumentation Controls Branch, Section B. You stated that on May 27,1999, at 9:00 a.m.,
jn Central Daylight Time (CDT), CPSES, Unit 1, would enter the Action associated with
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. TS 3.8.2.1, which would require CPSES, Unit 1, to restore Battery BT1ED2 to operable status lwithin 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> (complete the battery service test per TS 4.8.2.1d) or 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 /> and Cold Shutdown within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />. Entry into the required Action of
- TS 3.8.2.1 would result from your failure to comply with TS 4.8.2.1e. You requested that a Notice of Enforcement Discretion (NOED) be issued pursuant to the NRC's policy regarding exercise of discretiori for an operating facility, set out in Section Vll.c. of the " General Statement of Policy and Procedures for NRC Enforcement Actions"(Enforcement Policy),
NUREG-1600, and be effective for the period from 8:20 a.m., CDT, May 27,1999, until issuance of a change to TS 4.8.2.1e. This letter documents our telephone conversation on
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May 27,1999, at 8:20 a.m., CDT, when we orally issued this NOED causing you to exit from the Action associated with TS 3.8.2.1.
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. During the process of conducting reviews of battery surveillances, NRC discovered that, for battery BT1ED2, credit had been taken for the performance of a battery performance discharge i
. test in lieu of a service test more frequently than is permitted by TS Surveillance
- Requirement 4.8.2.1a. Since CPSES, Unit 1, was operating at the time, and the service test
. required by TS 4.8.2.1d can only be conducted during plant shutdown, TU requested that compensatory measures be approved in lieu of a plant shutdown and the conduct of a service
. test. As documented in your May 26,1999, request for issuance of an NOED, the Y
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C. L. Terry r2-June 2, 1999 compensatory measures consisted of an engineering evaluation, based on data available from the recent performance discharge tests (e.g., battery parameters such as connection resistances and individual cell voltages). A comparison of cell. connection resistance readings and cell voltage readings for BT1ED2 was made.
Your letter dated May 26,1999, indicated that cell connection resistance data was taken from connection surveillance tests performed in.CPSES, Unit 1, Refueling Outage 4 (1RF04),
1RF05, and 1RF06. You indicated that:
... resistance readings show no overall signs of degradation. The resistance readings of each intercell connector and interconnecting cables are taken and must be within tolerance. Connections that are not within tolerance must be reworked. The data from the above tests shows that very few connections have required rework. Four connections required rework during 1RF04, three during 1RF05, and two during 1RF06. Where rework was required, the deviations were
. Insignificant when compared to overall resistances and were well below Technical Specification limitations for individual cell readings. Specifically, for the two 1RFO6 out of tolerance readings, the acceptance criteria were 28 and 41 micro-ohms. The as-found readings were 30 and 44 micro-ohms respectively. The as-left readings were 19 and 40 micro-ohms respectively.
Weekly visual inspections, which include inspections for cleanliness and connection corrosion, are performed. Corrective actions are taken on any problems found. These inspections help to ensure that connections are not degrading between discharge tests.
A comparison of cell voltages between the service test conducted in 1RF04 and the discharge performance test conducted in 1RF06 was made. The individual cell voltage readings at the end of the service test during 1RF04 were all.a the range of 1.89 to 1.93 volts. The individual cell voltage readings at similar points
- in the performance discharge test (based on total amp-hour discharge) during 1RF06 ranged from 1.89 to 1.91 volts.
in addition, the SR 4.8.2.1b.2) inspection for visible corrosion of battery terminals and connectcrs was completed on April 28,1999. The inspection found no 4
evidence of corrosion.
i From the information presented in your May 26,1999, letter, the NRC stsff concludes that (1) a relatively small number of battery cell connections required remediation during previous refueling outages and are within the resistance _ specifications of TS 4.8.2.1c.3 (less than or equal to 150 micro-ohms), and (2) the battery voltage shows a large margin (approximately 10 volts) between minimum-required voltage and the voltage at the end of the service test. On the basis of the information provided, the NRC staff concludes that the subject battery would i
have passed the required service test; therefore, there is no need for a CPSES, Unit 1, shutdown for performance of a service test, at this time. Allowing TU to take credit for the pedormance discharge teat for CPSES, Unit 1, Battery BT1ED2, in lieu of a battery service test, twice during a 60-month period, avoids an undesirable transient as a result of forcing compliance with TS 4.8.2.1e, thus, minimizing potential safety consequences and operational risks.
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7 C. L. Terry June 2, 1999 On the basis of its evaluation of your request, the staff concludes that an NOED is warranted because the staff is clearly satisfied that this action involves minimal or no safety impact, is consistent with the enforcement policy and staff guidance, and has no adverse impact on public health and safety. Therefore, it is our intention to exercise discretion not to enforce compliance with TS 4.8.2.1d for the period from 8:20 a.m., CDT, May 27,1999, until issuance of a license amendment. Your letter dated May 26,1999, indicates that an application for license amendment will be submitted by May 28,1999. The NRC staff plans to complete its review and issue the license amendment within 4 weeks of the date of this letter.
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.
Sincerely, i
I Stuart A. Richards, Director Project Directorate IV & Decommissioning Division of Licensing Project Management Office of Nuclear Reaction Regulation Docket Nos. 50-445 and 50-446 cc: See next page DISTRIBUTION:
Docket File PUBLIC PD#4-1 Reading S. Collins /R. Zimmerman I
B. Sheron J. Zwolinski/S. Black OGC J. Tapia, RIV A. Howell, RIV c4 D. Thatcher gc,0Y 2,9 99 ACRS i ' paa J. Lieberman, OE NOED NRCWEB D. Lange (DJL)
- SEE PREVIOUS CONCURRE1CE To receive a copy of this document, indicate "c" in the box C PDIV-1M C ElCB/C*
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Comanche Peak Steam Electric Plant cc:
Senior Resident inspector Honorable Dale McPherson
- U.S. Nuclear Regulatory Commission County Judge P. O. Box 2159 P. O. Box' 851 Glen Rose, TX 76403-2159 Glen Rose,TX 76043 Regional Administrator, Region IV Office of the Governor U.S. Nuclear Regulatory Commission ATTN: John Howard, Director 611 Ryan Plaza Drive, Suite 400 Environmental and Natural Arlington,TX 76011-Resources Policy P. O. Box 12428 Mrs. Juanita Ellis, President Austin,TX 78711 Citizens Association for Sound Energy 1426 South Polk Arthur C. Tate, Director Dallas, TX 75224 Division of Compliance & Inspection Bureau of Radiation Control Mr. Roger D. Walker' Texas Department of Health Regulatory Affairs Manager 1100 West 49th Street TU Electric Austin, TX 78756-3189 P. O. Box 1002 Glen Rose, TX 76043 Jim Calloway Public Utility Commission of Texas George L. Edgar, Esq.
Electric Industry Analysis Morgan, Lewis & Bocklus P. O. Box 13326 1800 M Street, N.W.
Austin, TX 78711-3326 Washington, DC 20036-5869 May 1999