ML20210R222
| ML20210R222 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak |
| Issue date: | 08/12/1999 |
| From: | Howell A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Terry C TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| Shared Package | |
| ML20210R226 | List: |
| References | |
| 50-445-99-10, 50-446-99-10, NUDOCS 9908170054 | |
| Download: ML20210R222 (6) | |
See also: IR 05000445/1999010
Text
. .
$*"%g
UNITED STATES
3
&
NUCLEAR REGULATORY COMMISSION
4
?,
{
p
REGloN IV
%
I
611 RYAN PLAZA DRIVE. sulTE 400
% , , , , , '#
ARLINGTON, TEXAS 760118064
August 12,1999
EA 99-197
EA 99-203
Mr. C. L. Terry
TXU Electric
Senior, Vice President & Principal Nuclear Officer
ATTN: Regulatory Affairs Department
P.O. Box 1002
-
Glen Rose, Texas 76043
SUBJECT: NRC INSPECTION REPORT NO. 50-445/99-10; 50-446/99-10
i
Dear Mr. Terry-
l
This refers to the inspection conducted on May 10-14 and 24-28,1999, at the Comanche Peak
,
Steam Electric Station, Units 1 and 2, facilities. Additional review and inspection was performed
{
'
in the Region IV Office until June 28,1999. This inspection assessed your fire protection
'
program, safety evaluation program, and component cooling water system for conformance to
applicable regulatory requirements for the Comanche Peak facility. The enclosed report
l
presents the results of this inspection.
l
l
At the end of the onsite period of the inspection, the team leader briefed you and members of
your staff on May 28,1999. Following the onsite inspection, your staff provided the inspection
'
team with additional requested information on June 4 and 14,1999. Telephone conferences
were conducted with your staff on June 8 and 18,1999. An inspection exit meeting was
conducted at the Comanche Peak facility on June 28,1999. A supplemental telephonic exit
j
was held on August 12,1999.
Overall, we found that your safety evaluation and fire protection programs were effectively
implemented. Sections ill (E.2.1) and IV provide the details of our inspection in these areas.
With respect to our inspection of the component cooling water system, overall we concluded
that the system was capable of performing its intended safety function. However, the team
!
identified numerous problems associated with a 1993 modification of the sy: item, as well as,
calculations pertaining to the system. While none of these problems resulted in the
inoperability of the component cooling water system, extensive reviews had to be conducted to
demonstrate that the system and the associated safety-related components serviced by the
system remained operable. Examples of problems identified by the team included: improper
assumptions and design input affecting the results of design calculations; inconsistencies in a
modification safety evaluation; inadequate post-modification testing acceptance criteria; a
missing instrument uncertainty calculation; instances of failing to update a design calculation;
and failing to account for component cooling water pump degradation in design limits.
170014
9908170054 990812
ADOCK 05000445
G
L.
.
TXU Electric
-2-
In addition to the problems noted with engineering work products associated with the
component cooling water system, the team also identified a Unit 1 safety-related battery
surveillance which was not completed within the technical specification required surveillance
interval. This finding resulted in the granting of enforcement discretion by the NRC's Office of
Nuclear Reactor Regulation. The failure to perform the required technical specification
surveillance requirement was apparently caused by the failure of engineering personnel to
correctly interpret the technical specification surveillance requirements. In addition, we do not
agree with your position documented in your June 10,1999, Licensee Event Report (LER)
50-445/99-003-00. This LER indicated that TXU believes that crediting the battery performance
I
discharge test in the Unit 1 sixth refueling outage was acceptable relative to demonstrating
l
compliance with the subject technical specification.
The team also identified instances of failure to properly implement aspects of your temporary
modification program. Hardware and procedure changes had been implemented without the
required evaluation, and required walkdowns of temporary modifications were not performed as
required.
The nature and scope of the problems associated with the 1993 modification of the component
cooling water system may be indicative of similar types of problems associated with
,
modifications of other safety-related structures, systems, or components. Accordingly, we
j
encourage you, in evaluating the findings documented in this report, to consider the generic
l
implications, if any, associated with these findings.
Based on the results of this inspection, the NRC has determined that violations of NRC
requirements occurred. Three of these violations are being treated as noncited violations,
j
consistent with Appendix C of the Enforcement Policy. In regard to another violation involving
i
your fire protection program, discretion is being exercised after consultation with the Office of
Enforcement pursuant to Section Vll.B.6 of the Enforcement Policy and a violation is not being
'
issued. The noncited violations are described in the subject inspection report. if you contest
any of the violations or severity level of the noncited violations, you should provide a response
within 30 days of the date of this inspection report, with the basis for your denial, to the Nuclear
Regulatory Commission, ATTN: Document Control Desk, Washington DC 20555-0001, with
copies to the Regional Administrator, Region IV; the Director, Office of Enforcement, United
,
States Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Resident
inspector at the Comanche Peak facility,
in accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of this letter and its
enclosure will be placed in the NRC Public Document Room (PDR).
,
l
t
.
.
. TXU Electric
-3-
Should you have any questions concerning this inspection, we will be pleased to discuss them
with you.
Sincerely,
>
dJaPw
Arthur T. Howell 111, Director
Division of Reactor Safety
Docket Nos.: 50-445;50-446
Enclosure:
NRC Inspection Report No.
50-445/99-10;50-446/99-10
cc w/ enclosure:
Mr. Roger D. Walker -
TXU Electric
Regulatory Affairs Manager
P.O. Box 1002
Glen Rose, Texas 76043
Juanita Ellis
President - CASE
1426 South Polk Street
Dallas, Texas 75224
George L. Edgar, Esq.
1800 M. Street, NW
Washington, D.C. 20036
G. R. Bynog, Program Manager /
Chief Inspector
Texas Department of Licensing & Regu!ation
Boiler Division
P.O. Box 12157, Capitol Station
County Judge
P.O. Box 851
Glen Rose, Texas 76043
-
,
.
TU Electric
-4-
E-Mail report to T. Frye (TJF)
E-Mail report to D. Lange (DJL)
E-Mail report to NRR Event Tracking System (IPAS)
E-Mail report to Document Control Desk (DOCDESK)
E-Mail report to Richard Correia (RPC)
bec to DCD (IE01)
bec distrib. by RIV:
Regional Administrator
Resident inspector (2)
DRP Director
DRS Director
MIS System
Branch Chief (DRP/A)
RIV File
Project Engineer (DRP/A)
Branch Chief (DRP/TSS)
{
\\
DOCUMENT NAME: R:\\_CPSES\\CP910RP. JEW.WPD
To receive copy of document, indicate in box: "C" = Copy without enclosures *E" = Copy with enclosures "N" = No copy
RIV:SR!:EMB
SRI:EMB
l
SRl:EMB
SRI:PBA l
C:EMB l
C:PBA l
D:DRS
JEWhittemore/imb* LEEllershaw*
CEJohnson* RLBywater*
DAPowers* JITapia* ATHowelld
07/09/99
07/09/99
07/08/99
07/02/99
07/09/99
07/12/99 Cg/r2/99Q
Previously concurred
OFFICIAL RECORD COPY
Y
.
.
..
TXU Electric
-4-
Texas Radiation Control Program Director -
-- 1100 West 49th Street
John Howard, Director -
' Environmental and Natural Recources Policy
~ Office of the Governor
P.O. Box 12428
l
l
.
.
TU Electric
-4-
1
l
E-Mail report to T. Frye (TJF)
E-Mail report to D. Lange (DJL)
E-Mail report to NRR Event Tracking System (IPAS)
E-Mail report to Document Control Desk (DOCDESK)
E-Mail report to Richard Correia (RPC)
bec to DCD (IE01) '
bec distrib. by RIV:
Regional Administrator
Resident inspector (2)
l
DRP Director
1
DRS Director
MIS System
i
Branch Chief (DRP/A)
l
RIV File
j
Project Engineer (DRP/A)
~
Branch Chief (DRP/TSS)
i
i
l
DOCUMENT NAME: R:\\_CPSES\\CP910RP. JEW.WPD
l
To receive copy of document, Indicate in box: "C" = Copy without enclosures "E" = Copy with enclosures "N" = No copy
'
RIV: SRI:EMB
SRI:EMB
SRI:EMB
SRI:PBA
C:EMB
C:PBA
D:DRS
JEWhittemore/imb* LEEllershaw*
CEJohnson* RLBywater*
DAPowers* JITapia* ATHowelld
07/09/99
07/09/99
07/08/99
07/02/99
07/09/99
07/12/99 (3/r2./99%
Previously concurred
. OFFICIAL RECORD COPY
Y
i