ML20216H630
| ML20216H630 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 03/13/1998 |
| From: | Hannon J NRC (Affiliation Not Assigned) |
| To: | Terry C TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| References | |
| NOED-98-6-004, NOED-98-6-4, TAC-MA1145, TAC-MA1146, NUDOCS 9803230104 | |
| Download: ML20216H630 (5) | |
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NUCLEAR REQULATORY COMMISSION g
- %..... !g gg wasusworow, o..c. sness sooi March 13, 1998 p p-Mr. C. Lance Terry TU Electric Group Vice President, Nuclear
' Attn: Regulatory Affairs Department P. O. Box 1002 Glen Rose, TX 76043
SUBJECT:
NOTICE OF ENFORCEMENT DISCRETION FOR TEXAS UTILITIES ELECTRIC '
REGARDING COMANCHE PEAK STEAM ELECTRIC STATION - UNITS 1 AND 2 (TAC NOS. MA1145 AND MA1146)(NOED NO. 98-6-004)
Dear Mr. Terry:
By letter dated March 10,1998, you requested that the Nuclear Re0ulatory Commission (NRC) exercise discretion not to enforce compliance with the actions required in Comanche Peak Steam Electric Station (CPSES) Technical Specification (TS) Surveillance Requirements (SRs) 4.8.1.1.2f.4)b) and 4.8.1.1.2f.6)b) for not having performed portions of these SRs during shutdown. That letter documented information previously discussed with the NRC in a telephone conversation on March 10,1998, at 3:00 p.m. Eastem Standard Time (EST). You stated that i
due to the missed SRs you entered TS 4.0.3. You 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 Vll.c, of the " General Statement of Policy and Procedures for-NRC Enforcement Actions" (Enforcement Policy), NUREG-1600, and be effective for the period 1
of time it takes the NRC staff to process a proposed change to the TSs. The requested duration l
is to commence upon approval of this enforcement discretion request and to expire upon disposition of the proposed license amendment.
While performing reviews of surveillance procedures in accordance with NRC Generic Letter 96-01, your staff determined that some of the safety injection (SI) and blackout (80) sequencer contacts have not been tested in accordance with SRs 4.8.1.1.2f.4)b) and 4.8.1.1.2f.6)b). This omission in the surveillance program at CPSES has been present since the time of initiallicense and was identified on March 10,1998, at 11:30 a.m. Central Standard Time (CST). As the omission constitutes the failure to perform a SR within the surveillance frequency plus allowable extension in accordance with SR 4.0.2,24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> from March 10,1998, at 11:30 a.m. CST is allowed per SR 4.0.3 to perform the SR.
Yourletter requests that NRC exercise enforcement discretion to not enforce compliance with the
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- during shutdown" portion of SR 4.8.1.1.2f, in order that CPSES not be required to shut down both reactor units to allow credit for surveillance performance or declare otherwise operable diesel generators inoperable. In addition, you stated that CPSES will have already verified, prior to the expiration of the 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> provided by SR 4.0.3, the portion of the SRs which have not already been tested (during our telephone conversation on March 11,1998, which began at 9:00 a.m. EST, you informed the staff that the testing had been completed without incident). As such,
- you consider the surveillances to be complete with the exception of literal compliance with the -
- during shutdown" requirement and, therefore, request that NRC grant enforcement discretion to allow CPSES to credit the performance of SRs 4.8.1.1.2f.4)b) and 4.8.1.1.2f.6)b) for the Si and BO sequencer block contacts during power operations.
9003230104 980313 i
PDR ADOCK 05000445 NRC FM.E CENTER COPY
Mr. C. L"nce Tcrry March 13, 1998-NRC Inspection M:nu:1, Pcrt 9900, ' Operations - Notices of Enf:rcem:nt Discr: tion, " S ction B,0 item 1, states:
For an operating plant, the NOED is intended to (a) avoid undesirable transients as a r' esult of forcing compliance with the license condition and, thus, minimize potential safety consequences and operational risks or (b) eliminate testing, inspection, or system realignment that is inappropriate for the particular plant conditions.
s The NRC staff determined that crediting the performance of SRs 4.8.1.1.2f.4)b) and 4.8.1.1.2f.6)b) for the Si and 80 sequencer block contacts during power operations is acceptable because the SRs were satisfactorily completsd during the previous refueling outage for the purpose of demonstrating the capability of the diesel generators to carry their required loads.
However, the operability of the Si and BO sequencer block contacts for certain loads were not verified. Therefore, it was not clear whether the Si and BO block contacts sequenced these loads on the diesel generators. The licensee has completed the portions of the SRs which have not been tested during the previous refueling outage. In addition, the staff believes that verification of this segment of the integrated test during power operation would pose no adverse effect to the A.C. electrical distribution system. As a result, a shutdown of both CPSES units to establish the TS-required conditions to perform the SRs would constitute an unnecessary operational risk. Therefore, the criteria of NRC Inspection Manual Part 9900, Section B, item 1, are met.
On the basis of the staff's evaluation, the NRO staff concluded that an NOED is warranted because we are clearly satisfied that this action involves minimal or no safety impact and has no -
adverse radiologicalimpact on public health and safety. Therefore, it is our intention to exercise discretion not to enforce compliance with TS SRs 4.8.1.1.2f.4)b) and 4.8.1.1.2f.6)b) for the period from March 11,1998, at 9:25 a.m. EST untilissuance of a license amendment.
By letter dated March 12,1998, you submitted a license amendment request, and we will process that amendment as an exigent amendment. This letter documents our telephone conversation on March 11,1998, at 9:25 EST 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 noncompliance for which the NOED was necessary.
Sincerely, ORIGINAL SIGNED BY:
John N. Hannon, Director Project Directorate IV-1 Division of Reactor Projects Ill/IV F
Office of Nuclear Reactor Regulation Docket Nos. 50-445 and 50-446 cc: -See next page L
' DISTRIBUTION: See next page
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Mr. C. Lance Terry l l
NRC Inspection Manual, Part 9900, " Operations - Notices of Enforcement Discretion, " Section B, l
Item 1, states:
l For an operating plant, the NOED is 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 or (b) eliminate testing, inspection, or system -
realignment that is inappropriate for the particular plant conditions.
The NRC staff determined that crediting the performance of SRs 4.8.1.1.2f.4)b) and 4.8.1.1.2f.6)b) for the Si and BO sequencer block contacts during power operations is acceptable because the SRs were satisfactorily completed during the previous refueling outage for the
. purpose of demonstrating the capability of the diesel generators to carry their required loads.
j However, the operability of the Si and BO sequencer block contacts for certain loads were not I
verified. Therefore, it was not clear whether the Si and BO block contacts sequenced these i
loads on the diesel generators. The licensee has completed the portions of the SRs which have not been tested during the previous refueling outage. In addition, the staff believes that verification of this segment of the integrated test during power operation would pose no adverse effect to the A.C. electrical distribution system. As a result, a shutdown of both CPSES units to establish the TS-required conditions to perform the SRs would constitute an unnecessary operational risk. Therefore, the criteria of NRC Inspection Manual, Part 9900, Section B, item 1, are met.
On the basis of the staff's evaluation, the NRC staff 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 impact on public health and safety. Therefore, it is our intention to exercise discretion not to enforce compliance with TS SRs 4.8.1.1.2f.4)b) and 4.8.1.1.2f.6)b) for the period from March 11,1998, at 9:25 a.m. EST untilissuance of a license amendment.
By letter dated March 12,1998, you submitted a license amendment request, and we will process that amendment as an exigent amendment. This letter documents our telephone conversation on March 11,1998, at 9:25 EST 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 noncompliance for which the NOED i
was necessary.
Sincerely, k.
=m i
John N. Hannon, Director J
Project Directorate IV 1 Division of Reactor Projects lil/IV Office of Nuclear Reactor Regulation Docket Nos. 50-445 and 50-446 I
j cc: See next page
Mr. C. Lance Terry TU Electric Company Comanche Peak, Units 1 and 2 cc:
Senior Resident inspector Honorable Dale McPhersca 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 Govemor 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 i
TU Electric 1100 West 49th Street
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Regulatory Affairs Manager Austin, TX 78756-3189 P. O. Box 1002 l
Glen Rose, TX 76043 Jim Calloway Public Utility Commission of Texas Texas Utilities Electric Company Electric industry Analysis clo Bethesda Licensing P. O. Box 13326 3 Metro Center, Suite 810 Austin, TX 78711-3326 Bethesda, MD 20814 George L. Edgar, Esq.
Morgan, Lewis & Bockius 1800 M Street, N.W.
Washington, DC 20036-5869
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' DISTRIBUTION: NOED Dated March 13.1998 I
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