ML20217C530
| ML20217C530 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 03/17/1998 |
| From: | Hannon J NRC (Affiliation Not Assigned) |
| To: | Terry C TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| Shared Package | |
| ML20217B910 | List: |
| References | |
| NUDOCS 9803270052 | |
| Download: ML20217C530 (1) | |
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C. Lancs Terry 2-1 otherwise operable diesel generators inoperable. In addition, you stated that CPSES w'll have tested all contacts of concem at power prior to the expiration of the 72-hour extension requested in your March 12,1998, letter. As such, you w'll 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 portions of SRs 4.8.1.1.2f.4)a) and 4.8.1.1.2f.6)a) during power operations.
NRC Inspection Manual, Part 9900, " Operations - Notices of Enforcement Discretion," Section B, item 1, states:
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 allowing an additional 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> for the preparation and performance of portions of SRs 4.8.1.1.2f.4)a) and 4.8.1.1.2f.6)a)is acceptable. The NRC staff has also determined that crediting the performance of portions of SRs 4.8.1.1.2f.4)a) and 4.8.1.1.2f.6)a) during power operations is acceptable. These tests will demonstrate that the contacts from the undervoltage relays close upon actuation of the associated relay, thus completing the confirmation of the circuit by overlapping tests. Downstream actuation of the relays and breaker trips was confirmed during the normalintegrated surveillance test (with the exception of the bus tie breaker for MCC XEB4 3 for Unit 2, which was addressed in a previous 4
enforcement discretion). In addition, the staff believes that verification of these segments of the integrated tests during power operation would pose no adverse effect to the A.C. electrical distribution system. As a result, a sinutdown 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 radiologicalimpact on public health and safety. Therefore, it is our intention to exercise discretion not to enforce compliance with TS 4.0.3 for the period from March 13,1998, at 5:18 p.m. CST until March 16,1998, at 5:18 p.m. CST. In addition, it is our intention to exercise discretion not to enforce compliance with SRs 4.8.1.1.2f.4)a) and 4.8.1.1.2f.6)a) for the period from March 13,1998, at 3:10 p.m. EST untilissuance of a license amendment.
We understand that you will submit a license amendment request by March 18,1998, and we will process that amendment as an exigent amendment. This letter documents our telephone conversation on March 13,1998, at 3:10 p.m. EST when we orally issued this notice of enforcement discretion.
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