ML20249B325
| ML20249B325 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 05/20/1998 |
| From: | Merschoff E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Terry C TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| References | |
| 98-4-007, 98-4-7, NUDOCS 9806220322 | |
| Download: ML20249B325 (4) | |
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9 MAY 2 01998 Mr. C. L Terry TU Electric Group Vice Prerident, Nuclear ATTN: Regulatory Affairs Department-P.O. Box 1002 Glen Rose, Texas 76043 7
SUBJECT:
NOTICE OF ENFORCEMENT DISCRETION FOR TEXAS UTILITIES ELECTRIC REGARDING COMANCHE PEAK STEAM ELECTRIC STATION UNITS 1 AND 2, NOED NO. 98-4-007
Dear Mr. Terry:
On March 24,1998. Texas Utilities Electric (TU Electric) requested that the NRC exercise discretion to allow Comanche Peak Steam Electric Station (CPSES) Unit 2 to continue to operate and allow the refueling outage activities for Unit 1 to continue without having performed portions of Surveillance Requirements 4.8.1.1.2f.4(a),4.8.1.1.2f.4(b),4.8.1.1.2f.6(a),
4.8.1.1.2f.6(b) and 4.8.1.1.2f.6(c). Specifically, TU Electric requested that the NRC exercise discretion to not enforce the applicable Technical Specification ACTION requirements for an additional 14 days beyond the allowable 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period already allowed per Surveillance Requirement 4.0.3 for the missed surveillance. In a conference call between the Nuclear Regulatory Commission (NRC) staff and TU Electric on March 25,1998, at 2:25 p.m. (CDT), the NRC granted regional enforcement discretion as requested.
The safety basis for the staffs exercise of discretion was to allow TU Electric an opportunity to assess which devices had not been fully tested and either perform the tests, schedule the testing to be perfoimed, or determine that testing could not be performed safely at full power and, therefore, should be delayed.
7 On the basis of the staff's evaluation of your March 24 request, the staff concluded that a Notice
. of Enforcement Discretion (NOED) was warranted because we were clearly satisfied that this action involved minimal or no safety impact and had no adverse radiological impact on public health and safety. Additionally, we determined that your request satisfied the NRC's policy for
. enforcement discretion. Therefore, we exercised discretion not to enforce the applicable Technical Specification ACTION requirements for an additional 14 days beyond the allowabic 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period already allowed per Surveillance Requirement 4.0.3 for missed surveillance. This letter documents our telephone conversation on March 25,1998, at 2:25 p.m. (CDT) when we orally issued this notice of enforcement discretion.
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NOED 98-6-006 was granted by our Office of Nuclear Reactor Regulation (NRR) on April 8,1998 to: (1) allow the performance of at-power testing of load shed block seal-in and diesel generator non-emergency trip contacts, (2) take credit for previously performed at-power tests, and (3) delay some lockout relay contact testing until the next refueling outage or Mode 3.
These provisions were determined to not involve an unreviewed safety question.
NOED 98-6-006 also made reference to the March 25,1998, regional enforcement discretion, noting that it had been granted to extend the period of time when the applicable Technical Specification ACTION requirements for missed surveillance would be enforced.
It has been recognized that the letter documenting NOED 98-6-006 was not appropriate for documenting the approval of the 14 day extension which you requested on March 24. A specific letter granting the regional enforcement discretion should have been issued. Although the April 8,1998, NRR letter referred to the granting of an additional 14 days, this letter corrects the administrative oversight and specifically documents the granting of regional enforcement discretion on March 25,1998.
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 this NOED was necessary.
Sincerely,
/
Ellis W. Merscho Regional Admi trator Docket No.:
50-445 50-446 License No.: NPF-87 NPF-89 cc:
Mr. Roger D. Walker TU Electric Regulatory Affairs Manager P.O. Box 1002 Glen Rose, Texas 76043 Juanita Ellis
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