IR 05000280/2012008
| ML12131A650 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 05/10/2012 |
| From: | Croteau R Division Reactor Projects II |
| To: | Heacock D Virginia Electric & Power Co (VEPCO) |
| Catherine Morrison | |
| References | |
| EA-12-034 IR-12-008 | |
| Download: ML12131A650 (6) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION May 10, 2012
SUBJECT:
FINAL SIGNIFICANCE DETERMINATION - NRC INSPECTION REPORT 05000280/2012008 AND 05000281/20120008, SURRY POWER STATTION, UNIT 2
Dear Mr. Heacock:
This letter provides the final significance determination for the preliminary White finding discussed in NRC Inspection Report Nos. 05000280/2012007 and 05000281/2012007. The inspection finding was assessed under the significance determination process and was preliminarily characterized as White, i.e., an issue of low to moderate safety significance. The finding involved an apparent violation of Surry Unit 2 Technical Specification (TS) 6.4.A.7 for the failure to provide detailed written procedures with appropriate check-off lists and instructions for preventive or corrective maintenance.
At your request, an open regulatory conference was conducted with members of your staff on April 19, 2012, to discuss your views on this issue. Your staff presented the new information at the regulatory conference which include: 1) there are provisions in the stations procedures to flush and drain the standpipe after use to remove foreign material; 2) a letter from the standpipe manufacturer indicating that the procedures for the cleaning and flushing of the Surry reactor coolant system (RCS) standpipe provide adequate maintenance to meet the recommendations of the vendor technical manual; and 3) an independent assessment by MPR Associates, Inc.
which indicated that the erratic indications appear electrical in nature and are not associated with the established maintenance strategy for the standpipe. During the conference, your staff presented your assessment of the significance of the finding (ML12115A066), disagreed with the NRCs characterization of the finding as an apparent violation of regulatory requirements, and disagreed with NRCs estimate that the finding resulted in an incremental increase in core damage frequency of approximately 4E-06/year.
The continued unreliability of the Unit 2 RCS standpipe is an issue of concern to the NRC.
Industry experience has shown that unreliable indication of RCS level has been associated with potentially serious events during outages. Reliable and accurate RCS water level indication must be provided to the operators during higher risk evolutions, especially during reduced inventory operations. In Generic Letter 88-17, Loss of Decay Heat Removal the NRC
VEPCO 2 specified that each licensee should provide at least two independent, reliable, and continuous RCS water level indications whenever the RCS is in a reduced inventory condition. In Generic Letter 88-17, Loss of Decay Heat Removal, the NRC specified that each licensee should provide at least two independent, reliable, and continuous RCS water level indications whenever the RCS is in a reduced inventory condition. Surry Power Station intended to meet the performance standards articulated in the GL 88-17 by incorporating the following paragraph as Section 4.2.11 to its FSAR. Adequate indication of RCS level and temperature, and of RHR system performance, is provided in the control room. A permanent RCS standpipe and an ultrasonic level detector are installed to ensure that at least two independent, continuous RCS level indications are monitored in the control room during reduced inventory conditions. Both level monitors provide indication, trending, and low-level alarms in the control room. The NRC understands from the information presented at the regulatory conference that your staff is committed to identifying the definitive cause of Surry Unit 2 RCS standpipe erratic level indications and correcting it to prevent recurrence. If the definitive cause cannot be determined, a new reliable RCS level indication system will be installed during the next Unit 2 refueling outage. Please confirm our understanding of your plans with respect to the Unit 2 RCS level indication system in a letter to the NRC within 30 days. We request that your response address the Generic Letter 88-17 specifications for independent, reliable, and continuous RCS water level indication.
The NRC has concluded that the bases for the preliminary White finding and apparent violation described in the inspection report are no longer valid, based on the new information provided at the regulatory conference. Specifically, your VTM review process did not cause or contribute to the unreliability of the reactor coolant system (RCS) standpipe indication system, and in this case had no impact on Surrys existing maintenance procedures or processes. Accordingly, a violation of TS 6.4.A.7 did not occur. As acknowledged at the conference, an administrative error occurred associated with your inclusion of a blank form in the VTM records review package. The NRC concluded that this administrative error of the VTM review process represents a minor finding, but is not a violation because NRC regulations do not require such review and documentation for a non-safety related component. With respect to the risk significance of the finding, the final determination of the significance is not required since the performance deficiency described in the Inspection Reports 0500281/2012007 and 05000281/2012007 was determined to be minor.
The NRC will continue with our inspection process as you continue your troubleshooting efforts.
In the event that information provided in your 30 day response letter or the follow-up inspections reveal other performance deficiencies, we plan to disposition them in accordance with our processes.
In accordance with 10 CFR 2.390 of the NRCs Rules of Practice, a copy of this letter and your response (if any) will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of the NRCs Agency wide Document Access and management System (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
VEPCO 3 Should you have any questions regarding this letter, please contact Gerald McCoy, Chief, Reactor Projects Branch 5, Division of Reactor Projects, at 404-997-4551.
Sincerely,
/RA/
Richard P. Croteau, Director Division of Reactor Projects Docket Nos.: 50-280, 50-281 License Nos.: DPR-32, DPR-37
__ML12131A650______________ X SUNSI REVIEW COMPLETE X FORM 665 ATTACHED OFFICE RII:DRP RII:DRP RII:EICS OE NRR RII:DRP SIGNATURE GJM1 for GJM1 CFE Not required MaryAnnAshley RXC2 NAME SNinh GMcCoy CEvans By email RCroteau DATE 04/30/2012 04/30/2012 04/30/2012 04/ /2012 05/04/2012 05/10/2012 E-MAIL COPY? YES NO YES NO YES NO YES NO YES NO YES NO YES NO
VEPCO 4 cc: Michael M. Cline Larry Lane Director Site Vice President Virginia Department of Emergency Services Surry Power Station Management Virginia Electric and Power Company Electronic Mail Distribution Electronic Mail Distribution B. L. (Sonny) Stanley Director, Nuclear Safety and Licensing Virginia Electric and Power Company Electronic Mail Distribution Kenny B. Sloane Plant Manager Surry Power Station Virginia Electric & Power Company Electronic Mail Distribution Lillian M. Cuoco, Esq.
Senior Counsel Dominion Resources Services, Inc.
Electronic Mail Distribution Tom Huber Director, Nuclear Licensing & Operations Support Innsbrook Technical Center Electronic Mail Distribution Ginger L. Rutherford Virginia Electric and Power Company Electronic Mail Distribution Virginia State Corporation Commission Division of Energy Regulation P.O. Box 1197 Richmond, VA 23209 Attorney General Supreme Court Building 900 East Main Street Richmond, VA 23219 Senior Resident Inspector Surry Power Station U.S. Nuclear Regulatory Commission 5850 Hog Island Rd Surry, VA 23883
VEPCO 5 Letter to David from Richard P. Croteau dated May 10, 2012 SUBJECT: FINAL SIGNIFICANCE DETERMINATION - (NRC INSPECTION REPORT 05000280/2012008 AND 05000281/20120008, SURRY POWER STATTION, UNIT 2)
Distribution:
C. Evans, RII EICS L. Douglas, RII EICS G. McCoy, RII S. Ninh, RII J. Nadel, RII R. Clagg, RII F. MacDonald, RII OE Mail N. Coleman, OE M. Ashley, NRR G. Waig, NRR RIDSNRRDIRS PUBLIC RidsNrrPMSurry Resource