IR 05000338/2012008
| ML12082A045 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 03/21/2012 |
| From: | Croteau R Division Reactor Projects II |
| To: | Heacock D Virginia Electric & Power Co (VEPCO) |
| References | |
| EA-12-033 IR-12-008 | |
| Download: ML12082A045 (6) | |
Text
March 21, 2012
SUBJECT:
NORTH ANNA POWER STATION - NRC INSPECTION REPORT 05000338/2012008 AND 05000339/2012008; PRELIMINARY GREATER THAN GREEN FINDING
Dear Mr. Heacock:
This letter transmits one finding that has preliminarily been determined to be greater than very low safety significance (Greater than Green) for both units, which requires further risk evaluation to determine the final significance and the need for additional NRC action. The preliminary Greater than Green finding, as documented in NRC Inspection Report (IR) 05000338, 339/2011005, involved failure to adequately establish and maintain emergency diesel generator (EDG) maintenance procedure 0-MCM-0701-27, Replacement of Emergency Diesel Generator Cylinder Liners. This finding was determined to be an Apparent Violation (AV) of Technical Specification (TS) 5.4.1.a for failure to establish and maintain EDG maintenance procedures as recommended by Regulatory Guide 1.33, Appendix A, Section 9, Procedures for Performing Maintenance. Specifically, maintenance procedure 0-MCM-0701-27 did not provide adequate guidance for installation of the jacket water cooling inlet jumper gasket which resulted in a faulty gasket installation on the Unit 2 H (2H) EDG in May 2010. As a result, the 2H EDG failed to perform its safety function on August 23, 2011.
This preliminary Greater than Green finding does not represent a current safety concern because the failed gasket was replaced and the 2H EDG was declared operable on August 23, 2011. Similar gaskets located on both units EDGs were also inspected and no problems were identified. This finding was assessed based on the best available information, using the
ENCLOSURE TRANSMITTED HEREWITH CONTAINS SUNSI. WHEN SEPARATED FROM ENCLOSURE THIS TRANSMITTAL DOCUMENT IS DECONTROLLED. VEPCO 2 applicable Significance Determination Process (SDP). The analysis determined the resulting risk increase to be on the order of Greater than Green (>1E-06/year) for both units with the following key assumptions: 10-month exposure period for the performance deficiency, common cause failure potential applicable, and nominal values for EDG recovery actions (i.e., no guaranteed success assumed). Fire scenarios, another potential risk contributor, were not considered in this initial assessment due to lack of information available to the NRC analysts at the time of the assessment. The failure mode of the gasket, mitigating strategies (e.g. 10 CFR 50.54 (hh) strategies), and contribution of fire risk will need to be addressed in order to determine the final significance of this finding. Influential assumptions, dominant cut-set contributors, exposure time and sensitivity analysis, and the SDP Phase 3 evaluation results are discussed in the enclosure of this report. The final resolution of this finding will be conveyed in separate correspondence.
The finding is also an apparent violation (AV) of NRC requirements and is being considered for escalated enforcement action in accordance with the NRCs Enforcement Policy, which can be found on the NRCs Web site at http://www.nrc.gov/about-nrc/regulatory/enforcement/enforce-pol.html.
In accordance with NRC Inspection Manual Chapter (IMC) 0609, we intend to complete our evaluation using the best available information and issue our final determination of safety significance within 90 days from the issue date of NRC IR 05000338, 339/2011005. The significance determination process encourages an open dialogue between the NRC staff and the licensee; however, the dialogue should not impact the timeliness of the staffs final determination.
Before we make a final decision on this matter, we are providing you with an opportunity to (1)
attend a Regulatory Conference where you can present to the NRC your perspective on the facts and assumptions the NRC used to arrive at the finding and assess its significance, or (2)
submit your position on the finding to the NRC in writing. If you request a Regulatory Conference, it should be held within 30 days of the receipt of this letter and we encourage you to submit supporting documentation at least one week prior to the conference in an effort to make the conference more efficient and effective. If a Regulatory Conference is held, it will be open for public observation. The NRC will also issue a press release to announce the conference. If you decide to submit only a written response, such submittal should be sent to the NRC within 30 days of your receipt of this letter. If you decline to request a Regulatory Conference or submit a written response, you relinquish your right to appeal the final SDP determination, in that by not doing either, you fail to meet the appeal requirements stated in the Prerequisite and Limitation sections of Attachment 2 of IMC 0609.
If you choose to provide a written response, it should be clearly marked Response to Apparent Violation, in Inspection Report Nos. 05000338/2012008 and 05000339/2012008; EA-12-033, and should include: (1) the reason for the apparent violation, or, if contested, the basis for disputing the apparent violation, (2) the corrective steps that have been taken and the results achieved, (3) the corrective steps that will be taken to avoid further violations, and (4) the date VEPCO 3 when full compliance will be achieved. Your response may reference or include previously docketed correspondence, if the correspondence adequately addresses the required response.
If an adequate response is not received within the time specified or an extension of time has not been granted, NRC will proceed with its enforcement decision.
Please contact Gerald McCoy at (404) 997-4551 within 10 days of the date of this letter to notify the NRC of your intended response. If we have not heard from you within 10 days, we will continue with our significance determination decision. The final resolution of this matter will be conveyed in separate correspondence.
Because the NRC has not made a final determination as to the significance of the issue, no Notice of Violation is being issued at this time. Please be advised that the number and characterization of the AV described in the enclosure may change as a result of further NRC review.
In accordance with 10 CFR 2.390 of the NRC's "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 NRC's Agencywide 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).
Sincerely,
/RA/
Richard P. Croteau, Director Division of Reactor Projects
Docket Nos. 50-338, 50-339 License Nos. NPF-4, NPF-7
Enclosure: Phase 3 Significance Determination
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SIGNATURE SNinh GKolcum RClagg GMacDonald GMcCoy CEvans
NAME 03/ 14 /2012 03/14 /2012 03/14 /2012 03/ 14 /2012 03/ 19 /2012 03/ 16 /2012
DATE 3/ /2012 3/ /2012 3/ /2012 3/ /2012 3/ /2012 3/ /2012 3/ /2012 E-MAIL COPY?
YES NO YES NO YES NO YES NO YES NO YES NO YES NO OFFICE OE NRR RII:DRP RII:DRP
SIGNATURE
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NAME LCasey
WJones RCroteau
DATE 3/ /2012 3/ /2012 3/ /2012 3/ /2012 3/ /2012 3/ /2012 3/ /2012 E-MAIL COPY?
YES NO YES NO YES NO YES NO YES NO YES NO YES NO VEPCO 5 cc w/o Encl:
Mr. Gerald T. Bischof Site Vice President North Anna Power Station Virginia Electric & Power Company Electronic Mail Distribution
Fred Mladen Director, Station Safety & Licensing Virginia Electric and Power Company Electronic Mail Distribution
Michael Crist Plant Manager North Anna 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 Inssbrook 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 North Anna Power Station U.S. Nuclear Regulatory Commission P.O. Box 490 Mineral, VA 23117
Donald R. Taylor Licensing Supervisor North Anna Power Station P. O. Box 402 Mineral, VA 23117-0402
Michael M. Cline Director Virginia Department of Emergency Services Management Electronic Mail Distribution
Executive Vice President Old Dominion Electric Cooperative Electronic Mail Distribution
County Administrator Louisa County P.O. Box 160 Louisa, VA 23093 VEPCO 6 Letter to David from Gerald J. McCoy dated March 21, 2012
SUBJECT:
NORTH ANNA POWER STATION - NRC INSPECTION REPORT 05000338/2012008 AND 05000339/2012008; A PRELIMINARY GREATER THAN GREEN FINDING
Distribution w/o encl:
RidsNrrPMNorthAnna Resource C. Evans, RII EICS L. Douglas, RII EICS B. Westreich, NSIR (hard copy w/ encl)
E. McNiel, NSIR (hard copy w/ encl)
RIDSNRRDIRS OE Mail (email address if applicable)
PUBLIC