IR 05000348/2008012

EA-08-192, Final Significance Determination of White Finding and Notice of Violation (NRC Inspection Report No. 05000348-08-012, Joseph M. Farley Nuclear Plant Unit 1)

ML082480616
Person / Time
Site:	Farley
Issue date:	09/04/2008
From:	Reyes L Region 2 Administrator
To:	Jerrica Johnson Southern Nuclear Operating Co
References
EA-08-192 IR-08-012
Download: ML082480616 (6)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION

REGION II

ber 4, 2008

SUBJECT:

FINAL SIGNIFICANCE DETERMINATION OF WHITE FINDING AND NOTICE OF VIOLATION (NRC INSPECTION REPORT NO. 05000348/2008012, JOSEPH M. FARLEY NUCLEAR PLANT UNIT 1)

Dear Mr. Johnson:

This letter provides you the final significance determination of the preliminary White finding discussed in NRC Inspection Report No. 05000348/2008011, dated July 16, 2008. The finding involved inadequate work instructions to install the 1B Emergency Diesel Generator (EDG)

exhaust header. These work instructions did not adequately provide the vendors installation instructions which led to failure of the exhaust header causing the 1B EDG to be declared inoperable on March 13, 2008.

In a letter dated August 12, 2008, you provided a response to the NRC staffs preliminary determination regarding the finding. Your response indicated Southern Nuclear Operating Companys (SNC) agreement with the NRCs preliminary significance as determined by the Significance Determination Process (SDP). SNC noted, however, that the NRCs SDP assessment was highly conservative due to the selection of the 1B EDG exposure time, and stated that an alternate exposure time should be used. SNC acknowledged that the difference in exposure time selection would not alter the overall risk estimate. While the NRC acknowledges that the use of SNCs referenced exposure time would not alter the overall SDP determination, we believe that the 1B EDG exposure time used in our SDP analysis is more appropriate due to the unpredictability of the EDG failure mechanism.

After considering the information developed during the inspection, the NRC has concluded that the finding is appropriately characterized as White. You have 30 calendar days from the date of this letter to appeal the staff=s significance determination for this finding. Such appeals will be considered to have merit only if they meet the criteria given in NRC Inspection Manual Chapter 0609, Attachment 2.

The NRC has also determined that the inadequate work instructions used to install the 1B EDG exhaust header is a violation of Technical Specification 5.4.1 and NRC Regulatory Guide 1.33, as cited in the enclosed Notice of Violation (Notice). The circumstances surrounding the

SNC, Inc. 2 violation were described in NRC Inspection Report No. 05000348/2008011. In accordance with the NRC Enforcement Policy, the Notice is considered escalated enforcement action because it is associated with a White finding. This violation is identified as VIO 05000348/2008011-01, Inadequate Work Instructions Cause 1B EDG Exhaust Header Failure.

The NRC has concluded that the information regarding the reason for the violation, the corrective actions taken and planned to correct the violation and prevent recurrence, and the date when full compliance was achieved is already adequately addressed on the docket in the SNC letter of August 12, 2008. Therefore, you are not required to respond to this letter unless the description therein does not accurately reflect your corrective actions or your position.

At the end of the second quarter of 2008, Unit 1 was in the Degraded Cornerstone of the NRC Agency Action Matrix. The addition of this White finding does not change the status of Unit 1 with respect to the Action Matrix. Therefore, we will conduct a supplemental inspection using Inspection Procedure 95001, Inspection For One Or Two White Inputs In A Strategic Performance Area. On August 21, 2008, you informed us of your readiness for this supplemental inspection, which has been scheduled for the week of September 22, 2008.

In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and your response, if you choose to provide one, will be made available electronically for public inspection in the NRC Public Document Room or from the NRC=s document system (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html. To the extent possible, your response should not include any personal privacy, proprietary, or safeguards information so that it can be made available to the Public without redaction.

Sincerely,

/RA/

Luis A. Reyes Regional Administrator Docket No.: 50-348 License No.: NPF-2 Enclosure: Notice of Violation cc w/encl: (See page 3)

SNC, Inc. 3 cc w/encl:

B. D. McKinney Jim Sommerville Licensing Services Manager (Acting) Chief B-031 Environmental Protection Division Southern Nuclear Operating Company, Inc. Department of Natural Resources Electronic Mail Distribution Electronic Mail Distribution Jeffrey T. Gasser Executive Vice President Southern Nuclear Operating Company, Inc.

Electronic Mail Distribution William D. Oldfield Quality Assurance Supervisor Southern Nuclear Operating Company Electronic Mail Distribution L. Mike Stinson Vice President Fleet Operations Support Southern Nuclear Operating Company, Inc.

Electronic Mail Distribution David H. Jones Vice President Engineering Southern Nuclear Operating Company, Inc.

Electronic Mail Distribution Moanica Caston Vice President and General Counsel Southern Nuclear Operating Company, Inc.

Electronic Mail Distribution M. Stanford Blanton, Esq.

Balch and Bingham Law Firm Electronic Mail Distribution Dr. D. E. Williamson State Health Officer Alabama Dept. of Public Health Electronic Mail Distribution Mr. Mark Culver Chairman Houston County Commission P. O. Box 6406 Dothan, AL 36302

_________________________ G SUNSI REVIEW COMPLETE OFFICE EICS DRS RII:DRP RII:ORA NRR OE SIGNATURE /RA/ VIA EMAIL /RA/ /RA/ VIA EMAIL VIA EMAIL NAME CEVANS WROGERS LWERT VMCCREE MASHLEY NHILTON DATE 8/21/08 8/21/08 8/21/08 8/28/08 8/28/08 8/28/08 E-MAIL COPY? YES NO YES NO YES NO YES NO YES NO YES NO YES NO

NOTICE OF VIOLATION Southern Nuclear Operating Company Docket No. 50-348 Joseph M. Farley Nuclear Plant License No. NPF-2 Unit 1 EA-08-192 During an inspection completed by the NRC on June 26, 2008, a violation of NRC requirements was identified. In accordance with the NRC Enforcement Policy, the violation is set forth below:

Technical Specification (TS) 5.4.1 states, in part, that written procedures shall be established, implemented, and maintained covering the applicable procedures recommended in Regulatory Guide 1.33, Revision 2, Appendix A, February 1978.

Section 9 of Appendix A to Regulatory Guide 1.33 states that maintenance that can affect the performance of safety-related equipment should be properly pre-planned and performed in accordance with written procedures, documented instructions, or drawings appropriate to the circumstances.

Contrary to the above, on February 4, 2008, maintenance activities affecting the 1B Emergency Diesel Generator (EDG), safety related equipment, were not performed in accordance with documented instructions appropriate to the circumstances. Specifically, Work Order WO1052028501 did not provide adequate instructions to ensure the replacement exhaust header was installed in accordance with the vendors instructions.

As a result, the 1B EDG exhaust header failed on March 13, 2008.

This violation is associated with a White SDP finding.

The NRC has concluded that information regarding the reason for the violation, the corrective actions taken and planned to correct the violation and prevent recurrence and the date when full compliance will be achieved is already adequately addressed on the docket in your letter dated August 12, 2008. However, if the description therein does not accurately reflect your position or your corrective actions, you are required to submit a written statement or explanation under 10 CFR 2.201. In that case, or if you choose to respond, clearly mark your response as a Reply to a Notice of Violation, EA-08-192. and send it to the Director, Office of Enforcement, U.S.

Nuclear Regulatory Commission, One White Flint North, 11555 Rockville, MD 20852-2738, with a copy to the Regional Administrator, U.S., Nuclear Regulatory Commission, Region II, and a copy to the NRC Resident Inspector at your facility that is the subject of this NOV.

If you contest this enforcement action, you should also provide a copy of your response, with the basis for your denial, to the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001.

Because your response will be publicly available in the NRC Public Document Room or from the NRC=s document system (ADAMS), to the extent possible, it should not include any personal privacy, proprietary, or safeguards information so that it can be made available without redaction. If personal privacy or proprietary information is necessary to provide an acceptable response, then please provide a bracketed copy of your response that identifies the information that should be protected and a redacted copy of your response that deletes such information. If Enclosure

NOV 2 you request withholding of such material, you must specifically identify the portions of your response that you seek to have withheld and provide in detail the bases for your claim of withholding (e.g., explain why the disclosure of information will create an unwarranted invasion of personal privacy or provide the information required by 10 CFR 2.390(b) to support a request for withholding confidential commercial or financial information). If safeguards information is necessary to provide an acceptable response, please provide the level of protection described in 10 CFR 73.21.

In accordance with 10 CFR 19.11, you may be required to post this Notice within two working days.

Dated this 4th day of September 2008 Enclosure