ML080520023
| ML080520023 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  (NPF-042) |
| Issue date: | 02/20/2008 |
| From: | Collins E Region 4 Administrator |
| To: | Muench R Wolf Creek |
| References | |
| EA-08-052, NOED 08-4-001, TAC MD8098 | |
| Download: ML080520023 (5) | |
Text
February 20, 2008 Rick A. Muench, President and Chief Executive Officer Wolf Creek Nuclear Operating Corporation P.O. Box 411 Burlington, KS 66839
SUBJECT:
NOTICE OF ENFORCEMENT DISCRETION FOR WOLF CREEK NUCLEAR OPERATING CORPORATION REGARDING WOLF CREEK GENERATING STATION [TAC NO. MD8098, NOED NO. 08-4-001]
Dear Mr. Muench:
By letter dated February 15, 2008, Wolf Creek Nuclear Generating Operating Corporation (WCNOC) confirmed a February 13, 2008, verbal request that the NRC exercise discretion to not enforce compliance with the actions required in Wolf Creek Generating Station, Technical Specification (TS) 3.8.1 AC Sources - Operation, Action B.2.
WCNOC requested that a Notice of Enforcement Discretion (NOED) be granted pursuant to the NRCs policy regarding exercise of discretion for an operating facility, described in Section VII.C of the NRCs Enforcement Policy, and be effective for 15 hours1.736111e-4 days <br />0.00417 hours <br />2.480159e-5 weeks <br />5.7075e-6 months <br /> for TS 3.8.1.B.2 expiring on February 14, 2008 at 9:20 a.m. (all times discussed in this letter refer to Central Standard Time).
This letter documents our telephone conversation on February 13, 2008, at 7:50 p.m., when we verbally granted enforcement discretion. Subsequent to the verbal authorization of this enforcement discretion, we understand that the condition causing the need for this enforcement discretion was corrected by you causing you to exit from the actions required in TS 3.8.1 and from this NOED at 1:41 a.m. on February 14, 2008. The basis for our decision to grant the exercising of enforcement discretion is provided in the following discussion.
Your letter documented information previously discussed with the NRC in a telephone conference which occurred on February 13, 2008. The principal NRC staff members who participated in the telephone conference included: Dwight Chamberlian, Director, Division of Reactor Projects, (DRP), RIV; Roy Caniano, Director, Division of Rector Safety, (DRS), RIV; Tony Vegel, Deputy Director, DRP, RIV; John Lubinski, Deputy Director, Division of Operating Reactor Licensing, Office of Nuclear Reactor Regulation (NRR); Vincent Gaddy, Chief, Project Branch B, DRP, RIV; Tom Hiltz, Chief, Plant Licensing Branch 4, NRR; Tim Kobetz, Chief, Reactor Inspection Branch, NRR; Russ Bywater, Chief, Engineering Branch 1, DRS, RIV; Greg Cranston, NRR; Tim Kolb, NRR; Mike Runyan, Senior Reactor Analyst, DRS, RIV; Balwant Singal, Project Manager, NRR; Geoff Miller, Senior Project Engineer, Projects Branch E, DRP, RIV; Chris Long, Resident Inspector, DRP, RIV; See-Meng Wong, Senior Reactor Analyst, NRR; and Jay Robinson, Project Manager, NRR.
UNITED STATES NUCLEAR REGULATORY COMMISSION R E GI ON I V 611 RYAN PLAZA DRIV E, SUITE 400 ARLINGTON, TEXAS 76011-4005
Wolf Creek Nuclear Operating Corporation Your staff requested enforcement discretion to preclude declaring the Train B Centrifugal Charging Pump inoperable by 6:20 p.m. on February 13, 2008. On February 13, 2008, at 2:20 p.m. you identified leakage from the drain pan of the room cooler that supported operability of the Train A Centrifugal Charging Pump. The leakage rendered the room cooler inoperable and, therefore, required the licensee to declare the charging pump inoperable. Technical Specification 3.5.2 was entered with a 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> completion time to restore the Train A Centrifugal Charging Pump. After removal of the outer cover panel of the room cooler, a leak was identified on a room cooler H-bend assembly. Visual observation identified that the leak was due to a through-wall flaw at the threaded hex nut. Removal of the H-bend assembly identified that the most likely cause of the leak was due to flow induced erosion. This cooler is scheduled to be replaced in the upcoming refueling outage (March 2008).
The centrifugal charging pumps are part of the emergency core cooling system and the room cooler limits the pump room ambient temperature to assure operability of the pump.
Specifically, the room cooler is designed to limit the temperature of the pump room to 122o F during design basis accidents with a concurrent maximum lake temperature of 95o F to assure operability.
On February 11, 2008 at 5:02 a.m., you had entered TS 3.8.1 Action B.4.2.2, due to planned maintenance for Diesel Generator B. Action B.4.2.2 specified a 7 day completion time to restore the diesel generator to an operable status. When the Train A Centrifugal Charging Pump was declared inoperable, entry into TS 3.8.1 Action B.2 was required as discussed in the Technical Specification Bases.
As a result of Diesel Generator B being inoperable with Train A Centrifugal Charging Pump inoperable, TS 3.8.1 Action B.2 was entered. This required 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> to declare the required feature supported by the inoperable diesel generator inoperable when its required redundant feature (Train A centrifugal charging pump) was inoperable. The TS required the Train B Centrifugal Charging Pump to be declared inoperable in 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> after the Train A centrifugal charging pump was declared inoperable.
At 6:20 p.m., on February 13, 2008, the Train B Centrifugal Charging Pump was declared inoperable, and TS 3.0.3 was entered and actions were initiated within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> to place the Unit in Mode 3. You sought enforcement discretion to permit non-compliance with the completion time of Action B.2 of TS 3.8.1. to permit additional time to complete repairs and restoration of the Train A Centrifugal Charging Pump room cooler and Centrifugal Charging Pump before a plant shutdown was required. You requested an additional 15 hours1.736111e-4 days <br />0.00417 hours <br />2.480159e-5 weeks <br />5.7075e-6 months <br /> to restore the Train A Centrifugal Charging Pump and Room Cooler to an operable status by 9:20 a.m. on February 14, 2008, such that entry into Mode 3 would not be required until 4:20 p.m. on February 14, 2008.
Based on the information provided in the telephone conversation in February 13, 2008, and in your letter dated February 15, 2008, the NRC has determined that Criterion B.2.1.1.a of NRC Inspection Manual Part 9900, Technical Guidance, Operation - Notice of Enforcement Discretion, was met. The NRC reviewed your written request for enforcement discretion dated February 15, 2008, and verified consistency between your oral and written requests. The NRCs basis for this discretion considered: (1) the compensatory measures to reduce the probability of a plant transient while ensuring the availability of other safety-related equipment; (2) the availability of offsite electrical power; and (3) the quantitative risk assessment of the condition which indicated that the risk associated with increasing the allowed outage time an additional 15 hours1.736111e-4 days <br />0.00417 hours <br />2.480159e-5 weeks <br />5.7075e-6 months <br /> did not cause the risk to exceed the level determined acceptable during
Wolf Creek Nuclear Operating Corporation normal work controls. Based on the compensatory risk management measures, it was determined that there was no net increase in risk.
The WCNOC final quantitative risk analysis indicated that the incremental conditional core damage probability (ICCDP) for the proposed 15 hour1.736111e-4 days <br />0.00417 hours <br />2.480159e-5 weeks <br />5.7075e-6 months <br /> extension is 1.53E-08, and the incremental conditional large early release probability (ICLERP) for the proposed 15 hour1.736111e-4 days <br />0.00417 hours <br />2.480159e-5 weeks <br />5.7075e-6 months <br /> extension results is less than 5E-8. These values are both less than the guidance thresholds in Inspection Manual Part 9900 Technical Guidance. To further mitigate the risk impact in (1) above, WCNOC committed to implement a series of compensatory actions for the duration of the enforcement discretion period. Some of the compensatory actions that WCNOC committed to implement included: (1) avoidance of testing and maintenance impacting availability of the Train A safety bus, including but not limited to, the essential service water system, motor-driven auxiliary feedwater pump, turbine-driven auxiliary feedwater pump, component cooling water system, residual heat removal system, air conditioning units, all 125 Vdc system batteries, and the associated diesel generator to maximize the mitigative response to a station blackout.;
(2) ensuring no switchyard work is allowed: (3) enhanced operator sensitivity to safety bus electrical power supply issues to recognize and respond expeditiously to a station blackout or loss of offsite power event; (4) continual monitoring by the grid operator regarding grid conditions to anticipate challenges to offsite power availability; (5) availability of the Sharpe Station to mitigate a station blackout and station operator just-in-time training; and (6) just-in-time training for the top reactor operator manual actions as shown in the Wolf Creek PRA.
On the basis of the NRC staffs evaluation of your request, we have concluded that granting this NOED is consistent with the Enforcement Policy and staff guidance and has no adverse impact on public health and safety. Therefore, as we communicated to your staff at 7:50 p.m. on February 13, 2008, we exercised discretion to not enforce compliance with TS 3.8.1, Required Action B.2 for a period of 15 hours1.736111e-4 days <br />0.00417 hours <br />2.480159e-5 weeks <br />5.7075e-6 months <br /> from 6:20 p.m. February 13, 2008, to 9:20 a.m. February 15, 2008.
In addition, as discussed on February 13, 2008, the NRC staff agrees with WCNOCs determination that a follow-up TS amendment was not needed. The staff finds that a TS amendment (either a temporary or permanent amendment) needed for circumstances similar to those addressed by the NOED is not necessary because it involves a nonrecurring noncompliance and only involves a single request for extending the period of time that an inoperable plant component must be restored to operable status as specified per the plants TS.
As stated in the Enforcement Policy, action will 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,
/RA/
Elmo E. Collins Regional Administrator Docket: 50-482 License: NPF-42
Wolf Creek Nuclear Operating Corporation cc:
Vice President Operations/Plant Manager Wolf Creek Nuclear Operating Corp.
P.O. Box 411 Burlington, KS 66839 Jay Silberg, Esq.
Pillsbury Winthrop Shaw Pittman LLP 2300 N Street, NW Washington, DC 20037 Supervisor Licensing Wolf Creek Nuclear Operating Corp.
P.O. Box 411 Burlington, KS 66839 Chief Engineer Utilities Division Kansas Corporation Commission 1500 SW Arrowhead Road Topeka, KS 66604-4027 Office of the Governor State of Kansas Topeka, KS 66612 Attorney General 120 S.W. 10th Avenue, 2nd Floor Topeka, KS 66612-1597 County Clerk Coffey County Courthouse 110 South 6th Street Burlington, KS 66839-1798 Chief, Radiation and Asbestos Control Section Kansas Department of Health and Environment Bureau of Air and Radiation 1000 SW Jackson, Suite 310 Topeka, KS 66612-1366 Ronald L. McCabe, Chief Technological Hazards Branch National Preparedness Division DHS/FEMA 9221 Ward Parkway Suite 300 Kansas City, MO 64114-3372
Wolf Creek Nuclear Operating Corporation Electronic distribution by RIV:
Regional Administrator (EEC)
DRP Director (DDC)
DRS Director (RJC1)
DRS Deputy Director (ACC)
Senior Resident Inspector (SDC)
SRI, Callaway (DED)
Branch Chief, DRP/B (VGG)
Senior Project Engineer, (RWD)
Team Leader, DRP/TSS (CJP)
RITS Coordinator (MSH3)
T. Bloomer, Chief, TRPS, OEDO (TEB)
S. Richards, Deputy Director, DIRS, NRR (SAR)
J. Lubinski, Deputy Director, DORL, NRR (JWL)
C. Haney, Director, DORL, NRR (CXH)
T. Hiltz, Chief, PLB IV, DORL, NRR (TGH)
B. Singal, Project Manager (BKS)
D. Pelton, OEDO RIV Coordinator (DLP)
K. S. Fuller, RC/ACES (KSF)
C. A. Carpenter, D:OE (CAC)
OE:EA File (RidsOeMailCenter)
SUNSI Review Completed: _VGG__ ADAMS: Yes No Initials: _VGG_
Publicly Available Non-Publicly Available Sensitive Non-Sensitive R:\\_NOED\\NOED 2008\\WC NOED 08-4-001.doc ADAMS ML080520023 RIV:C:DRP/B SRA:DRS D:DRS VGGaddy MRunyan RCaniano
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02/19/2008 02/20/2008 02/20/2008 NRR DD:NRR D:DRP RA BSingal JLubinski DChamberlain EECollins
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02/20/2008 02/20/2008 02/20/2008 02/20/2008 OFFICIAL RECORD COPY T=Telephone E=E-mail F=Fax