ML083020687
| ML083020687 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 10/28/2008 |
| From: | Clifford J Division Reactor Projects I |
| To: | Sena P FirstEnergy Nuclear Operating Co |
| BELLAMY RR | |
| References | |
| Download: ML083020687 (5) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION REGION I 475 ALLENDALE ROAD KING OF PRUSSIA, PA 19406-1415 October 28, 2008 Mr. Peter P. Sena, III Site Vice President, Beaver Valley Power Station FirstEnergy Nuclear Operating Company Mail Stop A-BV-SEB1 P.O. Box 4, Route 168 Shippingport, PA 15077
SUBJECT:
NOTICE OF ENFORCEMENT DISCRETION FOR FIRSTENERGY NUCLEAR OPERATING COMPANY REGARDING BEAVER VALLEY POWER STATION UNIT 2 (NOED NO. 08-1-01)
Dear Mr. Sena:
By letter dated October 24, 2008, you requested that the NRC exercise discretion to not enforce compliance with the actions required in the Technical Specifications (TS) for Beaver Valley Power Station Unit 2. Specifically, you requested that NRC not enforce the requirements of your plant Technical Specification 3.5.2.B. Your letter documented information previously discussed with the NRC in a telephone conference on October 22, 2008, at 9:30 a.m. and we have determined that your October 24 document was consistent with the contents of your verbal request.
The principal NRC staff members who participated in that telephone conference included:
NRC Region I Staff James Clifford, Deputy Director, Division of Reactor Projects (DRP)
Ronald Bellamy, Chief, Projects Branch 6, DRP David Werkheiser, Senior Resident Inspector, Beaver Valley Power Station Marjorie McLaughlin, State Liaison Officer William Cook, Senior Reactor Analyst, Division of Reactor Safety (DRS)
Kevin Mangan, Senior Reactor Inspector, DRS Adam Ziedonis, Reactor Inspector, DRS NRC Headquarters Staff Robert Nelson, Deputy Director, Division of Operating Reactor Licensing (DORL), Office of Nuclear Reactor Regulation (NRR)
Mark Kowal, Chief, Plant Licensing Branch I-1, DORL, NRR Nadiyah Morgan, Project Manager for Beaver Valley, DORL, NRR Jeff Circle, Senior Reactor Analyst, Risk Assessment Operational Support and Maintenance Branch, Division of Risk Assessment, NRR Warren Lyon, Senior Reactor Systems Engineer, Reactor Systems Branch, Division of Safety Systems, NRR Robert Wolfgang, Senior Mechanical Engineer, Component Performance and Testing Branch (CPTB), Division of Component Integrity (DCI), NRR
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Jeffrey Bream, Mechanical Engineer, CPTB, DCI, NRR Sheldon Stuchell, Senior Project Manager, Generic Communication and Power Uprate Branch, Division of Policy and Rulemaking, NRR You stated that on October 19, 2008, at 11:26 p.m., Beaver Valley entered TS Limiting Condition for Operation (LCO) 3.5.2.A, when the A Low Head Safety Injection (LHSI) system pump was removed from service for routine preventive maintenance. During performance of the preventive maintenance, maintenance personnel noted that the pump would not freely rotate through a full 360 degrees. On October 20, 2008, at 0700, you notified the Senior Resident Inspector of the issue. Prompt action was taken to assemble a problem solving team to disassemble the pump and identify the cause of this issue. Disassembly of the pump revealed rubbing between the pump impeller wear ring outer diameter and the pump casing, thus preventing full free rotation of the pump. Your staff determined that the cause for the condition of the A LHSI pump was a lack of proper centralized alignment of the pump rotating assembly within the casing bore. The expected timeline for receipt of replacement parts, repair, realignment, and post maintenance testing of the LHSI pump would have exceeded the allowable LCO outage time specified in TS 3.5.2.A, which requires restoration of the LHSI pump within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> (October 22, 2008 at 11:26 p.m.). When the conditions of TS 3.5.2.A are not met, TS 3.5.2.B requires entry into Mode 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, and Mode 4 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. On October 20, 2008, at 10:15 a.m., you notified the Senior Resident Inspector of your intention to request a Notice of Enforcement Discretion (NOED) and began making plans for a shutdown to mode 4 in parallel with LHSI pump troubleshooting efforts. You requested that a NOED be granted pursuant to the NRCs policy regarding exercise of discretion for an operating facility, set forth in Section VII.C of the General Statement of Policy and Procedures for the NRC Enforcement Actions (Enforcement Policy), NUREG-1600, and be effective for a period of 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. This letter documents our telephone conversation on October 22, 2008, which culminated when we orally issued this NOED at 11:05 a.m.
Your staff determined that 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> provided sufficient time to restore operability of the A LHSI pump. Your staff stated that certain corrective actions would be taken to resolve the issue within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />, including replacement of the wear ring, realignment of the pump to prevent future rubbing of the wear ring, and post maintenance testing of the pump to verify operability.
Additionally, your staff provided a qualitative, as well as a quantitative, risk assessment to address the criteria of Section D.4 of the NOED guidance contained in NRC Inspection Manual, Part 9900: Technical Guidance, Operations - Notices of Enforcement Discretion, dated February 7, 2005. In order to provide additional assurance that other critical systems would not be impacted, and to enhance the availability of selected systems, your staff committed to certain compensatory measures to reduce the risk associated with the specific plant configuration during the period of enforcement discretion. These compensatory measures included: (1) no additional risk significant components would be intentionally taken out of service; (2) no scheduled switchyard activities would be allowed; (3) no additional maintenance activities that would impact risk significant equipment; (4) protection of the B LHSI pump; (5) protection of the 2-2 Emergency Diesel Generator; and (6) hourly fire tours in the B train Safeguard Room and 2-2 Emergency Diesel Generator room. Therefore, after review by your Plant On-site Review Committee, your staff concluded that this NOED involved no net increase in radiological risk to the public. Additionally, your evaluation concluded that both the Incremental Conditional Core Damage Probability (ICCDP) for the equipment out-of-service over a 36-hour duration (4.8E-09), as well as the Incremental Conditional Large Early Release Probability (ICLERP) for this 36-hour duration (5.6E-12), were below the allowable NRC guidance thresholds. The NRC reviewed your assessment and determined that based on your planned corrective actions, your
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compensatory measures, and your risk assessment, that you have provided an adequate technical basis for granting the NOED.
Your staff determined that all applicable criteria in Section D to the NRC Inspection Manual, Part 9900: Technical Guidance, Operations - Notices of Enforcement Discretion, dated February 7, 2005, have been met. As per section B.2.1, Criterion 1.a, your staff stated that this NOED is intended to avoid an unnecessary transient which would result from compliance with the TS LCO, in order to minimize potential safety consequences and operational risks. In addition, we agree with your staffs determination and justification that a license amendment is not warranted, based on staff evaluation of your conclusions that this is a one-time deferral of a non-recurring noncompliance involving a single request for extending the TS allowable outage time for a single inoperable component.
On the basis of the staffs evaluation of your request in accordance with NRC Inspector Manual Chapter Part 9900 Technical Guidance, Operations - Notices of Enforcement Discretion, we have concluded that granting this NOED is consistent with the Enforcement Policy and staff guidance, and has no adverse impact on the public health and safety or the environment.
Therefore it is our intention to not enforce compliance with TS LCO 3.5.2.B for the period from 11:26 p.m. on October 22, 2008, until 11:26 a.m. on October 24, 2008. Additionally, the NRC Resident Inspectors assigned to the Beaver Valley Power Station independently verified that the compensatory actions described above were implemented.
Although we granted the NOED for a period of 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />, you subsequently concluded that the operability criteria would not be met within this 36 hour4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> period, and commenced a plant shutdown. Accordingly, you exited the NOED as of 6:00 a.m. on October 24, 2008, when you entered TS 3.5.2, Required Action B.
As in all cases of NOEDs, appropriate enforcement action, consistent with the NRCs Enforcement Policy, will be considered for the root cause leading to the need for this NOED. If you have any questions about this matter, please contact Dr. Ronald R. Bellamy, Projects Branch Chief for Beaver Valley, at 610-337-5200.
Sincerely,
/RA/
James W. Clifford, Deputy Director Division of Reactor Projects Region I
Enclosure:
Request for Regional Enforcement Discretion dated October 24, 2008 Docket No. 50-412 License No. NPF-73
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cc w/encl:
J. Hagan, President and Chief Nuclear Officer J. Lash, Senior Vice President of Operations and Chief Operating Officer D. Pace, Senior Vice President, Fleet Engineering J. Rinckel, Vice President, Fleet Oversight P. Harden, Vice President, Nuclear Support G. Halnon, Director, Fleet Regulatory Affairs Manager, Fleet Licensing Company K. Ostrowski, Director, Site Operations E. Hubley, Director, Maintenance M. Manoleras, Director, Engineering L. Freeland, Director, Site Performance Improvement C. Keller, Manager, Site Regulatory Compliance D. Jenkins, Attorney, FirstEnergy Corporation M. Clancy, Mayor, Shippingport, PA D. Allard, Director, PADEP C. OClaire, State Liaison to the NRC, State of Ohio Z. Clayton, EPA-DERR, State of Ohio Director, Utilities Department, Public Utilities Commission, State of Ohio D. Hill, Chief, Radiological Health Program, State of West Virginia J. Lewis, Commissioner, Division of Labor, State of West Virginia W. Hill, Beaver County Emergency Management Agency J. Johnsrud, National Energy Committee, Sierra Club J. Powers, Director, PA Office of Homeland Security R. French, Director, PA Emergency Management Agency
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2005, have been met. As per section B.2.1, Criterion 1.a, your staff stated that this NOED is intended to avoid an unnecessary transient which would result from compliance with the TS CO, in order to minimize potential safety consequences and operational risks.. In addition, we agree with your staffs determination and justification that a license amendment is not warranted, based on staff evaluation of your conclusions that this is a one-time deferral of a non-recurring noncompliance involving a single request for extending the TS allowable outage time for a single inoperable component.
On the basis of the staffs evaluation of your request in accordance with NRC Inspector Manual Chapter Part 9900 Technical Guidance, Operations - Notices of Enforcement Discretion, we have concluded that granting this NOED is consistent with the Enforcement Policy and staff guidance, and has no adverse impact on the public health and safety or the environment. Therefore it is our intention to not enforce compliance with TS CO 3.5.2.B for the period from 11:26 p.m. on October 22, 2008, until 11:26 a.m. on October 24, 2008. Additionally, the NRC Resident Inspectors assigned to the Beaver Valley Power Station independently verified that the compensatory actions described above were implemented.
Although we granted the NOED for a period of 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />, you subsequently concluded that the operability criteria would not be met within this 36 hour4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> period, and commenced a plant shutdown. Accordingly, you exited the NOED as of 6:00 a.m. on October 24, 2008, when you entered TS 3.5.2, Required Action B.
As in all cases of NOEDs, appropriate enforcement action, consistent with the NRCs Enforcement Policy, will be considered for the root cause leading to the need for this NOED. If you have any questions about this matter, please contact Dr. Ronald R. Bellamy, Projects Branch Chief for Beaver Valley, at 610-337-5200.
Sincerely, James W. Clifford, Deputy Director /RA/
Division of Reactor Projects Region I Distribution w/encl:
S. Collins, RA M. Dapas, DRA D. Lew, DRP J. Clifford, DRP M. Scott, DRP M. Gamberoni, DRS D. Roberts, DRS M. McLaughlin, ORA R. Bellamy, DRP S. Barber, DRP C. Newport, DRP W. Cook, DRS K. Mangan, DRS A. Ziedonis, DRS C. Carpenter, OE J. Giitter, NRR S. Williams, RI OEDO R. Nelson, NRR M. Kowal, NRR N. Morgan, PM, NRR R. Guzman, NRR J. Circle, NRR W. Lyon, NRR R. Wolfgang, NRR J. Bream, NRR S. Stuchell, NRR D. Werkheiser, Senior Resident Inspector D. Spindler, Resident Inspector P. Garrett - Resident OA Region I Docket Room (with concurrences)
SUNSI REVIEW COMPLETE: _RRB________ (Reviewers Initials)
DOCUMENT NAME: G:\\DRP\\BRANCH 6\\BV_U2_NOED_08-1-01_DRAFT.DOC ML083020687 After declaring this document AAn Official Agency Record@ it will be released to the Public.
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