ML092050497
| ML092050497 | |
| Person / Time | |
|---|---|
| Site: | Hatch  |
| Issue date: | 07/24/2009 |
| From: | Reyes L Region 2 Administrator |
| To: | Madison D Southern Nuclear Operating Co |
| References | |
| EA-09-054, IR-09-008 | |
| Download: ML092050497 (5) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION REGION II SAM NUNN ATLANTA FEDERAL CENTER 61 FORSYTH STREET, SW, SUITE 23T85 ATLANTA, GEORGIA 30303-8931 July 24, 2009 EA-09-054 Mr. Dennis R. Madison Vice President Southern Nuclear Operating Company, Inc.
Edwin I. Hatch Nuclear Plant 11028 Hatch Parkway North Baxley, GA 31513
SUBJECT:
REPLY TO SOUTHERN NUCLEAR OPERATING COMPANY LETTER DATED JULY 2, 2009 REGARDING INSPECTION REPORT NO. 05000321/2009008 AND 05000366/2009008
Dear Mr. Madison:
Thank you for your letter dated July 2, 2009, in response to our Notice of Violation (EA-09-054) dated June 9, 2009. The Notice described a violation that was identified during an inspection conducted by the Nuclear Regulatory Commission (NRC) involving a failure to identify and correct cracks in the 1B emergency diesel generator (EDG) coupling.
We have reviewed your response and find that it meets the requirements of 10 CFR 2.201. We will review the adequacy of your corrective actions during a supplemental inspection utilizing Inspection Procedure 95001, once you have indicated you are ready for this inspection.
Your response requested that the NRC reconsider characterization of the cross-cutting aspect associated with this finding. We reviewed our assessment and concluded that the cross-cutting aspect as documented in Inspection Report 2009008 is appropriate to the circumstances. The cross-cutting aspect as defined in Inspection Manual Chapter 0305 P.1.(a) states in part that the licensee identifies issues impacting nuclear safety completely, accurately and in a timely manner commensurate with their safety significance. Although coupling cracks were identified in the EDG couplings in 1988 and 2004, a condition report (CR) was not created to document these cracks and enter them into your corrective action program. This was acknowledged in your root cause report as Root Cause D, "Condition Reports were not written by personnel who noted coupling cracking in the procedure data packages." The root cause report further states that this does not comply with procedure NMP-GM-002, Step 5.14, which states that all plant personnel should initiate a CR at any time or in any situation to identify an event, condition, problem or process that needs improvement. Additionally, your root cause report acknowledges that a visual inspection of the couplings was performed for each EDG every two years for the last twenty years. According to statements from maintenance personnel with knowledge of EDG preventative maintenance procedures, the coupling cracks have existed for several years on all of the EDG couplings. Several opportunities existed to identify and take action to correct the EDG coupling cracks during these biennial inspections with the most recent opportunity in
SNC 2
June 2008, approximately 3 weeks prior to the coupling degradation incident on July 12, 2008.
Since the EDG coupling cracks were not identified and entered into the Corrective Action Program and several opportunities existed for the coupling cracks to be identified, the NRC maintains the cross-cutting aspect described above is appropriate for this issue and was indicative of current licensee performance.
Although you did not appeal the finding, your letter indicated that Southern Nuclear Operating Company (SNC) planned to use the 1B EDG coupling issue as an example to work with the NRC and the Nuclear Energy Institute (NEI) to improve the common cause factor in significance determination process assessments. We have forwarded your letter, with Enclosure 2 which addresses common cause application, to staff in our Office of Nuclear Reactor Regulation and Office of Nuclear Regulatory Research responsible for our Risk Assessment Standardization Process (RASP) Handbook. The RASP Handbook provides guidance for risk assessments performed for Reactor Oversight Process significance determinations.
In the April 6, 2009, response to the NEI letter dated November 4, 2008, which provided industry comments on the RASP Handbook, NRC agreed that testing and inspections of redundant components within a common cause component group are sound engineering practices to demonstrate that multiple trains are not failed. However, these activities only prove that the component was not in a failed state. Redundant components may show greater likelihood of common cause failure due to observed degradation from the same root cause. The NRC is planning to include additional guidance on treatment of common cause failure in the next revision of the RASP Handbook. We look forward to continuing to work with the industry to address procedures and methodologies used for treating common cause failures. Although these future actions are planned, our conclusions concerning the common cause application for this specific case remain consistent with our Final Significance Determination Letter issued June 9, 2009.
In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, 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.
Sincerely,
/RA/
Luis A. Reyes Regional Administrator cc: (See page 3)
Docket Nos.: 50-321, 50-366 License Nos.: DRP-57, NPF-5
X SUNSI REVIEW COMPLETE SMS OFFICE RII:DRP RII:DRP RII:DRS RII:DRS RII:EICS RII:ORA SIGNATURE SMS /RA/
LDW /RA/
RLN /RA/
RLN /RA for/
VMM /RA/
NAME SShaeffer LWert RNease GMcDonald CEvans VMcCree DATE 07/23/2009 07/23/2009 07/22/2009 07/22/2009 07/24/2009 E-MAIL COPY?
YES NO YES NO YES NO YES NO YES NO YES NO YES NO
SNC 3
Angela Thornhill Managing Attorney and Compliance Officer Southern Nuclear Operating Company, Inc.
Electronic Mail Distribution Jeffrey T. Gasser Executive Vice President Southern Nuclear Operating Company, Inc.
Electronic Mail Distribution Raymond D. Baker Licensing Manager Licensing - Hatch Southern Nuclear Operating Company, Inc.
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 Steven B. Tipps Hatch Principal Engineer - Licensing Edwin I. Hatch Nuclear Plant Electronic Mail Distribution Mr. Ken Rosanski Resident Manager Edwin I. Hatch Oglethorpe Power Corporation Electronic Mail Distribution Lee Foley Manager of Contracts Generation Oglethorpe Power Corporation Electronic Mail Distribution Arthur H. Domby, Esq.
Troutman Sanders Electronic Mail Distribution Dr. Carol Couch Director Environmental Protection Department of Natural Resources Electronic Mail Distribution Cynthia Sanders Program Manager Radioactive Materials Program Department of Natural Resources Electronic Mail Distribution Jim Sommerville (Acting) Chief Environmental Protection Division Department of Natural Resources Electronic Mail Distribution Mr. Steven M. Jackson Senior Engineer - Power Supply Municipal Electric Authority of Georgia Electronic Mail Distribution Mr. Reece McAlister Executive Secretary Georgia Public Service Commission Electronic Mail Distribution Chairman Appling County Commissioners County Courthouse 69 Tippins Street, Suite 201 Baxley, GA 31513
4 Letter to Dennis R. Madison from Luis A. Reyes dated July 24, 2009
SUBJECT:
REPLY TO SOUTHERN NUCLEAR OPERATING COMPANY LETTER DATED JULY 2, 2009 REGARDING INSPECTION REPORT NO. 05000321/2009008 AND 05000366/2009008 Distribution w/encls:
RidsNrrPMHatch Resource R. Borchardt, OEDO C. Carpenter, OE E. Julian, SECY B. Keeling, OCA C. Marco, OGC J. Moore, OGC D. Decker, OCA Enforcement Coordinators RI, RIII, RIV E. Hayden, OPA G. Caputo, OI H. Bell, OIG M. Ashley, NRR M. Franovich, NRR E. Leeds, NRR B. Martin, NRR L. Reyes, RII V. McCree, RII K. Kennedy, RII L. Wert, RII S. Shaeffer, RII C. Rapp, RII S. Sparks, RII G. MacDonald, RII J. Hickey, RII C. Evans, RII L. Slack, RII OEMAIL RIDSNRRDIRS PUBLIC