ML093160200
| ML093160200 | |
| Person / Time | |
|---|---|
| Site: | Ginna  |
| Issue date: | 11/12/2009 |
| From: | Collins S Region 1 Administrator |
| To: | John Carlin Ginna |
| collins s j | |
| References | |
| EA-09-249, IR-09-008 EA-09-249-1 | |
| Download: ML093160200 (5) | |
See also: IR 05000244/2009008
Text
UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION!
475 ALLENDALE ROAD
KING OF PRUSSIA, PENNSYLVANIA 19406*1415
November 12, 2009
Mr. John Carlin, Vice President
R. E. Ginna Nuclear Power Plant. LLC
1503 Lake Road
Ontario, NY 14519
SUBJECT: FINAL SIGNIFICANCE DETERMINATION OF WHITE FINDING, WITH
ASSESSMENT FOLLOW-UP, AND NOTICE OF VIOLATION - RE. GINNA
NUCLEAR POWER PLANT (NRC Inspection Report No. 05000244/2009008)
Dear Mr. Carlin:
This letter provides you the final significance determination of the preliminary White finding sent
to you with the NRC letter dated November 12, 2009, as well as the result of our assessment of
the current performance of RE. Ginna Nuclear Power Plant (Ginna). This updated assessment
of Ginna supplements, but does not supersede, our mid-cycle assessment letter issued on
September 1, 2009 [ML092440230]. The finding, desoribed in detail in the subject inspection
report, is associated with failure to preclude recurrence of a significant condition adverse to
quality (SCAQ) associated with the turbine-driven auxiliary feed water (TDAFW) pump governor
control valve, that led to a failure of the TDAFW pump to operate on July 2, 2009. The finding
was identified during an inspeotion, for which a preliminary exit was held on August 27,2009.
The final exit meeting was conducted on October 7, 2009.
In a telephone conversation with Mr. Glenn Dentel of NRC, Region I, on October 2,2009, you
indicated that RE. Ginna Nuclear Power Plant, LLC did not contest the characterization of the
risk significance of this finding and did not desire to discuss this issue in a Regulatory
Conference or to provide a written response. Please note that by declining to request a
Regulatory Conference or submit a written response, you relinquished your right to appeal the
final SDP determination, in that by not doing either, you would not meet the appeal
requirements stated in the Prerequisite and Limitation sections of Attachment 2 of IMC 0609.
After considering the information developed during the inspection, and having assessed the
finding using the reactor safety significance determination process, the NRC has concluded that
the finding is appropriately characterized as White, a finding of low to moderate safety
Significance. The NRC has also determined that the finding is a violation of 10 CFR 50,
Appendix 8, Criterion XVI, "Corrective Actions," which requires, in part, that "measures shall be
established to assure that conditions adverse to quality, such as failures, malfunctions,
deficiencies. deviations, defective material and eqUipment, and non-conformances are promptly
identified and corrected. In the case of significant conditions adverse to quality, the measures
shall assure that the cause of the condition is determined and corrective action taken to
preclude repetition." The violation is cited in the attached Notice of Violation (Notice). In
J. Carlin 2
You are required to respond to this letter and should follow the instructions specified in the
enclosed Notice when preparing your response.
In addition to this White Finding, Ginna's Mitigating System Performance Index for the heat
removal system (auxiliary feedwater system) crossed the Green to White performance indicator
threshold based upon the 3rd quarter 2009 data submittal. In accordance with Inspection
Manual Chapter 0305, the PI and the finding will not be "double-counted" in the NRC's Action
Matrix. The White performance indicator was a direct result from the unavailability and reliability
associated with this inspection finding.
As a result of our review of Ginna performance, including this White finding, and in
consideration of the White Performance Indicator, and the previous White finding issued to you
on June 8, 2009 [ML091550004]. we have assessed Ginna to be in the Degraded Cornerstone
column of the NRC's Action Matrix. Therefore, we plan to conduct a supplemental inspection
using Inspection Procedure 95002, "Inspection for One Degraded Cornerstone or Any Three
White Inputs in a Strategic Performance Area," when your staff has notified us of your readiness
for this inspection. Although our June 8, 2009 letter indicated we were planning to perform
Inspection Procedure 95001 for the previous White finding, the NRC has determined that it will
encompass the 95001 inspection activities as part of the 95002 inspection. The 95002
inspection procedure is conducted to: (1) provide assurance that the root and contributing
causes of individual and collective (multiple white inputs) risk-significant performance issues are
understood; (2) independently assess the extent of condition and the extent of cause of
individual and collective (multiple white inputs) risk-significant performance issues; (3)
independently determine if safety culture components caused or significantly contributed to the
individual and collective (multiple white inputs) risk-significant performance issues; and, (4)
provide assurance that the corrective actions for risk-significant performance issues are
sufficient to address the root and contributing causes and prevent recurrence.
In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its
enclosure, and your response, 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,
~
Regional Administrator
Docket No. '50-244
License No. DPR-18
Enclosure: Notice of Violation
cc w/enc!: Distribution via ListServ
I
J. Carlin 2
You are required to respond to this letter and should follow.the instructions specified in the
enclosed Notice when preparing your response.
In addition to this White Finding, Ginna's Mitigating System Performance Index for the heat
removal system (auxiliary feedwater system) crossed the Green to White performance indicator
threshold based upon the 3n:! quarter 2009 data submittal. In accordance with Inspection
Manual Chapter 0305, the PI and the finding will not be "double-counted" in the NRC's Action
Matrix. The White performance indicator was a direct result from the unavailability and reliability
associated with this inspection finding.
As a result of our review of Ginna performance, including this White finding, and in
conSideration of the White Performance Indicator, and the previous White finding issued to you
on June 8, 2009 [ML091550004], we have assessed Ginna to be in the Degraded Cornerstone
column of the NRC's Action Matrix. Therefore, we plan to conduct a supplemental inspection
using Inspection Procedure 95002. "Inspection for One Degraded Cornerstone or Any Three
White Inputs in a Strategic Performance Area," when your staff has notified us of your readiness
for this inspection. Although our June 8, 2009 letter indicated we were planning to perform
Inspection Procedure 95001 for the previous White finding, the NRC has determined that it will
encompass the 95001 inspection activities as part of the 95002 inspection. The 95002
inspection procedure is conducted to: (1) provide assurance that the root and contributing
causes of individual and collective (multiple white inputs) risk-significant performance issues are
understood; (2) independently assess the extent of condition and the extent of cause of
individual and collective (multiple white inputs) risk-significant performance issues; (3)
independently determine if safety culture components caused or significantly contributed to the
individual and col/ective (multiple white inputs) risk-significant performance issues; and, (4)
provide assurance that the corrective actions for risk-significant performance issues are
sufficient to address the root and contributing causes and prevent recurrence.
In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its
enclosure, and your response, 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.
IRA!
Samuel J. Collins
Regional Administrator
Docket No. 50-244
License No. DPR-18
Enclosure: Notice of Violation
cc w/encl: Distribution via ListServ
SUNSI ReView Complete: gtd (Reviewer'S Initials)
DOCUMENT NAME: S;\Enf-allg\Enforcemenl\Proposed-Actlons\Region1\Glnna White NOV October 2009.doc
After declaring this document "An Official Agency Record* it will be released to the Publfc. ADAMS Accession No.:
"C* ;:: COpy without attachmenVenclosure WE" = Copy with attachment/enclosure "N" No~ = ML093160200
OFFICE RIIORA J RIIDRP I RIIDRS I P I RIfDRS I
NAME ADeFrancisco/aed" GDentel CCahlll JCllfford DRoberts
DATE 10/20/09 10/27 109 10/21 109 10/30 109 10/29/09
OFFICE RIIORA I RIIORA I HQlOE* I RIlRA 1 I
NAME KFarrarlMB for KF DHolody 'GBOVIIRlan SCollinslsjc
DATE 10/28 109 10/28/09 11105109 11/08/09
OFFICIAL RECORD COpy
OE provides quick review (not a fonnal concurrence). This was provided verbally to A. DeFrancisco on 11105.
"'see previous concurrence page
NOTICE OF VIOLATION
R.E. Ginna Nuclear Power Plant, LLC Docket No. 50-244
R.E. Ginna Nuclear Power Plant License No. DPR-18
During an NRC inspection, for which a final exit meeting was conducted on October 7, 2009, a
violation of NRC requirements was identified. In accordance with the NRC Enforcement Policy,
the violation is listed below:
10 CFR 50, Appendix B, Criterion XVI, "Corrective Actions,'" states, in part, "Measures
shall be established to assure that conditions adverse to quality, such as failures,
malfunctions, deficiencies, deviations, defective material and equipment, and
nonconformances are promptly identified and corrected. In the case of significant
conditions adverse to quality, the measures shall assure that the cause of the condition
is determined and corrective action taken to preclude repetition."
Contrary to the above, after identifying corrosion on the turbine-driven auxiliary feed
water (TDAFW) pump governor control valve stem on April 11, 2005, a significant
condition adverse to quality, R.E. Ginna Nuclear Power Plant, LLC did not take adequate
measures to determine the cause and prevent recurrence. The cause of the condition
was left uncorrected and resulted in additional stem corrosion that led to binding of the
governor control valve and the failure of the TDAFW pump on July 2, 2009.
This violation is associated with a White SDP finding.
Pursuant to the provisions of 10 CFR 2.201, R.E. Ginna Nuclear Power Plant, LLC is hereby
required to submit a written statement or explanation to the U.S. Nuclear Regulatory
Commission, ATIN: Document Control Desk, Washington, DC 20555-0001 with a copy to the
Regional Administrator, Region I, and a copy to the NRC Resident Inspector at the facility that is
the subject of this Notice, within 30 days of the date of the letter transmitting this Notice of
Violation (Notice). This reply should be clearly marked as a "Reply to a Notice of Violation;
EA-09-249" and should include: (1) the reason for the violation, or, if contested, the basis for
disputing the 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 when full
compliance will be achieved. Your response may reference or include previous docketed
correspondence, if the correspondence adequately addresses the required response. If an
adequate reply is not received within the time specified in this Notice, an order or a Demand for
Information may be issued as to why the license should not be modified, suspended, or
revoked, or why such other action as may be proper should not be taken. Where good cause is
shown, consideration will be given to extending the response time.
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 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.qov/reading-rmfadams.html. to the extent possible, it should not
include any personal privacy. proprietary. or safeguards information so that it can be made
available to the public without redaction. If personal privacy or proprietary information is
Notice of Violation 2
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 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 12th day of November 2009