ML102310595

Notice of Enforcement Discretion, NOED 10-2-004

ML102310595
Person / Time
Site:	Farley
Issue date:	08/19/2010
From:	Reyes L Region 2 Administrator
To:	Jerrica Johnson Southern Nuclear Operating Co
References
NOED-10-2-004
Download: ML102310595 (8)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION REGION II 245 PEACHTREE CENTER AVENUE NE, SUITE 1200 ATLANTA, GEORGIA 30303-1257 August 19, 2010 Mr. J. Randy Johnson Vice President - Farley Southern Nuclear Operating Company, Inc.

7388 North State Highway 95 Columbia, AL 36319

SUBJECT:

NOTICE OF ENFORCEMENT DISCRETION FOR SOUTHERN NUCLEAR OPERATING COMPANY REGARDING JOSEPH M. FARLEY NUCLEAR PLANT UNIT 1 [NOED NO. 10-2-004]

Dear Mr. Johnson:

By letter dated August 17, 2010, you requested that the NRC exercise discretion to not enforce compliance with the following: (1) Technical Specification (TS) 3.6.5, Required Action A.1.

Your letter documented information previously discussed with the NRC in a telephone conference on August 15, 2010, at 12:18 a.m. EDT. The principal NRC staff members who participated in that telephone conference are listed in the Enclosure. You stated that on August 14, 2010, at 2:00 p.m. CDT, Unit 1 entered TS 3.6.5 Required Action A.1 for containment temperature exceeding 120 and if not restored, you would be required to place the unit in Mode 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, and in Mode 5 within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. You requested that a Notice of Enforcement Discretion (NOED) be granted pursuant to the NRC's policy regarding exercise of discretion for an operating facility, set out in Section VII.C, of the "General Statement of Policy and Procedures for NRC Enforcement Actions" (Enforcement Policy), NUREG-1600, and be effective for the period from August 15, 2010, at 4:00 a.m. CDT, to August 15, 2010, at 10:00 p.m. CDT. This letter documents our August 15, 2010, telephone conversation during which we orally issued this NOED. We understand that the condition causing the need for this NOED was corrected by you, allowing you to exit from the TS and from this NOED on August 15, 2010, at 8:23 a.m. CDT.

On August 14, 2010, Unit 1 containment air temperature increased above the TS limit of 120, due to a TS required isolation of a penetration flow path. During a surveillance, service water from reactor coolant pump motor air cooler valve (Q1P16MOV3134) unexpectedly failed to indicate full closed; however, local observation of the valve indicated that the valve was closed.

Based on the questionable position indication, you entered TS 3.6.3, Containment Isolation Valves, which required isolation of the affected penetration flow path, resulting in reduced cooling of all three reactor coolant pumps motor exhaust. The penetration was isolated using an operable inboard containment isolation valve (MOV3131). This resulted in an increase in containment temperature. TS limiting condition for operation (LCO) 3.6.5 states that Containment average air temperature shall be < 120. Required Action A.1 of this specification requires restoration of the average air temperature to within the required limit

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within eight hours. Required Action B states that if the Required Action and associated Completion Time are not met, be in Mode 3 in 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in Mode 5 in 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. TS LCO 3.6.5 was entered at 2:00 p.m. CDT on August 15, 2010. The containment temperature was expected to remain above the TS limit beyond the allowable completion time. In your request for the NOED, you stated that prompt action was needed to avoid undesirable transients potentially associated with unit shutdown due to TS compliance for an issue with negligible impact on risk. You also stated that although 120 was the TS limit, the Final Safety Analysis Report (FSAR) Table 6.2-3, used 127 in the containment pressure analysis for the initial containment temperature prior to a design bases accident.

Your NOED request stated that efforts were made in an attempt to prove operability of the service water from reactor coolant pump motor air coolers valve, which would allow restoration of cooling for the reactor coolant pump motor air coolers. The following additional actions were taken in an attempt to avoid the need for the NOED: 1) Running the containment mini-purge continuously, 2) aligning emergency service water to the containment coolers and 3) running the containment dome fans in high speed. The planned actions to resolve the situation were to prove operability of the reactor coolant pump air cooler valve, which would allow restoration of cooling for the reactor coolant pump motor air coolers. The restoration of this cooling would reduce the containment temperature to within TS limits.

The NRC determined that the requested NOED was necessary to avoid unnecessary transients as a result of compliance with the license condition and, thus, minimize potential safety consequences and operational risks (Part 9900, Section B.2.1, criterion 1.a). The NRCs basis for this discretion considered: 1) Southern Nuclear Operating Company (SNC) assertion that work controls were in place to not take fan coolers or supporting systems out of service; 2) there was no switchyard or grid activity being conducted or scheduled that would threaten grid stability or off-site power source operability during the enforcement discretion; 3) the 2C diesel generator would be returned to service and maintained operable, the 1B closed cooling water heat exchanger would remain out of service for eddy current testing, and there were no other TS LCOs; 4) both off-site power sources and the on-site emergency diesel generators would be maintained operable; 5) SNCs calculated Incremental Conditional Core Damage Probability and Incremental Conditional Large Early Release Probability values did not exceed the threshold guidance provided in Inspection Manual Part 9900 Technical Guidance and were consistent with values calculated by NRC regional analysts; 6) that the cause and proposed path to resolve the situation were understood such that there was a high likelihood that planned actions to resolve the situation could be completed within the proposed NOED time frame; 7) that the noncompliance would not be of potential detriment to the public health and safety; and

8) SNCs commitment that the unit would be shutdown if containment air temperature exceeded 122 or the local leak rate test (LLRT) on MOV3134 fails the surveillance requirements.

On the basis of the staff's 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 or the environment. Therefore, it is our intention to exercise discretion to not enforce compliance with the TS listed above for the period from August 15, 2010, at 4:00 a.m. CDT, to August 15, 2010, at 10:00 p.m. CDT, 18 hours2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br />. You have determined that a follow up license amendment is not necessary.

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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 non-compliance for which this NOED was necessary.

Sincerely,

/RA/

Luis A. Reyes Regional Administrator Docket No.: 50-348 License No.: NPF-2

Enclosure:

As stated cc w/encl: (See page 4)

G SUNSI REVIEW COMPLETE OFFICE RII:DRP RII:DRP RII:RDS RII:DRS RII:ORA RII:ORA SIGNATURE SMS /RA/

LDW /RA/

Via telecon KMK /RA/

LAR /RA for/

LAR /RA/

NAME SShaeffer LWert WRogers KKennedy VMcCree LReyes DATE 08/19/2010 08/19/2010 08/19/2010 08/19/2010 08/19/2010 08/19/2010 E-MAIL COPY?

YES NO YES NO YES NO YES NO YES NO YES NO YES NO

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cc w/encl:

B. D. McKinney, Jr.

Regulatory Response Manager Southern Nuclear Operating Company, Inc.

Electronic Mail Distribution M. J. Ajluni Nuclear Licensing Director Southern Nuclear Operating Company, Inc.

Electronic Mail Distribution T. D. Honeycutt Regulatory Response Supervisor Southern Nuclear Operating Company, Inc.

Electronic Mail Distribution Todd L. Youngblood Plant Manager Joseph M. Farley Nuclear Plant Electronic Mail Distribution R. D. Baker Licensing Supervisor Southern Nuclear Operating Company, Inc.

Electronic Mail Distribution E. G. Anners Licensing Engineer Southern Nuclear Operating Company, Inc.

Electronic Mail Distribution Jeffrey T. Gasser Chief Nuclear Officer Southern Nuclear Operating Company, Inc.

Electronic Mail Distribution N. J. Stringfellow Licensing Manager Southern Nuclear Operating Company, Inc.

Electronic Mail Distribution L. Mike Stinson Vice President Fleet Operations Support Southern Nuclear Operating Company, Inc.

Electronic Mail Distribution Paula Marino 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 Chris Clark Commissioner Georgia Department of Natural Resources Electronic Mail Distribution John G. Horn Site Support Manager Joseph M. Farley Nuclear Plant Southern Nuclear Operating Company, Inc.

Electronic Mail Distribution Ted V. Jackson Emergency Response and Radiation Program Manager Environmental Protection Division Georgia Department of Natural Resources Electronic Mail Distribution Tom W. Pelham Performance Improvement Supervisor Joseph M. Farley Nuclear Plant Southern Nuclear Operating Company, Inc.

Electronic Mail Distribution Cynthia A. Sanders Radioactive Materials Program Manager Environmental Protection Division Georgia Department of Natural Resources Electronic Mail Distribution James C. Hardeman Environmental Radiation Program Manager Environmental Protection Division Georgia Department of Natural Resources Electronic Mail Distribution (cc w/encl continued next page)

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(cc w/enlc continued)

William D. Oldfield Principal Licensing Engineer Joseph M. Farley Nuclear Plant Electronic Mail Distribution Mr. Mark Culver Chairman Houston County Commission P. O. Box 6406 Dothan, AL 36302 James A. Sommerville Program Coordination Branch Chief Environmental Protection Division Georgia Department of Natural Resources Electronic Mail Distribution James L. McNees, CHP Director Office of Radiation Control Alabama Dept. of Public Health P. O. Box 303017 Montgomery, AL 36130-3017 State Health Officer Alabama Dept. of Public Health Electronic Mail Distribution F. Allen Barnes Director Environmental Protection Division Georgia Department of Natural Resources Electronic Mail Distribution

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Letter to J. R. Johnson from Luis A. Reyes dated August 19, 2010

SUBJECT:

NOTICE OF ENFORCEMENT DISCRETION FOR SOUTHERN NUCLEAR OPERATING COMPANY REGARDING JOSEPH M. FARLEY NUCLEAR PLANT UNIT 1 [NOED NO. 10-2-004]

Distribution w/encl:

C. Evans, RII OE Mail RIDSNRRDIRS PUBLIC A. Adams, NRR RidsNrrPMFarley Resource

Enclosure List of Participants NRC Region II Victor McCree, Deputy Regional Administrator for Operations, Region II (RII)

Kriss Kennedy, Director, Division of Reactor Safety (DRS), RII Leonard Wert, Director, Division of Reactor Projects (DRP), RII Scott Shaeffer, Chief, Reactor Projects Branch 2, DRP, RII Walt Rogers, Senior Risk Analyst, DRS, RII NRC Headquarters Jeff Circle, Senior Reliability and Risk Analyst, PRA Operational Support Branch, Division of Risk Assessment, Office of Nuclear Reactor Regulation (NRR)

Robert Dennig, Chief, Containment and Ventilation Branch, Division of Safety Systems, NRR Allen Howe, Deputy Director, Division of Operating Reactor Licensing (DORL), NRR Gloria Kulesa, Chief, Plant Licensing Branch II-1, DORL, NRR Robert Martin, Senior Project Manager, Plant Licensing Branch II-1, DORL, NRR Sheldon Stuchell, Senior Project Manager, Licensing Process Branch, Division of Policy and Rulemaking, NRR