ML110260461
| ML110260461 | |
| Person / Time | |
|---|---|
| Site: | McGuire, Mcguire  |
| Issue date: | 01/26/2011 |
| From: | Croteau R NRC/RGN-II/DCP |
| To: | Repko R Duke Energy Carolinas |
| References | |
| NOED 11-2-001 | |
| Download: ML110260461 (6) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION REGION II 245 PEACHTREE CENTER AVENUE NE, SUITE 1200 ATLANTA, GEORGIA 30303-1257 January 26, 2011 Mr. Regis T. Repko Vice President Duke Energy Carolinas, LLC McGuire Nuclear Station 12700 Hagers Ferry Road Huntersville, NC 28078-8985
SUBJECT:
NOTICE OF ENFORCEMENT DISCRETION (NOED) FOR MCGUIRE NUCLEAR STATION [NOED NO. 11-2-001]
Dear Mr. Repko:
By letter dated January 24, 2011, you requested that the NRC exercise discretion to not enforce compliance with the actions required in McGuire Nuclear Station (MNS), Units 1 and 2, Technical Specification (TS) Limiting Condition for Operation (LCO) 3.0.3. Your letter documented information previously discussed with the NRC in a telephone conference on January 20 at 10:00 p.m. (all times refer to Eastern Time). The principal NRC staff members who participated in the telephone conference are listed in the Enclosure. The staff determined that the information in your letter requesting the NOED was consistent with your oral request.
You stated that, on January 20 at 11:10 a.m., both units entered into TS LCO 3.0.3 for two trains of nuclear service water (RN) inoperable. TS LCO 3.0.3 required both MNS units be placed in Mode 3 by 6:10 p.m., on January 20, Mode 4 by 12:10 a.m., on January 21, and Mode 5 by 12:10 a.m., on January 22. You subsequently shut down both units to Mode 3 and requested that a NOED be granted pursuant to the NRCs policy regarding exercise of discretion for an operating facility, set out in Section 3.8 of the General Statement of Policy and Procedures for NRC Enforcement Actions (Enforcement Policy), NUREG-1600, and that the NOED be effective until January 25 at 12:00 p.m. This letter documents our telephone conversation on January 20 at 11:36 p.m., when we orally granted this NOED request. We understand that the condition causing the need for this NOED was corrected, allowing MNS to exit from TS LCO 3.0.3 and from this NOED on January 23 at 1:20 p.m.
On January 18, the 1B RN pump was started to perform a pump performance test.
Approximately fifteen minutes into the test, the 1B RN pump was stopped due to low pump suction pressure associated with high strainer differential pressure. Following additional evaluation, you determined that the high strainer differential pressure was due to strainer fouling as the result of a large number of small fish from the standby nuclear service water pond (SNSWP). Due to this condition, both RN trains for both units were subsequently declared inoperable and entered TS LCO 3.0.3 at 11:10 a.m. The action for TS LCO 3.0.3 required shutdown of both MNS units to Mode 3 within seven hours, Mode 4 within thirteen hours, and Mode 5 within thirty-seven hours. MNS Unit 1 entered Mode 3 at 3:18 p.m., and MNS Unit 2 entered Mode 3 at 6:01 p.m.
The NRC determined that the requested NOED was necessary to avoid an unnecessary transient 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
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for this discretion considered: (1) Both trains of RN for both units were functional and aligned to Lake Norman as a suction source; (2) your commitments to post two non-licensed Operators to manually backwash the 1B and 2B RN strainers upon direction from the Control room after automatic realignment to the SNSWP, protect the auxiliary feed water turbine driven pump (CATDP) and other important backup equipment, chemically treat the SNSWP to eliminate the fish as a fouling source, perform various inspections and restore both trains of RN to operable status following satisfactory testing using the SNSWP as a suction source, and to defer non-essential maintenance activities for the duration of the enforcement discretion period; (3) your qualitative risk assessment; (4) the cause of the condition and proposed path to resolve the situation were understood such that there was a high likelihood that planned actions could be completed within the requested NOED time allowance; (5) that the noncompliance would not be of potential detriment to the public health and safety; and (6) your protective strategy.
The NRC staff performed an independent qualitative assessment of the risk and a review of your protection strategy. Since standby conditions (e.g., extended operation while in Mode 3 versus shutting down to Mode 5) were not adequately represented in any PRA model, a credible quantifiable risk assessment was not possible. Both your staffs and the NRC risk analysis demonstrated that: (1) risk significant equipment (e.g., CATDP) would be available in Mode 3 to provide defense in depth to mitigate event sequences that would not have been available in Mode 5; (2) the relative likelihood of certain initiating events was lower while in Mode 3; and (3) your eliminating elective maintenance on risk significant systems and protection measures during the duration of the enforcement discretion balanced any risk increase associated with granting the NOED. Consequently, these actions provided reasonable assurance that the 5.0E-7 core damage frequency and 5.0E-8 large early release frequency guidance thresholds in Inspection Manual Part 9900 Technical Guidance were not exceeded.
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 or the environment. Therefore, as we informed you at 11:36 p.m.,
on January 20, 2011, we exercised discretion to not enforce compliance with the TS LCO 3.0.3 requirements that both units be in Mode 4 by 12:10 a.m., on January 21, and Mode 5 by 12:10 a.m., on January 22, for the period from 11:36 p.m., on January 20, until 12:00 p.m., on January 25, 2011. As stated during the conference call and in your letter you have determined that a follow up license amendment is not necessary. NRC staff agrees with this determination.
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/
Richard P. Croteau, Director Division of Reactor Projects Docket Nos.: 50-369, 50-370 License Nos.: NPF-9, NPF-17 cc w/encl: (See page 3)
G SUNSI REVIEW COMPLETE OFFICE RII:DRP RII:DRP RII:DRP RII:DRS NRR:DORL SIGNATURE Via email WBJ /RA/
RPC /RA/
Via telecon Via email NAME JBartley WJones RCroteau JHanna AHowe DATE 01/26/2011 01/26/2011 01/26/2011 01/26/2011 01/26/2011 E-MAIL COPY?
YES NO YES NO YES NO YES NO YES NO YES NO
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cc w/encl:
Steven D. Capps Station Manager Duke Energy Carolinas, LLC Electronic Mail Distribution Peter Schuerger Training Manager Duke Energy Carolinas, LLC Electronic Mail Distribution C. Jeff Thomas Fleet Regulatory Compliance & Licensing Manager Duke Energy Carolinas, LLC Electronic Mail Distribution Kenneth L. Ashe Regulatory Compliance Manager Duke Energy Carolinas, LLC Electronic Mail Distribution Lara Nichols Associate General Counsel Duke Energy Corporation Electronic Mail Distribution Kathryn B. Nolan Senior Counsel Duke Energy Corporation 526 South Church Street-EC07H Charlotte, NC 28202 David A. Repka Winston Strawn LLP Electronic Mail Distribution County Manager of Mecklenburg County 720 East Fourth Street Charlotte, NC 28202 W. Lee Cox, III Section Chief Radiation Protection Section N.C. Department of Environmental Commerce & Natural Resources Electronic Mail Distribution David A. Baxter Vice President, Nuclear Engineering Duke Energy Carolinas, LLC Electronic Mail Distribution Dhiaa M. Jamil Group Executive and Chief Nuclear Officer Duke Energy Carolinas, LLC Electronic Mail Distribution
DEC 4
Letter to Regis T. Repko from Richard P. Croteau dated January 26, 2011
SUBJECT:
NOTICE OF ENFORCEMENT DISCRETION (NOED) FOR MCGUIRE NUCLEAR STATION [NOED NO. 11-2-001]
Distribution w/encl:
C. Evans, RII L. Douglas, RII OE Mail RIDSNRRDIRS PUBLIC RidsNrrPMMcGuire Resource
Enclosure List of Participants NRC Region II Victor McCree, Regional Administrator, Region II (RII)
Len Wert, Deputy Regional Administrator for Operations, RII Rick Croteau, Director, Division of Reactor Projects (DRP), RII William Jones, Deputy Director, DRP, RII Jonathan Bartley, Chief, Reactor Projects Branch 1 (RPB1), DRP, RII John Hanna, Senior Reactor Analyst, Engineering Branch 2 (EB2), Division of Reactor Safety (DRS), RII Rudy Bernhard, Senior Reactor Analyst, EB2, DRS, RII Joe Brady, McGuire Senior Resident Inspector, RPB1, DRP, RII Jermaine Heath, McGuire Resident Inspector, RPB1, DRP, RII Eric Stamm, Project Engineer, RPB1, DRP, RII NRC Headquarters Allen Howe, Deputy Director, Division of Operator Reactor Licensing (DORL), Office of Nuclear Reactor Regulation (NRR)
Gloria Kulesa, Chief, Plant Licensing Branch 2-1 (LPL2-1), DORL, NRR Jon Thompson, McGuire Project Manager, LPL2-1, DORL, NRR Melissa Ash, Acting Licensing Processes Branch Chief, Division of Policy and Rulemaking, Office of Nuclear Reactor Regulation Sheldon Stuchell, Senior Project Manager, Licensing Processes Branch, Division of Policy and Rulemaking, NRR Jeff Mitman, Senior Reliability and Risk Analyst, PRA Operational Support Branch, Division of Risk Assessment, NRR Gerard Purciarello, Senior Reactor Systems Engineer, Balance of Plant Branch, Division of Safety Systems, NRR Matthew Hamm, Reactor Systems Engineer, Technical Specifications Branch, Division of Inspection and Regional Support, NRR