ML12228A623

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Notice of Enforcement Discretion (NOED) for Surry Power Station, Units 1 and 2, Technical Specification 3.16 Emergency Power System, Specific to Emergency Diesel Generator (EDG) 02-EE-EG-1 (NOED No. 12-2-003)
ML12228A623
Person / Time
Site: Surry  Dominion icon.png
Issue date: 08/15/2012
From: Croteau R
Division Reactor Projects II
To: Heacock D
Virginia Electric & Power Co (VEPCO)
References
Download: ML12228A623 (7)


Text

UNITED STATES NUCLEAR REGULATORY COMMISSION REGION II 245 PEACHTREE CENTER AVENUE NE, SUITE 1200 ATLANTA, GEORGIA 30303-1257 August 15, 2012 Mr. David A. Heacock President and Chief Nuclear Officer Virginia Electric and Power Company Innsbrook Technical Center 5000 Dominion Boulevard Glen Allen, VA 23060-6711

SUBJECT:

NOTICE OF ENFORCEMENT DISCRETION (NOED) FOR SURRY POWER STATION UNITS 1 AND 2, TECHNICAL SPECIFICATION 3.16 EMERGENCY POWER SYSTEM, SPECIFIC TO EMERGENCY DIESEL GENERATOR (EDG) 02-EE-EG-1 [NOED NO. 12-2-003]

Dear Mr. Heacock:

By letter dated August 13, 2012, you requested that the NRC exercise discretion to not enforce compliance with the actions required in Surry Power Station (SPS) Units 1 and 2, Technical Specification (TS) 3.16, Emergency Power System. Specifically, your request for enforcement discretion applies to TS 3.16.B.1.a.3 for EDG 02-EE-EG-1. Your letter documented information previously discussed with the NRC staff in a telephone conference on August 12, 2012, at 7:00 p.m. (all times refer to Eastern Daylight Time). The principal NRC and Dominion staff members who participated in the telephone conference are listed in the Enclosure. The NRC staff determined that the information in your letter requesting the NOED was consistent with your oral request.

You stated that the SPS number 2 EDG (02-EE-EG-1) was removed from service at 11:00 pm on August 6, 2012, to perform routine maintenance activities and testing. As part of the activities, 02-EE-EG-1 oil samples were collected and analyzed. The analysis identified the presence of silver particles in the EDG oil following a post-maintenance test run of the EDG, which indicated potential internal EDG component damage of the piston wrist pin bearing(s).

Consequently, the 02-EE-EG-1 wrist pin bearings were inspected, and it was determined that the piston number 5 wrist pin bearing exhibited evidence of damage. The identification of the wrist pin bearing damage occurred on day five of the seven-day allowed outage time (AOT) which would expire at 11:00 pm August 13, 2012. You requested an extension of the seven day AOT by an additional five days for a total of 12 days. The requested extension was necessary to perform the repairs required to restore 02-EE-EG-1 to operable status. You requested that a NOED be granted pursuant to the NRCs policy regarding the exercise of discretion for an operating facility, set out in Section 3.8 of the Enforcement Policy and that the NOED be effective until August 18, 2012, at 11:00 p.m. This letter documents our telephone conversation on August 12, 2012 at 7:00 p.m., when we orally granted this NOED request.

D. Heacock 2

The NRC staff 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 NRC staffs basis for this discretion considered your commitments including:

No planned unit transients will be allowed for the duration of the extended diesel AOT; The Operations department will monitor weather conditions to assess potential impacts on plant conditions due to adverse weather conditions; Valve 02-SW-MOV-201A will be maintained closed for the duration of the extended diesel AOT to prevent the intake canal from draining during a loss of offsite power; Appropriate personnel will be briefed by Operations on the procedures for a loss of offsite power and for energizing the 2H bus from the station blackout diesel (0-AAC-DG-0M);

Hourly fire watches will be established in the Unit 1 and Unit 2 cable vault/tunnels, Unit 1 emergency switchgear room, the Unit 1 and Unit 2 normal switchgear rooms, the #1 EDG room and the #3 EDG room; The following equipment will be protected in accordance with OP-SU-601, Protected Equipment during the discretionary period: station blackout diesel (0-AAC-DG-0M), #1 EDG (1-EE-EG-1), #3 EDG (3-EE-EG-1), reserve station system transformers, Unit 1 and Unit 2 turbine driven auxiliary feedwater pumps (1-FW-P-2 and 2-FW-P-2) and the switchyard; No scheduled maintenance or surveillance testing will be allowed on the following equipment during the extended diesel AOT: station blackout diesel (0-AAC-DG-0M), #1 EDG (1-EE-EG-1), #3 EDG (3-EE-EG-1), Unit 1 and Unit 2 turbine driven auxiliary feedwater pumps (1-FW-P-2 and 2-FW-P-2) and switchyard related activities with the potential to result in the loss of offsite power; A backup supply of fuel for the station blackout diesel (0-AAC-DG-0M) will be maintained onsite to extend the 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> supply if needed; and The performance of a daily confirmation of stable grid conditions.

The basis for this discretion also considered that:

Your 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; The cause and proposed plan 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; The noncompliance would not be of potential detriment to the public health and safety; and Independent verification of some of these conditions and actions will be verified by our inspection staff.

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 NRC staff guidance and has no adverse impact on public health and safety or the environment. Therefore, as we informed you at

D. Heacock 3

8:39 p.m., on August 12, 2012, we exercised discretion to not enforce compliance with SPS TS 3.16.B.1.a.3 for the period from August 13, 2012, at 11:00 p.m., until August 18, 2012, at 11:00 p.m. As stated during the conference call and in your letter, you have determined that a follow up license amendment is not necessary. The NRC staff agrees with this determination.

Sincerely,

/RA/

Richard P. Croteau, Director Division of Reactor Projects Docket No.:

50-280, 50-281 License No.: DPR-32, DPR-37 cc w/encl: (See next page)

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X SUNSI REVIEW COMPLETE G FORM 665 ATTACHED OFFICE RII:DRP RII:DRP RII:DRP RII:DRP SIGNATURE

/RA/

/RA Bt SShaeffer/

/RA/

/RA/

NAME JMcCoy SNinh BJones RCroteau DATE 815/2012 814/2012 8/14/2012 8/14/2012 E-MAIL COPY?

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

D. Heacock 4

cc w/encl:

Larry Lane Site Vice President Surry Power Station Virginia Electric and Power Company Electronic Mail Distribution B. L. (Sonny) Stanley Director, Nuclear Safety and Licensing Virginia Electric and Power Company Electronic Mail Distribution Kenny B. Sloane Plant Manager Surry Power Station Virginia Electric & Power Company Electronic Mail Distribution Lillian M. Cuoco, Esq.

Senior Counsel Dominion Resources Services, Inc.

Electronic Mail Distribution Tom Huber Director, Nuclear Licensing & Operations Support Inssbrook Technical Center Electronic Mail Distribution Virginia State Corporation Commission Division of Energy Regulation P.O. Box 1197 Richmond, VA 23209 Attorney General Supreme Court Building 900 East Main Street Richmond, VA 23219 Senior Resident Inspector Surry Power Station U.S. Nuclear Regulatory Commission 5850 Hog Island Rd Surry, VA 23883 Michael M. Cline Director Virginia Department of Emergency Services Management Electronic Mail Distribution

D. Heacock 5

Distribution w/encl:

V. McCree, RA R. Zimmerman, OE B. Boger, NRR M. Evans, NRR S. Coffin, NRR S. Meighan, NRR N. Salgado, NRR J. Andersen, NRR S. Kennedy, OEDO K. Cotton, NRR V. Sreenivas, NRR C. Evans, RII EICS L. Douglas, RII EICS G. McCoy, DRP J. Nadel, DRP RIDSNRRDIRS NOED OEWEB PUBLIC RidsNrrPMSurry Resource

Enclosure List of Participants NRC REGION II ATTENDEES V. McCree, Regional Administrator L. Wert, Deputy Regional Administrator W. Jones, Deputy Director, Division of Reactor Projects G. McCoy, Chief, Reactor Projects Branch 5, Division of Reactor Projects J. Nadel, Surry Acting Senior Resident Inspector, Division of Reactor Projects R. Clagg, North Anna Resident Inspector, Division of Reactor Projects G. MacDonald, Senior Reactor Analyst, Division of Reactor Projects NRC HQ ATTENDEES S. Coffin, Acting Deputy Director, Division of Operating Reactor Licensing, NRR B. Martin, Acting Branch Chief, Division of Operating Reactor Licensing, NRR A. McMurtray, Branch Chief, Component Performance and Testing Branch, NRR R. Mathew, Team Leader, NRR R. Wolfgang, Senior Mechanical Engineer, NRR J. Circle, Senior Reliability and Risk Analyst, NRR S. Stuchell, Senior Project Manager, NRR J. Boska, Project Manager, NRR V. Sreenivas, Project Manager, NRR LICENSEE ATTENDEES L. Lane, Site Vice President, Surry Power Station C. Olsen, Director, Nuclear Engineering, SPS F. Mladen, Director, Station Safety and Licensing, North Anna E. Hendrixson, Director, Nuclear Engineering, North Anna T. Huber, Director Licensing and Operations Support, Innsbrook K. Sloane, Plant Manager, SPS R. Scanlan, Maintenance Manager, SPS R. Johnson, Operations Manager, SPS J. Rosenberger, Engineering (Programs) Manager, SPS J. Henderson, Engineering (Systems) Manager, SPS P. Phelps, Engineering (Design) Manager, SPS R. Sturgill, Nuclear Design Manager, Innsbrook D. Wilson, Assistant Operations Manager, SPS D. Herring, Organizational Effectiveness Supervisor, SPS M. Haduck, Outage and Planning Supervisor, SPS A. Farmer, Electrical Engineering Supervisor, SPS S. Gutner, PRA Supervisor, Innsbrook B. Garber, Licensing Supervisor, SPS D. Sommers, Licensing Supervisor, Innsbrook C. Lovett, Licensing Engineer, SPS J. Ashley, Licensing Engineer, SPS G. Miller, Licensing Engineer, Innsbrook C. Tiernan, PRA Engineer, Innsbrook