ML22208A280
| ML22208A280 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 07/27/2022 |
| From: | Mark Miller Division Reactor Projects II |
| To: | Stoddard D Virginia Electric & Power Co (VEPCO) |
| References | |
| EA-2022-073, EPID I-2022-003-0023, EPID L-2022-LLD-0006 | |
| Download: ML22208A280 (5) | |
Text
EA-2022-073 Mr. Daniel Stoddard Senior Vice 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 (EPID: I-2022-003-0023 AND EPID: L-2022-LLD-0006)
Dear Mr. Stoddard:
By letter dated July 25, 2022 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML22208A175), Virginia Electric and Power Company (Dominion Energy) requested that the U.S. Nuclear Regulatory Commission (NRC) exercise discretion for compliance with the actions required in Surry Power Station (SPS), Units 1 and 2, Technical Specifications (TS) Limiting Condition for Operation (LCO) 3.16, Emergency Power System, Action B.1.a.3 and TS LCO 3.0.2.
This letter documented information previously discussed with the NRC in telephone conferences on July 22, and July 24, 2022. The principal NRC staff members who participated in the telephone conferences are listed in the Enclosure. The staff determined that the information in your letter requesting the NOED was consistent with your oral request.
On July 19, 2022, at approximately 07:00 eastern daylight time (EDT), SPS management notified the resident inspector of the potential request for this NOED. On July 24, 2022, during a teleconference with NRC staff, SPS management orally requested that a NOED be issued pursuant to the NRCs policy regarding the exercise of enforcement discretion for an operating power reactor, set out in the NRC Enforcement Manual, Appendix F, Notices of Enforcement Discretion, dated October 1, 2019. SPS management requested that the NOED be effective for 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> past the LCO expiration (i.e., until 09:56 EDT on Wednesday, July 27, 2022). This letter documents the event and our telephone conversation on July 24, at 14:27 EDT, during which NRC staff verbally granted this NOED request.
July 27, 2022
D. Stoddard 2
On July 18, 2022, at 09:56 EDT, the SPS Unit 1 emergency diesel generator (EDG)
(01-EE-EG-01) was removed from service for monthly surveillance testing. EDG performance issues, including a partial loss of load, were identified during the test that required the test to be terminated prior to completion. Subsequent EDG inspection identified extensive damage to the generator. SPS determined that the direct cause of the failure was a grounded rotor field pole on the generator and that the failure would require a complete generator replacement prior to returning the EDG to service. On July 24, 2022, at approximately 08:00 EDT, it was determined that the activities required to repair, perform post-maintenance testing, and return the SPS Unit 1 EDG to service could not be accomplished within the TS 3.16 7-day allowed outage time (AOT) for an inoperable EDG. The need for enforcement discretion was due to elevated vibrations identified during the EDGs return to service testing and SPS required additional time to balance the Unit 1 EDG. In addition, TS LCO 3.0.2 requires that any individual systems, subsystems, trains, components, and devices supported by Unit 1 EDG (01-EE-EG-01) also be governed by the 7-day EDG AOT. Since 01-EE-EG-01 provides emergency power to certain equipment and systems common to Units 1 and 2, Unit 2 would also be required to shut down upon the expiration of the 7-day AOT.
During the teleconference on July 24, 2022, and as further elaborated in your July 25, 2022, letter, Dominion Energy requested enforcement discretion to avoid an unnecessary shutdown of SPS Units 1 and 2 without a corresponding benefit to public health and safety or the environment. The proposed enforcement discretion would provide an extension period of 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> to remain in Mode 1 rather than progressing to hot shutdown by 15:56 EDT on July 25 and cold shutdown by 21:56 on July 26, 2022. The requested extension was needed to allow time to complete the repair and return the Unit 1 EDG to operable status. Dominion Energy requested that the NOED be in effect from 09:56 EDT, the end of the TS AOT, on July 25, 2022, until the restoration of the Unit 1 EDG, but not to exceed 09:56 EDT on July 27, 2022.
You indicated that the incremental conditional core damage probability (ICCDP) for SPS associated with two additional days of EDG unavailability was 3.301E-08. The incremental conditional large early release probability (ICLERP) for SPS was 1.967E-09. These values were less than the 5E-7 ICCDP and 5E-8 ICLERP guidance thresholds specified in the NRC Enforcement Manual, Appendix F, Notices of Enforcement Discretion.
Some of the compensatory measures that SPS took to reduce the risk were:
No work that jeopardized plant operation, such as alignment changes, balance of-plant function testing, or switchyard work were allowed.
The system load dispatcher was contacted once per day to ensure no grid perturbations were expected.
The shift technical advisor checked once per day for severe weather condition procedure entry criteria and updated the online risk monitor, as necessary.
The Unit 2 and swing EDGs (02-EE-EG-1 and 03-EE-EG-1) were operable, and the station blackout diesel generator (0-AAC-DG-0M) was functional. The status of the EDGs and the A, B, and C reserve station service transformers (RSSTs) were monitored once per shift.
Equipment was protected in accordance with OP-SU-601, "Protected Equipment, during the discretionary period, including: Unit 2, swing, and station blackout diesel generators; all RSSTs and associated supply circuit breakers (CBs) (152, 172, 252, 272, 462, and 472);
transfer buses D, E, and F; 4160-volt emergency buses 1H and 1J; Unit 1 and Unit 2 auxiliary feedwater pumps and associated cross-tie valves
D. Stoddard 3
(1/2-FW-P-2, 1/2-FW-P-3A/3B, 1/2-FW-MOV-160A/B & 260A/B); and switchyard transformers
- 2, #4, and associated CBs (H202, L202, H402, L402).
Hot work was restricted, and fire watches established in areas of the plant to reduce the likelihood of initiating events and likelihood of unavailability of redundant trains.
The SPS Facility Safety Review Committee reviewed and approved submission of the NOED request on July 24, 2022.
Based on the NRC staffs evaluation of the NOED request, the staff determined that granting this NOED was consistent with the NRCs Enforcement Policy and staff guidance. The NOED request met the criteria specified in Section 2.5 of Appendix F, Notices of Enforcement Discretion, of the NRCs Enforcement Manual. Granting this NOED avoided an unnecessary shutdown of two reactors without a corresponding benefit to public health and safety or the environment. Therefore, as communicated orally to your staff at 14:27 EDT on July 24, 2022, the NRC staff exercised discretion not to enforce compliance with TS LCO 3.16, Action B.1.a.3 and TS LCO 3.0.2, for an additional period of 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />, which extended expiration from 09:56 EDT on July 25, 2022, to 09:56 EDT on July 27, 2022. As stated during the conference call and in Dominion Energys letter, a determination was made that a follow up license amendment was not necessary. The NRC staff agrees with this determination.
The NRC staff noted, after its verbal approval for enforcement discretion, that the condition causing the need for this NOED was corrected and SPS Unit 1 exited from TS LCO 3.16, Action B.1.a.3 at approximately 17:05 EDT on July 26, 2022. As a result, this NOED terminated at 17:05 EDT on July 26, 2022, within the period of the enforcement discretion.
As stated in the NRC Enforcement Policy, action will be taken, to the extent that any violation was involved, for the root cause that led to the noncompliance for which this NOED was necessary.
In accordance with Title 10 of the Code of Federal Regulations (10 CFR) 2.390 of the NRCs Rules of Practice, a copy of this letter will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRC's document system (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely, Mark Miller, Director Division of Reactor Projects Docket No. 05000280, 05000281 License No. DPR-32, DPR-37
Enclosure:
As stated cc w/encl: Distribution via LISTSERV Signed by Miller, Mark on 07/27/22
SUNSI Review X
Non-Sensitive
Sensitive X
Publicly Available
Non-Publicly Available OFFICE RII:DRP RII:DRP RII:DRP RII:NRR RII:NRR RII:DRP NAME S. Kennedy M. Fannon A. Rosebrook B. Pham S. Devlin-Gill M. Miller DATE 7/27/2022 7/27/2022 7/27/2022 07/27/2022 7/27/2022 7/27/2022
LIST OF KEY NRC PERSONNEL PARTICIPANTS NRC REGION II Mark Miller, Director, Division of Reactor Projects (DRP)
Mark Franke, Director, Division of Reactor Safety (DRS)
LaDonna Suggs, Deputy Director, DRP Matthew Fannon, Chief, Reactor Projects Branch 4 (RPB4), DRP James Baptist, Chief, Engineering Branch 1 (EB1), DRS Andy Rosebrook, Senior Reactor Analyst, RPB6, DRP Geoffrey Ottenberg, Senior Reactor Inspector, EB1, DRS Silas Kennedy, Senior Resident Inspector - Surry Power Station, RPB4, DRP Brian Towne, Resident Inspector - Surry Power Station, RPB4, DRP OFFICE OF NUCLEAR REACTOR REGULATION Bo Pham, Director, Division of Operating Reactor Licensing (DORL)
Jake Zimmerman, Acting Deputy Director, DORL Sheila Ray, Acting Chief, Electrical Engineering Branch (EEEB), Division of Engineering and External Hazards (DEX)
Stephanie Devlin-Gill, Acting Chief, Plant Licensing Branch II-1, DORL Stewart Bailey, Chief, Mech. Eng. & In-Service Testing Branch (EMIB), DEX Michelle Kichline, Senior Reliability and Risk Analyst, PRA Licensing Oversight Branch (APOB),
Division of Risk Assessment (DRA)
Ed Miller, Senior Project Manager, Plant Licensing Branch II-1, DORL John Klos, Project Manager, Plant Licensing Branch II-1, DORL Ian Tseng, Mechanical Engineer, EMIB, DEX Khadijah West, Safety and Plant Systems Engineer, Tech. Specs. Branch (STSB), Division of Safety System (DSS)
Lundy Pressley, Reliability and Risk Analyst, APOB, DRA Vijay Goel, Electrical Engineer, EEEB, DEX Enclosure