ML12208A344

Notice of Enforcement Discretion (NOED) for Shearon Harris Nuclear Power Plant, Unit 1 (NOED No. 12-2-001)

ML12208A344
Person / Time
Site:	Harris
Issue date:	07/26/2012
From:	Croteau R P Division Reactor Projects II
To:	Hamrick G Carolina Power & Light Co
References
NOED 12-2-001
Download: ML12208A344 (8)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION REGION II 245 PEACHTREE CENTER AVENUE NE, SUITE 1200 ATLANTA, GEORGIA 30303-1257 July 26, 2012 Mr. George Hamrick, Vice President Carolina Power and Light Company Shearon Harris Nuclear Power Plant P. O. Box 165, Mail Code: Zone 1 New Hill, North Carolina 27562-0165

SUBJECT:

NOTICE OF ENFORCEMENT DISCRETION (NOED) FOR SHEARON HARRIS NUCLEAR POWER PLANT, UNIT 1 [NOED NO. 12-2-001]

Dear Mr. Hamrick:

By letter dated July 24, 2012, you requested that the NRC exercise discretion to not enforce compliance with the actions required in Shearon Harris Nuclear Power Plant, Unit 1 (HNP) required action of Technical Specification (TS) 3.8.1 A.C. Sources - Operating. Your letter documented information previously discussed with the NRC staff in a telephone conference on July 21, 2012, at 5:00 p.m. (all times refer to Eastern Daylight Time). The principal NRC 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.

To summarize, you stated that, on July 19, 2012, at 4:00 a.m., Emergency Diesel Generator B (B-EDG) was removed from service for routine maintenance. Shearon Harris Nuclear Power Plant, Unit 1 (HNP), entered Technical Specification (TS) 3.8.1, "A.C. Sources - Operating," TS 3.8.1.1, Action b.3, which requires the inoperable EDG to be restored to operable status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> (i.e., on July 22, 2012, at 4:00 a.m.). On July 19, 2012, B-EDG was being barred locally as part of post-maintenance testing. During the barring, water was observed issuing from the 5L cylinder. Investigation has determined that the cause of the water intrusion is a cracked cylinder head of the 5L cylinder. At the time of your request, repair efforts were complete, however, the time needed to complete the operability testing associated with the planned and emergent maintenance may not have been sufficient to preclude exceeding the existing allowed out-of-service time (AOT). You requested that a NOED be granted pursuant to the NRC's 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 July 22, 2012, at 4:00 p.m. This letter documents our telephone conversation of July 21, 2012 at 5:00 p.m., when we orally granted your NOED request. We understand that the condition which prompted your request for this NOED was corrected allowing HNP to exit from the TS action listed above at 1:50 a.m. on July 22, 2012. Because the TS AOT was not exceeded, this NOED was not needed in order to comply with the existing TS.

G. Hamrick 2 On July 19, 2012, at 4:00 a.m. EDT, B-EDG was removed from service for unrelated routine maintenance. On July 19, 2012, at approximately 11:46 p.m., restoration from maintenance revealed that the 5L cylinder on B-EDG had water intrusion that was later confirmed to be from a crack in the cylinder head. You informed us that there have been no similar failures associated with the HNP EDG cylinder heads. Due to the emergent nature of the failure and lack of historical problems associated with the EDG cylinder heads, you stated that the need for an NOED could not have been reasonably avoided. The cracked head was replaced and the cylinder liner inspected to confirm there were no additional sources of leakage.

The NRC staff determined that the requested NOED was necessary to avoid an unnecessary transient as a result of compliance with the license conditions and, thus, minimize potential safety consequences and operational risks (Part 9900, Technical Guidance, Operations - Notices of Enforcement Discretion, Section B.2.1, criterion 1.a). The NRC staff's basis for this discretion considered: (1) your commitment to defer non-essential surveillances and other maintenance activities in the switchyard to reduce the likelihood of a loss of offsite power; (2) your commitment to defer non-essential surveillances and other maintenance activities on risk-significant equipment including, A-EDG and its auxiliaries (i.e., including emergency service water), Turbine-Driven Auxiliary Feedwater Pump (TDAFWP), Dedicated Shutdown Diesel Generator (DSDG), Essential train A AC/ DC power, Division A Switchgear, and Diesel-driven Fire Pump; (3) to review and brief operator actions related to connection of the DSDG to station battery chargers; (4) to review and brief operator actions related to restoration of power using the start-up transformers in the event of an automatic transfer failure; (5) to protect against maintenance and surveillances that could result in a reactor trip; (6) to protect against maintenance and surveillances that could result in loss of main Feedwater; (7) to protect breakers from the Unit Auxiliary Transformers and Startup Transformers to 1D and 1E buses; (8) to walk-down the alternate seal injection system for challenges to functionality; (9) to verify grid conditions are stable; (10) to verify 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; (11) to assure 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; (12) to assure that the noncompliance would not be of potential detriment to the public health and safety; and (13) independent verification of some of these conditions and actions by our inspection staff.

On the basis of the NRC staff's 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 6:15 p.m., on July 21, 2012, we exercised discretion to not enforce compliance with TS 3.8.1.1, Action b.3 for the period from July 22, 2012, at 4:00 a.m., until July 22, 2012, at 4:00 p.m. As stated during the conference call and in your letter, you have determined that a follow up license amendment is not necessary; however, you plan to perform a study to evaluate extended TS Completion Times for the EDGs and associated equipment. The NRC staff agrees with this determination.

G. Hamrick 3 Because you did not use the extended allowed outage time granted by this NOED, enforcement action related to this matter is not anticipated.

Sincerely,

/RA/

Richard P. Croteau, Director Division of Reactor Projects Docket No.: 50-400 License No.: NPF-63 cc w/encl: (See page 4)

_________________________

G SUNSI REVIEW COMPLETE G FORM 665 ATTACHED OFFICE RII:DRP RII:DRP NRR RII:DRP RII:DRP SIGNATURE Via email RAM /RA/ Via email Via email EFG /RA for/ NAME JDodson RMusser SCoffin CEvans RCroteau DATE 07/26/2012 07/26/2012 07/26/2012 07/26/2012 07/26/2012 E-MAIL COPY? YES NO YES NO YES NO YES NO YES NO YES NO YES NO G. Hamrick 4 cc w/encl: Brian Bernard Manager, Nuclear Services and EP Nuclear Protective Services Shearon Harris Nuclear Power Plant Electronic Mail Distribution Brian C. McCabe Manager, Nuclear Oversight Shearon Harris Nuclear Power Plant Progress Energy Electronic Mail Distribution Robert J. Duncan II Vice President Nuclear Operations Progress Energy Electronic Mail Distribution Donald L. Griffith Training Manager Shearon Harris Nuclear Power Plant Progress Energy Electronic Mail Distribution R. Keith Holbrook Manager, Support Services Shearon Harris Nuclear Power Plant Electronic Mail Distribution David H. Corlett Supervisor Licensing/Regulatory Programs Progress Energy Electronic Mail Distribution

David T. Conley Senior Counsel Legal Department Progress Energy Electronic Mail Distribution Donna B. Alexander Manager, Nuclear Regulatory Affairs (interim) Progress Energy Electronic Mail Distribution

John H. O'Neill, Jr. Shaw, Pittman, Potts & Trowbridge 2300 N. Street, NW Washington, DC 20037-1128

Joseph W. Donahue Vice President Nuclear Oversight Progress Energy Electronic Mail Distribution W. Lee Cox, III Section Chief Radiation Protection Section N.C. Department of Environmental Commerce & Natural Resources Electronic Mail Distribution Kelvin Henderson General Manager Nuclear Fleet Operations Progress Energy Electronic Mail Distribution Public Service Commission State of South Carolina P.O. Box 11649 Columbia, SC 29211 Chairman North Carolina Utilities Commission Electronic Mail Distribution Terrence E. Slake Manager Nuclear Plant Security Shearon Harris Nuclear Power Plant Electronic Mail Distribution Robert P. Gruber Executive Director Public Staff - NCUC 4326 Mail Service Center Raleigh, NC 27699-4326 (cc w/encl continued next page)

G. Hamrick 5 (cc w/encl continued)

Chair Board of County Commissioners of Wake County P.O. Box 550 Raleigh, NC 27602 Ernest J. Kapopoulos Jr.

Plant General Manager Carolina Power and Light Company Shearon Harris Nuclear Power Plant Electronic Mail Distribution Chair Board of County Commissioners of Chatham County P.O. Box 1809 Pittsboro, NC 27312

G. Hamrick 6 Letter to George Hamrick from Richard P. Croteau dated July 26, 2012

SUBJECT:

NOTICE OF ENFORCEMENT DISCRETION (NOED) FOR SHEARON HARRIS NUCLEAR POWER PLANT, UNIT 1 [NOED NO. 12-2-001]

Distribution w/encl

C. Evans, RII L. Douglas, RII OE Mail RIDSNRRDIRS PUBLIC RidsNrrPMShearonHarris Resource

Enclosure List of Participants NRC REGION II ATTENDEES L. Wert, Deputy Regional Administrator R. Croteau, Director, Division of Reactor Projects W. Jones, Deputy Director, Division of Reactor Projects R. Musser, Chief Reactor Projects Branch 4, Division of Reactor Projects J. Austin, Harris Senior Resident Inspector, Division of Reactor Projects J. Hanna, Senior Reactor Analyst, Division of Reactor Projects R. Bernhard, Senior Reactor Analyst, Division of Reactor Projects NRC HQ ATTENDEES S. Coffin, Acting Deputy Director, Division of Operating Reactor Licensing, NRR J. Quichocho, Acting Branch Chief, Division of Operating Reactor Licensing, NRR J. Andersen, Branch Chief, Electrical Engineering Branch; NRR G. Waig, Senior Reactor Systems Engineer, NRR M. McConnell, Senior Electrical Engineer, NRR R. Wolfgang, Senior Mechanical Engineer, NRR D. Chung, Reliability and Risk Analyst, NRR J. Rowley, Project Manager, NRR A. Billoch Colón, Project Manager, NRR LICENSEE ATTENDEES G. Hamrick, Harris Site Vice President E. Kapopoulos, Jr., Harris Plant Manager B. McCabe, Manager, Harris Nuclear Oversight M. Denny, Manager, Harris Systems Engineering J. Caves, Lead Engineer, Harris Licensing R. Rishel, Manager, Probabilistic Safety Assessment