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{{#Wiki_filter:UNITED STATES NUCLEAR REGULATORY COMMISSION REGION II SAM NUNN ATLANTA FEDERAL CENTER 61 FORSYTH STREET, SW, SUITE 23T85 ATLANTA, GEORGIA 30303-8931 October 2, 2008 Mr. William R. Campbell, Jr.
{{#Wiki_filter:UNITED STATES NUCLEAR REGULATORY COMMISSION REGION II SAM NUNN ATLANTA FEDERAL CENTER 61 FORSYTH STREET, SW, SUITE 23T85 ATLANTA, GEORGIA 30303-8931 October 2, 2008 Mr. William R. Campbell, Jr.
Chief Nuclear Officer and Executive Vice President Tennessee Valley Authority 3R Lookout Place 1101 Market Street Chattanooga, TN 37402-2801
Chief Nuclear Officer and Executive Vice President Tennessee Valley Authority 3R Lookout Place 1101 Market Street Chattanooga, TN 37402-2801  


==SUBJECT:==
==SUBJECT:==
NOTICE OF ENFORCEMENT DISCRETION (NOED) FOR TENNESSEE VALLEY AUTHORITY REGARDING SEQUOYAH NUCLEAR PLANT, UNITS 1 AND 2 [TAC NO. MD9719 AND MD9720, NOED NO.08-2-001]
NOTICE OF ENFORCEMENT DISCRETION (NOED) FOR TENNESSEE VALLEY AUTHORITY REGARDING SEQUOYAH NUCLEAR PLANT, UNITS 1 AND 2 [TAC NO. MD9719 AND MD9720, NOED NO.08-2-001]  


==Dear Mr. Campbell:==
==Dear Mr. Campbell:==
 
By {{letter dated|date=September 26, 2008|text=letter dated September 26, 2008}}, Tennessee Valley Authority (TVA) confirmed a September 26, 2008, verbal request that the NRC exercise discretion to not enforce compliance with the actions required in Sequoyah Nuclear Plant, Units 1 and 2 (SQN), Technical Specifications (TS) 3.0.5 Limiting Condition for Operation.
By letter dated September 26, 2008, Tennessee Valley Authority (TVA) confirmed a September 26, 2008, verbal request that the NRC exercise discretion to not enforce compliance with the actions required in Sequoyah Nuclear Plant, Units 1 and 2 (SQN), Technical Specifications (TS) 3.0.5 Limiting Condition for Operation.
TVA requested that a Notice of Enforcement Discretion (NOED) be granted pursuant to the NRCs policy regarding exercise of discretion for an operating facility, described in Section VII.C of the NRCs Enforcement Policy, to extend the time required by TS 3.0.5.1 to be in at least HOT STANDBY in 6 hours by an additional 36 hours. The discretion, which began on September 26, at 6:55 a.m., would expire on September 27, 2008, at 6:55 p.m., (all times discussed in this letter refer to Eastern Daylight Time).
TVA requested that a Notice of Enforcement Discretion (NOED) be granted pursuant to the NRCs policy regarding exercise of discretion for an operating facility, described in Section VII.C of the NRCs Enforcement Policy, to extend the time required by TS 3.0.5.1 to be in at least HOT STANDBY in 6 hours by an additional 36 hours. The discretion, which began on September 26, at 6:55 a.m., would expire on September 27, 2008, at 6:55 p.m., (all times discussed in this letter refer to Eastern Daylight Time).
This letter documents our telephone conversation on September 26, 2008, at 4:04 a.m., when we verbally granted enforcement discretion. Subsequent to the verbal authorization of this enforcement discretion, we understand that the condition causing the need for this enforcement discretion was corrected by you causing you to exit from the actions required in TS 3.0.5 and from this NOED at 2:00 p.m., on September 26, 2008. The basis for our decision to grant the exercising of enforcement discretion is provided in the following discussion.
This letter documents our telephone conversation on September 26, 2008, at 4:04 a.m., when we verbally granted enforcement discretion. Subsequent to the verbal authorization of this enforcement discretion, we understand that the condition causing the need for this enforcement discretion was corrected by you causing you to exit from the actions required in TS 3.0.5 and from this NOED at 2:00 p.m., on September 26, 2008. The basis for our decision to grant the exercising of enforcement discretion is provided in the following discussion.
Your letter documented information previously discussed with the NRC in a telephone conference which occurred on September 26, 2008. The principal NRC staff members who participated in the telephone conference included: Jim Moorman, Deputy Director, Division of Reactor Projects (DRP), Region II (RII); Eugene Guthrie, Chief, Reactor Projects Branch 6 (RPB-6), DRP, RII; Cale Young, Sequoyah Senior Resident Inspector, RPB-6, DRP, RII; Kriss Kennedy, Director, Division of Reactor Safety (DRS), RII; Rudy Bernhard, Senior Reactor Analyst, Engineering Branch 2, DRS, RII; Tom Boyce, Chief, Plant Licensing Branch II-2, Division of Operating Reactor Licensing (DORL), Office of Nuclear Reactor Regulation (NRR);
Your letter documented information previously discussed with the NRC in a telephone conference which occurred on September 26, 2008. The principal NRC staff members who participated in the telephone conference included: Jim Moorman, Deputy Director, Division of Reactor Projects (DRP), Region II (RII); Eugene Guthrie, Chief, Reactor Projects Branch 6 (RPB-6), DRP, RII; Cale Young, Sequoyah Senior Resident Inspector, RPB-6, DRP, RII; Kriss Kennedy, Director, Division of Reactor Safety (DRS), RII; Rudy Bernhard, Senior Reactor Analyst, Engineering Branch 2, DRS, RII; Tom Boyce, Chief, Plant Licensing Branch II-2, Division of Operating Reactor Licensing (DORL), Office of Nuclear Reactor Regulation (NRR);
Tracy Orf, Project Manager, Plant Licensing Branch II-2, DORL, NRR; Robert Dennig, Chief, Containment and Ventilation Branch, Division of Safety Systems, NRR; and Brendan Moroney, Sequoyah Project Manager, Plant Licensing Branch II-2, DORL, NRR.
Tracy Orf, Project Manager, Plant Licensing Branch II-2, DORL, NRR; Robert Dennig, Chief, Containment and Ventilation Branch, Division of Safety Systems, NRR; and Brendan Moroney, Sequoyah Project Manager, Plant Licensing Branch II-2, DORL, NRR.  


TVA                                               2 Your staff requested enforcement discretion to preclude having to be in at least HOT STANDBY in 6 hours per TS 3.0.5 due to the B train of control room air conditioning system (CRACS) being inoperable (B main control room (MCR) air handling unit (AHU) had failed) concurrently with the A train CRACS being inoperable solely due to its emergency backup power supply, 1A-A Emergency Diesel Generator (EDG), being inoperable. The 1A-A EDG was inoperable because its associated control power and field flash battery had not yet been returned to operable status after replacement. The licensee determined that the battery had been charged sufficiently to start and operate the 1A-A EDG but not enough to meet the requirements of TS to be declared operable, i.e., the 1A-A EDG was functionally available to perform its intended safety function. The sequence of events follows:
TVA 2
Your staff requested enforcement discretion to preclude having to be in at least HOT STANDBY in 6 hours per TS 3.0.5 due to the B train of control room air conditioning system (CRACS) being inoperable (B main control room (MCR) air handling unit (AHU) had failed) concurrently with the A train CRACS being inoperable solely due to its emergency backup power supply, 1A-A Emergency Diesel Generator (EDG), being inoperable. The 1A-A EDG was inoperable because its associated control power and field flash battery had not yet been returned to operable status after replacement. The licensee determined that the battery had been charged sufficiently to start and operate the 1A-A EDG but not enough to meet the requirements of TS to be declared operable, i.e., the 1A-A EDG was functionally available to perform its intended safety function. The sequence of events follows:
At 5:05 p.m., on September 24, Units 1 and 2 entered TS 3.8.1.1, action (b) for one EDG being inoperable due to the replacement of the 1A-A EDG battery.
At 5:05 p.m., on September 24, Units 1 and 2 entered TS 3.8.1.1, action (b) for one EDG being inoperable due to the replacement of the 1A-A EDG battery.
At 10:07 p.m., on September 25, the 1A-A EDG battery discharge test was completed and the battery was subsequently placed on a portable charger.
At 10:07 p.m., on September 25, the 1A-A EDG battery discharge test was completed and the battery was subsequently placed on a portable charger.
Line 39: Line 39:
At 5:07 a.m., on September 26, the 1A-A EDG battery was aligned to the 125 volt DC distribution system and charger after charging current from the portable charger decreased to less than 2 amperes, the point at which the high level equalize may be terminated. The 1A-A EDG was considered functionally available but inoperable per TS.
At 5:07 a.m., on September 26, the 1A-A EDG battery was aligned to the 125 volt DC distribution system and charger after charging current from the portable charger decreased to less than 2 amperes, the point at which the high level equalize may be terminated. The 1A-A EDG was considered functionally available but inoperable per TS.
At 2:00 p.m., on September 26, the 1A-A EDG was declared operable after its battery passed its TS required surveillance test. The NOED was exited.
At 2:00 p.m., on September 26, the 1A-A EDG was declared operable after its battery passed its TS required surveillance test. The NOED was exited.
Based on the information provided in the telephone conversation on September 26, 2008, and in your letter dated September 26, 2008, the NRC has determined that Criterion B.2.1.1.a of NRC Inspection Manual Part 9900, Technical Guidance, Operation - Notice of Enforcement Discretion, was met. The NRC reviewed your written request for enforcement discretion dated September 26, 2008, and verified consistency between your oral and written requests. The NRCs basis for this discretion considered: (1) the compensatory measures to administratively control and protect vital plant equipment and to ensure that plant equipment could perform its design function for the duration of the enforcement discretion period; (2) the availability of offsite electrical power; and (3) the qualitative risk assessment which considered that the risk was bound by the risk associated with the TS 3.7.15.a allowed outage time, 30 days, for one train of CRACS being out of service, since the A train CRACS had its normal offsite power available and the 1A-A EDG was functionally able to start and provide emergency backup power to the train, if necessary.
Based on the information provided in the telephone conversation on September 26, 2008, and in your {{letter dated|date=September 26, 2008|text=letter dated September 26, 2008}}, the NRC has determined that Criterion B.2.1.1.a of NRC Inspection Manual Part 9900, Technical Guidance, Operation - Notice of Enforcement Discretion, was met. The NRC reviewed your written request for enforcement discretion dated September 26, 2008, and verified consistency between your oral and written requests. The NRCs basis for this discretion considered: (1) the compensatory measures to administratively control and protect vital plant equipment and to ensure that plant equipment could perform its design function for the duration of the enforcement discretion period; (2) the availability of offsite electrical power; and (3) the qualitative risk assessment which considered that the risk was bound by the risk associated with the TS 3.7.15.a allowed outage time, 30 days, for one train of CRACS being out of service, since the A train CRACS had its normal offsite power available and the 1A-A EDG was functionally able to start and provide emergency backup power to the train, if necessary.
During the phone call, the staff based their decision to exercise enforcement discretion, in part, on a qualitative versus a quantitative assessment of risk. In the written request, your staff provided a different quantitative risk analysis results than discussed during the verbal request.
During the phone call, the staff based their decision to exercise enforcement discretion, in part, on a qualitative versus a quantitative assessment of risk. In the written request, your staff provided a different quantitative risk analysis results than discussed during the verbal request.  


TVA                                             3 The new information supported the qualitative risk assessments conclusion that the exercise of discretion would result in acceptable plant risk. This new risk analysis indicated that the incremental conditional core damage probability (ICCDP) for the proposed 36 hour extension is 5.03E-08, and the incremental conditional large early release probability (ICLERP) for the proposed 36 hour extension is 2.28E-9. These values are both less than the 5.0E-7 and 5.0E-8 guidance thresholds, respectively, in Inspection Manual Part 9900 Technical Guidance.
TVA 3
The new information supported the qualitative risk assessments conclusion that the exercise of discretion would result in acceptable plant risk. This new risk analysis indicated that the incremental conditional core damage probability (ICCDP) for the proposed 36 hour extension is 5.03E-08, and the incremental conditional large early release probability (ICLERP) for the proposed 36 hour extension is 2.28E-9. These values are both less than the 5.0E-7 and 5.0E-8 guidance thresholds, respectively, in Inspection Manual Part 9900 Technical Guidance.
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. Therefore, as we communicated to your staff at 4:04 a.m., on September 26, 2008, we exercised discretion to not enforce compliance with TS 3.0.5 to place both units in at least HOT STANDBY within the next 6 hours while the 1A-A EDG remains functionally available to perform its intended safety function of supplying power to the A CRACS train and the A CRACS train remained available on off-site power for the period of time from 6:55 a.m., on September 26, to 6:55 p.m., on September 27, 2008.
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. Therefore, as we communicated to your staff at 4:04 a.m., on September 26, 2008, we exercised discretion to not enforce compliance with TS 3.0.5 to place both units in at least HOT STANDBY within the next 6 hours while the 1A-A EDG remains functionally available to perform its intended safety function of supplying power to the A CRACS train and the A CRACS train remained available on off-site power for the period of time from 6:55 a.m., on September 26, to 6:55 p.m., on September 27, 2008.
In addition, as discussed on September 26, 2008, the NRC staff agrees with your staffs determination that a follow-up TS amendment is not needed. The NRC staff finds that a TS amendment (either a one-time or permanent amendment) is not necessary, in this case, because: (1) the circumstances surrounding the noncompliance are unlikely to re-occur, i.e.,
In addition, as discussed on September 26, 2008, the NRC staff agrees with your staffs determination that a follow-up TS amendment is not needed. The NRC staff finds that a TS amendment (either a one-time or permanent amendment) is not necessary, in this case, because: (1) the circumstances surrounding the noncompliance are unlikely to re-occur, i.e.,
the NOED involves a single request for extending the period of time the units could operate before being placed in HOT STANDBY when an EDG is inoperable per plant TSs but is functionally available to perform its intended safety function of supplying power to a CRACS train; and (2) the information in this NOED approval letter provides sufficient and complete documentation of the bases for the exercise of discretion.
the NOED involves a single request for extending the period of time the units could operate before being placed in HOT STANDBY when an EDG is inoperable per plant TSs but is functionally available to perform its intended safety function of supplying power to a CRACS train; and (2) the information in this NOED approval letter provides sufficient and complete documentation of the bases for the exercise of discretion.
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.
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,
Sincerely,  
                                              /RA By Victor McCree For/
/RA By Victor McCree For/
Luis A. Reyes Regional Administrator Docket Nos.: 50-327, 50-328 License Nos.: DPR-77, DPR-79 cc: (See next page)
Luis A. Reyes Regional Administrator Docket Nos.: 50-327, 50-328 License Nos.: DPR-77, DPR-79 cc: (See next page)  


_________________________
X SUNSI REVIEW COMPLETE OFFICE RII:DRP RII:DRP RII:DRP RII:DRS RII:DRS NRR:DORL NRR:DORL SIGNATURE  
X SUNSI REVIEW COMPLETE OFFICE             RII:DRP         RII:DRP         RII:DRP         RII:DRS         RII:DRS         NRR:DORL       NRR:DORL SIGNATURE         /RA/           /RA/           /RA/           /RA/             /RA By Telcom/ /RA By E-Mail/ /RA By E-Mail/
/RA/  
NAME               *LGarner       *EGuthrie       LWert           *KKennedy       *RBernard       JGiiter         TBoyce DATE                   9/30/08         9/30/08         10/           9/30/08         9/29/08       10/01/08       10/01/08 E-MAIL COPY?         YES       NO YES         NO /200810/01/08 YES         NO YES         NO YES         NO YES         NO YES         NO OFFICE             NRR:DCRL       RII:ORA         NRR:PM         NRR:APOB SIGNATURE         /RA By E-Mail/ /RA/           /RA By E-Mail/ /RA By E-Mail/
/RA/  
NAME               RDennig         VMcCree         BMoroney       MFranovch DATE                   9/30/08       10/02/08       10/01/08       10/01/08 E-MAIL COPY?         YES       NO YES         NO YES         NO YES         NO YES         NO YES         NO YES         NO
/RA/  
/RA/  
/RA By Telcom/  
/RA By E-Mail/  
/RA By E-Mail/
NAME  
*LGarner  
*EGuthrie LWert  
*KKennedy  
*RBernard JGiiter TBoyce DATE 9/30/08 9/30/08 10/  
/200810/01/08 9/30/08 9/29/08 10/01/08 10/01/08 E-MAIL COPY?
YES NO YES NO YES NO YES NO YES NO YES NO YES NO OFFICE NRR:DCRL RII:ORA NRR:PM NRR:APOB SIGNATURE  
/RA By E-Mail/  
/RA/  
/RA By E-Mail/  
/RA By E-Mail/
NAME RDennig VMcCree BMoroney MFranovch DATE 9/30/08 10/02/08 10/01/08 10/01/08 E-MAIL COPY?
YES NO YES NO YES NO YES NO YES NO YES NO YES NO  


TVA                                     4 cc contd:
TVA 4
Ashok S. Bhatnagar                         General Counsel Senior Vice President                     Tennessee Valley Authority Nuclear Generation Development and         Electronic Mail Distribution Construction Tennessee Valley Authority                 Beth A. Wetzel Electronic Mail Distribution               Manager Corporate Nuclear Licensing and Industry William R. Campbell, Jr.                   Affairs Chief Nuclear Officer and Executive Vice   Tennessee Valley Authority President                                  Electronic Mail Distribution Tennessee Valley Authority 3R Lookout Place                           James D. Smith 1101 Market Street                         Manager, Licensing and Industry Affairs Chattanooga, TN 37402-2801                 Sequoyah Nuclear Plant Tennessee Valley Authority Christopher R. Church                      Electronic Mail Distribution Plant Manager Sequoyah Nuclear Plant                     Larry E. Nicholson Tennessee Valley Authority                General Manager Electronic Mail Distribution              Performance Improvement Tennessee Valley Authority Tom Coutu                                  Electronic Mail Distribution Vice President Nuclear Support                            Michael A. Purcell Tennessee Valley Authority                Senior Licensing Manager 3R Lookout Place                          Nuclear Power Group 1101 Market Street                        Tennessee Valley Authority Chattanooga, TN 37402-2801                Electronic Mail Distribution Michael J. Lorek                          Senior Resident Inspector Vice President, Nuclear Engineering and    U.S. Nuclear Regulatory Commission Projects                                  Sequoyah Nuclear Plant Tennessee Valley Authority                2600 Igou Ferry Road Electronic Mail Distribution              Soddy Daisy, TN 37379-3624 Timothy P. Cleary                          Lawrence Edward Nanney Site Vice President                        Director Sequoyah Nuclear Plant                    Division of Radiological Health Tennessee Valley Authority                TN Dept. of Environment & Conservation Electronic Mail Distribution               Electronic Mail Distribution John C. Fornicola                          County Mayor General Manager                            Hamilton County Courthouse Nuclear Assurance                          208 Courthouse Tennessee Valley Authority                625 Georgia Avenue Electronic Mail Distribution              Chattanooga, TN 37402-2801 (cc contd - See next page)
cc contd:
Ashok S. Bhatnagar Senior Vice President Nuclear Generation Development and Construction Tennessee Valley Authority Electronic Mail Distribution William R. Campbell, Jr.
Chief Nuclear Officer and Executive Vice President Tennessee Valley Authority 3R Lookout Place 1101 Market Street Chattanooga, TN 37402-2801 Christopher R. Church Plant Manager Sequoyah Nuclear Plant Tennessee Valley Authority Electronic Mail Distribution Tom Coutu Vice President Nuclear Support Tennessee Valley Authority 3R Lookout Place 1101 Market Street Chattanooga, TN 37402-2801 Michael J. Lorek Vice President, Nuclear Engineering and Projects Tennessee Valley Authority Electronic Mail Distribution Timothy P. Cleary Site Vice President Sequoyah Nuclear Plant Tennessee Valley Authority Electronic Mail Distribution John C. Fornicola General Manager Nuclear Assurance Tennessee Valley Authority Electronic Mail Distribution General Counsel Tennessee Valley Authority Electronic Mail Distribution Beth A. Wetzel Manager Corporate Nuclear Licensing and Industry Affairs Tennessee Valley Authority Electronic Mail Distribution James D. Smith Manager, Licensing and Industry Affairs Sequoyah Nuclear Plant Tennessee Valley Authority Electronic Mail Distribution Larry E. Nicholson General Manager Performance Improvement Tennessee Valley Authority Electronic Mail Distribution Michael A. Purcell Senior Licensing Manager Nuclear Power Group Tennessee Valley Authority Electronic Mail Distribution Senior Resident Inspector U.S. Nuclear Regulatory Commission Sequoyah Nuclear Plant 2600 Igou Ferry Road Soddy Daisy, TN 37379-3624 Lawrence Edward Nanney Director Division of Radiological Health TN Dept. of Environment & Conservation Electronic Mail Distribution County Mayor Hamilton County Courthouse 208 Courthouse 625 Georgia Avenue Chattanooga, TN 37402-2801 (cc contd - See next page)


TVA                           5 cc contd:
TVA 5
James H. Bassham Director Tennessee Emergency Management Agency Electronic Mail Distribution Ann Harris 341 Swing Loop Rockwood, TN 37854
cc contd:
James H. Bassham Director Tennessee Emergency Management Agency Electronic Mail Distribution Ann Harris 341 Swing Loop Rockwood, TN 37854  


TVA                     6 Distribution:
TVA 6
Distribution:
V. McCree,DRAO K. Kennedy, DRS L. Wert, DRP E. Guthrie, DRP S. Vias, DRP C. Young, SRI Seq.
V. McCree,DRAO K. Kennedy, DRS L. Wert, DRP E. Guthrie, DRP S. Vias, DRP C. Young, SRI Seq.
C. Evans, EICS L. Slack, EICS C. Carpenter, OE T. McGinty, NRR T. Boyce, NRR B. Moroney, NRR T. Bloomer, OEDO T. Farnholtz, EDO RIDSNRRDIRS RidsNrrOd RidsNrrAdes RidsNrrAdro RidsNrrDorl C. Goodwin, NRR RidsNrrLACSola RidsNrrPMBMoroney RidsNrrDorlLp2-2 RidsOgcRp RidsNrrDssScvb RidsDraApob RidsNrrDprPgcb RidsAcrsAcnw&mMailCenter RidsOeMailCenter RidsRgn2MailCenter NOED OEWEB PUBLIC}}
C. Evans, EICS L. Slack, EICS C. Carpenter, OE T. McGinty, NRR T. Boyce, NRR B. Moroney, NRR T. Bloomer, OEDO T. Farnholtz, EDO RIDSNRRDIRS RidsNrrOd RidsNrrAdes RidsNrrAdro RidsNrrDorl C. Goodwin, NRR RidsNrrLACSola RidsNrrPMBMoroney RidsNrrDorlLp2-2 RidsOgcRp RidsNrrDssScvb RidsDraApob RidsNrrDprPgcb RidsAcrsAcnw&mMailCenter RidsOeMailCenter RidsRgn2MailCenter NOED OEWEB PUBLIC}}

Latest revision as of 14:51, 14 January 2025

Notice of Enforcement Discretion (NOED) for Tennessee Valley Authority Regarding Sequoyah Nuclear Plant, Units 1 and 2 (TAC No. MD9719 & MD9720, NOED No. 08-2-001)
ML082760667
Person / Time
Site: Sequoyah  Tennessee Valley Authority icon.png
Issue date: 10/02/2008
From: Reyes L
Region 2 Administrator
To: Campbell W
Tennessee Valley Authority
References
08-2-001, NOED No. 08-2-001, TAC MD9719, TAC MD9720
Download: ML082760667 (7)
v • d • e


Text

UNITED STATES NUCLEAR REGULATORY COMMISSION REGION II SAM NUNN ATLANTA FEDERAL CENTER 61 FORSYTH STREET, SW, SUITE 23T85 ATLANTA, GEORGIA 30303-8931 October 2, 2008 Mr. William R. Campbell, Jr.

Chief Nuclear Officer and Executive Vice President Tennessee Valley Authority 3R Lookout Place 1101 Market Street Chattanooga, TN 37402-2801

SUBJECT:

NOTICE OF ENFORCEMENT DISCRETION (NOED) FOR TENNESSEE VALLEY AUTHORITY REGARDING SEQUOYAH NUCLEAR PLANT, UNITS 1 AND 2 [TAC NO. MD9719 AND MD9720, NOED NO.08-2-001]

Dear Mr. Campbell:

By letter dated September 26, 2008, Tennessee Valley Authority (TVA) confirmed a September 26, 2008, verbal request that the NRC exercise discretion to not enforce compliance with the actions required in Sequoyah Nuclear Plant, Units 1 and 2 (SQN), Technical Specifications (TS) 3.0.5 Limiting Condition for Operation.

TVA requested that a Notice of Enforcement Discretion (NOED) be granted pursuant to the NRCs policy regarding exercise of discretion for an operating facility, described in Section VII.C of the NRCs Enforcement Policy, to extend the time required by TS 3.0.5.1 to be in at least HOT STANDBY in 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> by an additional 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. The discretion, which began on September 26, at 6:55 a.m., would expire on September 27, 2008, at 6:55 p.m., (all times discussed in this letter refer to Eastern Daylight Time).

This letter documents our telephone conversation on September 26, 2008, at 4:04 a.m., when we verbally granted enforcement discretion. Subsequent to the verbal authorization of this enforcement discretion, we understand that the condition causing the need for this enforcement discretion was corrected by you causing you to exit from the actions required in TS 3.0.5 and from this NOED at 2:00 p.m., on September 26, 2008. The basis for our decision to grant the exercising of enforcement discretion is provided in the following discussion.

Your letter documented information previously discussed with the NRC in a telephone conference which occurred on September 26, 2008. The principal NRC staff members who participated in the telephone conference included: Jim Moorman, Deputy Director, Division of Reactor Projects (DRP), Region II (RII); Eugene Guthrie, Chief, Reactor Projects Branch 6 (RPB-6), DRP, RII; Cale Young, Sequoyah Senior Resident Inspector, RPB-6, DRP, RII; Kriss Kennedy, Director, Division of Reactor Safety (DRS), RII; Rudy Bernhard, Senior Reactor Analyst, Engineering Branch 2, DRS, RII; Tom Boyce, Chief, Plant Licensing Branch II-2, Division of Operating Reactor Licensing (DORL), Office of Nuclear Reactor Regulation (NRR);

Tracy Orf, Project Manager, Plant Licensing Branch II-2, DORL, NRR; Robert Dennig, Chief, Containment and Ventilation Branch, Division of Safety Systems, NRR; and Brendan Moroney, Sequoyah Project Manager, Plant Licensing Branch II-2, DORL, NRR.

TVA 2

Your staff requested enforcement discretion to preclude having to be in at least HOT STANDBY in 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> per TS 3.0.5 due to the B train of control room air conditioning system (CRACS) being inoperable (B main control room (MCR) air handling unit (AHU) had failed) concurrently with the A train CRACS being inoperable solely due to its emergency backup power supply, 1A-A Emergency Diesel Generator (EDG), being inoperable. The 1A-A EDG was inoperable because its associated control power and field flash battery had not yet been returned to operable status after replacement. The licensee determined that the battery had been charged sufficiently to start and operate the 1A-A EDG but not enough to meet the requirements of TS to be declared operable, i.e., the 1A-A EDG was functionally available to perform its intended safety function. The sequence of events follows:

At 5:05 p.m., on September 24, Units 1 and 2 entered TS 3.8.1.1, action (b) for one EDG being inoperable due to the replacement of the 1A-A EDG battery.

At 10:07 p.m., on September 25, the 1A-A EDG battery discharge test was completed and the battery was subsequently placed on a portable charger.

At approximately 10:50 p.m., on September 25, the B train MCR AHU failed during starting due to a faulted motor.

At 10:55 p.m., on September 25, the B train of CRACS was declared to be inoperable due to the failure of the B train MCR AHU to function. With the redundant (B) train out of service and the A CRACS trains backup emergency power supply inoperable (1A-A EDG), TS 3.0.5 was entered.

At 5:07 a.m., on September 26, the 1A-A EDG battery was aligned to the 125 volt DC distribution system and charger after charging current from the portable charger decreased to less than 2 amperes, the point at which the high level equalize may be terminated. The 1A-A EDG was considered functionally available but inoperable per TS.

At 2:00 p.m., on September 26, the 1A-A EDG was declared operable after its battery passed its TS required surveillance test. The NOED was exited.

Based on the information provided in the telephone conversation on September 26, 2008, and in your letter dated September 26, 2008, the NRC has determined that Criterion B.2.1.1.a of NRC Inspection Manual Part 9900, Technical Guidance, Operation - Notice of Enforcement Discretion, was met. The NRC reviewed your written request for enforcement discretion dated September 26, 2008, and verified consistency between your oral and written requests. The NRCs basis for this discretion considered: (1) the compensatory measures to administratively control and protect vital plant equipment and to ensure that plant equipment could perform its design function for the duration of the enforcement discretion period; (2) the availability of offsite electrical power; and (3) the qualitative risk assessment which considered that the risk was bound by the risk associated with the TS 3.7.15.a allowed outage time, 30 days, for one train of CRACS being out of service, since the A train CRACS had its normal offsite power available and the 1A-A EDG was functionally able to start and provide emergency backup power to the train, if necessary.

During the phone call, the staff based their decision to exercise enforcement discretion, in part, on a qualitative versus a quantitative assessment of risk. In the written request, your staff provided a different quantitative risk analysis results than discussed during the verbal request.

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The new information supported the qualitative risk assessments conclusion that the exercise of discretion would result in acceptable plant risk. This new risk analysis indicated that the incremental conditional core damage probability (ICCDP) for the proposed 36 hour4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> extension is 5.03E-08, and the incremental conditional large early release probability (ICLERP) for the proposed 36 hour4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> extension is 2.28E-9. These values are both less than the 5.0E-7 and 5.0E-8 guidance thresholds, respectively, in Inspection Manual Part 9900 Technical Guidance.

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. Therefore, as we communicated to your staff at 4:04 a.m., on September 26, 2008, we exercised discretion to not enforce compliance with TS 3.0.5 to place both units in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> while the 1A-A EDG remains functionally available to perform its intended safety function of supplying power to the A CRACS train and the A CRACS train remained available on off-site power for the period of time from 6:55 a.m., on September 26, to 6:55 p.m., on September 27, 2008.

In addition, as discussed on September 26, 2008, the NRC staff agrees with your staffs determination that a follow-up TS amendment is not needed. The NRC staff finds that a TS amendment (either a one-time or permanent amendment) is not necessary, in this case, because: (1) the circumstances surrounding the noncompliance are unlikely to re-occur, i.e.,

the NOED involves a single request for extending the period of time the units could operate before being placed in HOT STANDBY when an EDG is inoperable per plant TSs but is functionally available to perform its intended safety function of supplying power to a CRACS train; and (2) the information in this NOED approval letter provides sufficient and complete documentation of the bases for the exercise of discretion.

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 By Victor McCree For/

Luis A. Reyes Regional Administrator Docket Nos.: 50-327, 50-328 License Nos.: DPR-77, DPR-79 cc: (See next page)

X SUNSI REVIEW COMPLETE OFFICE RII:DRP RII:DRP RII:DRP RII:DRS RII:DRS NRR:DORL NRR:DORL SIGNATURE

/RA/

/RA/

/RA/

/RA/

/RA By Telcom/

/RA By E-Mail/

/RA By E-Mail/

NAME

  • LGarner
  • EGuthrie LWert
  • KKennedy
  • RBernard JGiiter TBoyce DATE 9/30/08 9/30/08 10/

/200810/01/08 9/30/08 9/29/08 10/01/08 10/01/08 E-MAIL COPY?

YES NO YES NO YES NO YES NO YES NO YES NO YES NO OFFICE NRR:DCRL RII:ORA NRR:PM NRR:APOB SIGNATURE

/RA By E-Mail/

/RA/

/RA By E-Mail/

/RA By E-Mail/

NAME RDennig VMcCree BMoroney MFranovch DATE 9/30/08 10/02/08 10/01/08 10/01/08 E-MAIL COPY?

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

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cc contd:

Ashok S. Bhatnagar Senior Vice President Nuclear Generation Development and Construction Tennessee Valley Authority Electronic Mail Distribution William R. Campbell, Jr.

Chief Nuclear Officer and Executive Vice President Tennessee Valley Authority 3R Lookout Place 1101 Market Street Chattanooga, TN 37402-2801 Christopher R. Church Plant Manager Sequoyah Nuclear Plant Tennessee Valley Authority Electronic Mail Distribution Tom Coutu Vice President Nuclear Support Tennessee Valley Authority 3R Lookout Place 1101 Market Street Chattanooga, TN 37402-2801 Michael J. Lorek Vice President, Nuclear Engineering and Projects Tennessee Valley Authority Electronic Mail Distribution Timothy P. Cleary Site Vice President Sequoyah Nuclear Plant Tennessee Valley Authority Electronic Mail Distribution John C. Fornicola General Manager Nuclear Assurance Tennessee Valley Authority Electronic Mail Distribution General Counsel Tennessee Valley Authority Electronic Mail Distribution Beth A. Wetzel Manager Corporate Nuclear Licensing and Industry Affairs Tennessee Valley Authority Electronic Mail Distribution James D. Smith Manager, Licensing and Industry Affairs Sequoyah Nuclear Plant Tennessee Valley Authority Electronic Mail Distribution Larry E. Nicholson General Manager Performance Improvement Tennessee Valley Authority Electronic Mail Distribution Michael A. Purcell Senior Licensing Manager Nuclear Power Group Tennessee Valley Authority Electronic Mail Distribution Senior Resident Inspector U.S. Nuclear Regulatory Commission Sequoyah Nuclear Plant 2600 Igou Ferry Road Soddy Daisy, TN 37379-3624 Lawrence Edward Nanney Director Division of Radiological Health TN Dept. of Environment & Conservation Electronic Mail Distribution County Mayor Hamilton County Courthouse 208 Courthouse 625 Georgia Avenue Chattanooga, TN 37402-2801 (cc contd - See next page)

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cc contd:

James H. Bassham Director Tennessee Emergency Management Agency Electronic Mail Distribution Ann Harris 341 Swing Loop Rockwood, TN 37854

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Distribution:

V. McCree,DRAO K. Kennedy, DRS L. Wert, DRP E. Guthrie, DRP S. Vias, DRP C. Young, SRI Seq.

C. Evans, EICS L. Slack, EICS C. Carpenter, OE T. McGinty, NRR T. Boyce, NRR B. Moroney, NRR T. Bloomer, OEDO T. Farnholtz, EDO RIDSNRRDIRS RidsNrrOd RidsNrrAdes RidsNrrAdro RidsNrrDorl C. Goodwin, NRR RidsNrrLACSola RidsNrrPMBMoroney RidsNrrDorlLp2-2 RidsOgcRp RidsNrrDssScvb RidsDraApob RidsNrrDprPgcb RidsAcrsAcnw&mMailCenter RidsOeMailCenter RidsRgn2MailCenter NOED OEWEB PUBLIC

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