ML100980478: Difference between revisions

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{{#Wiki_filter:April 8, 2010  
{{#Wiki_filter:UNITED STATES NUC LE AR RE G UL AT O RY C O M M I S S I O N R E GI ON I V 612 EAST LAMAR BLVD , SU I TE 400 AR LI N GTON , TEXAS 76011-4125 April 8, 2010 Mr. Adam C. Heflin, Senior Vice President and Chief Nuclear Officer Union Electric Company P.O. Box 620 Fulton, MO 65251
 
Mr. Adam C. Heflin, Senior Vice   President and Chief Nuclear Officer Union Electric Company P.O. Box 620 Fulton, MO 65251  


==SUBJECT:==
==SUBJECT:==
NOTICE OF ENFORCEMENT DISCRETION FOR UNION ELECTRIC COMPANY REGARDING CALLAWAY PLANT, UNIT 1 [TAC NO. ME3686, NOED NO. 10-4-001]  
NOTICE OF ENFORCEMENT DISCRETION FOR UNION ELECTRIC COMPANY REGARDING CALLAWAY PLANT, UNIT 1 [TAC NO. ME3686, NOED NO. 10-4-001]


==Dear Mr. Heflin:==
==Dear Mr. Heflin:==


By letter dated April 6, 2010, Union Electric Company (UE), the licensee for Callaway Plant, Unit 1 (Callaway Plant) confirmed an April 2, 2010, verbal request that the NRC exercise discretion to not enforce compliance with the actions required in Callaway Plant, Technical Specification (TS) 3.8.1 "AC Sources - Operating," Required Actions B.4.
By letter dated April 6, 2010, Union Electric Company (UE), the licensee for Callaway Plant, Unit 1 (Callaway Plant) confirmed an April 2, 2010, verbal request that the NRC exercise discretion to not enforce compliance with the actions required in Callaway Plant, Technical Specification (TS) 3.8.1 AC Sources - Operating, Required Actions B.4.
UE requested that a Notice of Enforcement Discretion (NOED) be granted pursuant to the NRC's policy regarding exercise of discretion for an operating facility, described in Section VII.C of the NRC's Enforcement Policy, and be effective for 48 hours for TS 3.8.1.B.4 expiring on April 4, 2010 at 6:08 p.m. (all times discussed in this letter refer to Central Time).  
UE 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, and be effective for 48 hours for TS 3.8.1.B.4 expiring on April 4, 2010 at 6:08 p.m. (all times discussed in this letter refer to Central Time).
 
This letter documents our telephone conversation on April 2, 2010, at 5:35 p.m., when we verbally granted enforcement discretion. 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 April 2, 2010, at 5:35 p.m., when we verbally granted enforcement discretion. 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 April 2, 2010. The principal NRC staff members who participated in the telephone conference included: Dwight Chamberlian, Director, Division of Reactor Projects, (DRP), Region IV (RIV); Troy Pruett, Deputy Director, Division of Reactor Safety, (DRS), RIV; Tony Vegel, Deputy Director, DRP, RIV; Robert Nelson, Deputy Director, Division of Operating Reactor Licensing, Office of Nuclear Reactor Regulation (NRR); Geoff Miller, Chief, Project Branch B, DRP, RIV; George Wilson, Chief, Electrical Engineering Branch, NRR; Randy Hall, Plant Licensing Branch 4, NRR; Mike Hay, Chief, Technical Support Branch, DRS, RIV; Chuck Paulk, Team Lead, Technical Support Branch, DRS, RIV; Fernando Ferrante, NRR; Antonios Zoulis, NRR; George Replogle, Senior Reactor Analyst, DRS, RIV; David Dumbacher, Senior Resident Inspector, DRP, RIV; and Jeremy Groom, Resident Inspector, DRP, RIV. UNITED STATESNUCLEAR REGULATORY COMMISSIONREGION IV612 EAST LAMAR BLVD, SUITE 400ARLINGTON, TEXAS 76011-4125
Your letter documented information previously discussed with the NRC in a telephone conference which occurred on April 2, 2010. The principal NRC staff members who participated in the telephone conference included: Dwight Chamberlian, Director, Division of Reactor Projects, (DRP), Region IV (RIV); Troy Pruett, Deputy Director, Division of Reactor Safety, (DRS), RIV; Tony Vegel, Deputy Director, DRP, RIV; Robert Nelson, Deputy Director, Division of Operating Reactor Licensing, Office of Nuclear Reactor Regulation (NRR); Geoff Miller, Chief, Project Branch B, DRP, RIV; George Wilson, Chief, Electrical Engineering Branch, NRR; Randy Hall, Plant Licensing Branch 4, NRR; Mike Hay, Chief, Technical Support Branch, DRS, RIV; Chuck Paulk, Team Lead, Technical Support Branch, DRS, RIV; Fernando Ferrante, NRR; Antonios Zoulis, NRR; George Replogle, Senior Reactor Analyst, DRS, RIV; David Dumbacher, Senior Resident Inspector, DRP, RIV; and Jeremy Groom, Resident Inspector, DRP, RIV.
 
Union Electric Company Your staff requested enforcement discretion to preclude commencing a plant shutdown at 6:08 p.m. on April 2, 2010. Previously at 6:08 p.m. on Tuesday, March 30, 2010, the Train A emergency diesel generator tripped unexpectedly during a planned 24 hour surveillance run and was declared inoperable. This caused your staff to enter Technical Specification 3.8.1, Required Action B.4, which specified a 72 hour completion time to restore the diesel generator or commence a plant shutdown. The exact cause of the trip was unknown at the time. The station activated the Operations Control Center at 7:00 a.m. on March 31, 2010, to coordinate troubleshooting and repair activities in response to the diesel generator malfunction. Station operators tested the electrical protection circuitry and determined that the diesel generator had not tripped due to an electrical fault. In consultation with the vendor, your staff inspected the fuel oil system and commenced engine governor testing.  


By the morning of April 2, 2010, your staff had identified that the governor drive splined sleeve connection was worn to the point that it caused a loss of hydraulic oil pressure in the governor, resulting in the observed failure mechanism from the March 30, 2010, engine trip. By mid-day your staff determined the coupling wear had been caused by a lack of lubrication to the coupling assembly. This lack of lubrication resulted from the installation of an improperly made gasket during the last maintenance performed on this component in 1999. The gasket was cut from stock material at the site and was missing a hole needed to allow lubricating oil flow though an oil port in the assembly housing. Your staff determined the Train B emergency diesel generator was not susceptible to the same failure since the work records from maintenance performed in 2005 documented that the correct vendor-manufactured gasket was installed in Train B. Warehouse records reflected a vendor supplied gasket was procured for this work, and the color of the visible portions of the gasket matched the vendor supplied material and not the material used on Train A. During a conference call with the NRC at 3:30 p.m. on April 2, 2010, your staff verbally requested enforcement discretion to allow additional time to complete the necessary repairs to the Train A emergency diesel generator prior to the expiration of the Technical Specification required action to commence a plant shutdown.  
Union Electric Company                        Your staff requested enforcement discretion to preclude commencing a plant shutdown at 6:08 p.m. on April 2, 2010. Previously at 6:08 p.m. on Tuesday, March 30, 2010, the Train A emergency diesel generator tripped unexpectedly during a planned 24 hour surveillance run and was declared inoperable. This caused your staff to enter Technical Specification 3.8.1, Required Action B.4, which specified a 72 hour completion time to restore the diesel generator or commence a plant shutdown. The exact cause of the trip was unknown at the time. The station activated the Operations Control Center at 7:00 a.m. on March 31, 2010, to coordinate troubleshooting and repair activities in response to the diesel generator malfunction. Station operators tested the electrical protection circuitry and determined that the diesel generator had not tripped due to an electrical fault. In consultation with the vendor, your staff inspected the fuel oil system and commenced engine governor testing.
By the morning of April 2, 2010, your staff had identified that the governor drive splined sleeve connection was worn to the point that it caused a loss of hydraulic oil pressure in the governor, resulting in the observed failure mechanism from the March 30, 2010, engine trip. By mid-day your staff determined the coupling wear had been caused by a lack of lubrication to the coupling assembly. This lack of lubrication resulted from the installation of an improperly made gasket during the last maintenance performed on this component in 1999. The gasket was cut from stock material at the site and was missing a hole needed to allow lubricating oil flow though an oil port in the assembly housing. Your staff determined the Train B emergency diesel generator was not susceptible to the same failure since the work records from maintenance performed in 2005 documented that the correct vendor-manufactured gasket was installed in Train B.
Warehouse records reflected a vendor supplied gasket was procured for this work, and the color of the visible portions of the gasket matched the vendor supplied material and not the material used on Train A. During a conference call with the NRC at 3:30 p.m. on April 2, 2010, your staff verbally requested enforcement discretion to allow additional time to complete the necessary repairs to the Train A emergency diesel generator prior to the expiration of the Technical Specification required action to commence a plant shutdown.
Based on the information provided in the telephone conversation on April 2, 2010, and in your letter dated April 6, 2010, 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 and verified consistency between your oral and written requests. The NRCs basis for this discretion considered: (1) the compensatory measures to reduce the probability of a plant transient while ensuring the availability of other safety-related equipment; (2) the availability of offsite electrical power; and (3) the quantitative risk assessment of the condition which indicated that the risk associated with increasing the allowed outage time an additional 48 hours did not cause the risk to exceed the level determined acceptable during normal work controls. Based on the compensatory risk management measures, it was determined that there was no significant net increase in risk.
The UEs final quantitative risk analysis indicated that the incremental conditional core damage probability (ICCDP) for the proposed 48 hour extension was 2.58E-7, and the incremental conditional large early release probability (ICLERP) for the proposed 48 hour extension results was 7.34E-11. These values are both less than the guidance thresholds in Inspection Manual Part 9900 Technical Guidance. To further mitigate the risk impact in (1) above, UE committed to implement a series of compensatory actions for the duration of the enforcement discretion period. Some of the compensatory actions that UE committed to implement included:
(1) ensuring no switchyard work which may cause a loss of offsite power is allowed; (2) monitoring the weather during the NOED period and addressing any severe weather per the


Based on the information provided in the telephone conversation on April 2, 2010, and in your letter dated April 6, 2010, 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 and verified consistency between your oral and written requests. The NRC's basis for this discretion considered: (1) the compensatory measures to reduce the probability of a plant transient while ensuring the availability of other safety-related equipment; (2) the availability of offsite electrical power; and (3) the quantitative risk assessment of the condition which indicated that the risk associated with increasing the allowed outage time an additional 48 hours did not cause the risk to exceed the level determined acceptable during normal work controls. Based on the compensatory risk management measures, it was determined that there was no significant net increase in risk.
Union Electric Company                       Callaway Plants Maintenance Rule 10 CFR 50.65(a)(4) program; and (3) not taking any other risk-significant systems, structures, or components out of service for testing or preventative maintenance during the NOED period.
The UE's final quantitative risk analysis indicated that the incremental conditional core damage probability (ICCDP) for the proposed 48 hour extension was 2.58E-7, and the incremental conditional large early release probability (ICLERP) for the proposed 48 hour extension results was 7.34E-11. These values are both less than the guidance thresholds in Inspection Manual Part 9900 Technical Guidance. To further mitigate the risk impact in (1) above, UE committed to implement a series of compensatory actions for the duration of the enforcement discretion period. Some of the compensatory actions that UE committed to implement included:  (1) ensuring no switchyard work which may cause a loss of offsite power is allowed; (2) monitoring the weather during the NOED period and addressing any severe weather per the Union Electric Company Callaway Plant's Maintenance Rule 10 CFR 50.65(a)(4) program; and (3) not taking any other risk-significant systems, structures, or components out of service for testing or preventative maintenance during the NOED period.
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 5:35 p.m. on April 2, 2010, we exercised discretion to not enforce compliance with TS 3.8.1, Required Action B.4 for a period of 48 hours from 6:08 p.m. April 2, 2010, to 6:08 p.m. April 4, 2010.
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 staff guidance and has no adverse impact on public health and safety. Therefore, as we communicated to your staff at 5:35 p.m. on April 2, 2010, we exercised discretion to not enforce compliance with TS 3.8.1, Required Action B.4 for a period of 48 hours from 6:08 p.m. April 2, 2010, to 6:08 p.m. April 4, 2010.
We understand that subsequent to the granting of this NOED, UE completed repairs to the Train A emergency diesel generator and declared the diesel generator operable, exiting Technical Specification 3.8.1 Required Action B.4 at 12:20 p.m. on April 4, 2010.
We understand that subsequent to the granting of this NOED, UE completed repairs to the Train A emergency diesel generator and declared the diesel generator operable, exiting Technical Specification 3.8.1 Required Action B.4 at 12:20 p.m. on April 4, 2010.
In addition, as discussed on April 2, 2010, the NRC staff agrees with UE's determination that a follow-up Technical Specification amendment was not needed. The staff finds that an amendment (either a temporary or permanent amendment) needed for circumstances similar to those addressed by the NOED is not necessary because it involves a nonrecurring noncompliance and only involves a single request for extending the period of time that an inoperable plant component must be restored to operable status as specified per the plant's Technical Specifications.
In addition, as discussed on April 2, 2010, the NRC staff agrees with UEs determination that a follow-up Technical Specification amendment was not needed. The staff finds that an amendment (either a temporary or permanent amendment) needed for circumstances similar to those addressed by the NOED is not necessary because it involves a nonrecurring noncompliance and only involves a single request for extending the period of time that an inoperable plant component must be restored to operable status as specified per the plants Technical Specifications.
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,       /RA/
Sincerely,
Dwight D. Chamberlain, Director       Division of Reactor Projects Docket:   50-483 License: NPF-30  
                                              /RA/
 
Dwight D. Chamberlain, Director Division of Reactor Projects Docket: 50-483 License: NPF-30
Union Electric Company Mr. Luke H. Graessle Director, Operations Support AmerenUE P.O. Box 620 Fulton, MO  65251
 
E. Hope Bradley Manager, Protective Services AmerenUE P.O. Box 620 Fulton, MO  65251
 
Tom Voss Ameren UE 1901 Choteau Avenue St. Louis, MO  63103 Mr. Scott Sandbothe, Manager Plant Support AmerenUE P.O. Box 620 Fulton, MO  65251
 
R. E. Farnam Assistant Manager, Technical    Training AmerenUE P.O. Box 620 Fulton, MO  65251 J. S. Geyer Radiation Protection Manager AmerenUE P.O. Box 620 Fulton, MO  65251 John O'Neill, Esq. Pillsbury Winthrop Shaw Pittman LLP 2300 N. Street, N.W. Washington, DC  20037 Missouri Public Service Commission P.O. Box 360 Jefferson City, MO  65102-0360
 
Dru Buntin Director of Government Affairs Department of Natural Resources P.O. Box 176 Jefferson City, MO  65102-0176
 
Union Electric Company Matthew W. Sunseri, President and  Chief Executive officer Wolf Creek Nuclear Operating Corporation P.O. Box 411 Burlington, KS  66839
 
Kathleen Logan Smith, Executive Director and Kay Drey, Representative, Board of Directors Missouri Coalition for the Environment 6267 Delmar Boulevard, Suite 2E St. Louis, MO  63130
 
Presiding Commissioner Callaway County Court House 10 East Fifth Street Fulton, MO 65251 Director, Missouri State Emergency Management Agency P.O. Box 116 Jefferson City, MO  65102-0116 Mr. Scott Clardy, Administrator Section for Disease Control Missouri Department of Health and  Senior Services P.O. Box 570 Jefferson City, MO 65102-0570


Certrec Corporation 4200 South Hulen, Suite 422 Fort Worth, TX  76109
Union Electric Company              Mr. Luke H. Graessle Director, Operations Support AmerenUE P.O. Box 620 Fulton, MO 65251 E. Hope Bradley Manager, Protective Services AmerenUE P.O. Box 620 Fulton, MO 65251 Tom Voss Ameren UE 1901 Choteau Avenue St. Louis, MO 63103 Mr. Scott Sandbothe, Manager Plant Support AmerenUE P.O. Box 620 Fulton, MO 65251 R. E. Farnam Assistant Manager, Technical Training AmerenUE P.O. Box 620 Fulton, MO 65251 J. S. Geyer Radiation Protection Manager AmerenUE P.O. Box 620 Fulton, MO 65251 John ONeill, Esq.
Pillsbury Winthrop Shaw Pittman LLP 2300 N. Street, N.W.
Washington, DC 20037 Missouri Public Service Commission P.O. Box 360 Jefferson City, MO 65102-0360 Dru Buntin Director of Government Affairs Department of Natural Resources P.O. Box 176 Jefferson City, MO 65102-0176


Mr. Keith G. Henke, Planner II Division of Community and Public Health Office of Emergency Coordination Missouri Department of Health and   Senior Services 930 Wildwood Drive P.O. Box 570 Jefferson City, MO 65102 Chief, Technological Hazards Branch FEMA Region VII 9221 Ward Parkway, Suite 300 Kansas City, MO 64114-3372  
Union Electric Company                  Matthew W. Sunseri, President and Chief Executive officer Wolf Creek Nuclear Operating Corporation P.O. Box 411 Burlington, KS 66839 Kathleen Logan Smith, Executive Director and Kay Drey, Representative, Board of Directors Missouri Coalition for the Environment 6267 Delmar Boulevard, Suite 2E St. Louis, MO 63130 Presiding Commissioner Callaway County Court House 10 East Fifth Street Fulton, MO 65251 Director, Missouri State Emergency Management Agency P.O. Box 116 Jefferson City, MO 65102-0116 Mr. Scott Clardy, Administrator Section for Disease Control Missouri Department of Health and Senior Services P.O. Box 570 Jefferson City, MO 65102-0570 Certrec Corporation 4200 South Hulen, Suite 422 Fort Worth, TX 76109 Mr. Keith G. Henke, Planner II Division of Community and Public Health Office of Emergency Coordination Missouri Department of Health and Senior Services 930 Wildwood Drive P.O. Box 570 Jefferson City, MO 65102 Chief, Technological Hazards Branch FEMA Region VII 9221 Ward Parkway, Suite 300 Kansas City, MO 64114-3372


Electronic distribution by RIV: Regional Administrator (Elmo.Collins@nrc.gov) Acting Deputy Regional Administrator (Art.Howell@nrc.gov) DRP Director (Dwight.Chamberlain@nrc.gov) DRP Deputy Director (Anton.Vegel@nrc.gov) DRS Director (Roy.Caniano@nrc.gov)
Electronic distribution by RIV:
DRS Deputy Director (Troy.Pruett@nrc.gov) Senior Resident Inspector (David.Dumbacher@nrc.gov) Resident Inspector (Jeremy.Groom@nrc.gov) Branch Chief, DRP/B (Geoffrey.Miller@nrc.gov) Senior Project Engineer, DRP/B (Rick.Deese@nrc.gov)
Regional Administrator (Elmo.Collins@nrc.gov)
CWY Administrative Assistant (Dawn.Yancey@nrc.gov) Public Affairs Officer (Victor.Dricks@nrc.gov) Public Affairs Officer (Lara.Uselding@nrc.gov) Project Manager (Mohan.Thadani@nrc.gov) Branch Chief, DRS/TSB (Michael.Hay@nrc.gov) RITS Coordinator (Marisa.Herrera@nrc.gov) Regional Counsel (Karla.Fuller@nrc.gov)
Acting Deputy Regional Administrator (Art.Howell@nrc.gov)
Congressional Affairs Officer (Jenny.Weil@nrc.gov) OEMail Resource NOED Resource (NOED.Resource@nrc.gov) OE Web Resource (OEWEB.Resource@nrc.gov) DRS/TSB STA (Dale.Powers@nrc.gov)
DRP Director (Dwight.Chamberlain@nrc.gov)
OEDO RIV Coordinator (Leigh.Trocine@nrc.gov) NRR DORL Director (Joseph.Giitter@nrc.gov) Director, Office of Enforcement (Roy.Zimmermon@nrc.gov) NRR/DE/EEEB Chief (George.Wilson@nrc.gov) NRR/DORL/Plant Licensing Branch IV-1 Chief (Michael.Markley@nrc.gov)
DRP Deputy Director (Anton.Vegel@nrc.gov)
NRR/DORL Deputy Director (Robert.Nelson@nrc.gov)  
DRS Director (Roy.Caniano@nrc.gov)
DRS Deputy Director (Troy.Pruett@nrc.gov)
Senior Resident Inspector (David.Dumbacher@nrc.gov)
Resident Inspector (Jeremy.Groom@nrc.gov)
Branch Chief, DRP/B (Geoffrey.Miller@nrc.gov)
Senior Project Engineer, DRP/B (Rick.Deese@nrc.gov)
CWY Administrative Assistant (Dawn.Yancey@nrc.gov)
Public Affairs Officer (Victor.Dricks@nrc.gov)
Public Affairs Officer (Lara.Uselding@nrc.gov)
Project Manager (Mohan.Thadani@nrc.gov)
Branch Chief, DRS/TSB (Michael.Hay@nrc.gov)
RITS Coordinator (Marisa.Herrera@nrc.gov)
Regional Counsel (Karla.Fuller@nrc.gov)
Congressional Affairs Officer (Jenny.Weil@nrc.gov)
OEMail Resource NOED Resource (NOED.Resource@nrc.gov)
OE Web Resource (OEWEB.Resource@nrc.gov)
DRS/TSB STA (Dale.Powers@nrc.gov)
OEDO RIV Coordinator (Leigh.Trocine@nrc.gov)
NRR DORL Director (Joseph.Giitter@nrc.gov)
Director, Office of Enforcement (Roy.Zimmermon@nrc.gov)
NRR/DE/EEEB Chief (George.Wilson@nrc.gov)
NRR/DORL/Plant Licensing Branch IV-1 Chief (Michael.Markley@nrc.gov)
NRR/DORL Deputy Director (Robert.Nelson@nrc.gov)
R:\_REACTORS\_CW\NOED 10-4-001.DOC                                ADAMS ML100980478 ADAMS:        No    ; Yes        ; SUNSI Review Complete        Reviewer Initials: RWD
                                  ; Publicly Available          ; Non-Sensitive
.                                  Non-publicly Available        Sensitive RIV:C:DRP/B              SRA:DRS                  NRR PM              RIV:ACES GMiller                  GReplogle                MThadani            WJones
/RD for/                  /RA by Email/            /RA by Email/      /RA/
4/7/10                    4/7/10                  4/7/10              4/7/10 D:DRS                    DD:NRR/DORL              D:DRP RCaniano                  RNelson                  DChamberlain
/TP for/                  /RA by Email/            /RA/
4/7/20                  4/7/10                    4/8/10


R:\_REACTORS\_CW\NOED 10-4-001.DOC  ADAMS ML100980478 ADAMS:    No      Yes  SUNSI Review Complete Reviewer Initials: RWD Publicly Available  Non-Sensitive . Non-publicly Available  Sensitive RIV:C:DRP/B SRA:DRS NRR PM RIV:ACES GMiller GReplogle MThadani WJones
Wolf Creek Nuclear Operating Corporation OFFICIAL RECORD COPY                         T=Telephone E=E-mail F=Fax}}
/RD for/ /RA by Email/ /RA by Email/
/RA/ 4/7/10 4/7/10 4/7/10 4/7/10 D:DRS DD:NRR/DORL D:DRP  RCaniano RNelson DChamberlain 
/TP for/ /RA by Email/
/RA/  4/7/20 4/7/10 4/8/10 Wolf Creek Nuclear Operating Corporation OFFICIAL RECORD COPY                                         T=Telephone           E=E-mail       F=Fax}}

Latest revision as of 20:00, 13 November 2019

Notice of Enforcement Discretion for Union Electric Company Regarding Callaway Plant, Unit 1 (TAC No. ME3686, NOED No. 10-4-001)
ML100980478
Person / Time
Site: Callaway Ameren icon.png
Issue date: 04/08/2010
From: Chamberlain D
NRC/RGN-IV/DRP
To: Heflin A
Union Electric Co
References
NOED No. 10-4-001, TAC ME3686
Download: ML100980478 (7)
v • d • e


Text

UNITED STATES NUC LE AR RE G UL AT O RY C O M M I S S I O N R E GI ON I V 612 EAST LAMAR BLVD , SU I TE 400 AR LI N GTON , TEXAS 76011-4125 April 8, 2010 Mr. Adam C. Heflin, Senior Vice President and Chief Nuclear Officer Union Electric Company P.O. Box 620 Fulton, MO 65251

SUBJECT:

NOTICE OF ENFORCEMENT DISCRETION FOR UNION ELECTRIC COMPANY REGARDING CALLAWAY PLANT, UNIT 1 [TAC NO. ME3686, NOED NO. 10-4-001]

Dear Mr. Heflin:

By letter dated April 6, 2010, Union Electric Company (UE), the licensee for Callaway Plant, Unit 1 (Callaway Plant) confirmed an April 2, 2010, verbal request that the NRC exercise discretion to not enforce compliance with the actions required in Callaway Plant, Technical Specification (TS) 3.8.1 AC Sources - Operating, Required Actions B.4.

UE 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, and be effective for 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> for TS 3.8.1.B.4 expiring on April 4, 2010 at 6:08 p.m. (all times discussed in this letter refer to Central Time).

This letter documents our telephone conversation on April 2, 2010, at 5:35 p.m., when we verbally granted enforcement discretion. 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 April 2, 2010. The principal NRC staff members who participated in the telephone conference included: Dwight Chamberlian, Director, Division of Reactor Projects, (DRP), Region IV (RIV); Troy Pruett, Deputy Director, Division of Reactor Safety, (DRS), RIV; Tony Vegel, Deputy Director, DRP, RIV; Robert Nelson, Deputy Director, Division of Operating Reactor Licensing, Office of Nuclear Reactor Regulation (NRR); Geoff Miller, Chief, Project Branch B, DRP, RIV; George Wilson, Chief, Electrical Engineering Branch, NRR; Randy Hall, Plant Licensing Branch 4, NRR; Mike Hay, Chief, Technical Support Branch, DRS, RIV; Chuck Paulk, Team Lead, Technical Support Branch, DRS, RIV; Fernando Ferrante, NRR; Antonios Zoulis, NRR; George Replogle, Senior Reactor Analyst, DRS, RIV; David Dumbacher, Senior Resident Inspector, DRP, RIV; and Jeremy Groom, Resident Inspector, DRP, RIV.

Union Electric Company Your staff requested enforcement discretion to preclude commencing a plant shutdown at 6:08 p.m. on April 2, 2010. Previously at 6:08 p.m. on Tuesday, March 30, 2010, the Train A emergency diesel generator tripped unexpectedly during a planned 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> surveillance run and was declared inoperable. This caused your staff to enter Technical Specification 3.8.1, Required Action B.4, which specified a 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> completion time to restore the diesel generator or commence a plant shutdown. The exact cause of the trip was unknown at the time. The station activated the Operations Control Center at 7:00 a.m. on March 31, 2010, to coordinate troubleshooting and repair activities in response to the diesel generator malfunction. Station operators tested the electrical protection circuitry and determined that the diesel generator had not tripped due to an electrical fault. In consultation with the vendor, your staff inspected the fuel oil system and commenced engine governor testing.

By the morning of April 2, 2010, your staff had identified that the governor drive splined sleeve connection was worn to the point that it caused a loss of hydraulic oil pressure in the governor, resulting in the observed failure mechanism from the March 30, 2010, engine trip. By mid-day your staff determined the coupling wear had been caused by a lack of lubrication to the coupling assembly. This lack of lubrication resulted from the installation of an improperly made gasket during the last maintenance performed on this component in 1999. The gasket was cut from stock material at the site and was missing a hole needed to allow lubricating oil flow though an oil port in the assembly housing. Your staff determined the Train B emergency diesel generator was not susceptible to the same failure since the work records from maintenance performed in 2005 documented that the correct vendor-manufactured gasket was installed in Train B.

Warehouse records reflected a vendor supplied gasket was procured for this work, and the color of the visible portions of the gasket matched the vendor supplied material and not the material used on Train A. During a conference call with the NRC at 3:30 p.m. on April 2, 2010, your staff verbally requested enforcement discretion to allow additional time to complete the necessary repairs to the Train A emergency diesel generator prior to the expiration of the Technical Specification required action to commence a plant shutdown.

Based on the information provided in the telephone conversation on April 2, 2010, and in your letter dated April 6, 2010, 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 and verified consistency between your oral and written requests. The NRCs basis for this discretion considered: (1) the compensatory measures to reduce the probability of a plant transient while ensuring the availability of other safety-related equipment; (2) the availability of offsite electrical power; and (3) the quantitative risk assessment of the condition which indicated that the risk associated with increasing the allowed outage time an additional 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> did not cause the risk to exceed the level determined acceptable during normal work controls. Based on the compensatory risk management measures, it was determined that there was no significant net increase in risk.

The UEs final quantitative risk analysis indicated that the incremental conditional core damage probability (ICCDP) for the proposed 48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> extension was 2.58E-7, and the incremental conditional large early release probability (ICLERP) for the proposed 48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> extension results was 7.34E-11. These values are both less than the guidance thresholds in Inspection Manual Part 9900 Technical Guidance. To further mitigate the risk impact in (1) above, UE committed to implement a series of compensatory actions for the duration of the enforcement discretion period. Some of the compensatory actions that UE committed to implement included:

(1) ensuring no switchyard work which may cause a loss of offsite power is allowed; (2) monitoring the weather during the NOED period and addressing any severe weather per the

Union Electric Company Callaway Plants Maintenance Rule 10 CFR 50.65(a)(4) program; and (3) not taking any other risk-significant systems, structures, or components out of service for testing or preventative maintenance during the NOED period.

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 5:35 p.m. on April 2, 2010, we exercised discretion to not enforce compliance with TS 3.8.1, Required Action B.4 for a period of 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> from 6:08 p.m. April 2, 2010, to 6:08 p.m. April 4, 2010.

We understand that subsequent to the granting of this NOED, UE completed repairs to the Train A emergency diesel generator and declared the diesel generator operable, exiting Technical Specification 3.8.1 Required Action B.4 at 12:20 p.m. on April 4, 2010.

In addition, as discussed on April 2, 2010, the NRC staff agrees with UEs determination that a follow-up Technical Specification amendment was not needed. The staff finds that an amendment (either a temporary or permanent amendment) needed for circumstances similar to those addressed by the NOED is not necessary because it involves a nonrecurring noncompliance and only involves a single request for extending the period of time that an inoperable plant component must be restored to operable status as specified per the plants Technical Specifications.

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/

Dwight D. Chamberlain, Director Division of Reactor Projects Docket: 50-483 License: NPF-30

Union Electric Company Mr. Luke H. Graessle Director, Operations Support AmerenUE P.O. Box 620 Fulton, MO 65251 E. Hope Bradley Manager, Protective Services AmerenUE P.O. Box 620 Fulton, MO 65251 Tom Voss Ameren UE 1901 Choteau Avenue St. Louis, MO 63103 Mr. Scott Sandbothe, Manager Plant Support AmerenUE P.O. Box 620 Fulton, MO 65251 R. E. Farnam Assistant Manager, Technical Training AmerenUE P.O. Box 620 Fulton, MO 65251 J. S. Geyer Radiation Protection Manager AmerenUE P.O. Box 620 Fulton, MO 65251 John ONeill, Esq.

Pillsbury Winthrop Shaw Pittman LLP 2300 N. Street, N.W.

Washington, DC 20037 Missouri Public Service Commission P.O. Box 360 Jefferson City, MO 65102-0360 Dru Buntin Director of Government Affairs Department of Natural Resources P.O. Box 176 Jefferson City, MO 65102-0176

Union Electric Company Matthew W. Sunseri, President and Chief Executive officer Wolf Creek Nuclear Operating Corporation P.O. Box 411 Burlington, KS 66839 Kathleen Logan Smith, Executive Director and Kay Drey, Representative, Board of Directors Missouri Coalition for the Environment 6267 Delmar Boulevard, Suite 2E St. Louis, MO 63130 Presiding Commissioner Callaway County Court House 10 East Fifth Street Fulton, MO 65251 Director, Missouri State Emergency Management Agency P.O. Box 116 Jefferson City, MO 65102-0116 Mr. Scott Clardy, Administrator Section for Disease Control Missouri Department of Health and Senior Services P.O. Box 570 Jefferson City, MO 65102-0570 Certrec Corporation 4200 South Hulen, Suite 422 Fort Worth, TX 76109 Mr. Keith G. Henke, Planner II Division of Community and Public Health Office of Emergency Coordination Missouri Department of Health and Senior Services 930 Wildwood Drive P.O. Box 570 Jefferson City, MO 65102 Chief, Technological Hazards Branch FEMA Region VII 9221 Ward Parkway, Suite 300 Kansas City, MO 64114-3372

Electronic distribution by RIV:

Regional Administrator (Elmo.Collins@nrc.gov)

Acting Deputy Regional Administrator (Art.Howell@nrc.gov)

DRP Director (Dwight.Chamberlain@nrc.gov)

DRP Deputy Director (Anton.Vegel@nrc.gov)

DRS Director (Roy.Caniano@nrc.gov)

DRS Deputy Director (Troy.Pruett@nrc.gov)

Senior Resident Inspector (David.Dumbacher@nrc.gov)

Resident Inspector (Jeremy.Groom@nrc.gov)

Branch Chief, DRP/B (Geoffrey.Miller@nrc.gov)

Senior Project Engineer, DRP/B (Rick.Deese@nrc.gov)

CWY Administrative Assistant (Dawn.Yancey@nrc.gov)

Public Affairs Officer (Victor.Dricks@nrc.gov)

Public Affairs Officer (Lara.Uselding@nrc.gov)

Project Manager (Mohan.Thadani@nrc.gov)

Branch Chief, DRS/TSB (Michael.Hay@nrc.gov)

RITS Coordinator (Marisa.Herrera@nrc.gov)

Regional Counsel (Karla.Fuller@nrc.gov)

Congressional Affairs Officer (Jenny.Weil@nrc.gov)

OEMail Resource NOED Resource (NOED.Resource@nrc.gov)

OE Web Resource (OEWEB.Resource@nrc.gov)

DRS/TSB STA (Dale.Powers@nrc.gov)

OEDO RIV Coordinator (Leigh.Trocine@nrc.gov)

NRR DORL Director (Joseph.Giitter@nrc.gov)

Director, Office of Enforcement (Roy.Zimmermon@nrc.gov)

NRR/DE/EEEB Chief (George.Wilson@nrc.gov)

NRR/DORL/Plant Licensing Branch IV-1 Chief (Michael.Markley@nrc.gov)

NRR/DORL Deputy Director (Robert.Nelson@nrc.gov)

R:\_REACTORS\_CW\NOED 10-4-001.DOC ADAMS ML100980478 ADAMS: No  ; Yes  ; SUNSI Review Complete Reviewer Initials: RWD

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Wolf Creek Nuclear Operating Corporation OFFICIAL RECORD COPY T=Telephone E=E-mail F=Fax

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