NL-10-1601, Request for Enforcement Discretion from Technical Specification 3.6.5

Request for Enforcement Discretion from Technical Specification 3.6.5

ML102290535
Person / Time
Site:	Farley
Issue date:	08/17/2010
From:	Marino P Southern Nuclear Operating Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NL-10-1601
Download: ML102290535 (9)

Text

Paula M. Marino Southern Nuclear Vice President Operating Company, Inc Engineering 40 Inverness Center Parkway Birmingham. Alabama 35242 Tel 205.992.7707 Fax 205.992.6165 pmmarino@southernco.com August 17,2010 SOUTHERN.\\

Docket No.: 50-348 NL-10-1601 COMPANY U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555 Joseph M. Farley Nuclear Plant Unit 1 Request for Enforcement Discretion from Technical Specification 3.6.5 Ladies and Gentlemen:

On August 14, 2010, pursuant to the NRC Inspection Manual, Part 9900, Southern Nuclear Operating Company (SNC) requested that a Notice of Enforcement Discretion (NOED) be granted for Joseph M. Farley Nuclear Plant (FNP) Unit 1. The need for a NOED occurred due to the unforeseen emergent plant condition of containment air temperature exceedin~

the Technical SpeCification (TS) Limiting Condition for Operation (LCO) 3.6.5 limit of 120 F.

Containment heatup resulted from the required isolation per LCO 3.6.3 of a penetration flow path from a reactor coolant pump motor air cooler.

The one-time enforcement discretion was requested for a duration of no longer than eighteen hours for non-compliance with LCO 3.6.5. Local leak rate testing verified proper function of the affected penetration flow path, enabling exit of LCO 3.6.3 and restoration of cooling flow at 08:00 CDT on August 15, 2010. With containment air temperature reduced below the 120°F limit, LCO 3.6.5 was exited at 08:23 CDT.

During a telephone call at 00:57 CDT on August 15, 2010, NRC granted FNP's verbal request for enforcement discretion and agreed that a follow-up license amendment was not needed. During that telephone call, SNC made a commitment to provide a written NOED request within two working days of the NRC verbally granting the NOED. The Enclosure to this letter satisfies that commitment by providing SNC's written NOED request for FNP.

This letter contains no NRC commitments. If you have any questions, please contact Jack Stringfellow at (205) 992-7037.

Respectfully submitted, P. M. Marino Vice President - Engineering PMM/JLSllac

U. S. Nuclear Regulatory Commission NL-IO-1601 Page 2

Enclosure:

Request for Enforcement Discretion cc:

Southern Nuclear Operating Company M. J. Ajluni, Nuclear Licensing Director Mr. J. T. Gasser, Executive Vice President Mr. J. R Johnson, Vice President - Farley RType: CFA04.054 U. S. Nuclear Regulatorv Commission Mr. L. A Reyes, Regional Administrator Mr. R E. Martin, NRR Project Manager - Farley Mr. E. L. Crowe, Senior Resident Inspector - Farley Mr. P. Boyle, NRR Project Manager Alabama Department of Public Health Dr. D. E. Williamson, State Health Officer

Joseph M. Farley Nuclear Plant Unit 1 Enclosure Request for Enforcement Discretion

Enclosure Request for Enforcement Discretion

Background

Joseph M. Farley Nuclear Plant (FNP) Unit 1 encountered the unforeseen emergent plant condition of containment air temperature exceeding 120°F, due to a Technical Specification (TS) required isolation of a penetration flow path. During surveillance, a Service Water from Reactor Coolant Pump Motor Air Coolers valve (Q1P16MOV3134) failed to show closed indication. TS 3.6.3 required isolation of the affected penetration flow path, resulting in reduced cooling of the Reactor Coolant Pump motor exhaust air. The penetration was isolated using operable inboard Containment isolation valve MOV3131. This resulted in an increase in Containment temperature. TS Limiting Condition for Operation (LCD) 3.6.5 states that "Containment average air temperature shall be S 120°F." Required Action A of this specification requires restoration of the average air temperature to within limit within eight hours. Required Action B requires, if required action and associated Completion Time not met, to be in Mode 3 in six hours and be in Mode 5 in thirty-six hours. TS LCD 3.6.5 was entered at 14:00 CDT on August 14, 2010. The containment temperature is expected to remain above the TS limit beyond the allowed completion time.

1. The Technical Specification or other licensing condition that will be violated.

TS LCD 3.6.5 states that "Containment average air temperature shall be S 120°F." Required Action A of this specification requires restoration of the average air temperature to within limit within eight hours. Required Action B requires, if required action and associated Completion Time not met, to be in Mode 3 in six hours and be in Mode 5 in thirty-six hours.

2. The circumstances surrounding the situation; including likely causes; the need for prompt action; action taken in an attempt to avoid the need for an NOED; and identification of any relevant historical events.

FNP Unit 1 encountered the unforeseen emergent plant condition of containment air temperature exceeding 120°F, due to a TS required isolation of a penetration flow path.

During surveillance, a Service Water valve from Reactor Coolant Pump Motor Air Coolers valve (Q1 P16MOV3134) failed to show closed indication. TS 3.6.3 required isolation of the affected penetration flow path, resulting in reduced cooling of the Reactor Coolant Pump motor exhaust air. This resulted in an increase in Containment temperature. TS LCD 3.6.5 states that "Containment average air temperature shall be S 120°F." Required Action A of this specification requires restoration of the average air temperature to within limit within eight hours. Required Action B requires, if required action and associated Completion Time not met, to be in Mode 3 in six hours and be in Mode 5 in thirty-six hours. TS LCD 3.6.5 was entered at 14:00 CDT on August 14, 2010. The containment temperature is expected to remain above the TS limit beyond the allowed completion time.

Prompt action is needed to avoid undesirable transients potentially associated with unit shutdown due to TS compliance for an issue with negligible impact on risk. As indicated in FSAR Table 6.2-3, although 120°F is the TS limit, 127DF was used in the analysis.

Actions taken in an attempt to avoid the need for a Notice of Enforcement Discretion (NOED) include efforts to prove operability of the Service Water from Reactor Coolant Pump Motor Air Coolers valve, which will allow restoration of cooling for the Reactor Coolant Pump Motor E1

Enclosure Request for Enforcement Discretion Air Coolers. Additional actions include running Containment mini-purge continuously, aligning Emergency Service Water to Containment coolers, and running the Containment dome fans in high speed.

No known relevant historical events exist.

3. Information to show that the cause and proposed path to resolve the situation are understood by the licensee, such that there is a high likelihood that planned actions to resolve the situation can be completed within the proposed NOED time frame.

The cause of the event is due to a required isolation of a penetration flow path, resulting in reduced cooling of the Reactor Coolant Pump motor exhaust air. This resulted in an increase in Containment temperature. The planned actions are to prove operability of the Reactor Coolant Pump Motor Air Coolers valve, which will allow restoration of cooling for the Reactor Coolant Pump Motor Air Coolers. Restoration of this cooling will reduce the Containment temperature to within TS limits. A local observation of the valve indicated that the valve was closed.

4. The safety basis for the request, including an evaluation of the safety significance and potential consequences of the proposed course of action.

Continued operation of the plant during the period of enforcement discretion will not cause risk to exceed the level determined acceptable during normal work controls: therefore, there is no net increase in radiological risk to the public. The penetration is isolated and the analysis was based on 12flF The following information should be provided in support of this evaluation. To the extent practicable, the licensee should address the quantitative and qualitative aspects noted below. The numerical guidance for acceptance was established to augment qualitative arguments that the continued operation of the plant during the period of enforcement discretion will not cause risk to exceed the level determined acceptable during normal work controls and, therefore, there is no net increase in radiological risk to the public.

a. Use the zero maintenance PRA model to establish the plant's baseline risk and the estimated risk increase associated with the period of enforcement discretion. For the plant*specific configuration the plant intends to operate in during the period of enforcement discretion, the incremental conditional core damage probability (ICCDP) and incremental conditional large early release probability (ICLERP) should be quantified and compared with guidance thresholds of less than or equal to an ICCDP of 5E-7 and an ICLERP of 5E*8. These numerical guidance values are not pasa.fail criteria.

High containment temperature will have an impact on containment pressure, which in turn may have a potential impact on the containment recirculation capability and containment leak rate. Based on the Final Safety Analysis Report, containment temperature up to 12flF does not impact containment integrity or the containment recirculation capability. It is also noted that during the next eighteen hours, with containment isolation valve closed, containment temperature is not expected to go above 122°F. Therefore, the impact on E2

Enclosure Request for Enforcement Discretion the PRA figures of merit, the Core Damage Frequency (CDF) and the Large Early Release Frequency (LERF), is negligible. If the temperature exceeds 122°F, the unit will be shut down.

b. Discuss the dominant risk contributors (cut sets/sequences) and summarize the risk insights for the plant-specific configuration the plant intends to operate in during the period of enforcement discretion. This discussion should focus primarily on risk contributors that have changed (increased or decreased) from the baseline model as a result of the degraded condition and resultant compensatory measures, if any.

There is negligible increase in risk as a result of the noncompliant condition or the resultant enforcement discretion; therefore, none of the risk contributors have changed from the values in the baseline model.

c. Explain compensatory measures that will be taken to reduce the risk associated with the specified configuration. Compensatory measures to reduce plant vulnerabilities should focus on both event mitigation and initiating event likelihood.

The objectives are to:

i. reduce the likelihood of initiating events; ii. reduce the likelihood of unavailability of trains redundant to the equipment that is out-of-service during the period of enforcement discretion; iii. increase the likelihood of successful operator recovery actions in response to initiating events.

Compensatory measures include running Containment mini-purge continuously, aligning Emergency Service Water to Containment coolers, and running the Containment dome fans in high speed. Work controls are in place to not take fan coolers or supporting systems out of service.

d. Discuss how the proposed compensatory measures are accounted for in the PRA.

These modeled compensatory measures should be correlated, as applicable, to the dominant PRA sequences identified in item b. above. In addition, other measures not directly related to the equipment out-of-service may also be implemented to reduce overall plant risk and, as such, should be explained. Compensatory measures that cannot be modeled in the PRA should be assessed qualitatively.

The compensatory measures will assist in maintaining the analytical limit of 12T>F.

e. Discuss the extent of condition of the failed or unavailable component(s} to other trains/divisions of equipment and what adjustments, if any, to the related PRA common cause factors have been made to account for potential increases in their failure probabilities. The method used to determine the extent of condition should be discussed. It is recognized that a formal root cause or apparent cause is not required given the limited time available in determining acceptability of a proposed NOED. However, a discussion of the likely cause should be provided with an associated discussion of the potential for common cause failure.

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Enclosure Request for Enforcement Discretion The failed component affects a single penetration which serves only the Reactor Coolant Pump motor coolers. The penetration has been isolated and no other components or trains are isolated.

f. Discuss external event risk for the specified plant configuration. An example of external event risk is a situation where a reactor core isolation cooling (RCIC) pump has failed and a review of the licensee's Individual Plant Examination of External Events or full-scope PRA model identifies that the RCIC pump is used to mitigate certain fire scenarios. Action may be taken to reduce fire ignition frequency in the affected areas or reduce human error associated with time-critical operator actions in response to such scenarios.

The condition has no impact on external events.

g. Discuss forecasted weather conditions for the NOED period and any plant vulnerabilities related to weather conditions.

No severe weather conditions are forecast for the foreseeable portion of the enforcement discretion period. Probable weather conditions during the enforcement discretion period are not expected to expose the plant to any vulnerability.

5. The justification for the duration of the noncompliance.

Justification of the duration of the eighteen-hour proposed enforcement discretion is six hours for valve restoration and twelve hours for Containment temperature to return to within TS limits.

6. The condition and operational status of the plant (including safety-related equipment out of service or otherwise inoperable).

The unit is at full power, the 2C diesel generator is being returned to service, the 1 B Closed Cooling Water heat exchanger is out of service for eddy current testing. There are no other TS LCOs.

7. The status and potential challenges to off-site and on-site power sources.

Both the off-site power sources and the on-site emergency diesel generators are operable.

The 2C diesel generator is being returned to service. There are no storms or high winds forecasted for the duration of the proposed enforcement discretion.

There is no switchyard or grid activity being conducted or scheduled that would threaten grid stability or off-site power source operability during the enforcement discretion period.

8. The basis for the licensee's conclusion that the noncompliance will not be of potential detriment to the public health and safety.

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Enclosure Request for Enforcement Discretion The proposed enforcement discretion will not be a potential detriment to the health and safety of the public, based on the following:

High containment temperature will have an impact on containment pressure, which in turn may have a potential impact on the containment recirculation capability and containment leak rate. Based on the Final Safety Analysis Report, containment temperature up to 12rF does not impact containment integrity or the containment recirculation capability. It is also noted that during the next eighteen hours, with containment isolation valve closed, containment temperature is not expected to go above 122°F. Therefore, the impact on the PRA figures of merit, the Core Damage Frequency (CDF) and the Large Early Release Frequency (LERF), is negligible.

9. The basis for the Iicensee1s conclusion that the noncompliance will not involve adverse consequences to the environment.

The Southern Nuclear Operating Company (SNC) has evaluated the proposed enforcement discretion and has determined that in accordance with 10 CFR 51.21, the enforcement discretion is excluded from the requirement of an environmental impact statement.

10. A statement that the request has been approved by the facility organization that normally reviews safety issues (Plant On-site Review Committee, or its equivalent).

The basis for the request for enforcement discretion was reviewed and approved by the Plant Review Board on August 14, 2010.

11. The request must specifically address which of the NOED criteria for appropriate plant conditions specified in Section B is satisfied and how it is satisfied.

This NOED addresses the criteria in Section B.1.a, that for a plant in power operation, an NOED is intended to avoid unnecessary transients as a result of compliance with the license condition and, thus, minimize potential safety consequences and operational risks.

12. Unless otherwise agreed as discussed in Section B, a commitment is required from the licensee that the written NOED request will be submitted within 2 working days and the follow-up amendment will be submitted within 4 working days of verbally granting the NOED. The Iicensee1s amendment request must describe and justify the exigent circumstances (see 10 CFR 50.91(a)(6>>. The licensee should state if staff has agreed during the teleconference that a follow-up amendment is not needed. If the licensee intends to propose a temporary amendment, the licensee's amendment request shall include justification for the temporary nature of the requested amendment.

On August 15, 2010, NRC granted FNP's verbal request for enforcement discretion and agreed that a follow-up license amendment was not needed. During that telephone call, SNC made a commitment to provide a written NOED request within two working days of the NRC verbally granting the NOED. This Enclosure satisfies that commitment by providing SNC's written NO ED request for FNP.

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Enclosure Request for Enforcement Discretion

13. In addition to items 1-12 above, for severe weather NOED request the licensee must provide the following information.

a. The name, organization and telephone number of the official in the government or independent entity who made the emergency situation determination. If deemed necessary, the staff may contact the appropriate official to independently verify the information provided by the licensee prior to making an NOED determination.

b. Details of the basis and nature of the emergency situation including, but not limited to, its effect on:

i. on-site and off-site emergency preparedness; ii. plant and site ingress and egress; iii. off-site and on-site power sources; iv. grid stability; and

v. actions taken to avert and/or alleviate the emergency situation (e.g.,

coordinating with other utilities and the load dispatcher organization for buying additional power or for cycling load, or shedding interruptible industrial or non-emergency loads).

c. Potential consequences of compliance with existing license requirements (e.g.,

plant trip, controlled shutdown).

d. The impact of the emergency situation on plant safety including the capability of the ultimate heat sink.

e. Potential adverse effects on public health and safety from enforcing compliance with specific license requirements during the emergency situation.

This proposed enforcement discretion is not in regard to severe weather or nature phenomena-related emergencies.

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